PRIVACY POLICY

Effective: November 28, 2013

Power2Patient ("P2P"), a division of Ageology, LLC, is a confidential Internet application service provider that enables healthcare providers and their patients to communicate through a patient portal - Power2Patient. P2P requires all persons using its services to adhere to this Privacy Policy and accept the Terms of Use. This Privacy Policy only applies to those P2P services, which are provided through a subscription agreement with your physician or medical practice ("Provider").

P2P respects your privacy and takes Internet privacy very seriously. By accepting P2P's Terms of Use, you consent to the use and disclosure of personally identifiable information provided to us as outlined in this Privacy Policy. P2P will operate in compliance with the Health Insurance Portability and Accountability Act of 1996, as amended from time to time ("HIPAA"), and the HIPAA implementing regulations regarding privacy and security at 45 Code of Federal Regulations ("C.F.R.") Parts 160-164, as promulgated by the United States Department of Health and Human Services ("HHS") and as amended from time to time ("Privacy and Security Rules").

Collecting Information

P2P provides you ("Patient") and your physician, designated users or authorized member of a physician's practice (individually and collectively, "Provider") with the ability to communicate with each other regarding medical issues and/or general health matters. Because P2P provides a service for Web-based communication between you and your Provider, we ask you for personal information your Provider's office needs to provide appropriate care and treatment. Certain Patient contact information is collected when you register (for example name, email address, home address, zip code, date of birth, etc). Since P2P is an interactive communication platform, P2P collects information from you at several points during your subscription.

P2P will not sell, share or rent your information that is collected in the P2P service to others in ways different than from what is disclosed in this policy.

  • Patient Contact Information.

    • Information Request. If you wish to request more information about P2P prior to registering, you are required to provide contact information so that P2P can contact you about our services. It is optional for you to provide additional contact information (for example, health plan and physician).

    • Pre-Registration. With your consent, your Provider or a member of your Provider's staff will pre-register you for P2P. The pre-registration process consist of the Provider assisting you in selecting a unique patient identifier (i.e. sign-in name - "Patient ID") and being provided an initial password. In addition, your Provider will obtain your contact information, and may request additional information, such as your home phone number, email address, home address, health plan information, etc). This information will be used by P2P to contact you about our services. In order to complete the pre-registration process to use P2P, you will be asked to agree to P2P's Terms of Use.

    • Registration. Upon your initial log-in to P2P using the Patient ID and initial password, you will be required to select a new password that will not be shared with your Provider. Upon registration, you may be asked to provide contact information directly, if this information was not entered during pre-registration, and to provide additional information of your health status. In order to complete registration, you will be asked to agree to P2P's Terms of Use before being able to use P2P.

  • Patient Medical Information.

    • Provider-Patient Communications. P2P offers various messaging platforms relating to specific requests and/or purposes to facilitate communications (for example, Referral Requests, Prescription Renewal Request; Appointment Request). Either you or your Provider can initiate such messages and/or communications. Your response and/or provision of information regarding these communications is voluntary; therefore, you have a choice whether or not to disclose this information. Information provided via these communications may be used to update your Health Record. In addition, by initiating and/or responding to such communications, your Health Record will be accessible to your Provider. All communication using P2P will be recorded and maintained in your Health Record. P2P will not edit the content of the communication between you and your Provider. P2P considers these communications to be personal and private and will not use or disclose these communications except as provided for in this Privacy Policy or where required by law. However, P2P may block or remove certain communications materials (for example, offensive or otherwise unacceptable materials for which a complaint has been reported). P2P does not capture and will not record any electronic communication (e.g. email, text, etc) between you and your Provider that occurs outside of P2P, such as via Google mail, or SMS tex.

    • Health Record. The Health Record is a tool that permits you to provide and store health information online, including health conditions, allergies and medications. You have the ability to enter information into your Health Record directly. Your Provider will be able to enter information into your Health Record.

    • Pre-Filled Health Record. At your option and based upon consents received from you by your Provider, your Provider may elect to pre-fill medical information and create a Health Record for you via P2P. The creation of a Health Record may include the collection of contact information, as well as certain health information about you, including health conditions, medications and allergies. This information may be used by P2P to contact you about our services. In order to register to use P2P, you will be asked to confirm the information provided, review your Health Record and agree to P2P's Terms of Use. You have the ability to request not to receive information from P2P at any time.

    • Patient Intake Questionnaire. The Intake Questionnaire is a voluntary interactive interview guiding a patient through clinically relevant questions based on clinical care algorithms to aid the Provider in making an accurate and thorough medical assessment of your condition. Once you initiate P2P, you will be asked to complete the Intake Questionnaire. Information provided by you via a Intake Questionnaire will be used to update your Health Record. Your Provider will have access to your Health Record, including the Intake Questionnaire.

    • Patient Log Files. P2P collects and stores the Internet Protocol (IP) address of the computer you are using; the name of the domain and host from which you access the Internet; the browser software you use and your operating system; the date and time you access the service; and the Internet address of the Web site from which you directly linked to P2P. P2P uses this log file information to analyze trends, administer the service, and monitor service traffic and usage patterns for internal security purposes and to help make the P2P service more useful.

  • Provider Information.

    • Provider Registration. When Provider arrives at P2P, we require the collection of certain contact information as part of the Provider registration process (for example, name, office address, office zip code, office fax, e-mail address).

    • Provider-Designated User Registration. We require the collection of certain contact information as part of the registration process for any person designated by the Provider to engage with P2P (for example, name, user function, office zip code, office fax, e-mail address). All Provider designated users must agree to P2P's Terms of Use before being able to use P2P.

    • Provider Log Files. P2P collects and stores the Internet protocol address of the computer Provider is using; the name of the domain and host from which Provider accesses the Internet; the browser software Provider used and Provider's operating system; the date and time Provider accesses the service; and the Internet address of the Web site from which Provider directly linked to P2P. P2P uses this log file information to analyze trends, administer the service, and monitor service traffic and usage patterns for internal security purposes and to help make the P2P service more useful.

Use And Disclosure of Information

Except as specifically set forth in this Policy, your information, including your Health Record, will only be used and disclosed in accordance with the Notice of Privacy Practice provided to you by your Provider. A copy of your Provider's policies may be obtained by contacting your Provider.

  • Use of Patient Information.

    • Identifying and providing educational materials, sending appointment reminders and wellness information;

    • Send prescription information to pharmacies, and updating your Health Record based upon interactive communications and your use of P2P (including prescription information);

    • Providing you with appointment reminders, educational materials, and wellness information;

    • Providing information as required by law.

  • Disclosure of Patient Information.

    • Health Record. Your Provider may review your Health Record and adjust it and respond to your messages. In addition, any person authorized by you to use your Patient ID and password ("Patient Authorized User") may access your Health Record, those individuals authorized by you will also have the ability to review and enter information into your Health Record.

    • Health Record Changes. If you would like to update or change information in your Health Record, you can send a message to your Provider stating the change or correction you think is needed or you may update portions of your Health Record directly.

    • Provider Referrals. Where your Provider determines that it is clinically appropriate, they may send a referral message to another provider and/or refer you as a patient to another provider. This referral message may include personally identifiable medical and/or health information about you, including, but not limited to, your Health Record. Although the consulting provider may be able to view this information, they are not able to update and/or edit your Health Record.

    • Sharing of Information with Providers. P2P may disclose the contact, billing and/or health information provided by you in our service to provide your Provider or other healthcare provider with updated and/or supplemental information for their files or systems about you.

    • Compliance with Laws. P2P will not disclose personal information (contact, health and/or billing) to third parties other than as provided for in this Privacy Policy, in accordance with your Provider's Notice of Privacy Practices, and applicable state and Federal laws, including HIPAA.

    • Pharmacies and Pharmacy Benefits. When you or your Provider use the P2P service to send your prescription to a pharmacy, we will release your name, address, prescription information and insurance plan information to the pharmacy. In addition, we may disclose certain necessary claims data to other entities (for example, the provider of your drug benefit) as required to facilitate and/or coordinate your pharmacy benefits (for example, health plan, mailing address, billing information for copayment purposes).

    • Diagnostic Clinical Laboratories. When you or your Provider use the P2P service to send your test order/requisition to or receive results from a clinical laboratory, P2P will release your name, address, test order information and insurance plan information to the clinical laboratory.

  • Aggregate Data

    P2P may use non-identifiable anonymous data that is taken from your Health Record and combine it with other anonymous data to create what is referred to as "aggregate data" that may be disclosed to third parties. Aggregate data is information that describes the conditions, treatments, habits, usage patterns, demographics and/or such other health related information of users as a group but does not reveal the identity or locator information of particular users. Locator information is your name, electronic messaging address, physical address, or other data that enables someone to personally identify you. This data will not identify you but will be used as statistical information to determine such things as user demographics and usage patterns of our services. P2P may use aggregate data within P2P to conduct research in order to understand the needs and activities of the P2P community of users. Aggregate data may be provided or sold to third parties. P2P may use this aggregate data to give potential users, providers, or business partners a picture of the P2P community and services. P2P and your Internet Access Provider may use Locator Information as is necessary to enforce any of the terms of the P2P Terms of Use.

Deactivation of Your Health Record

Your Health Record with P2P may be deactivated by (i) providing notice of your request to your Provider in accordance with your Provider's Notice of Privacy Practices (ii) by your Provider providing notice to P2P, or (iii) by P2P in the event that you violate the Terms of Use or the Privacy Policy or your Provider ceases to be a subscriber to P2P. P2P will forward to your Provider an electronic copy of your Health Record and thereafter P2P will deactivate your access to P2P and your Health Record will be securely archived. P2P retains archived information for a period of ten years (or longer if required by law) as necessary to comply with legal obligations, resolve disputes, enforce our agreements, or other authorized uses under this Policy. Your archived information will remain available for use as aggregate data.

Storage and Maintenance of Information

P2P stores and maintains all electronic communications sent via P2P, the content of all Patient Questionnaires, your Health Record, contact information, financial information and all attachments and/or files uploaded or posted to P2P for the duration of your Provider's subscription agreement with P2P. At the expiration or termination of your Provider's subscription agreement with P2P, P2P will forward to your Provider an electronic copy of your Health Record and thereafter P2P will deactivate your access to P2P and your Health Record.

Security

P2P takes all reasonable measures to secure your data on our servers, in our data center in accordance with our Security Policy. For more information, please refer to P2P's Security Policy.

Protecting Your Privacy

In order to protect your privacy while you can:

Never share your sign in name or password.

Always sign out when you are finished using the service.

Changes to this Privacy Policy

Although P2P is required to adhere to the terms of your Provider's Notice of Privacy Practices, P2P reserves the right to change the terms of this Privacy Policy at any time by posting those changes on our services so that you are always aware of our processes related to collection, use and disclosure of information. We will inform you of any material change to our Privacy Policy that involves the use of your personal health information in order to give you the opportunity to choose to terminate your Health Record with P2P.

Questions

If you have any questions about this Privacy Policy or the use of your information via P2P, please contact us at customerservice@power2patient.com.





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