If you are a physician or other healthcare or medical provider (“Provider”), or an individual who is authorized by a Provider to access and use the Services (“Designee”), we collect Personal Information about you when the Provider subscribes to the Services as well as when you register to use the Services. The Personal Information about Providers and Designees that we collect includes, without limitation, the Provider’s and Designee’s name, specialty, email address, phone number, and business postal address. We do not collect Protected Health Information about Providers or their Designees.
If you are a patient of a Provider who has subscribed to the Services (“Patient”), we collect Personal Information about you when you register to use the Services and through your or your Authorized Caregiver’s use of the Services, including when you, your Authorized Caregiver and your Provider communicate with each other. If you are an individual authorized by a Patient to use the Services to communicate with such Patient’s Provider (“Authorized Caregiver”), we collect Personal Information about you, including, without limitation, your name, email address, phone number and your relationship to the Patient. When communicating with the Provider in using the Services, the Patient, Authorized Caregivers, Provider and its Designees may disclose Personal Information about the Patient, which may include Protected Health Information. We do not collect Protected Health Information about Authorized Caregivers.
We may use Personal Information, as follows:
We may disclose Personal Information, including Protected Health Information (defined below) as follows:
We may use and/or disclose Protected Health Information in the same manner as Personal Information, described above, except our use and disclosure of Protected Health Information is further limited as provided by the administrative simplification provision of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the Health Information Technology for Economic and Clinical Health Act of 2009 (“HITECH”) and the Omnibus regulations promulgating Standards for Privacy of Individually Identifiable Health Information and Security Standards for the Protection of Electronic Protected Health Information promulgated thereto.
Specifically, as described above, all uses or disclosures of PHI shall require Patient authorization or a valid authorization on the patient’s behalf, except: (1) uses or disclosures by or to the Patient; (2) uses or disclosures for treatment, payment or healthcare operations; (3) as part of any valid use or disclosure; or (4) in compliance with and pursuant to Applicable Law.
Meplis may disclose PHI for most other purposes only pursuant to Patient’s valid authorization, as follows: (1) for most uses and disclosures of psychotherapy notes; (2) for use or disclosure of PHI for marketing purposes; (3) for disclosures that constitute a sale of PHI; or (4) for other uses or disclosures that are not exempt from the authorization requirement.
We will enter into business associate agreements with the Patient’s Providers who are “Covered Entities” when we are a “Business Associate,” as those terms are defined by HIPAA. We will use and disclose Protected Health Information only for those uses and disclosures permitted by HIPAA and under the applicable business associate agreement. We may use or disclose Protected Health Information to provide Services to the Patient or the Provider. We may also use Protected Health Information for our proper management and administration or to carry out our legal responsibilities.NON-PERSONAL INFORMATION
“Non-Personal Information” is any information that does not reveal your specific identity, such as:
We and our third party service providers may collect Non-Personal Information in a variety of ways, including:
Because Non-Personal Information does not personally identify you, we may use and disclose Non-Personal Information for any purpose whatsoever. In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your geographical location). If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.
Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user uses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites.
We use IP Addresses for purposes such as calculating usage levels, helping diagnose server problems, and administering the Services. We may also use and disclose IP Addresses for all the purposes for which we use and disclose Personal Information. Please note that we treat IP Addresses, server log files and related information as Non-Personal Information, except where we are required to do otherwise under applicable law.
We use reasonable organizational, technical and administrative measures to protect Personal Information under our control, consistent with the Omnibus regulations promulgating Standards for Privacy of Individually Identifiable Health Information and Security Standards for the Protection of Electronic Protected Health Information. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.
Likewise, Meplis will notify affected Providers and Patients of any breach of unsecured PHI within twenty-four (24) hours of notice and confirmation thereof.
How you can access or change your Personal Information
If you would like to review, correct, update, delete or otherwise limit our use of your Personal Information that has been previously provided to us, you may contact us in accordance with the “Contacting Us” section below.
In your request, please make clear what information you would like to have changed, whether you would like to have your Personal Information deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. We will try to comply with your request as soon as reasonably practicable. Please note that in order to comply with certain requests to limit use of your Personal Information we may need to terminate your account with us and your ability to access and use the Services, and you agree that we will not be liable to you for such termination or for any refunds of prepaid fees paid by you. Although we will use reasonable efforts to do so, you understand that it may not be technologically possible to remove from our systems every record of your Personal Information. The need to back up our systems to protect information from inadvertent loss means a copy of your Personal Information may exist in a non-erasable form that will be difficult or impossible for us to locate or remove.
The Services are not permitted for use by individuals under the age of eighteen (18) unless they have provided the written consent of their parents or legal guardians, and we request that these individuals do not provide Personal Information to us.