PRIVACY POLICY
This Telemedicine Portal Privacy Policy (this “Privacy Policy”)
governs the collection and use of your information via the Valley Health
telemedicine mobile app, the Valley Health telemedicine website and/or
members-only website (collectively, the "Platform"). This Privacy Policy governs only the collection and use of your
information via the Platform operated by Valley Health System and its
affiliates and subsidiaries, (collectively, “Valley Health”). This Platform is used in the provision of telemedicine services
by physicians affiliated with Valley Health, who may be employed by, independent
contractors of, or medical staff members of hospitals operated by Valley
Health (each, a “Provider”). This Privacy Policy does not govern any information you may share
directly with the Provider outside of this Platform, such as in the course
of a consultation.
Agreement to Privacy Policy
YOUR ACCESS AND USE OF THIS PLATFORM IS SUBJECT TO YOUR AGREEMENT WITH
THE BELOW POLICY, ALONG WITH THE TELEMEDICINE WEBSITE TERMS OF USE AND
Patient Registration Agreement, as applicable.
[ADD
LINKS] BY USING THIS PLATFORM, YOU EXPRESSLY AGREE TO THE TERMS OF THIS PRIVACY
POLICY AND CONSENT TO THE COLLECTION AND USE OF INFORMATION AS DISCUSSED
IN THIS PRIVACY POLICY.
IF YOU DO NOT AGREE WITH THE BELOW POLICY, PLEASE DO NOT USE OR ACCESS
THIS PLATFORM FOR ANY PURPOSE. PLEASE PRINT A COPY OF THIS PRIVACY POLICY
FOR YOUR RECORDS.
Modifications to Privacy Policy
Valley Health MAY REVISE THIS POLICY REGARDING THE COLLECTION OF INFORMATION
AT ANY TIME. SHOULD ANY NEW POLICY TAKE EFFECT, Valley Health WILL GIVE
NOTICE TO YOU AND ALL USERS BY POSTING A NOTICE REGARDING THE NEW POLICY
ON THIS PLATFORM, AND THE NEW POLICY WILL APPLY ONLY TO INFORMATION COLLECTED
THEREAFTER. NEW POLICIES WILL BE EFFECTIVE AS OF THEIR POSTING UNLESS
OTHERWISE STATED.
BY ACCESSING OR USING THIS PLATFORM AFTER SUCH CHANGES ARE POSTED YOU AGREE
AND CONSENT TO ALL SUCH CHANGES.
Applicability of this Privacy Policy
This Privacy Policy applies solely to the Platform and provides you information
on the specific information that Valley Health may collect from you via
the Platform and how we may use it, whether you are using the Platform
as a patient (or legal representative) or as a Provider.
If you are a patient or legal representative, the Providers’ use
and disclosure of your identifiable health information is subject to the
Valley Health Notice of Privacy Practices, which is available on the Valley
Health website {link}. We cannot control any Provider’s use of a
patient's identifiable health information. Valley Health provides
this Platform to provide telemedicine services and therefore protects
identifiable health information as required by applicable federal or state
laws and regulations as well as any applicable agreements between Valley
Health and the Providers.
Disclosure of Information Practices
Whether you are a patient (or legal representative) or a Provider, if we
collect information from or about you via the Platform, we will tell you
what information we are collecting either at the point of collection or
via this Privacy Policy. The amount and type of information that we receive
depends on how you use this Platform and the information you choose to
submit to us via the Platform.
Whether you are a patient (or legal representative) or a Provider, we may
track use of your user name and may also capture the paths taken as you
move from page to page (i.e., your "click stream" activity).
When you log in, your user name and password will be logged by our system
in an audit log.
As a user of the Platform, you may also choose to use the secure messaging
feature of the Platform which will allows the exchange of communications
between patients and Providers and which may contain identifiable health
information. Communications sent via this feature are recorded and maintained
by Valley Health. Platform users have the ability to view the trail of
messages received and sent via their Platform account. Valley Health does
not edit the content of the communications between patients and Providers.
Personally
Identifiable Information
You may request additional information about the Platform and the Services
by submitting your information to us or otherwise contacting us as set
forth on the Platform. If you elect to send us your contact information,
we will use your contact information to provide you the information you
requested and otherwise communicate with you to respond to your inquiry.
Identifiable
Health Information
If you are a patient or the legal representative of a patient, you must
provide certain identifiable health information and medical history in
order to complete your registration for Platform to request behavioral
health or other medical consultations provided by the Providers (“Services”).
If you are a patient (or the legal representative of a patient), we will
collect identifiable health information from you during the registration
process and in the event you later request information or Services. We
may collect any identifiable information that you provide to us, such
as your name, address, e-mail address, gender, birth date and phone number.
We also need your medical history in order for you to request Services.
When you register for the Platform via the Website, the registration process
requires you to choose a user name and password for your account, which
you should keep and maintain as confidential. If you choose to share your
user name and password you understand that those individuals to whom you
share that information will have access to your identifiable health information
and will be able to add to your identifiable health information as though
they were you. You will be responsible for all activities by users resulting
from sharing or not maintaining the confidentiality of your user name
or password.
If you are a registered patient user of the Platform, your identifiable
health information (or that of the patient for whom you are the legal
representative) will become accessible to Valley Health in order to provide
you access to such information through the Platform. This information
includes the information you provide to Valley Health for us to share
with Providers and information uploaded to the Platform by Providers related
to any Services.
Non-Identifiable Health Information
Either Valley Health or our third party vendor on behalf of Valley Health
may also collect non-identifiable information, which is automatically
collected as you browse or otherwise access the Platform. We may collect
such information by tracking, or asking our third party vendor to track,
your click-stream activity when such information is not tied to a user
ID through the use of "cookie" technology or by tracking internet
protocol (IP) addresses, as explained below.
Cookies
Like many companies, we may use "cookie" technology on and off
of the Platform. “Cookies” are small pieces of information
that are stored by your browser on your computer’s hard drive. They
enhance your online experience by saving your preferences while you are
visiting a particular website. The cookies do not contain any identifiable
health information and cannot profile your system or collect information
from your hard drive.
When you view or access our Platform we may place a cookie on your computer,
which may be either temporary or permanent. Temporary cookies are used
to complete transactions with this Platform and for other purposes such
as counting the number of visits to our certain web pages. These temporary
cookies are eliminated when you exit your browser.
A permanent cookie may also be stored on your computer by your browser.
When you log in, this type of cookie tells us whether you've visited
us before or if you are a new visitor. The cookie doesn't obtain any
identifiable health information about you or provide us with any way to
contact you, and the cookie doesn't extract any information from your computer.
The "help" portion of the toolbar on most browsers will tell
you how to prevent your browser from accepting certain types of cookies,
how to have the browser notify you when you receive a new cookie, or how
to disable cookies altogether. Please note that disabling temporary cookies
may prevent you from using and accessing this Platform. Disabling permanent
cookies may also impact your use and access of the Platform and in particular
will not allow you to see any personalization on the Platform that you
may activate.
In addition, if you visit our Platform again after deleting a cookie, a
new cookie may be activated.
Since third parties may use their own cookies when you click on a hypertext
link to their site or service, you should carefully review the privacy
policy of other sites you link to from our Platform.
IP Addresses
We may also log and track IP addresses for systems administration purposes
and for reporting usage trends. Your IP address is usually associated
with the physical place from which you enter the Internet, the name of
the domain and host from which you access the Internet, the browser software
you use and your operating system, and may also depend on the date and
time you access the Platform. By collecting your IP address, we may record
the page that linked you to this Platform, the web pages you visit, the
ads you see or click on, and other information about the type of web browser,
computer, platform and settings you are using, and any search terms you
enter on this Platform. IP addresses are not used to track an individual
user’s session. This information only helps us determine how often
different areas of our Website and Platform are visited.
We may combine non-identifiable information collected automatically (such
as through IP addresses, cookies or click-stream monitoring) with any
previously submitted personal information that we may have received from you.
Geographic
Location
We may collect your geographic location based on your IP address and other
location-based data. However, we do not collect any device identifications.
Analytics
We may also use various third party internet vendors to collect, track
and analyze track analytical data regarding Website usage and trends.
Surveys
Users of the Platform may have the opportunity to participate through the
Platform in various Valley Health surveys regarding use of the Platform
and receipt of the Services.
If you choose not to receive survey invitations through the Platform you
may change your privacy settings within the Platform.
Any survey responses that you choose to submit may be aggregated, deidentified
and provided or sold to third parties as set forth below.
How Will Your Information Be Used And Disclosed?
We will not sell, share or rent the information that is collected via the
Platform to others in ways that differ from what is disclosed in this
Privacy Policy.
Identifiable
Health Information
We may use any identifiable health information or other information that
you voluntarily provide us in order to provide you with information, products
or services that you may request from Valley Health or the Providers.
If you are a patient or the legal representative of a patient, any identifiable
health information that you share via the Platform will be made accessible
to the Providers provider and will become a part of the records maintained
by Valley Health on behalf of the Providers, which records are subject
to the Valley Health Notice of Privacy Practices. Any information generated
by the Providers in providing the Services will be provided back to Valley
Health by the Providers and will also become part of the records maintained
by Valley Health. Valley Health has no control over or responsibility
for the Provider’s use or disclosure of information that you may
provide via the Platform.
We may also use your identifiable information to send you appointment reminders
or other notifications regarding the Services. If you elect to provide
us a cell phone number, you expressly consent that we can provide these
communications to you via text message. Data or text charges may apply.
You may change your preferred method of communication in your “My
Account” setting.
To the extent permitted by applicable law, Valley Health may use your information
to communicate to you special offers and featured items from third parties,
Valley Health, Valley Health's affiliates, and/or other suppliers
and vendors. If you are receiving additional communications and special
offers, you may revoke your authorization to receive such materials from
Valley Health via the Platform at any time by contacting us using the
contact information below or as outlined in the applicable communication.
We will implement your revocation as soon as is commercially reasonable.
Valley Health cannot control any communications and other materials that
you may receive directly from third parties.
We will also use your information to customize your browsing experience
and communicate with you and otherwise respond to your questions and suggestions
regarding use of the Platform as may be permitted by applicable law.
We will share your information only with the Providers and our suppliers
and vendors to the limited extent necessary to provide this Platform and
the Services. We require those suppliers and vendors to comply with all
applicable data privacy laws and regulations, including HIPAA. We do not
sell, lease or rent your identifiable health information.
Non- identifiable Health Information
The non- identifiable health information we collect may be deidentified
and shared with our suppliers and vendors and used in the aggregate to
create summary statistics that help us analyze Platform usage trends,
assess what information is of most and least importance, determine technical
design specifications, arrange the Website in the most user-friendly way,
and identify system performance or problem areas.
We may also use your geographic location to provide you with specific content
and direct you to your closest service providers to the extent permitted
by applicable law.
Aggregate
Data
We may aggregate and deidentify identifiable health information in accordance
with HIPAA, either alone or with other data to create anonymous "aggregate
data" regarding the users of our Platform. Aggregate and deidentified
data is information that describes the habits, treatment plans, usage
patterns and/or demographics of users as a group but does not reveal the
identity of particular users. This data will not identify you, but will
be used as statistical information to determine such things as user demographics
and usage patterns of our Platform. Valley Health may use aggregate data
to understand the needs of our community of users and determine what kinds
of programs and services we can help provide. Aggregate data may also
be provided or sold to third parties, including to give third party vendors,
suppliers, business partners and/or affiliates a picture of our community
and services.
Other
Use
and Ownership
We also reserve the right to share your information collected from this
Platform with third parties to the extent permitted by applicable law
and, in the case of identifiable health information, pursuant to Valley
Health's business associate agreement with the applicable Provider.
Valley Health maintains full rights to any information collected on this
Platform, and may freely collect, use and disclose such information unless
prohibited by this Privacy Policy or applicable law.
Transfer of Data
In the event of a change in control of Valley Health or sale by Valley
Health of substantially all of its assets or other acquisition, sale,
merger or reorganization, any information owned by or in the control of
Valley Health may be transferred and/or sold to such Valley Health successor,
who will comply with the terms of this Privacy Policy.
Security
While no web site can guarantee security, we maintain physical, administrative,
electronic, technical and procedural safeguards to help protect your personal
information collected via the Platform as required by applicable law.
While we cannot guarantee that loss, misuse or alteration to data will
not occur, we use industry standards, such as Secure Socket Layers ("SSL")
technology, to help safeguard against such occurrences. In certain areas,
the information passed between your browser and our system is encrypted
with SSL technology to create a protected connection between you and our
website to ensure confidentiality.
Our data center is both physically and electronically secured. Our servers
are protected behind the Internet by using firewall and encryption technology.
All data is stored and transferred in encrypted formats that exceed standards
defined by HIPAA. No data is transferred to users that do not have specific
data access keys.
We limit access to personally identifiable information about you to our
employees and third-party agents, who we reasonably believe need to have
access to your information to provide you with the information or services
you request via the Platform.
In the event that a breach in our security systems occurs and there is
a possibility that an unauthorized person acquires your personal information,
we will notify you of such a breach as may be required by applicable law.
In order to help maintain security, you should never share your user ID
or password and should always sign out when you are finished using the Platform.
Access
We will maintain your information and allow you to request updates at any
time by logging into your Platform account to access your information.
We will also take steps to make sure that any updates that you provide
are processed in a timely and complete manner.
Third Party Websites
If you use the Platform to link to another web site, which is not controlled
or maintained by Valley Health, you may decide to disclose personal information
at that web site. For example, you might provide your contact information
to obtain an information packet from an organization. Please be aware
that in contacting that site, or in providing information on that site,
that third party may obtain personal information about you. This Privacy
Policy does not apply when you leave the Platform and go to a third party
web site from the Platform. We structure the Service so that no personal
or health information goes in the search string or URL when you move from
the Platform to a linked web site. We encourage you to be aware when you
leave our Service and to read the privacy statements of each and every
site that collects personally identifiable information.
What if I am accessing this Platform from outside of the United States?
If you are visiting our Platform from outside the United States, please
be aware that your information may be transferred to, stored or processed
in the United States, where our servers are located and our central database
is operated. The data protection and other laws of the United States and
other countries might not be as comprehensive as those in your country,
but please be assured that we take steps to protect your privacy. By using
the Platform, you understand that your information may be transferred
to our facilities and those third parties with whom we share it as described
in this privacy policy.
Important Note Regarding Children
This Website and Platform is not directed toward children under 18 years
of age and Valley Health does not knowingly collect information from children
under 18 through this Website or Platform. Any information submitted via
the Platform regarding a minor under the age of 18 must be submitted by
the minor's legal representative. To the extent permitted by applicable
state law, minors may access their identifiable health information through
their physician.
What if I have questions or concerns regarding this Privacy Policy?
If you have any questions about this Privacy Policy or the use of your
information by Valley Health please contact the Valley Health Privacy
Officer at
Valley Health Compliance Department
220 Campus Blvd., Suite 420
Winchester, Virginia 22601
Phone: (540) 536-8993
Fax: (540) 536-5493
Email: wsowers@valleyhealthlink.com