Effective as of January, 2010

CarePartners Plus ("CarePartners" or “we”) has developed this privacy policy (the "Privacy Policy") for the benefit of the users ("Users" or "you") of its web site, namely, http://www.carepartnersplus.com, to demonstrate our serious commitment to protecting your privacy. The following information summarizes how CarePartners collects, uses and discloses personal data on and through this website.  (Please see the section below entitled “Information Collected Through the Wellby Monitor” for our practices involving the collection, disclosure and usage of information submitted through the Wellby^TM monitors at healthcare providers’ offices.)  By using this web site and/or any of the tools or services available on or through this site (collectively, the “Site”), you consent to the collection, use and disclosure of information from you in accordance with this Privacy Policy.  

We reserve the right to change the terms of this Privacy Policy at any time. When we make changes, we will revise the "last updated" date at the top of the Privacy Policy and post the changed policy on the Site.  If there are material changes to this Privacy Policy or in how CarePartners will use personal information collected from you, we will notify you by prominently posting a notice of such changes here or on our home page, or by sending you an e-mail.  Notwithstanding the foregoing, your provision of any information on or through the Site following any such change will constitute your consent to the collection, disclosure and use of such information in accordance with the changed policy.  Accordingly, we encourage you to review this Privacy Policy whenever you visit the Site in order to familiarize yourself with the most recent version.  Please also see CarePartners’ Terms of Use for more information on the terms and conditions governing the use of this Site.

Why does CarePartners need my personal information and how is it used?

We ask for personal information in order to verify our Users’ authorization to access restricted areas of the Site and restricted information on the Site and to provide our Users with a more personalized, relevant, and intelligent service.  Additionally, CarePartners regularly makes improvements to this Site. The collection of personal data greatly assists CarePartners in this improvement process by identifying the interests and needs of the many Users to this Site.  This data collection assists CarePartners by enabling us to display content more relevant to you.   

Although CarePartners' primary goal in collecting personal information through the Site is to deliver a customized, personalized and useful service to you, CarePartners may also use the personal information it collects to (i) send Users e-mail notification of new features or information available through the Site or that CarePartners otherwise feels might be of interest to Users of the Site, send account- or transaction-related communications such as welcome letters and transaction confirmations, and provide you with newsletters, RSS feeds, reports, or other communications or services which you have signed up for or otherwise agreed to receive; (ii) process any transactions you request and provide customer service; and (iii) perform research and analysis aimed at improving our products, services and technologies. CarePartners also collects IP addresses, or the location of your computer on the Internet, for systems administration, security and troubleshooting purposes, to enhance your User experience as you navigate through the Site, and to report anonymous, aggregate information (but NEVER information that is personally identifiable, i.e., linked to you individually or any of your patients or plan participants, as applicable) to our advertisers, research partners and others. 

Please see the section below entitled “Information Collected Through the Wellby Monitor” for our practices involving the use of information submitted through the Wellby monitors at healthcare providers’ offices.  

How and what information does CarePartners gather or track?

CarePartnersCarePartners collects both personally identifiable data (i.e., linked to you individually) and anonymous or non-personally identifiable data.  For example, if you are a doctor or are representing a healthcare provider or health insurance plan, we will collect personal and/or business information, such as name, organization name, mailing address, e-mail address, telephone number, and professional licensure information, in order to enable you to register to access the restricted areas of the Site and obtain reports, verify that you are entitled to receive information collected from your patients or plan participants (as applicable) through the Wellby monitors at healthcare providers’ offices, and access and view all permissible information relevant to you.

In addition, and more generally, through the use of "cookies" (as described below) and online data entry, survey and registration forms, CarePartners may collect and/or monitor, in both personally identifiable and anonymous or aggregated form, the following facts, data and information:

The personal information in the “Reference” column is necessary to enable Users to register on the Site and authenticate your identity so that you can use the valuable tools and services available through the Site.  However, all of the personal information collected on this Site is optional with respect to use of the Site.  Users determine what personally identifiable information they wish to submit on a voluntary basis to CarePartners.  However, for privacy and security reasons, if you do not wish to submit personal information, you will not be able to access the restricted areas of the Site. 

For specific information on our practices involving the collection, disclosure and use of information submitted by patients through the Wellby monitor, please see the section below entitled “Information Collected Through the Wellby Monitor”.

Cookies, Web Beacons and Other Information Collecting Technologies

CarePartners may place and store Internet cookies on a User’s hard drive. Cookies can save any of the types of technical information noted above, as well as username and password. "Cookies" are small pieces of information that are stored by your web browser software on your computer's hard drive or temporarily in your computer's memory. The use of cookies is now an industry standard, and Users will find them on most major web sites.

Cookies enable CarePartners to personalize the viewing experience of a User of this Site. When the User revisits this Site, CarePartners can recognize the User by the cookie and customize the User's experience at this Site accordingly. For example, CarePartners may use cookies to recognize User access privileges to this Site, track Site usage and traffic patterns, record the date and time of your visit and your session identification number, add advertisements for products or services of interest, and estimate this Site's audience size. CarePartners may also use cookies to store usernames and passwords that are supplied at registration in order to improve your user experience.  Cookies offer you many conveniences. They may be used, for example, to allow us to identify registered Users when they return to the Site so that they can retrieve previous image search results.  Cookies can also save you time by eliminating the need to repeatedly enter the same information.

CarePartners does NOT utilize cookies or other information collecting technologies to store personally identifiable health- or treatment-related information, other sensitive personal information such as financial account information, or personal contact information such as names, addresses or telephone numbers, either for ourselves or for third parties. 

Although most web browsers are initially set up to accept cookies, if you prefer, a User may decline the placement of a cookie on his or her hard drive by using the appropriate feature(s) of one's web browser software (if available) to delete the cookie. Users should understand, however, that certain areas within this Site may not function properly if the web browser will not accept cookies.

CarePartners may use other technologies, including web beacons, on our Site and in promotional e-mail messages or newsletters. For example, we may embed third-party traffic measurement software, such as Google Analytics, on the public pages of the Site to help us analyze web traffic. Web beacons (sometimes known as single-pixel gifs) are tiny electronic images can be used to assist us in determining how many users have visited certain pages or opened messages or newsletters. We do not use these images to collect personal information.  We may also place flash objects on your computer in order to collect browser and other information that helps us improve the security of your online communications with our Site.

Does CarePartners disclose personal information to third parties?

Except as set forth below, CarePartners will NOT disclose your personal information collected on the Site to third parties.  

1.    We may employ third parties to perform services or functions on our behalf in order to provide or improve our Site, marketing and promotional efforts, communications or other services. Those third parties may include authorized contractors, consultants and other companies working with us (collectively, "agents"). They only have access to your information as needed to perform their functions, and they may not share any of your information with others or use it for any other purpose than providing or improving CarePartners' services and offerings.  These third parties have confidentiality obligations to CarePartners and must protect personal information to the same extent as CarePartners, including not using it for any improper purpose. 

2.    CarePartners may be obligated to cooperate with various law enforcement inquiries. CarePartners reserves the right to share or transfer your registration information or other information as permitted by applicable laws to comply with a legal requirement, and/or to disclose any activities or information about you to law enforcement or other government officials as we, in our sole discretion, determine necessary or appropriate, in connection with an investigation of fraud, the administration of justice, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability.

3.    CarePartners discloses personal information in anonymous, aggregate form to third parties, such as researchers, advertisers, marketers and providers of health-related products and services, in a manner by which you will not be personally identifiable.

4.    To the extent permitted by applicable law, information about our Users, including personal information, may be disclosed as part of any merger, acquisition, or sale of CarePartners and/or its assets, as well as in the unlikely event of insolvency, bankruptcy, or receivership, in which case personal information would be transferred as one of the business assets of the company.

5.    Personal information collected from patients through the Wellby monitor at healthcare providers’ offices may be disclosed as set forth in the section below entitled “Information Collected Through Wellby Monitor.”  If you are a patient, note that you have the option of de-identifying information submitted through the Wellby monitor so that we cannot link it to you. 

Note that CarePartner does NOT disclose any health or treatment information to third parties for purposes of targeted advertising. 

Information Collected Through the Wellby Monitor

This Privacy Policy is primarily intended to describe CarePartners’ practices regarding the collection, use and disclosure of information you submit through the Site.  However, information submitted by patients through the Wellby monitor at healthcare providers’ offices is stored in our database.  Patients submitting information through the Wellby monitor at their healthcare provider’s office always can choose to de-identify their information, i.e., ensure that it is not linked to them individually.  If you are a doctor or healthcare provider, you should be prepared to refer patients to the wellby.com website so that they can become fully informed about our privacy practices concerning information that they choose to submit to us.  Personal information collected through the Wellby monitor and stored on our database, should patients choose to submit such information., As noted above, submission of all identifying information is voluntary; patients are not required to do so in order to answer the survey questions. 

CarePartners will NOT use or disclose any information collected from patients through the Wellby monitor except as provided in this section:

1.    Health and treatment information will be viewable to persons to whom it may be disclosed under the Health Insurance Portability and Accountability Act ("HIPAA") Privacy Rule (to the extent it is applicable) and applicable state and federal privacy laws.  These persons include individuals and organizations involved in a patient’s care or payment for such care, such as the patient’s doctor, the hospital or other healthcare organization that employs the doctor, and the patient’s health insurer.  Access to this information is controlled on the basis of the role of each person or organization seeking access to the information, so that access is granted only to the extent and for purposes permitted by applicable federal and state privacy laws, including to assist in the patient’s care, to ensure that they receive the proper quality of care, or the processing of payment for such care, and also to view the treatment and services the patient received to (i) verify that the services were actually provided and/or (ii) evaluate the performance of the healthcare provider’s staff and ensure that the patient and other patients of the same healthcare provider are cared for with medical excellence.  

2.    We may disclose information when required to do so by federal, state or local law.  For example, we may disclose this information to representatives of the Office for Civil Rights of the U.S. Department of Health and Human Services so that they may ensure that we are appropriately protecting the privacy of health information.

3.    We may use and disclose information when necessary to prevent a serious threat to a patient’s health and safety or the health and safety of the public or another person.  Any disclosure, however, would only be to someone able to help prevent the threat. 

4.    If a patient is an organ or body donor, we may release health and treatment information to organizations that handle organ or body procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary to facilitate organ, tissue or body donation and transplantation. 

5.    If a patient is a member of the armed forces, we will release their information as required by military command authorities.

6.    Information that is de-identified, i.e., not linkable to the patient, in accordance with the requirements of the HIPAA Privacy Rule may be shared in aggregate, anonymous form with third parties, such as researchers, advertisers, marketers and providers of health-related products and services.

7.    We may disclose patient information to employees and third-party service providers as necessary for them to provide, maintain and improve our database.  They only have access to patient information as needed to perform their functions, and they may not share any of this information with others or use it for any purpose other than as necessary to perform their function.  These third parties have confidentiality obligations to CarePartners and must protect personal information to the same extent as CarePartners, including not using it for any improper purpose.

8.    We may use and disclose information as necessary to process a transaction a patient has requested from us, such as using their credit or debit card to pay a medical bill. 

9.    Patients’ answers to survey questions may be used for their benefit to notify their doctor or healthcare organization about potential risks relating to their examination or treatment.  We may also use them in combination with similar information from other patients to generate scores or ratings (including our PRQA^TM Scores) evaluating potential risks associated with, or the quality of care offered by, their doctor or healthcare organization.  These ratings and scores may be disclosed or sold by CarePartners to third parties.  However, no personal information about the patient will be disclosed to such third parties.

10. In all other circumstances, we will ONLY disclose personal information (including health and treatment information) collected through the Wellby monitor if we obtain the patient’s express informed consent prior to the disclosure or if the patient is a registered user of our Wellby.com^TM website and directs us to share the information through that website.  Our Wellby.com privacy policy can be viewed at www.wellby.com/privacy. 

CarePartners will require any third party receiving any of the information collected through the Wellby monitor to maintain the privacy of the information in accordance with the HIPAA Privacy Rule (to the extent it is applicable) and applicable state and federal privacy laws. CarePartners cannot guarantee that any third party will maintain the privacy of such information, even if the third party has promised to comply with the HIPAA Privacy Rule.

We will NEVER disclose personally identifiable information collected through the Wellby monitor to third-party marketers or use it for purposes of targeted advertising.

What about external web sites?

To the extent hyperlinks are utilized to access third party sites (such as when you click on a link for a third party article or product), Users should be aware that these third party web sites are not controlled by CarePartners and, therefore, are not subject to this Privacy Policy. Users should check the privacy policies of these individual sites to see how their personal information will be utilized by the proprietors and operators of those third party web sites. We assume no responsibility for the privacy or security policies or practices of such linked sites, and encourage you to become acquainted with them prior to use.  For example, such sites may use cookies, web beacons, pixels, flash objects and/or other technologies to track traffic and gather personal information (as well as use and disclose such gathered information) in ways different from ours.

What does CarePartners do to keep this Site and personal information secure?

CarePartners maintains rigorous physical, technical and administrative safeguards, compliant with applicable laws and meeting high standards for medical and military system information collection, storage and exchange, to prevent the unauthorized release of or access to personal information, whether collected through the Site or otherwise stored in our database.  These safeguards include security features designed to meet strict levels of logical security, physical security and external systems communications security.  Our security features include, but are not limited to, system access controls, internal and external firewalls, encryption of personal information transmitted between your browser and the Site via Secure Sockets Layer (SSL) technology, and controlled physical access to our premises.  CarePartners grants access to any stored personal information only to authorized personnel and parties.

Users can further enhance the security of their information by following reasonable personal security measures.  This would include choosing a non-obvious and “strong” password (i.e., at least eight characters and mixing letters and numerals), as well as safeguarding their password and not leaving their information on an unattended computer. 

Please be advised, however, that although CarePartners has endeavored to create a secure and reliable Site for its Users, the confidentiality of any communication or material transmitted to/from CarePartners via this Site, e-mail or the Wellby monitor cannot be guaranteed.  When disclosing any personal information, all Users should remain mindful of the fact that it is potentially accessible to the public, and consequently, can be collected and used by others without User consent.  Accordingly, Users should consider carefully if they want to submit sensitive information (such as health or treatment information) that they would not want disclosed to the public and should recognize that their use of the Internet, this Site and the Wellby monitor is solely at their own risk. Users, alone, are ultimately responsible for maintaining the secrecy of their personal information.  CarePartners urges all of its Users to be careful and responsible whenever they are online.

Can I opt out of having my personal information used for marketing purposes?

CarePartners does not share personally identifiable information obtained through the Site with third parties to use in marketing their own products or services.  Users can opt out of receiving marketing e-mails from CarePartners by clicking on the "opt-out" or “unsubscribe” link in any such e-mail sent to you by CarePartners (or by choosing the appropriate option on our Preferences page).  Please keep in mind that, even if you choose not to receive these communications, you may continue to receive transactional or account communications (e.g., confirmation e-mails) and other communications which are required or permitted by applicable law.  Please also see the section below about your ability to access, correct or remove your personal data record.

 Do I have the ability to access and correct my personal information?

At any time, a User or other individual who has submitted personal information may contact CarePartners via e-mail to request:

• A summary of any personal information retained by CarePartners on such person,
• A change to such individual’s personal data record maintained by CarePartners, or
• Removal of such individual’s personal data record from CarePartners' database.

You may send your request to the following e-mail address, info@carepartnersplus.com. California residents with privacy questions should also contact us at this e-mail address.  In the event CarePartners receives such a request, CarePartners may require you to confirm or verify any change to your personal record. NOTE, however, that such requests apply only to your personal data record, not to any PRQA Score or other rating that may relate to you; such scores and ratings are the proprietary information of CarePartners.  

Responsibility for Patient Health Information

The Site and the Wellby monitor provide tools, reports and technologies to enable doctors, healthcare organizations and health insurance plans to provide a better quality of care, to reduce unnecessary medical costs, and to empower patients to take charge of their own health and medical treatment.  Doctors, healthcare organizations, health insurance plans and other parties permitted under the HIPAA Privacy Rule to access and view patient health information through the Site or obtain reports containing patient health information via the Site (collectively, “Permitted Parties”) are responsible for safeguarding the privacy and security of such patient health information in accordance with the HIPAA Privacy Rule and Security Rule and other applicable federal and state privacy laws (collectively, “Privacy Laws”).  Accordingly, if you are a Permitted Party, you agree that you will NOT access, view, disclose or use (or permit another to do so) patient health information, whether on the Site or in a report obtained via the Site, except in strict accordance with Privacy Laws.  You also agree to comply with any additional confidentiality restrictions in CarePartners’ Terms of Use and any other agreement you may have with us.  If you are not a Permitted Party, you may NOT access, view or receive patient health information through the Site. 

What about the collection of personal information from children?

This Site is intended for individuals of age eighteen (18) years and older.  Accordingly, CarePartners will not knowingly collect through the Site information from persons under the age of eighteen (18).  Parents and/or legal guardians accompanying patients under the age of eighteen are permitted to provide information through the Wellby monitor on behalf of the patient.

Further Questions?

CarePartners welcomes questions or comments Users may have regarding this Privacy Policy or the use of your personal information. Please send any questions or comments to CarePartners at the following e-mail address, info@carepartnersplus.com.