PRIVACY POLICY AND NOTICE OF PRIVACY PRACTICES

CareCoach Privacy Policy and Notice of Privacy Practices Effective on February 24, 2012.
This privacy statement describes how Verilogue, Inc. collects and uses the personal information and protected healthcare information you provide on our Web site: www.carecoach.com and through any associated CareCoach mobile application. It also describes the choices available to you regarding our use of your personal and non-personal information and protected health information and how you can access and update this information. We collect and use Personal Information and Protected Health Information as described below. Please note that some categories of information may be both Personal, Non-Personal and Protected Health Information and subject to all policies.
CareCoach is a division of Verilogue, Inc. and references to CareCoach, herein, include Verilogue, Inc.
CareCoach is a patient-focused initiative that provides patients, healthcare providers and other caregivers with information, support and tools to improve their communications with one another.
Personal and Non-Personal Information is the data we collect from you as described in the Privacy Policy below.
Protected Health Information (PHI) is any information, whether oral or recorded in any form or medium: (i) that relates to the past, present or future physical or mental health or condition of an individual; the provision of health care to an individual; or the past, present or future payment for the provision of health care to an individual, and (ii) that identifies the individual or with respect to which there is a reasonable basis to believe the information can be used to identify the individual. PHI is protected under the Healthcare Portability and Accountability Act of 1996 ("HIPAA").

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PRIVACY POLICY: Collection and Use of Personal Information

Personal information
We collect the following personal information from you
We use this information to
Non-Personal information
We collect the following non-personal information from you
We use this information to
As is true of most Web sites, we automatically gather information about your computer such as your IP address, browser type, referring/exit pages, and operating system. We use this information to
Protected Health Information (PHI)
To review how we may collect your Protected Health Information (PHI), please refer to the HIPAA Notice of Privacy Practices: Protected Health Information section.

Information Sharing

Personal Information
We may share your personal information with third parties only in the ways that are described in this privacy statement. We do not sell your personal information to third parties. We may also disclose your personal information
Non-Personal Information
We may share and disclose your non- personal information for the purpose described in this statement or where it is collected, or any other legal purpose, including, when and where applicable, sharing and disclosing non-personally identifiable information combined with personally identifiable information. We may also disclose your non-personal information
We may use cookies, for example, to keep track of your preferences and profile information. Cookies are also used to collect general usage and volume statistical information that does not include personal information. We use a third party to gather information about how you and others use our Web site. For example, we will know how many users access a specific page and which links they clicked on. We use this aggregated information to understand and optimize how our site is used.
Protected Health Information (PHI)
We may request permission to use and share your de-identified health information; including, audio recordings, transcripts and personal health information that you have submitted or will submit in the future. Upon your permission to do so, de-identified health information may be made available for use by third parties to conduct training, research, quality improvement projects and/or for other uses aimed at marketing and improving healthcare. De-identification will include the removal of your name, location, and all other demographic information that identifies you or your healthcare providers from the health information. Verilogue will not share audio de-identified health information with any third parties without your explicit permission to do so.
You may give us written authorization to use your protected health information or to disclose it to another person and for the purpose you designate. If you give us authorization, you may withdraw it in writing at any time. Your withdrawal will not affect any use or disclosures permitted by your authorization while it was in effect. Unless you give us written authorization, we cannot use or disclose your PHI for any reason except those described in this notice or required by law.

Security

The security of your personal information is important to us. When you enter sensitive information (such as credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

Risks and Benefits

While our goal is to help patients communicate better and improve healthcare outcomes, there are no certain benefits to using this website. However, planning ahead and tracking doctor visits has been shown to be helpful in improving overall health.
There are also no known risks to using this website, but there is a possibility that users may feel uncomfortable sharing information online. It is possible that a user could be identified using information shared on CareCoach (and/or in conjunction with other data sources). Users should understand that anyone can register at CareCoach and view the shared data in the system. If you are reading this Privacy Policy because you have access to the Personal Information of a Site participant, we urge you to recognize and fulfill your responsibility to protect the privacy of that person.
In using the website, users are free to skip any non-required questions or data fields that make them feel uncomfortable. Users are also free to stop using this service at any time.

Links to Other Web Sites

Our Site includes links to other Web sites whose privacy practices may differ from those of Verilogue. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.

Additional Policy Information

Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Please exercise discretion and use caution with respect to your information, especially in such public areas. We do not control who reads postings on our websites, or how they may use or disclose such information. If you choose to voluntarily disclose information on public portions of our websites, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION ABOUT YOURSELF OR OTHERS IN PUBLIC AREAS OF OUR WEBSITES. WE ARE NOT RESPONSIBLE FOR THE USE OR DISCLOSURE OF SUCH INFORMATION.

Correcting and Updating Your Personal Information

To review and update your personal information to ensure it is accurate, contact us at support@carecoach.com.

Notification of Privacy Statement Changes

We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We will also keep prior versions of this Privacy Policy in an archive for your review. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

You can contact us about this privacy statement by writing or email us at the address below:
Verilogue
200 Gibraltar Road, Suite 300
Horsham, PA, United States 19044
Email: support@carecoach.com

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HIPAA NOTICE OF PRIVACY PRACTICES: Protected Health Information

This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review this notice carefully.
This Notice is provided to you pursuant to the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations ("HIPAA") as amended. It is designed to tell you how we may, under federal law, use or disclose your Protected Health Information.

  1. HIPAA Covered Entities May Use or Disclose Your Health Information for Purposes of Treatment, Payment or Healthcare Operations without Obtaining Your Prior Authorization:

    • Although we do not provide treatment, we may disclose your Health Information to health care professionals - including doctors, nurses and technicians - for purposes of assisting them with obtaining payment for health care that they have provided to you. However, we will only make such disclosures with your consent.
    • Although we do not make or process claims for payment, HIPAA Covered Entities are permitted to disclose information for purposes of verifying treatment for payment of health insurance claims.
    • We may access or send your information to our attorneys or accountants in the event we need the information in order to address one of our own business functions.
    • We may disclose your personal health information to another entity that is subject to federal Privacy Rules and that has a relationship with you for its health care operations relating to quality assessment and improvement activities, reviewing the competence or qualifications of healthcare professionals, case management and care coordination or detecting or preventing health care fraud and abuse.

  2. We May Also Use or Disclose Your Health Information Under the Following Circumstances without Obtaining Your Prior Authorization:

    As Required by Law.

    For Marketing of Our Services. We may contact you as part of a marketing effort for Verilogue. As part of our marketing, we may tell you about Verilogue's health-related products and services that may be of interest to you. If you receive a communication from us for either marketing or fundraising purposes, you will be told how you can choose not to receive any further marketing or fundraising communications.

    For Public Health Purposes. We may use or disclose your Health Information to provide information to state or federal public health authorities, as required by law to prevent or control disease, injury or disability; to report child abuse or neglect; report domestic violence; report to the Food and Drug Administration problems with products and reactions to medications; and report disease or infection exposure.

    The following uses will only occur as required by law. Verilogue will not voluntarily use your Health Information for any of the following uses:

    For Health Oversight Activities. We may use or disclose your Health Information to health oversight agencies during the course of audits, investigations, certification and other proceedings as required by applicable law. We do not anticipate this situation will arise given the scope of our activities.

    In Response to Civil Subpoenas or for Judicial and Administrative Proceedings. We may use or disclose your Health Information, as directed, in the course of any civil administrative or judicial proceeding. However, in general, we will attempt to ensure that you have been made aware of the use or disclosure of your Health Information prior to providing it to another person.

    To Law Enforcement Personnel. We may use or disclose your Health Information to a law enforcement official to identify or locate a suspect, fugitive, material witness or missing person, comply with a court order or grand jury subpoena and other law enforcement purposes. We do not anticipate this situation will arise given the scope of our activities.

    To Coroners or Funeral Directors. Under HIPAA, a Covered Entity may use or disclose your Health Information for purposes of communicating with coroners, medical examiners and funeral directors. We do not anticipate this situation will arise given the scope of our activities.

    For Purposes of Organ Donation. Under HIPAA, a Covered Entity may use or disclose your Health Information for purposes of communicating to organizations involved in procuring, banking or transplanting organs and tissues. We do not anticipate this situation will arise given the scope of our activities.

    For Public Safety. Under HIPAA, a Covered Entity may use or disclose your Health Information in order to prevent or lessen a serious and imminent threat to the health or safety of a particular person or the general public. We do not anticipate this situation will arise given the scope of our activities.

    To Aid Specialized Government Functions. If necessary, we may use or disclose your Health Information for military or national security purposes. We do not anticipate this situation will arise given the scope of our activities.

    For Worker's Compensation. Under HIPAA, a Covered Entity may use or disclose your Health Information as necessary to comply with worker's compensation laws. We do not anticipate this situation will arise given the scope of our activities.

    To Correctional Institutions or Law Enforcement Officials, if You are an Inmate. We do not anticipate this situation will arise given the scope of our activities.

  3. For All Other Circumstances, We May Only Use or Disclose Your Health Information After You Have Signed an Authorization. If you authorize us to use or disclose your Health Information for another purpose, you may revoke your authorization in writing at any time.

  4. You Should Be Advised that We May Also Use or Disclose Your Health Information for the Following Purposes:

    Change of Ownership. In the event that our company is sold or merged with another organization, your Health Information/record will become the property of the new owner.

  5. Your Rights.

    1. You have the right to request restrictions on the uses and disclosures of your Health Information.
    2. You have the right to receive your Health Information through confidential means through a reasonable alternative means or at an alternative location.
    3. You have the right to inspect and copy your Health Information and you also have the right to a copy of your Health Information in an electronic format, but only if it is contained in an Electronic Health Record ("EHR"). We may charge you a reasonable cost-based fee to cover copying, postage and/or preparation of a summary, and in the case of a request for a copy of your Health Information maintained in an EHR (or a summary or explanation of such information) in an electronic format, we may charge you the amount of our labor costs in responding to your request.
    4. You have a right to request that we amend your Health Information that is incorrect or incomplete. We are not required to change your Health Information and will provide you with information about our denial and how you can disagree with the denial.
    5. You have a right to receive an accounting of disclosures of your Health Information made by us, except that we do not have to account for disclosures: authorized by you; provided to you; provided in response to an Authorization; made in order to notify and communicate with family; and/or for certain government functions, to name a few. We also generally do not have to account for disclosures made for treatment, payment and health care operations, except when such disclosures of your Health Information are made through an EHR.
    6. You have a right to a paper copy of this Notice of Privacy Practices. If you would like to have a more detailed explanation of these rights or if you would like to exercise one or more of these rights, contact us using the information provided below.

  6. Our Duties.

    We are required by law to maintain the privacy of your Health Information and to provide you with a copy of this Notice.

    We are also required to abide by the terms of this Notice.

    We reserve the right to amend this Notice at any time in the future and to make the new Notice provisions applicable to all your Health Information - even if it was created prior to the change in the Notice. We will provide you with another copy of this Notice at any time, upon request.

  7. Complaints to the Government.

    You may make complaints to the Secretary of the Department of Health and Human Services ("DHHS") if you believe your rights have been violated.

    We promise not to retaliate against you for any complaint you make to the government about our privacy practices.

  8. Contact Information.

    You may contact us about our privacy practices by writing or calling the Privacy Officer at:

    Verilogue
    200 Gibraltar Road, Suite 300
    Horsham, PA, United States 19044
    Email: support@carecoach.com

    You may contact the DHHS at:

    Office for Civil Rights
    Department of HHS
    Jacob Javits Federal Building
    26 Federal Plaza - Suite 3312
    New York, NY 10278
    Voice Phone: (212) 264-3313
    Fax: (212) 264-3039
    TDD: (212) 264-2355

  9. Electronic Notice

    This Notice of Privacy Practices is also available on our web page at carecoach.com/privacyPolicy.