Portal Privacy Policy

INTRODUCTION

Citizen Care Health Solutions ( “CCHS,” “we,” “us,” or “our”) may collect information through the use of the Citizen Care Health Solutions Portal and the Citizen Care Health Solutions Provider Application (collectively “Portal”). This information may include, but is not limited to information such as your name, employment information, postal address, email address, phone number and other contact information (“Personal Information”), as well as any health information about patients which may be entered and/or accessed in the Portal, such as name, gender, age, email address, postal address, health care provider, medical tests ordered, results of such tests and/or medical device information (“Patient Information”). This privacy policy (“Portal Privacy Policy”) describes how we may collect, use, and disclose Personal Information and Patient Information when you use the Portal.

This Portal Privacy Policy does not apply to your use of the Citizen Care Health Solutions Website, which is governed by a separate policy which can be found here  www.citizencarehealth.com/privacy-policy.  Any and all notices that may be required by the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”), will be provided to the patient by the health care provider and/or the covered entity that is required to provide any such notice.

COLLECTION OF INFORMATION

In connection with your use of the Portal, we may collect Personal Information such as names, email addresses, phone numbers, name of employer, position/role in the organization, location, username and encrypted password to access the Portal and other information. We may also collect Patient  Information such as names, unique identifiers, gender, age, email address, postal address, health care provider, medical tests ordered, and results of those tests, such as the patient’s weight and blood pressure. When you enter Patient Information in the Portal that may be considered protected health information, you represent and warrant that the collection and disclosure of such information complies with all applicable laws and that you have provided required notices to patients about whom the information pertains and/or obtained any required consent or permission before entering the information on the Portal.

In addition, we may collect information regarding your use of the Portal through the use of cookies (described below), and information from other sources such as our business partners. Such other information may include, but is not limited to the date and time of your visit, your IP address, your browser type, your operating system and language, the pages you visited, and the address of the website from which you came.

We do not intend to transfer your Personal Information or Health Information to any third parties without your consent, except under the limited conditions described under the section entitled “Use and Disclosure of Information” below.

NO COLLECTION OF CHILDREN’S PERSONALLY IDENTIFIABLE INFORMATION

Our Portal is intended for general audiences at least 18 years old and for commercial use. We do not knowingly collect any information from children under the age of eighteen (18). By using the Portal you certify that you are over the age of 18. We reserve the right to delete any information we believe to be in violation of this Portal Privacy Policy.

USE AND DISCLOSURE OF INFORMATION

We may use Personal Information and Patient Information to manage and maintain the Portal, diagnose errors in the Portal or servers, assist with technical problems and provide the information and services that you may have requested or for which you have contracted with us. We may also use Personal Information and Patient Information to keep you informed about events, services, or publications that may interest you. We may use Personal Information and Patient Information entered on the Portal for our own internal management, administration, data aggregation and legal obligations, and enforcing compliance with this Portal Privacy Policy, but only to the extent such use is permitted under applicable laws. We may also disclose information if we are under a duty to disclose in order to comply with any legal or regulatory obligation and to protect our rights or the rights or safety of others.  We may also disclose Personal Information and Patient Information to prospective service providers or business partners that assist us in providing requested services.  If CCHS is involved in a merger, acquisition, or any form of transfer or sale of some or all of CCHS, whether as part of a bankruptcy, liquidation, or similar proceeding, Personal Information and Patient Information may be transferred along with the business as part of any such transaction.

We do not sell or share Personal Information or Patient Information with anyone outside CCHS without your consent, unless we are required to do so by law or as provided in this Portal Privacy Policy.

COOKIES

When you access the Portal, we may place a “cookie” on your device. A cookie is a file that a website can store on your web browser, computer, or device and later retrieve. A cookie allows the Portal to recognize you as a prior user and provide us with information regarding your use.

Cookies set by the website you are visiting are normally referred to as “first-party cookies,” and typically only track your activity on that particular site. Cookies set by other sites and companies (i.e., third parties) are called “third-party cookies,” and can be used to track you on other websites that use the same third-party service.

Cookies we use can be categorized as one of the following: (i) Essential Functionality Cookies; (ii) Non-essential Functionality Cookies; (iii) Statistics Cookies and; (iv) Marketing Cookies.

Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, shopping carts, and payment processing. For example, we may use Captcha cookies to distinguish between humans and bots when the Portal is accessed.

Non-Essential Functionality Cookies are used in collecting information about your device and any settings you may configure on the website you’re visiting (like language and time zone settings). For example, we may use cookies to authenticate and manage user sessions, such as by remembering the user’s language preference during the browsing session.

Statistics Cookies help website owners understand how visitors interact with websites by collecting and reporting information anonymously.

Marketing Cookies allow for the collection of visitor behavior for statistical purpose and to track visitors across devices and marketing channels.

In addition to the above, we may employ third-party companies and individuals for our Website and/or Platform — for example, analytics providers and content partners. We grant these third parties access to selected information to perform specific tasks on our behalf. They may also set third-party cookies in order to deliver the services they are providing. For example, we may use cookies for the purpose of advertisement optimization and personalization. Third-party cookies can be used to track you on other websites that use the same third-party service. As we have no control over third-party cookies, they are not covered by our Privacy Policy.

In addition to the cookies listed above, the Portal may use the cookies utilized by our Website, which are described in a separate privacy policy that can be found here www.citizencarehealth.com/privacy-policy.

If you do not wish to accept cookies from us, you can instruct your browser to refuse cookies from our Portal. Most browsers are configured to accept cookies by default, but you can update these settings to either refuse cookies altogether, or to notify you when a website is trying to set or update a cookie. If you browse websites from multiple devices, you may need to update your settings on each individual device.

Although some cookies can be blocked with little impact on your experience of a website, blocking all cookies may mean you are unable to access certain features and content across the sites you visit.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Our Portal is not currently configured to respond to Do Not Track signals. In order to potentially identify cookies on our Portal, you may use a browser plug-in that scans a website for cookies. We do not guarantee the accuracy, effectiveness and/or security of any such browser plug-in.

You may choose whether to receive some interest-based advertising by submitting opt-outs. Some of the advertisers and service providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding interest-based advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices.  Please be aware that, even if you are able to opt out of certain kinds of interest-based advertising, you may continue to receive other types of ads. Opting out only means that those selected NAI/DAA members should no longer deliver certain Interest-based Advertising to you, but does not guarantee that you will no longer receive any targeted content and/or ads (e.g., from other advertising networks). Also, if your browsers are configured to reject cookies when you visit these opt-out websites,  you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), or you shut down or restart your device or browser, your NAI / DAA browser-based opt-out may not, or may no longer, be effective.

WEB BEACONS

We may use pixel tags (also known as pixel gifs or web beacons) and other methods to gather information about the emails we send to Agencies, Users and/or Providers.  Pixel tags are tiny graphic files that are included in our HTML-encoded email messages. When such a message is opened in an HTML-capable email program, the recipient’s computer will access our servers to retrieve the pixel tag file, allowing us to record and store information such as email address, date and time the recipient viewed the email message, if the recipient’s email program is capable of receiving HTML, and other logging information. We may use this information to optimize delivery of future messages to specific recipients.

ONLINE TRACKING / DO NOT TRACK SIGNALS

“Do Not Track” (DNT) signals are options available on your browser to tell operators of websites that you do not wish to have your online activity tracked. The Portal is not currently set up to respond to these signals. If you choose to block cookies and other trackers, certain features of the Portal may not work. On a mobile device, you may also be able to adjust your settings to limit ad tracking.

YOUR ACCESS TO INFORMATION

As a user of the Portal, you are the primary source of information entered in the Portal. As such, you are responsible for the accuracy and completeness of the information you enter in the Portal. Information entered in the Portal, including Personal Information and Patient Information is accessible from the Portal. If you would like to modify such information, please contact us in writing as described below. We will make reasonable efforts to modify any such information as soon as reasonably practicable.

We will use reasonable efforts to assist you in responding to requests by consumers wishing to exercise their rights under applicable laws.

WE OPERATE IN CANADA AND THE UNITED STATES

If you use the Portal outside of the United States or are a citizen or resident of a country other than the United States that has laws and policies governing the disclosure and management of your Personal Information, you understand and agree that the information you exchange with the Portal may be maintained indefinitely on systems located within Canada or the systems of those third parties with whom we share it as described in this Portal Privacy Policy that are located in the United States. By using the Portal, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in Canada and those third parties with whom we share it as described in this Portal Privacy Policy located in the United States.

INFORMATION SECURITY; NO LIABILITY

We strive to protect the information entered in the Portal, including Patient Information; however, we urge you to take every precaution to protect the confidentiality, integrity and accessibility of the information you enter on the Portal by adopting reasonable security procedures including, but not limited to securing  usernames and passwords that provide access to the Portal, establishing and implementing procedures and policies to regulate access to the Portal and monitoring compliance with these policies and procedures. 

We will maintain reasonable physical, technical and administrative measures in order to protect and safeguard information on the Portal. Unfortunately, information transferred over the internet is not completely secure. Accordingly, we do not guarantee that your information will not be misused or disclosed to third parties. You acknowledge and agree that any transmission of information to our Portal is made at your own risk. We will have no liability to you for any misuse or disclosure of your information. If you share information with third parties via the Portal, you do so at your own risk. Any such information you share with the third party will not be governed by this Privacy Policy and we have no liability to you with respect to such information.

You understand that electronic communications may be accessed by unauthorized parties when communicated across the internet, network communications facilities, or other electronic means. You understand and agree that we are not responsible for any electronic communication or any of your information which may be lost, altered, intercepted, or stored without authorization during the transmission of any data whatsoever across networks not owned or operated by us.

CHANGES

We reserve the right to change this Portal Privacy Policy, at any time, without notice to you; provided, however, that any changes will only apply to information collected after such changes go into effect.

This Privacy Policy was last updated on 24th March 2023.

If you continue to use the Portal or provide Personal Information to us after we change this Portal Privacy Policy, that signifies your consent to such changes and your use of the Portal will be subject to the terms set forth in the most recent version of the Portal Privacy Policy.

QUESTIONS AND CONTACT INFORMATION

If you have any questions or comments about this Portal Privacy Policy or if you need assistance regarding your information, please contact: