IntelliCentrics SEC3URE Platform Privacy PolicyOVERVIEWIntelliCentrics, Inc. (collectively “IntelliCentrics,” “we,” “us,” “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and protect your personal information about you in relation to the www.sec3ure.com platform (the “Platform”). To help explain things and to help you make decisions when you access or use the Platform, please read on. If you have any questions about this Privacy Policy and the Platform, you can contact us at Privacy@IntelliCentrics.com.This IntelliCentrics SEC3URE Privacy Policy is effective from June 8, 2021. ACCEPTING THIS PRIVACY POLICYPLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. By accepting our Terms of Use when accessing the Platform, you are confirming that you have read and understand this Privacy Policy, including how and why we use your personal information, and you consent to the collection and processing of your information as described in this Privacy Policy and any addenda thereto. If you do not want us to collect or process your personal information in the ways described in this Privacy Policy, you should not access or use the Platform.We are not responsible for the content or the privacy policies or practices of any of the Platform’s users (“Users”), third-party websites imbedded or linked through the Platform or third-party applications. WHAT INFORMATION WE COLLECT OR RECEIVEWe collect your personal information in the course of your use of the Platform in a few different ways. Here are some of the types of information we gather:
FOR PLATFORM SERVICES OTHER THAN SEC3URE LINK OR SEC3URE VISITOR MANAGEMENT The information we collect from Users for the Platform, other than for SEC3URE LINK or SEC3URE VISITOR, does not qualify as “protected health information” or “PHI” as defined by the Health Insurance Portability and Accountability Act of 1996, as amended from time to time (“HIPAA”), because the information is (i) willingly disclosed by Users to IntelliCentrics, either directly by a User or indirectly by another person who has been granted valid authorization by the User or third party to disclose such information, removing its HIPAA-protected status; (ii) not used or disclosed by IntelliCentrics for purposes of healthcare treatment, payment or operations by a healthcare provider or health plan, thus not qualifying as a use or disclosure by a “covered entity” under HIPAA; and (iii) not used by IntelliCentrics for or on behalf of a covered entity for purposes of a User’s healthcare treatment, payment or operations, thus not qualifying as a use or disclosure as a “business associate” under HIPAA. IntelliCentrics takes extra precautions with respect to the User information it collects, however, and has implemented this Privacy Policy and related security safeguards to protect such information from inappropriate access or use. FOR SEC3URE LINK AND SEC3URE VISITOR MANAGEMENT For services performed for Users of SEC3URE LINK or SEC3URE VISITOR, it is possible that, from time to time, we receive or maintain PHI from Users that are Facilities and qualify as “covered entities” for HIPAA purposes. The receipt or maintenance of PHI through SEC3URE LINK or SEC3URE VISITOR may be for treatment or operational purposes of the Facility, but other than the respective Facility, this PHI will not relate to Subscribers. Instead, the PHI will relate to patients or clients of the specific Facility who have acknowledged the Facility’s use of PHI via the Facility’s Notice of Privacy Practices. Such individuals are not Users, and we are not responsible for the content or use of the Facility’s privacy notices, policies, or practices, or for the Facility’s processes to maintain the confidentiality or integrity of the PHI as part of their third-party records. Instead, we are solely responsible for our efforts to safeguard any PHI uploaded to the Platform by a Facility or its patients, which will be done in accordance with this Privacy Policy and the HIPAA Privacy Practices Addendum and Business Associate Addendum to this Privacy Policy, as well as applicable state and federal law. When using, collecting, maintaining, or transmitting such non-User PHI for a Facility, we will only do so as allowed by HIPAA. Unless allowed by HIPAA or required by law, such PHI is not shared or otherwise used outside the Platform; however, we may aggregate such PHI for purposes of security and operations management, statistical analysis, or research and development. To the maximum extent possible, such use will result in de-identified data that can no longer be used to identify an individual and no longer qualifies as PHI. HOW WE USE YOUR INFORMATIONWe use your Personal Information to operate, provide, and improve the Platform. Our purposes for using your personal information include:
HOW WE SHARE YOUR INFORMATIONInformation about our Users is an important part of our business, but we are not in the business of selling our Users’ personal information to others. We share personal information only as described below.We may share your Personal Information with others, as follows:
LINKS TO THIRD-PARTY SERVICE PROVIDERSWe provide links to websites of third-party service providers in order to make their services available to you through the SEC3URE Platform (“Linked Website”).Linked Websites are independent from us and are not governed by this Privacy Policy. We do not manage or control them or the products or services they provide, and consequently, accept no liability for them. All of the Linked Websites use tracking “cookies.” As a convenience to you, links to the privacy notices of the Linked Websites are provided below, together with certain information taken from them as of November 2018. But the descriptions below are not complete and may not include information which is important to you. You should consult their privacy notices before electing to receive products or services from them: IQ Data Systems, Inc. d/b/a Backgrounds Online (“BGO”) provides background screening services. It states that it uses the ClickTale web analytics service to improve navigation and forms on its website; may place “advertising cookies” on a visitor’s computer so that when they visit another site that has an agreement with its advertising network, the other side will use the cookie to display an advertisement to them on the other site; and provides personally-identifying information to third parties such as courts, state agencies, employers, schools, references, credit bureaus, and other information sources, in order to prepare background reports. It states that it recognizes its responsibilities under the Fair Credit and Reporting Act; uses information only for purposes allowed by law; requires written authorization before conducting searches; provides pre-adverse action notification; provides full report only to (and allows discussion with) the user, not IntelliCentrics; commits to data security; that information is only to be used exclusively by BGO; and that it requires affiliates to handle information in accordance with its policies. ClearStar Inc. provides medical testing services and related reports. It states that it uses tracking “cookies,” and may disclose personally-identifying information to third parties in order to provide the service its user has requested. It may also “engage third-parties in processing services requested by customers, such as screening for…occupational health.” ClearStar states that it requires such third parties to abide by ClearStar privacy policy and institute safeguards to protect the confidentiality of that information; recognizes its responsibilities under Fair Credit and Reporting Act; commits to compliance with applicable law; requires written authorization before performing services, including notice that report may be re-disclosed by client outside of HIPAA; disclaims responsibility for links to third-party Site; reports only status and “pass-fail” result to IntelliCentrics; allows access and correction; commits to data security; and is Privacy Shield-compliant. CVS/MinuteClinic provides vaccination services and related reports. It states that it uses cookies of its own and third parties for website improvement and for advertising; commits to comply with applicable law; requires written authorization before services; disclaims coverage of HIPAA and requires IntelliCentrics to maintain security and confidentiality as well as MinuteClinic. Landauer provides radiation dosimeters and related services, including records of radiation exposure. It states that it is the data controller of information submitted to it, and “may allow others to serve advertisements on our behalf across the Internet and to provide analytics services through cookies, web beacons and other technologies;” commits to comply with applicable law; has two privacy policies, one for European and one for U.S. residents; disclaims responsibility for links to third party Site; commits to data security; may use information for own marketing unless opt out or law requires opt in; does not distribute to outsiders for their own direct marketing. Zuora provides payment processing services. Even though Zuora is embedded in the Platform, it performs its services through its own portal and website and according to its own privacy policies. Its Privacy Statement provides in part that it “partner[s] with third parties to display advertising on our Web site or to manage our advertising on other Site. Our third-party partners may use technologies such as cookies to gather information about your activities on this Site and other Sites to provide you advertising based upon your browsing activities and interests. If you do not wish to have this information used for the purpose of serving you interest-based ads, you may opt out by clicking here (or if you are located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.” InContact, Inc. (“inContact”) provides live-chat functionality on the Platform. Even though customer-service provided through such feature is provided by us, inContact requires Users to provide their RepID#, Email, and Phone Number directly to inContact. Medical Sales Advocates (“MSA”) provides insurance procurement services through Nicholas Hill Benefits Group, Inc., which states that it reports only when and what services have been completed; does not share any personal data or underwriting information with any third party without express permission; uses industry-standard data protection; disclaims responsibility for links to third party Site; supplies information to insurance companies only with approval, and not for marketing or other purposes without permission (or as required by law); and will not sell personal information to third parties. Magnifi Group, Inc. EU-US & Swiss Privacy Shield Policy Magnifi Group, provider of Learn-WiseGo sales training solutions, respects individual privacy and values the confidence of its customers, employees, business partners, and others. Not only does Magnifi strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, it also has a tradition of upholding the highest ethical standards in its business practices. These EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Policies (the “Policies”) set forth the privacy principles that Magnifi follows with respect to transfers of personal information from the EU and Switzerland to the United States, respectively. Magnifi states that it will report to credentialing agencies, only for purposes of providing continuing-education credits or maintaining accreditation. If you decide to access any of the Linked Websites, or obtain any of their services, you do so at your own risk. HOW WE MAINTAIN AND PROTECT YOUR INFORMATIONWe maintain physical, technical, organizational, and administrative safeguards designed to protect your personal information from unauthorized access or use. Among many other steps, these include unique user names and passwords for all Users; use of international industry standards for encryption; and control of information availability according to a User’s role, permissions, and associations within the Platform. User account information is shared only with authorized IntelliCentrics administrators and persons whom a User has authorized to see it. We also train employees to safeguard Personal Information and restrict access to Personal Information to those employees who need it in order to perform their duties, and we contractually require business partners with whom we share your Personal Information to safeguard it and to use it only for the purpose for which it was shared. We use Personal Information only for the purpose it was provided and as described in this Privacy Policy. Once it is no longer reasonably necessary for business purposes, we will destroy it in accordance with our record retention policy. However, we cannot ensure or warrant the security of any Personal Information you or others in relation to the Platform. Therefore, we cannot guarantee that the Platform is immune to unauthorized access to the personal information stored therein or to other information security risks.We also contractually require business partners with whom we share your Personal Information to safeguard it and to use it only for the purpose for which it was shared. HOW WE USE COOKIES AND SIMILAR TECHNOLOGY
HOW YOU CONTROL YOUR INFORMATIONYou may view, update, and delete certain information about your account at any time through the Platform. You may not, however, amend, delete or correct Personal Information which has been submitted by or obtained from a third party such as a credentialing company, records provider, or similar agency through the Platform. If you feel you need to challenge the accuracy of such information, you may contact that third-party provider directly, or you may contact us for assistance at Privacy@IntelliCentrics.com.California (under the California Consumer Privacy Act of 2018 (“CCPA”), among others), Canada, the European Economic Area (under the General Data Protection Regulation (“GDPR”)), and some other jurisdictions provide individuals with specific rights. These rights may include rights and control over your personal information, including the right to know, the right to delete, and the right to opt-out of the sale of personal information that we may collect about you. For example, you may click on the following links to find out more about these rights:
We are a data “controller” as provided under the GDPR. HOW YOU OPT-OUT OF MARKETING MATERIALSYou may opt-out of marketing and informational materials at any time. Either click on the “unsubscribe” feature at the bottom of an email or other electronic material, or contact us at Privacy@IntelliCentrics.com and indicate your wish. If you do so, we may still contact you regarding transactional or administrative topics, such as service requests.INTERNATIONAL TRANSFER OF PERSONAL INFORMATIONWe maintain information received through or by the Platform in the United States. If you are providing information from another country, you understand and agree that it will be transferred, used, and stored in the United States.CAN CHILDREN USE THE PLATFORM?No. The Platform is not directed to children under 18. If you are under 18, you should not submit information to the Platform.We do not knowingly collect information from children. If we obtain actual knowledge that we have collected information from a child under 18, we will promptly destroy it, unless we are legally obligated to retain it. If you believe we have mistakenly collected information from a child under 18, please contact us at Privacy@IntelliCentrics.com. CHANGES TO THIS Privacy PolicyWe may change this Privacy Policy at any time, effective when we post the revised Privacy Policy on the Platform. Your use of the Platform means you accept our revised Privacy Policy. If, however, IntelliCentrics plans to use personal information in a manner that is materially different from that which is stated at the time such information was collected, IntelliCentrics will post notice of the change on the Platform for at least fifteen (15) days before the change will take effect.We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and share Personal Information. CONTACT USIf you have questions, concerns or complaints about our privacy practices, please email us at Privacy@IntelliCentrics.com or contact us at (817) SEC3URE (732-3873)     Back to SEC3URE.com 4831-4079-6350 6/64599-1/1390/082422 |