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 RECEIVE
We 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:
This may include the following "Personal Information:"
- information you give us, such as your name, password, employer, credentials, facilities, in order to register and participate in the IntelliCentrics community; credit card information you send to our payment processor in order to carry out transactions; and other personal information you may choose to provide us, to provide the services you are requesting;
- information we collect from third parties who perform services you choose or authorize, such as information from your authorized representatives (such as an employer), from medical training, licensing, regulatory, or credential verification organizations and public records, from third-party service providers, from payment facilities, from healthcare providers, or others (note that for many third-party services, you will provide your information directly to that service provider and not to us);
- information we collect from third parties who perform services or provide information about you pursuant to database searches or background checks requested or required for your authorized representatives (such as an employer) or for individuals or companies with which you have a relationship (such as a healthcare provider or facility);
- information about your computer for system administration purposes, such as your IP address, operating system and browser type, which we may combine with data collected via “session cookies,” but this information is statistical data about our User’s browsing patterns and generally does not identify our Users; and
- non-personal information that is collected on an aggregate basis as you browse our Site.
We only collect Personal Information that you choose to submit to us or authorize us or others to obtain. You may choose not to submit information to us, or to permit us or others to obtain it. If you choose not to do so, however, we will not be able to provide the corresponding service to you. You may also choose to ask us to amend or delete certain of your information already provided to us. If you choose to make such a request and we are able to agree to the request, we may no longer be able to provide the corresponding service to you.
- Identification information such as name, log-in, password, organization, mail and email addresses, phone number(s), For medical staff specifically: former name(s), Social Security number, place and date of birth, gender, or other responses to security questions, driver’s license number, photographs or bio-identifiers for proof of identity;
- Employment-related information, such as your employment status, employers, positions, and lengths of employment;
- Credentials and other records of your education, training, certifications, professional history, and qualifications;
- Authorizations and purchase orders for products or services, such as Confirmation of acceptable background checks on a pass/fail basis based on the requirements set by IntelliCentrics, our third-party service provider, and/or by each healthcare provider or facility you select (the details of which are only shared with you and a selected healthcare provider or facility and are not further collected or stored by us without express authorization); Vaccination appointments, histories and/or proof of immunization; Pass/fail records of titer or other medical tests, based on Center for Disease Control standards, and other medical records as you authorize; Radiation dosimeter purchases and exposure histories; records of Training and Continuing Education; and Certificates of Insurance coverage which may be provided to us;
- Access history, training records, and other information regarding your previous interaction(s) at facilities;
- Any other information or documents you may upload to your profile, such as photos, or in questions, comments, complaints, or inquiries submitted to us; and
FOR PLATFORM SERVICES OTHER THAN SEC3URE LINK OR SEC3URE VISITOR MANAGEMENT
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.
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 INFORMATION
We use your Personal Information to operate, provide, and improve the Platform. Our purposes for using your personal information include:
- Providing the Platform to you, along with products and services that you request through the Platform, including providing healthcare providers and facilities you select with access to your profile, assistance with their credentialing processes and databases, and access tracking and control services, and responding to questions, comments, complaints, and other inquiries;
- Assisting third-party service providers in providing products and services that you request on the Platform, such as vaccinations, medical tests and histories, background checks, training, insurance, radiation dosimeters and reports, and other products and services;
- Administering the Platform and running our business, including protection and improvement of the Platform, account management and analysis, customer support, communication, and market analysis;
- Marketing of our products and services that we think may be of interest to you; and
- Otherwise as we have a legitimate interest. For example, we may use it to communicate with you, to administer our Site and run our business, to protect ourselves and others, for our own individual or market research, or in connection with a corporate transaction such as a merger or acquisition. We may also use it when, in our judgment, we believe it is necessary, appropriate, or required, such as communicate with third parties such as insurers, service providers, consultants, advisors, or agents, or to comply with and enforce legal and regulatory requirements, agreements, and policies, or to protect a person’s vital interests. We may also use it for any other purpose disclosed to you at the time you provide personal information or with your consent.
HOW WE SHARE YOUR INFORMATION
Information 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:
- Employees, contractors, and agents who “need to know” in order to serve you: We may share your personal information with our employees, contractors, and agents who “need to know” in order to serve you. These may include third-party service providers who perform services for us, such as our payment processor, but their use of such information is limited to the performance of their duties and is consistent with our purposes for using such information;
- Third-party service providers you choose or authorize: We may share your personal information with the third-party services providers you select, who provide services to you as you choose or authorize including credential records, background checks, vaccination appointments and records, titer tests and other medical records, radiation dosimeters and reports, education and training, insurance coverage, and payment processing. In most cases, you will be directed to their websites and provide your information yourself. We require our service providers to maintain the confidentiality and security of your Personal Information and to use it only to provide services on yours or our behalf or as otherwise required or permitted by applicable law;
- Other third parties you choose or authorize: We may share certain of your personal information with other third parties whom you have chosen or authorized, who are permitted by law to receive it, and who need that information in order to manage their accounts with us (such as your employer, or other entity on whose behalf you work); and
- Protection of ourselves or others: We may share your personal information when we believe release is appropriate: to (a) comply with a law, legal process or regulations; (b) protect the vital interests of a person; (c) protect our property, Platform, services or legal rights; or (d) support our audit, compliance and governance functions.
- In aggregated form: We may aggregate your information with the information of others who use our Site and share the aggregated information with third parties to discover and reveal trends about how Users like you engage with our services. This normally results in information in a statistical or summary form that does not include any personal identifiers. To the extent possible, we will only use medical information in a way that ensures it is de-identified and no longer considered protected information for healthcare data privacy purposes (see HIPAA Privacy Practices Addendum).
- At Your Option: Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.
LINKS TO THIRD-PARTY SERVICE PROVIDERS
We provide links to websites of third-party service providers in order to make their services available to you through the SEC3URE Platform (“Linked Website”).
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.
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.
Medcom, Inc. provides training and education services. It states that it commits to take “all measure necessary” to preserve and protect any personally identifiable information of (or privacy obligations related to) IntelliCentrics, its customers, or those of their respective patients or customers of which Medcom may become aware or to which it may gain access.” For professionals, Medcom 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 INFORMATION
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.
- Do not track signals and requests: ‘Do not track signals and requests’ are sent from your browser to the website you visit indicating that you do not want to be tracked or monitored. Websites are not required to accept these requests, and many do not. At this time, our Platform does not honor do not track signals or requests.
HOW YOU CONTROL YOUR INFORMATION
You 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:
To exercise any rights your jurisdiction may provide, contact us at
Privacy@IntelliCentrics.com. We may require you to verify your identity before exercising your individual rights. We will respond to your request within the time frames required in your jurisdiction.
We are a data “controller” as provided under the GDPR.
HOW YOU OPT-OUT OF MARKETING MATERIALS
You 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 INFORMATION
We 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.
If 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)