PRIVACY POLICY
Star Clinics, Inc. (“Star Clinics,” “We” or “Us”) is committed to respecting the privacy rights of visitors to the websites operated by Star Clinics, including without limitations startherapy.us (the “Site”), onpatient (the “Patient Portal”), all subdomains, all social media accounts held or operated by Star Clinics (collectively, the “Sites”), and all of the Star Clinics systems, applications, clinical guidance, content and services (collectively, “Services”) made available or provided from the Sites. The Patient Portal is an Internet application that enables a patient to have secure web-based access to personal medical information, as released by the treating health care provider, and allows a patient to view, among other things, past appointment information as well as schedule future appointments. Star Clinics has adopted the privacy policies outlined below (this “Privacy Policy”), which serve as the basis for our use of personal information in our business relationships through the Sites. This Privacy Policy is intended to comply with privacy laws applicable to Star Clinics and the operation of the Site, the Patient Portal and the Services. This Privacy Policy, however, does not cover Star Clinics’ offline privacy practices.
WHAT TYPE OF INFORMATION DOES Star Clinics COLLECT?
We may collect three types of information from time to time about users: (1) “Personal Information” (such as name, email address, IP address, location, phone number, personal preferences, injury/insurance information, personally identifiable information, individually identifiable health information, and other account-related information); (2) “De-Identified Information” (such as statistical information on Sites usage, data and knowledge base requirements or qualifications); and (3) “Aggregate Information” (such as information about how many users log on to the Sites on a daily basis):
- Personal Information is collected online when users voluntarily submit non-public personal information by establishing a customer account, requesting information, sending or receiving electronic notices or other similar communications on the Sites. Only your IP address and/or user name would be collected automatically when you access the Sites or the Services for purposes of processing your login to your account in the Star Clinics Patient Portal or enhancing your web site browsing via cookies or standard settings. Your Personal Information will be retained for fulfillment of the intended purposes for which such Personal Information is collected.
- De-Identified Information is collected online information in which all personal and individually identifiable identifiers have been removed by Star Clinics. De-Identified Information is used in a collective manner for analyses and statistics in order to improve the Services. De-Identified Information does not personally identify a specific user.
- Aggregate Information is non-personally identifiable (or anonymous) information about you, such as pages most frequently accessed by you. Aggregate Information is used in a collective manner, and no single person can be identified by that compiled information (for example, the number of people who logged into the Sites in a particular day). Aggregate Information does not personally identify a specific user.
We will establish minimum and maximum retention periods based upon the type of information collected (i.e. sensitivity), the intended purposes and as otherwise may be legally required.
Personal Information will NOT include any personal information posted or sent by or to you in any public forum (such as a comment box on a particular page or a social media account) on the Sites. Participation in such public forums requires the public release and dissemination of such information, and thus Star Clinics cannot commit to treating such information confidentially in the same manner that other personal information will be treated under this Privacy Policy. Participation in these features of the Sites is voluntary and thus your consent to certain terms is required before participation is allowed.
HOW DOES Star Clinics SECURE MY PERSONAL INFORMATION?
Star Clinics maintains commercially reasonable safeguards to ensure the security, integrity and privacy of the Personal Information provided by you. Such security safeguards are intended to be appropriate to the sensitivity of the Personal Information collected. To the extent that Star Clinics transfers any Personal Information to third parties, we will use commercially reasonable efforts to assure that such third parties to whom we may transfer any Personal Information have knowledge of our Privacy Policy and provide sufficient protection of such Personal Information. Star Clinics is committed to properly securing the Personal Information collected online. To help us accomplish this, we take the following steps:
- We employ internal access controls to ensure that the only people who see your information are those with a need to do so to perform their official duties.
- We train relevant personnel on our privacy and security measures and applicable legal requirements.
- We physically secure the areas where we hold hard copies (if any) of the information that we collect online.
- We regularly back up the information that we collect online to insure against loss.
- We use technical controls to secure the information that we collect online as appropriate, including but not limited to: encryption, firewalls, and password protections.
- We periodically test our security procedures to ensure personnel and technical compliance.
- We disclose your identifiable Personal Information only to your employer and others to whom you have given consent, or as otherwise required or permitted by law.
- We disclose the minimum amount of Personal Information as necessary for the particular purpose in compliance with applicable law.
The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and certain privacy and security regulations promulgated by the U.S. Department of Health and Human Services to implement certain provisions of HIPAA and the Health Information Technology for Economic and Clinical Health Act, as modified by the Omnibus Final Rule (collectively the “HIPAA Requirements”), as well as other applicable federal and state privacy and security laws and regulations, regulate and limit the use and disclosure of your protected health information. Star Clinics has established privacy practices with respect to any Personal Information comprising protected health information in order to be compliant with applicable HIPAA Requirements.
Please note that Personal Information stored on the Sites will be collected, stored and processed in the United States of America. By this Privacy Policy, Star Clinics has intended to abide by the safe harbor principles published by the United States Department of Commerce regarding the collection, use and retention of data from the European Union and the Personal Information Protection and Electronic Documents Act (PIPEDA) regarding the collection, use, and retention of data from Canada. For more information on the safe harbor framework, please visit the U.S. Department of Commerce’s website at http://export.gov/safeharbor/.
DOES Star Clinics USE COOKIES TO COLLECT PERSONAL INFORMATION ON THE SITES?
The Sites may utilize a standard technology called a “cookie” to collect information about how the Sites are used. A “cookie” is a small text file placed on your hard drive by our web page server. These cookies do not collect Personal Information, only Aggregate Information.
Your browser is probably set to accept cookies. However, if you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies. If you choose to have your browser refuse cookies, it is possible that some areas of our Sites or the Services will not function properly when you view them.
We do not combine Aggregate Information collected through cookies with other Personal Information to determine who you are or your e-mail or IP address. The Sites can access the Aggregate Information only from a cookie sent by the Sites. We cannot access other cookies sent by other websites or the information contained in those other websites. Additionally, we cannot learn your email or IP address through the use of a cookie.
You must specifically submit Personal Information to Star Clinics via the Services or the Sites. For example, in order to set up an account, you must voluntarily submit your name and email address to Star Clinics. We use cookies to track usage of the Sites and the Services and further customize your experience when you are visiting the Sites or using the Services. By tracking usage, we can best determine what features of the Sites and the Services best serve the users. Without cookies, the features would “forget” items that may be stored. The session information used by the Sites is deleted when your browser is closed.
When you visit the Sites, we automatically collect Aggregate Information about your visit. We can tell the type of computer, browser, and web service that you are using. We also know the date, time, and pages that you visit on the Sites and the geolocation of the device that you are using. Collecting this information helps us design the Sites and the Services to enhance your experience during access. We may use Aggregate Information for internal purposes, such as tracking demographic data and providing targeted content to make the Sites or the Services more useful to our visitors. The gathering of this Aggregate Information may be accomplished by the use of cookies.
In particular, Star Clinics may collect an IP Address from all visitors to the Sites. An IP Address is a number that is automatically assigned to your computer when you use the Internet. We use IP addresses to help diagnose problems with our server, administer our Sites, analyze trends, track users’ movement on the Sites, gather broad demographic information for aggregate use in order for us to improve the Sites, and deliver customized, personalized content. IP addresses, however, are not linked to Personal Information.
We may at times provide third parties with De-Identified Information or Aggregate Information about our users, as more fully set forth in this Privacy Policy. On those pages of the Sites not requiring your account login, you may decline to accept cookies sent by the Sites by selecting an option on your browser to reject cookies. However, some portions of the Sites may require account login or account registration in order to access those areas. In such case, we ask that you provide us with basic information on your account set-up page. Cookies enable our server to know that you are a registered user. Therefore, our registration system requires that you accept the cookies from the Sites. Other websites linked to the Sites also may send cookies; however we do not control such activities.
In certain instances on our Sites, you may be asked to opt-in to the use of cookies before you will be given access. You will only be asked to opt-in upon your initial visit to those portions of the Sites only. However, if you elect to not opt-in to the use of cookies, you may not be able to access those portions of the Sites or your ability to use those Sites features will be impacted.
Star Clinics also may use a unique assigned number located with the Sites’ URL to determine each web site from which you navigated to get to the Sites. While this number may not be apparent to you, it does not contain your Personal Information.
HOW DOES Star Clinics USE PERSONAL INFORMATION?
Your privacy is important to us. We will use the Personal Information provided by you in accordance with good commercial practice and applicable law. If you provide us with your e-mail address (or have done so in the past), we will send notifications, newsletters or e-mail offers to you in accordance with the user account preferences opted by you. When you set up your user account (and at any time thereafter), you will select and control how Personal Information is shared from your account settings. The default setting will select all types of email notifications offered by Star Clinics. Your email will be used for notifications or newsletters only. Star Clinics does not share your public email address with others in its public forums.
We also may use information provided by you, for example, to provide notifications about certain features of our Sites or the Services to measure consumer interest in our various services, and to inform you about various products and services offered on the Sites (including both our own products and the products of others). These offers may be based on information provided by you in your account settings, in surveys, from information that may indicate your preferences, as well as information available from external sources. These e-mail offers will come exclusively from Star Clinics or its affiliates. All offers are carefully developed to ensure that they meet our standards. Our goal is to target offers to Sites users who we believe will find them of value. The lists used to send you product and service offers are developed and managed under conditions designed to safeguard the security and privacy of your Personal Information. By providing information using the Sites or the Services, you warrant to Star Clinics that your Personal Information is reliable for its intended uses, accurate, complete and correct, and that you will promptly notify use if such Personal Information is no longer current or correct.
We also may use your Personal Information collected via the Sites in the performance of all Services in order to provide, maintain and improve our Services as well as to develop new products and services to be offered as part of the Services. For example, we may use Personal Information to analyze data, to improve our Services and to tune our outputs based on a particular individual’s patterns of usage of our Services.
DOES Star Clinics SHARE YOUR PERSONAL INFORMATION WITH OTHERS?
As a general policy, Star Clinics does not share, sell or trade Personal information with third parties without permission from the user. However, we may provide your Personal Information to third parties directly involved in the operation, performance, support, hosting and/or maintenance of the Sites or the Services and each product or service offered on the Sites, including without limitation, our websites designers, hosts, service providers, technical consultants, and business partners. Any Personal Information, however, will be used by such organizations only to perform their functions and/or to provide services in support of the Sites or the Services, and as otherwise permitted by law or approved by you in accordance with this Privacy Policy. Aggregate Information or De-Identified Information may at times be shared with Star Clinics’s business partners and other third parties.
We reserve the right to assign or transfer your Personal Information to any successor in interest to our business associated with the Sites or the Services by merger, reorganization, sale of all or substantially all of our assets or equity interests or operation of law. We also may divulge Personal Information if such information is required for us to comply with any valid legal process, such as a subpoena, search warrant, statute or court order, or if we reasonably believe that you have commit unlawful acts or acts that may endanger the health or safety of another user or of the general public.
DO I HAVE THE CHOICE TO OPT-IN OR OPT-OUT OF ANY USES OF MY PERSONAL INFORMATION?
[Star Clinics provides its account users with an easy means to decline receiving notifications, newsletters or offers by email. We recognize the importance of providing you with the choice to “opt-out.” You can control the number of notifications sent by email by logging into your user account and changing your account preferences. If you prefer, you also can “opt-out” of receiving any email notifications by contacting our Privacy Officer at the Contact Address below. All e-mail offers sent by Star Clinics will inform you as to how you can “opt-out” or decline receiving further e-mail offers. However, with respect to any Personal Information that is sensitive in nature, we will require you to “opt-in” to having such Personal Information used or shared by Star Clinics.]
Star Clinics has made available the public forums on the Sites so that you may have an opportunity to interact with other Sites visitors in order to share knowledge and news or participate in social media postings or community activities. Since participation in such forums is voluntary, you control what Personal Information may be disclosed to others. In order to avoid your email address or other Personal Information from being gathered and used by others for unsolicited, inappropriate or harmful purposes, Star Clinics advises that you should be cautious about posting your email address or phone number or other personal information in any public forums, and you do so at your own discretion and risk. Star Clinics is not responsible and shall not be held liable for information and Personal Information posted in the public forums. In addition, access to Personal Information contained in your account is protected by use of a password so keep your password private and secure.
CAN I MAKE CORRECTIONS TO PERSONAL INFORMATION COLLECTED ONLINE?
[Additionally, you may request to view the Personal Information collected about you through your use of the Sites operated by Star Clinics by accessing your user account on the Sites. If you prefer, you can send an e-mail to our Privacy Officer at the Contact Address below. If you send your request by email, we will likely send such Personal Information (or a summary thereof) to your email address on file for the account name in our database, or we will send the Personal Information to you in another secure manner. If at any time you wish to change, correct or update your Personal Information, or have it removed from our database, you may do so by accessing your user account on the Sites. You also may submit a change request to our Privacy Officer by sending an email to the Contact Address below.]
WHO CAN I CONTACT AT Star Clinics IF I HAVE QUESTIONS ABOUT THIS PRIVACY POLICY OR ANY CHALLENGES AS TO COMPLIANCE?
We have designated our Privacy Officer, who can be contacted at the following address (“Contact Address”):
By Mail: Star Clinics, Inc.
10248 Sawmill Parkway,
Powell, OH 43065
By Telephone: (614) 389-4945
By Facsimile: (614) 340-6090
By Email: support@startherapy.us
Our Privacy Officer is accountable for Star Clinics’s compliance with this Privacy Policy and applicable federal and state privacy laws. If you have any challenge concerning our compliance with this Privacy Policy, or if you have any questions about Star Clinics’s purposes for the collection and retention of your Personal Information, then please contact our Privacy Officer at the Contact Address and provide a description of your concerns sufficient in detail to permit the Privacy Officer to investigate your concerns and contact you. It is our intent to make available to you through the Privacy Officer specific information about this Privacy Policy and our management of your Personal Information as may be required by applicable law.
Star Clinics uses a self-assessment approach to ensure compliance with this Privacy Policy and periodically verifies that this Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implement and accessible and in conformity with applicable laws, including without limitation the safe harbor principles. We encourage you to raise any concerns using the contact information provided above.
DOES Star Clinics COLLECT PERSONAL INFORMATION FROM CHILDREN?
Star Clinics does not knowingly solicit data from children or knowingly market to children. Star Clinics is concerned about the safety of children and their use of the Internet. Therefore, in accordance with the U.S. Children’s Online Privacy Protection Act of 1998, we do not knowingly request or solicit personally identifiable information from anyone under the age of 13 without prior verifiable parental consent. In the event that we receive actual knowledge that we have collected such Personal Information without the required and verifiable parental consent, we will delete that information from our database as quickly as is reasonably practical.
WHAT ABOUT PRIVACY ON INTERNET WEBSITES LINKED TO THE SITES?
You should be aware that other Internet websites to which you hyperlink from the Sites may contain privacy statements that differ from our Privacy Policy. Star Clinics encourages you to read and understand such privacy policies and terms of use of any linked websites accessed by you. If you decide to access such linked websites and/or provide any personal information to such linked websites, you do so entirely at your own risk. Star Clinics is not responsible for such provisions, and expressly disclaims any and all liability related to such provisions.
WHAT ELSE SHOULD I KNOW ABOUT Star Clinics’S PRIVACY POLICY?
No transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Star Clinics to intercept or access transmissions or private communications unlawfully. If you choose to visit the Sites or use the Services, your visit and any dispute over privacy is subject to this Privacy Policy, including but not limited to limitations of damages and application of the law of the State of Texas and the laws, regulations, ordinances and treaties of the United States of America.
WHAT IS THE EFFECTIVE DATE OF THIS PRIVACY POLICY AND HOW CAN CHANGES BE MADE?
This Privacy Policy was last modified on October 1, 2017. This Privacy Policy has been adopted with the recognition that Internet technologies are rapidly evolving, and that underlying business models are still not established. Accordingly, these policies are subject to change at any time and Star Clinics expressly reserves the right to modify the terms of this Privacy Policy at any time and in our reasonable discretion, by posting a change notice to the home page of the Sites. Your continued use of the Sites or the Services following our posting of a change notice will constitute binding acceptance of this Privacy Policy and all changes thereto.
