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© LIFELINK SYSTEMS INC
Introduction
Lifelink Systems Inc. ('LifeLink', 'We', 'Us', 'Our'), 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 health care organizations ('Provider', 'Providers') to engage, coordinate care, and communicate with their customers ('User', 'Users').
This policy (the 'Privacy Policy') defines the manner in which LifeLink collects, uses, maintains, and discloses information from the Software and Services, the www.lifelinksystems.com Web site, other web pages that We operate in which We post a direct link to this Privacy Policy (each a 'LifeLink Site'). It also describes the choices available to You regarding the use of, Your access to, and how to update and correct Your personal information. 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 applicable United States ('U.S.') state and federal laws and applicable laws outside of the U.S. where required, relating to patient privacy and health data security and where applicable, personal privacy and 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 voluntarily using the Software, Services, and/or providing data or other information by or through a LifeLink Site, You, User and/or Provider, as applicable (on behalf of Yourself and/or the legal entity that You represent), are indicating your consent to these Terms and agree (on behalf of Yourself and/or the legal entity that You represent) to be bound by 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 LifeLink Site, Software and/or Services or any information or content contained therein. Continued use of the LifeLink Site, Software and/or Services following the posting of changes to the Privacy Policy, as described below, shall be deemed to be acceptance of those changes.
If You are a California resident or data subject in Europe, please see the California and European Union and Switzerland sections, respectively. For protected health information in the U.S., please see the User Protected Health Information section below. If You have any questions or wish to exercise Your rights and choices, please contact us as set out in the Contact section below.
Personal Identification Information
You can visit a LifeLink Site without telling us who You are and without actively revealing any personal information about Yourself except for certain personal information which may be collected as a result of Your visit to the Site. There are times, however, when LifeLink may require Your personal information. LifeLink may ask You for Your personal identification information, including, but not limited to, first and last name, email address, date of birth, 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 information related to the coordination of care from Providers.
Medical Information
In order to facilitate the coordination of care between Users and Providers, Users may be required to provide LifeLink with information regarding Your medical history, a description of symptoms, lifestyle behaviors, 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. For more information regarding cookies and how LifeLink collects and uses cookies, see Our Cookie Policy.
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 products and services LifeLink offers.
_ To authenticate and personalize the use of LifeLink Software and Services. If You are a LifeLink User, Provider, customer, or partner, We use Your personal information to provide You with an identity in Your usage of the products and services LifeLink offers. As part of LifeLink's general security features, LifeLink also collects IP addresses from You and sets certain cookies when You log into the Software and Services. Additionally, We use cookies to remember users’ settings (e.g. language preference), for authentication on the LifeLink applications and to provide relevant information on Our public websites. For information about how users can control the use of cookies, please see Our Cookie Policy. If You reject cookies, You may still use Our website, but Your ability to use some features or areas of Our website may be limited.
_ To improve customer service. LifeLink may use Your Information to respond to customer service requests and support needs more efficiently.
_ To manage Customer and Partnership Relationships. If You are a LifeLink customer or partner, or You are working with LifeLink sales personnel on a possible engagement between LifeLink and Your company, We may use Your personal information You provided to Us, particularly Your business contact information and information relevant for the engagement, for the purpose of managing the relationship and in connection with any potential contractual arrangements between Our companies. We also may process Your personal information as a part of a professional services engagement and/or in order to provide You with Our technical support services.
_ To improve the Software and Services. LifeLink may use Your feedback and usage data 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.
_ For marketing. Software and Services may be delivered to a 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 advertising 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.
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 Sites, Software and/or Services outside of the U.S., information that LifeLink collects about You may be transferred to servers inside the U.S. and maintained indefinitely. By allowing LifeLink to collect information about You, You consent to such transfer and treatment of Your data. Where required by applicable law, information that LifeLink collects about You may be required to remain inside the applicable jurisdiction.
How LifeLink Protects Your Information
The Software and Services may require You to create unique identifiers (such as Your name and password) in order to log into some 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 of 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 assume 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 companies that help us provide the LifeLink Site, Software and/or Services, to perform certain business-related functions for Us or that process information on Our behalf for Our business purposes or in order to provide certain services to LifeLink or to complete or confirm a transaction between the You and LifeLink. These companies include affiliated business partners or agents, consultants or related companies and may provide services such as payment processing, data analytics, marketing and advertising, website hosting, fraud prevention and detection, communication services, technical support or implementation services. When We employ another company to perform a function of this nature, We only provide it with the information that it needs to perform its specific function. Transfers to these third parties are covered by the provisions in this Privacy Policy and in the service agreements We have with You. Transfers of personal information to these third parties is subject to all applicable data protection laws and regulations, and, whenever required, subject to the specific contractual arrangements between Us and the third party.
From time to time, We may partner with other companies to jointly offer products or services. If You purchase or specifically express interest in a jointly offered product or service from us, LifeLink may share certain information collected in connection with Your purchase or expression of interest with Our joint promotion partner(s). LifeLink does not control Our business partners' use of the information We share with them, and their use of the information will be in accordance with their own privacy policies. If You do not wish for Your information to be shared in connection with any joint offerings, You may opt not to purchase or specifically express interest in a jointly offered product or service.
In certain situations, LifeLink may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose Your personal information as required by law, such as to comply with a subpoena or other legal demand, when We believe in good faith that disclosure is necessary to protect Our rights, protect Your safety or the safety of others, investigate fraud, or respond to a government request.
If LifeLink were to be involved in a merger, acquisition, or sale of all or a portion of its assets, You will be notified via email and/or by way a prominent notice on the LifeLink Site of any change in ownership, uses of Your personal information, and choices You may have regarding Your personal information. We may also disclose Your personal information to any other third party with Your prior consent.
Your Rights and Choices
Removal
You may opt-out of receiving promotional communications, remove Your information from Our database, remove Your information from blogs, forums or testimonials, unsubscribe from communications related to the LifeLink Software or Services, or cancel Your account by contacting us at compliance@lifelinksystems.com. In some cases, We may not be able to remove Your personal information, in which case We will explain that We are unable to do so and why.
Correcting, Updating and Accessing
Upon Your request and authentication of Your identity, LifeLink will provide You with information about the personal information We have collected from You, whether We hold Your personal information or whether We process Your personal information on behalf of a third party. You have the right to contact us to request the correction, modification or deletion of Your personal information. To make such a request and/or to pose any other questions regarding this Privacy Policy, please contact Us at compliance@lifelinksystems.com. Requests made to LifeLink to access, change or delete personal information will be addressed within 30 days, or earlier if required by applicable laws or regulations.
Where We are unable to provide access to certain personal information that You request and are required to refuse, we will notify You in writing, document the reasons and outline further steps which are available to You.
Cookies
Most browsers accept cookies by default. You can instruct Your browser, by changing its settings, to decline or delete cookies in accordance with the LifeLink Cookie Policy.
Information Retention
We will retain Your personal information for as long as needed to provide the applicable service, and as needed to comply with Our legal obligations, resolve disputes, and enforce Our agreements. We may also retain data from which You cannot directly be identified.
Third Party Web Site Links
A LifeLink Site may contain links to other websites. LifeLink is not responsible for the privacy practices or the content of such third party websites. Inclusion of such websites on the LifeLink Site does not indicate LifeLink's endorsement of such third parties or confirm that LifeLink has reviewed or approved the third party websites. LifeLink recommends contacting the operators of those websites directly for information regarding their privacy policies.
California
The following disclosures apply only to individuals who reside in California. The California Consumer Privacy Act (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing Personal Information to provide notice of rights California residents have and can exercise.
California Notice of Collection. LifeLink collects information corresponding to the following categories of information identified in the CCPA.
For more information on what We collect, please review the sections above regarding personal information collection. We collect and use these categories of Personal Information for the business purposes described in the section on “How We Use Personal Information We Collect From You”, including to provide and manage the services related to Our LifeLink Platform.
LifeLink does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities, We will comply with applicable law as to such activity.
LifeLink discloses the following categories of information for commercial purposes:
We use and partner with different types of entities to assist with daily operations and manage the LifeLink Site, Software and Service.
Right to Know and Delete. If You are a California resident, You have the right to know certain information about Our data practices in the 12 months preceding any such request. In particular, You have the right to request the following from Us:
You also have the right to have the Personal Information that LifeLink has collected from You deleted. This is, however, not an absolute right and LifeLink may have legal grounds for keeping such data.
Exercising Your Rights. To exercise any of these rights, please submit a request to compliance@lifelinksystems.com. Your request should specify which right You are seeking to exercise and the scope of the request. We will strive to confirm receipt of Your request within 10 days. We may require specific information from You to help us verify Your identity and process Your request. If We are unable to verify Your identity, We may deny Your requests to know or delete.
Authorized Agent. You can designate an authorized third party to submit requests on Your behalf. However, We will require written proof of the agent’s permission to do so and verify Your identity directly.
Right to Non-Discrimination. You have the right to not be discriminated against by Us as a result of Your exercising any of Your rights.
Canada
Transfer Of Data. We primarily store data about You, including personal information, on servers located and operated within the U.S. If You reside or are located outside of the U.S., We may send and store Your Personal Information (also commonly referred to as personal data) to the U.S. in order to provide and operate the LifeLink Site, Software and Services. By accepting the terms of this Privacy Policy, You acknowledge the transfer to and processing of Your Personal Information on servers located in the U.S. and other countries. You may contact our privacy team (at the contact information provided below) to obtain information about our policies and practices regarding our transfer of personal information outside of Canada, or to ask questions about the collection, use, disclosure or storage of personal information by us or our foreign service providers.
Interest-Based Advertising in Canada. For more information about interest-based ads, or to opt in or out of having Your web-browsing information used for behavioral advertising purposes, please see our Cookie Policy.
Information Retention. We will keep personal information used to make a decision affecting You for at least one year after using it to make the decision. We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for a legal or business purpose. We will take due care when destroying personal information so as to prevent unauthorized access to the information.
European Union and Switzerland
Data Sub-processor. If You are a LifeLink customer or partner, We and/or Our third party agents act as Your data sub-processors. LifeLink primarily processes and stores Your data, including personal information, on servers located and operated within the U.S. If You reside or are located outside of the U.S., We may send to and store Your personal information in the U.S. in order to provide and operate the LifeLink Site, Software and Services. If Your personal information (as defined in the EU General Data Protection Regulation (“GDPR”) as “personal data”) that is being processed by LifeLink is subject to GDPR, We undertake to ensure an adequate level of protection of the personal data transferred outside the European Economic Area, either by us, Our affiliates, and/or third party agents, in accordance with applicable legislation, in particular via the signature of the standard contractual clauses approved by the European Commission or the Privacy Shield certification.
If You wish to exercise any of these privacy rights under GDPR, or if You need further information regarding those privacy rights, please contact LifeLink at compliance@lifelinksystems.com.
Data Controller. In limited circumstances, where LifeLink processes Your personal information as a data controller, You are entitled to certain privacy rights under certain circumstances:
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
This Privacy Policy describes the choices available to You regarding the use of, Your access to, and how to update and correct Your personal information. Please see the sections above entitled ‘How LifeLink Collects and Uses Your Information’ and ‘Your Rights and Choices’ for more information.
LifeLink participates in, and has certified its compliance with, the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the U.S., respectively (“Privacy Shield Framework”). LifeLink has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Our certification, please visit https://www.privacyshield.gov/.
LifeLink is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. LifeLink complies with the Privacy Shield Principles for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal information received or transferred pursuant to Privacy Shield, LifeLink is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, LifeLink may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If You have questions or concerns regarding this Privacy Policy, please contact LifeLink at compliance@lifelinksystems.com.
In compliance with the Privacy Shield Principles, LifeLink commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact LifeLink at compliance@lifelinksystems.com.
LifeLink has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.
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.
_ 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.
_ 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.
Arbitration
Where allowed in accordance with applicable law, any controversy or claim arising out of or relating to this Privacy Policy, or the breach thereof, that You and LifeLink fail to amicably settle shall be settled in accordance with the Rules of Conciliation and Arbitration of the International Chamber of Commerce then in effect, and judgment on the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof.
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 LifeLink Policy Updates. 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:
Compliance Officer (Data Privacy Officer for GDPR Purposes)
Lifelink Systems Inc.
1625 Clay Street, 3rd Floor
Oakland, CA 94612
compliance@lifelinksystems.com
+1.510.543.1633
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© LIFELINK SYSTEMS INC