- Summary of Data Practices
- What information EBC Collects
- How EBC Uses Your Information
- How the Information is Shared with Third Parties
- Choices You Have About How EBC Uses Your Information
- What About Data from Children Under 18
- How EBC Protects Your Information
- How We Provide Required Notices of Security Breaches
Summary of Data Practices
Do we release your PHR Data for the following purposes?
|Marketing and Advertising
|Medical and pharmaceutical research
|Reporting about our company and our customer activity
|To your insurer and employer
|For developing software applications
|Do we require Limiting Agreements that restrict what third party Service Providers can do with your Personal Information?
|Do we stop releasing your Personal Information if you close or transfer your PHR?
|Do we have Security Measures that are reasonable and appropriate to protect PHR Data, in any form, from unauthorized access, disclosure, or use?
|Do we store PHR Data in the U.S. only?
|Do we keep Personal Information Activity Logs for your review?
Activity logs are EBC and its Service Providers records of when PHR Data is created, accessed, modified, deleted, released, or exported from and/or within the PHR.
Aggregate Data is PHR Data that is: (1) grouped so it does not connect to you as an individual and (2) has names and other identifiers removed or altered. In other words, Aggregate Data is de-identified data and cannot be used to identify you as an individual.
An Authorized Individual is someone you authorize to access your Pregwell account on your behalf.
A Dependent is a minor child or other individual over whom an Authorized Individual has legal authority.
"PHR" means Personal Health Record. A PHR is an electronic health data application that can help you collect, manage, and share your health information. The Pregwell Health Record is a PHR.
When you sign up for the Pregwell Health Record, you provide and/or you authorize all or some of your Providers to provide to the Pregwell Health Record information about you. This information makes up PHR Data. Any information in the Pregwell Health Record is considered PHR Data. PHR Data might include, but is not limited to the following:
o Your name and contact information, such as your address, phone number, or email address
o Your medical history, conditions, treatments, and medications
o Your healthcare claims, health plan account numbers, bills, and insurance information
o Demographic information, such as your age, gender, ethnicity, and occupation
o Computer information, such as your IP address and "cookie" preferences
As described further below, EBC may use your PHR Data to achieve the following:
o Operate and manage the Pregwell Health Record platform, software, and website
o Maintain and protect its computer systems
o Comply with the law, such as responding to subpoenas and search warrants
PHR Data includes Personal Information and Aggregate Data.
Personal Information means information about you that reasonably can be linked to you such as your name, health information, and other identifiers. Personal Information may also include but is not limited to your financial information or social security number.
A healthcare provider, healthcare practice, or hospital that you authorize to provide information to your Pregwell personal health record. When you sign up for the Pregwell Health Record, you may provide authorization for a healthcare practice or hospital, and associated authorized users to send Personal Information to your PHR.
EBC and our Service Providers might report about business activities and customers (you) to others, such as investors, auditors, potential business partners, or public communities. Reports will not include Personal Information without your specific permission or as permitted or required by law.
A Service Provider is an entity that is hired to perform certain functions for EBC to support the development, maintenance, and implementation of Pregwell. Service Providers may include software or website designers and data storage providers.
Security measures can include computer safeguards, secured files, and employee security training. In addition, EBC may be required by law to notify you about particular data breaches.
What Information EBC Collects
1.Before you register for the Service, EBC may collect your information in two ways:
(1) if you contact EBC through the Internet and provide EBC with your contact information (e.g., name, mailing address, email address and other information);
(2) EBC may obtain your contact information from a healthcare Provider with which EBC partners. In either case, EBC will use such information for the sole purpose of informing you about the Service and inviting you to register for the Service.
3.In general, EBC collects all information that you supply directly to the Service. EBC also may collect information from participating Providers whom you expressly authorize to use the Service with respect to you and your information (each, a "Provider" and collectively, the "Providers"). By authorizing a Provider, you also authorize EBC to collect information regarding you from your Provider's support staff and from other practitioners affiliated with your Provider or in your Provider's practice. Further, EBC may collect information from other third party information providers that you expressly authorize to send information to your Pregwell account.
4.EBC passively collects information from you as you navigate through our Service. EBC may track IP addresses, use industry standard tracking devices (e.g., session and persistent cookies, flash cookies, web beacons), and electronically gather information about the technology you use to access the Service and the areas of the Service you utilize. EBC passively collects this information for operational purposes such as evaluating, updating and improving the Service.
How EBC Uses Your Information
2.If you choose to authorize a Provider to participate in the Service with you, then EBC may use your information to facilitate the exchange of information and communication between you and your Provider (e.g., the Service would enable you to schedule an appointment with your Provider and receive an appointment reminder in return).
5.If you elect to utilize any billing services features of the Service, EBC also may use your information to process payments, send invoices and conduct other billing-related activities as requested by you.
Sharing Your Information With Third Parties
1.EBC may make your Personal Information available to third parties participating in the Service that are authorized by you or as necessary to complete transactions you authorize.
2.EBC may disclose your Personal Information to EBC' Service Providers that provide technical support or other services to EBC related to the Service. All such Service Providers are subject to confidentiality obligations and may only access and utilize your data for purposes of fulfilling their obligations to EBC.
3.EBC may provide or sell Aggregate Data that is de-identified to third parties. However, Aggregate Data will not include any of your Personal Information or be individually identifiable.
Choices You Have About How EBC Uses Your Information
1.Managing Your Account. You have the following choices regarding the Personal Information you provide to EBC for use:
You may access your Pregwell account at any time to review your PHR Data. To request a change to any of your Personal Information, please contact your healthcare provider or the organization that provided the Personal Information for your Pregwell account. For technical questions related to the Pregwell product, please access the email support link on the Pregwell Support page.
b. You may opt out of receiving communications from your Provider with regard to the Service by changing your account settings or, if the account settings feature is unavailable, by notifying EBC at firstname.lastname@example.org.
2.Authorized Individuals.You may grant access to your Pregwell account to one or more Authorized Individuals or Authorized Individual-Representatives. You may grant an Authorized Individual access to your Pregwell account by specifically authorizing Pregwell to permit access by such Authorized Individual to your Pregwell account. When you grant access to an Authorized Individual, you may permit the Authorized Individual to: (a) have the same level of access to your Pregwell account as you have, i.e., the Authorized Individual will be authorized to access your Pregwell health record and to communicate with your Providers and/or engage in other transactions with your Providers to the same extent that you are able using Pregwell; or (b) have "read-only" access to your Pregwell account, i.e., the Authorized Individual will be authorized to access and read your Pregwell health record ONLY, and will NOT be able to communicate with or otherwise engage in transactions with your Providers. Whether or not to grant an Authorized Individual full-access or read-only access to your Pregwell account is your decision. You acknowledge and agree that: (a) you are solely responsible for verifying the identity of, and monitoring the use by, any Authorized Individual you select; and (b) EBC has no responsibility or liability in connection with any access to, or use of, your account and information by any Authorized Individual or Authorized Individual-Representative.
3.Deactivating a Provider, Other Third-Party or Authorized Individual. You may revoke any Provider's, third-party's, or Authorized Individual's authorization to communicate with you, or request information from you or your Pregwell Health Record through the Service by utilizing the account management tool of the Service. Once revoked, the Provider, third-party, or Authorized Individual may no longer access and use the Service with respect to you and your Personal Information. Any disclosure of your PHR Data or Personal Information made prior to the authorization revocation cannot be recalled, removed, or retrieved by EBC. By using the Service, you agree that EBC cannot, and has no obligation to, remove Personal Information from your Provider's, other third-party's or Authorized Individual's records once properly disclosed.
4.Terminating Your Account. You may terminate your EBC account at any time by notifying us at email@example.com. In addition, except with respect to an Authorized Individual-Representative who establishes an account on behalf of a Dependent, EBC will terminate your account within thirty (30) days of its receipt of a death certificate certifying your death. With respect to an Authorized Individual-Representative, EBC will terminate all accounts associated with such Authorized Individual-Representative within thirty (30) days of its receipt of a death certificate certifying the death of such Authorized Individual-Representative unless a Dependent also has a living Authorized Individual-Representative associated with the account. Otherwise, EBC will maintain and/or destroy all PHR Data and Personal Information associated with your account in accordance with its then current document retention and destruction policies. Please note that copies of your Personal Information may remain in your Providers', other third-parties' and Authorized Individual-Representative's and/or Authorized Individual's records, as described in Section 3, above.
Data from Children Under the Age of 18
An Authorized Individual-Representative may authorize and/or have access to a Pregwell Health Record for a Dependent. Through the account, the Authorized Individual-Representative may: (a) review and update the Dependent's personal health record as maintained on Pregwell; and (b) engage in such communications and transactions as permitted between the Authorized Individual-Representative and the Dependent's Providers through the Pregwell Health Record. Accounts created for Dependents are specific to each healthcare Provider. Thus, an Authorized Individual-Representative will have to specifically authorize each Provider to establish a Pregwell account in the name of the Dependent. A Dependent's Pregwell account will be linked to an Authorized Individual-Representative's Pregwell Health Record account until the earlier of the date: (i) the Dependent reaches the age of 18; (ii) the Authorized Individual-Representative is no longer the legal representative of the Dependent; or, (iii) Pregwell is notified by the Dependent's Provider or a court of law or agency with appropriate authority that the Dependent has been emancipated, attained legal custody of his or her own health information, or that a different Authorized Individual-Representative has been named. Each Authorized Individual-Representative agrees that a Dependent's Pregwell account also may be linked to the Pregwell account of another Authorized Individual-Representative, and each Authorized Individual-Representative will have the same rights to access and communicate through the Dependent's Pregwell account.
How EBC Protects Your Information
EBC uses both technical and procedural Security Measures to maintain the integrity and security of the Pregwell Health Record and other databases, including the use of firewalls. Pregwell encrypts all PHR Data during transmission between your Provider and Pregwell. Within Pregwell, all Personal Information is encrypted at three levels: each individual has a unique encryption key; demographic information is encrypted; and clinical data is separately encrypted.
The safety and security of your Personal Information also depends on you. Never share your password with anyone else. Notify EBC promptly if you believe your password has been breached. Also, remember to log off of the Pregwell site before you leave your computer.
Security Breach Notification Requirements
Pursuant to applicable law, EBC may be required to send you notice of security breaches or suspected security breaches that impact your Personal Information. In the unlikely event that EBC must provide you a notice of a security breach, EBC will send you security breach notices to the e-mail address contained in your account information unless we are otherwise require by law. Please note: many e-mail systems have built in SPAM filters. If you have one in place, you should check with your system administrator or the available instructions to confirm that e-mails from EBC are not blocked by the filter (e.g., by confirming that the Service domain name (Pregwell.com) is a permitted domain name.
If you have additional questions, please contact EBC any time. Or write to the company at:
Expert Business Consulting
ATTN: Privacy Matters
4600 Touchton Road ste 1150
Jacksonville, FL 32216
Date last modified: Dec 4, 2018