Introduction
Lifelink Systems Inc. ('LifeLink'), a Delaware Corporation, is the operator of the www.lifelinksystems.com website, developer of assorted web and mobile applications, and provider of associated software and services ('Software and Services'). The Software and Services enable people desiring feedback about an existing medical condition ('User', 'Users') to request and receive remote second opinions from providers ('Provider', 'Providers'). This policy (the 'Privacy Policy') defines the manner in which LifeLink collects, uses, maintains, and discloses information from the Software and Services. As both Users and Providers utilize the Software and Services references throughout this Privacy Policy to 'You' or 'Your' are to the applicable User or Provider as the context requires.
LifeLink complies with the Health Insurance Portability and Accountability Act of 1996 ('HIPAA') and applicable U.S. state laws relating to patient privacy and health data security. This Privacy Policy demonstrates LifeLink's commitment to our Users' and Providers' privacy. LifeLink recognizes that when You provide your personal information, You expect and trust LifeLink to handle that information carefully and responsibly. LifeLink is committed to making sure Your personal information is safe and secure.
Please read this Privacy Policy carefully before using LifeLink's Software and Services. By using the Software and Services, User and Provider, as applicable, signifies assent to these Terms. If a User or Provider does not accept and agree to be bound by these Terms, the User or Provider is not authorized to access or otherwise use the Software and Services or any information or content contained therein. Continued use of the Software and Services following the posting of changes to the Privacy Policy, as described below, shall be deemed to be acceptance of those changes.
Personal Identification Information
LifeLink may ask You for Your personal identification information, including, but not limited to, first and last name, email address, mailing address, phone number, and Social Security number (collectively, the 'Personal Identification Information'), when visiting or utilizing the Software and Services. LifeLink will collect Your Personal Identification Information only if You voluntarily consent. If You refuse to supply Personal Identification Information, You may be prevented from engaging in certain activities related to the Software and Services, including, but not limited to, requesting and/or receiving remote second opinions from Providers.
Medical Information
In order to facilitate accurate second opinions regarding User's health, User may be required to provide LifeLink with past and current medical records, a description of symptoms, a medical history, lifestyle descriptions, any imaging or other diagnostic test results, and other relevant medical information and/or documentation (collectively, the 'Medical Information').
Non-Personal Identification Information
Web Browser Cookies
Like most major websites, the Software and Services use 'cookies' to enhance Your experience. Your web browser places cookies on Your hard drive for record-keeping purposes and sometimes to track information about You. You may choose to set Your web browser to refuse cookies or to alert You when cookies are being set, although some parts of the Software and Services may not function properly.
How LifeLink Collects and Uses Your Information
LifeLink may collect and use Personal Identification Information, Medical Information, and non-Personal Identification Information (collectively, 'Your Information') for the following purposes:
_ To provide the LifeLink Software and Services. LifeLink may request Your Information that is necessary to provide the medical second opinions and other products and services LifeLink offers.
_ To improve customer service. LifeLink may use Your Information to respond to customer service requests and support needs more efficiently.
_ To improve the Software and Services. LifeLink may use Your feedback to improve LifeLink's Software and Services.
_ To process payments. LifeLink may use Your Information to collect and remit payments on behalf of Users and Providers. LifeLink does not share this information with outside parties except to the extent necessary to provide the service.
_ To send periodic emails. LifeLink may use the email address to send Users and Providers information and updates pertaining to the Software and Services.
LifeLink may be legally obligated to disclose information about You to the government or third parties under certain circumstances, such as in connection with illegal activity on Software and Services or to respond to a subpoena, court order, or other legal process. LifeLink reserves the right to release Your Information to law enforcement or other government officials as deemed necessary or appropriate in LifeLink's sole and absolute discretion.
If You access LifeLink's Software and Services outside of the United States, information that LifeLink collects about You may be transferred to servers inside the United States and maintained indefinitely. By allowing LifeLink to collect information about You, You consents to such transfer and treatment of Your data.
How LifeLink Protects Your Information
The Software and Services require You to create unique identifiers (such as a Your name and password) in order to log into many areas of the Software and Services. LifeLink utilizes these unique identifiers to verify Your identity and eligibility in order to protect You from the release Your Information to unauthorized parties. To help protect the privacy of data transmitted through the Software and Services, where Your Information is requested, LifeLink uses technology designed to encrypt the information before it is sent to LifeLink using Secure Sockets Layer (SSL) technology or similar encryption technology. In addition, LifeLink takes steps to protect Your Information against unauthorized access. These measures include appropriate data collection, storage and processing practices, and security measures to protect against unauthorized access, alteration, disclosure, or destruction of Your personal information, Your name, password, transaction information, and data stored on LifeLink's Software and Services. However, You should keep in mind that LifeLink's Software and Services are run on software, hardware, and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond LifeLink's control.
LifeLink will make every reasonable effort to secure its Software and Services but does not represent, warrant, or covenant anything related to sage, complete, or hack-proof transmissions in transit or at rest within the Software and Services. You assumes the risk of any unauthorized disclosure or intentional intrusion, or of any delay, failure, interruption, or corruption of data or other information transmitted or stored at rest in connection with the use of the LifeLink Software and Services.
Sharing Your Information
LifeLink does not sell, trade, or rent Personal Identification Information to others. LifeLink may share generic aggregated demographic information not linked to any Personal Identification Information regarding visitors and users of the Software and Services with LifeLink's business partners, trusted affiliates, and advertisers.
LifeLink may disclose Your Information to LifeLink's third-party contractors (such as billing and collections companies) in order to provide certain services to LifeLink or to complete or confirm a transaction between the You and LifeLink.
User Protected Health Information
To the extent that User's Personal Identification Information and/or Medical Information constitutes protected health information, as defined in 45 CFR ' 160.103 ('Protected Health Information'), LifeLink shall use and disclose such Protected Health information only in accordance with HIPAA. Users' rights regarding such Protected Health Information include:
_ Right to access User's Protected Health Information. User has the right to review or obtain copies of User's Protected Health Information records. User's request to review and/or obtain a copy of Protected Health Information records must be made in writing. LifeLink may charge a fee for the costs of producing, copying, and mailing the requested information. LifeLink will inform the User of the cost in advance.
_ Right to amend User's Protected Health Information. If User feels that User's Protected Health Information maintained by LifeLink is incorrect or incomplete, User may request that LifeLink amend the information. User's request must be made in writing and must include the reason User is seeking a change. LifeLink may deny User's request if, for example, User asks us to amend information that was not created by LifeLink, or User asks to amend a record that is already accurate and complete. If LifeLink denies User's request to amend, LifeLink will notify User in writing. User then has a right to submit to LifeLink a written statement of disagreement with LifeLink's decision, and LifeLink will have the right to rebut that statement. (Please note that any amendment of records prepared by a healthcare provider, which User has forwarded to us, is the responsibility of the original provider. In such an instance, User should direct User's request to that provider.)
_ Right to an accounting of disclosures. User has the right to request an accounting of disclosures LifeLink has made of User's Protected Health Information. The list will not include LifeLink's disclosures related to User's treatment, LifeLink's payment or health care operations, or disclosures made to User with authorization. The list may also exclude certain other disclosures, such as for national security purposes.
_ Right to request restrictions on the use and disclosure of User's Protected Health information. User has the right to request that LifeLink restrict or limit how LifeLink uses or discloses User's Protected Health Information for treatment, payment or health care operations[1] .
_ Right to receive confidential communications. By using the Software and Services, User has consented to receive any confidential communications from LifeLink as electronic communications that shall be made and may be accessed through the Software and Services or in any other less secure form to which User consents, including but not limited to email, SMS, or other messaging services.[2]
_ Right to receive notification of a breach of Protected Health Information. In the event of a breach of User's Protected Health Information, User has the right to receive notification of such breach. User has consented to receive such notification through an electronic communication through the Software and Services.
_ Right to a paper copy of this Privacy Policy. User has a right at any time to request a paper copy of this Privacy Policy, even if User has previously agreed to receive an electronic copy.
Advertising
Ads appearing on LifeLink's Software and Services may be delivered to User or Provider by advertising partners who may set cookies. These cookies allow the ad server to recognize Your computer each time they send You an online advertisement to compile non-personal identification information about You or others who use User's computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of interest to You. This Privacy Policy does not cover the use of cookies by any advertisers.
Changes to this Privacy Policy
LifeLink has the discretion to update this Privacy Policy at any time. If and when LifeLink does so, LifeLink will post a notification on the LifeLink website at www.lifelinksystems.com/privacy. LifeLink encourages User to frequently check this page for any changes to stay informed about how LifeLink is protecting Your Information collected through the Software and Services. User acknowledges and agrees that it is Your responsibility to review this Privacy Policy periodically and be aware of modifications.
Contact
If User has any questions about this Privacy Policy, the practices of the Software and Services, or User's dealings with the Software and Services, or if User wishes to exercise any of the rights described above or submit a complaint regarding this Privacy Policy, contact LifeLink at:
Chief Compliance Officer
Lifelink Systems Inc.
1625 Clay Street, 3rd Floor
Oakland, CA 94612