1. Types of Information Collected
(a) Personally Identifiable Information
Personally identifiable information (“PII”) means information that specifically identifies you as an individual, such as your full name, telephone number, email address, postal address or certain account numbers. VNS Health may ask you for certain kinds of PII to provide and promote the various services available through the Platform. You do not have to provide us with PII if you do not want to; however, that may limit your ability to use certain functions of the Platform or to request from VNS Health or to benefit from certain services or information.
(b) Usage Information
Whenever you visit or interact with the Platform, we, as well as our third-party service providers, use a variety of technologies that automatically or passively collect information about how you access and use the Platform (“Usage Information”). Usage Information includes your Internet Protocol address or other unique identifier for your device, your device type, your browser type, your operating system, the pages you view on the Platform, the pages you view immediately before and after you access the Platform and the search terms you enter into the Platform. Most Usage Information does not directly identify you and is considered non-personally identifiable information (“Non-PII”); however, if Usage Information is used in a way that could directly identify you, we will treat it as PII.
VNS Health may also use “pixel tags” (sometimes called “web beacons” or “clear gifs”), which are tiny graphic images, on the Platform. Pixel tags may help VNS Health analyze users’ online behavior and measure the effectiveness of the Platform. Pixel tags and cookies in VNS Health’s emails may be used to track your interactions with those messages, such as when you receive, open or click a link in an email message from VNS Health.
(c) Personal Health Information
Personal Health Information is the health information about you (which includes any individually identifiable information that we obtain from you or others that relates to your past, present or future physical or mental health, the health care you have received, or payment for your health care) that VNS Health collects, creates and maintains. This information may qualify as “protected health information,” or “PHI,” under the Health Insurance Portability and Accountability Act of 1996, as amended and its implementing regulations, and Health Information Technology for Economic and Clinical Health Act and its implementing regulations (collectively, “HIPAA”). Such information may include member eligibility and claims data. VNS Health is required by law to maintain the privacy of PHI. VNS Health is also required by law to provide you with a Notice of HIPAA Privacy Rights as to PHI, which can be accessed at https://www.vnshealth.org/corporate-compliance-privacy/privacy-statements/hipaa-privacy-notice/ and we will comply with the terms as stated there in so far as PHI is communicated or collected through the Platform. For more information about VNS Health’s policies concerning medical information, you can also visit https://www.vnshealthplans.org/hipaa-privacy-policy.
Please understand that the terms of the Notice of HIPAA Privacy Rights apply to PHI that we may collect, or that you may share with us, through electronic communications. This includes that in certain circumstances VNS Health may use and disclose your health information without your specific written authorization, as described in the Notice of HIPAA Privacy Rights. It also means that you may consent to use or disclosure of your PHI under other circumstances as well.
2. Use of Information
VNS Health uses the information collected from you when you use the Platform for various purposes. These include, without limitation:
- to provide the services you request;
- to process your application as requested by you;
- to follow up with you regarding your interest and/or use of the VNS Health services;
- to keep you informed about the status of your services;
- to identify your preferences so VNS Health can notify you of information or products, services and promotions that might be of interest to you;
- to personalize your experience on the Platform;
- to improve customer service and the overall experience with VNS Health;
- to generate and analyze statistics about the preferences of users of the Platform;
- to comply with applicable laws, regulations and legal process; and
- to communicate with and advertise to users of the Platform and others by email, postal mail, telephone, text message or other means.
VNS Health may also combine or aggregate any of the information it collects through the Platform or elsewhere for any of these purposes.
3. Sharing of Information
By using the Platform, you are deemed to consent to certain limited uses of your PII, including that VNS Health may share your PII under certain circumstances with businesses to help the Platform function or improve VNS Health services. VNS Health may therefore disclose information to outside companies that help promote and bring users like you the services VNS Health offers. For example, VNS Health may work with an outside company to: (a) manage a database of customer information; (b) assist in distributing emails; (c) assist with direct marketing and data collection; (d) provide data storage and analysis; (e) provide fraud prevention; (f) provide customer service by phone and/or (g) provide other services designed to assist VNS Health in maximizing its business potential and maintaining the Platform. VNS Health requires that these outside companies keep confidential all information VNS Health shares with them and (except as described below with respect to aggregate information or Non-PII) to use the information only to perform their obligations in their agreements with VNS Health.
VNS Health does not share, sell or trade with third parties (other than Related Parties and third parties hired by VNS Health to help operate the Platform or our business) any of your PII or any specific details about you as an individual, except with your consent, as may be needed to operate our business, or as may be required or permitted by law, each as described below.
VNS Health will ask You for certain kinds of PII to provide the various services available through the Platform. This PII includes:
Your Partners in Care Account – Partners in Care is an affiliate of VNS Health. In order to use and access some portions of the Partners in Care Site, You will have to create a personal account (the “Account”) with VNS Health, either through the Partners in Care Site or by speaking directly with a VNS Health representative. Once You create an Account, You may access Your Account online at any time to add, delete or change Your information.
VNS Health may, from time to time, add account features to other Platforms, and these same policies will apply to such accounts with such Platforms. Your creation of an account with or for such Platforms is deemed an acceptance of these policies and terms.
E-mail List – When You create an Account and You opt-in to receiving e-mail from VNS Health, You will be added to VNS Health’s e-mail list. Your e-mail address will not be sold to, or shared with, anyone who is not affiliated with or working for VNS Health. Your subscription to the e-mail list can be cancelled at any time. To be removed from VNS Health e-mail list, please e-mail VNS Health at [email protected] and include Your name and e-mail address in the message, or click the unsubscribe button found at the bottom of the e-mails You receive from VNS Health.
Calls to Customer Service/Participation in Surveys – If You call VNS Health Customer Service center or participate in one of VNS Health’s User surveys, You may be asked for additional information, such as Your age, interests or service preferences. This information will be stored by VNS Health as well.
VNS Health may share PII when legally required, to cooperate with police investigations or other legal proceedings, to protect against misuse/unauthorized use of the Platform, to limit VNS Health’s legal liability or to protect the rights, property or safety of other users of the Platform or the public. VNS Health may share PII with outside companies that help bring you the services VNS Health offers. VNS Health may share PII with any successor company, such as a company that acquires VNS Health or its assets, or an affiliate, service provider or other third party to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition or sale of our assets.
In addition, VNS Health may share aggregate reports of user demographics, traffic, patterns and other Non-PII with third parties for any reason. VNS Health may also make such information available, in aggregate form, to marketing partners, advertisers and others in order to assist VNS Health in providing its services and identifying potential customers. Further, the information that VNS Health collects may be used to improve the Platform, to personalize Your online experience, to help VNS Health deliver information to You, to determine the effectiveness of VNS Health’s advertising and for other internal business purposes.
VNS Health may also work with business partners that use tracking and related technologies (such as Facebook’s Custom Audience) to deliver advertisements on VNS Health’s behalf across the Internet. These companies may collect Non-PII about Your visits to the Platform and Your interaction with VNS Health’s communications. VNS Health may combine the information it collects through these companies, cookies and pixel tags with other information including PII (like your email address) VNS Health has collected from You. By using the Platform or agreeing to receive any VNS Health email or newsletter, you agree and consent to VNS Health sharing your email address to Facebook for use solely in connection with its Custom Audience Targeting program. Facebook will match your email address to its database and will display advertisements for VNS Health on your Facebook portal. If you do not wish to see such targeted advertisements, please opt-out of the Custom Audience by following the instructions available here.
DMD Healthcare Communications Network Privacy Statement
This digital service participates in the DMD Healthcare Communication Network (the “Network”), and as such has implemented various technologies for universal registration/login among all Network member websites. These technologies are managed by DMD Marketing Corp. (“DMD”), and may involve the collection, receipt, and sharing of information with DMD, its clients and other Network members. If you would like to understand how this digital service’s participation in the Network affects your privacy, please click here: http://usersupport.dmdconnects.com/PrivacyPolicy.htm.
VNS Health may share your PHI as noted in the HIPAA Privacy Notice. This may include sharing such information with qualified healthcare professionals, their staff and others who have agreed to maintain the confidentiality of such information consistent with HIPAA. This includes advising such persons, among other things, as follows:
The Platform may provide qualified healthcare professionals with access to patient health information that may qualify as “protected health information,” or “PHI,” under the Health Insurance Portability and Accountability Act of 1996, as amended and its implementing regulations, and Health Information Technology for Economic and Clinical Health Act and its implementing regulations (collectively, “HIPAA”). Such information may include member eligibility and claims data. You are responsible for ensuring that your use of the Platform complies with the requirements of HIPAA and any other applicable federal or state laws. You should follow appropriate security measures in connection with use of the Platform, including but not limited to:
- Logging in only under your user ID
- Keeping your login credentials confidential and safe from discovery from others
- Logging off from or locking your computer or mobile device when it is unattended
- Closing your browser after using the Platform
- Contacting us immediately if you suspect that your login credentials have been compromised
FAILURE TO COMPLY WITH HIPAA AND OTHER APPLICABLE FEDERAL AND STATE PRIVACY LAWS COULD LEAD TO DISCIPLINARY SANCTIONS, WHICH MAY INCLUDE FINES AND CIVIL OR CRIMINAL PROSECUTION.
Code of Conduct and Provider Manual
Finally, please understand that there are portions of the Platform where one may post comments that become available to other users. VNS Health is not responsible for the content of such posts, and cautions you as a user not to disclose in such forums any information that you consider, or wish to remain, private or confidential.
4. Security of Information
VNS Health uses reasonable physical, electronic and administrative safeguards to maintain the security of PII it collects, including restricting physical access to our offices and computer servers, as well as employing electronic security systems and password protections that guard against unauthorized access. However, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While VNS Health will use reasonable means to protect the security of information you transmit to VNS Health, VNS Health cannot guarantee that such information will not be intercepted by third parties and VNS Health will not be liable for the acts of third parties.
Additionally, please note that email is not encrypted and is not considered to be a secure means of transmitting information, so please do not email VNS Health any confidential, financial or sensitive information.
5. Links to Other Websites
6. Children and Privacy
The Platform is not meant for children and VNS Health will not knowingly collect any PII from anyone under the age of 18. By providing VNS Health with PII, you are verifying that you are at least 18 years old. Further, if you become aware that a child under your care has provided us PII without your consent, please contact us at the contact information listed below.
8. Contact Information
Chief Compliance Officer
220 East 42nd Street, 6th Floor
New York, NY 10017