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.
HOW DOES Star Clinics SECURE MY PERSONAL INFORMATION?
- 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.
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.
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.
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.
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?
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.]
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: email@example.com
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?