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Medical Design Technologies, LLC (“MD Tech”, the “Company”, and/or “We”) values your privacy.  In this Privacy Policy (“Policy”), We describe how We collect, use, and disclose information that We may obtain about visitors to the Website, www.mdtech.com and any related sites (together with its subdomains, the “Site” or “Sites”), users/subscribers of MD Coder, MD Message and MDTech’s other interactive applications, and the services related to the foregoing (collectively, the “Services”).

By using the Services and/or Sites, you agree to the terms and conditions of this Policy.  You should also read this Policy with the terms and conditions associated with the use of the Services and/or Sites found at www.mdtech.com/terms.

Persons with disabilities may obtain this notice in alternative format upon request by contacting us at the number listed below.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE SERVICES AND/OR SITES.  IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, DO NOT USE THE SERVICES AND/OR SITES. When you use the Services and/or Sites, you understand that We may collect, use, and disclose technical data and related information about you in various ways in accordance with this Privacy Policy.

By accessing or using the Services and/or Sites, you expressly accept all of the provisions of this Privacy Policy and the Terms of Service and represent to us that you are at least 21 years of age, are not located in the European Union, and are legally competent to enter into and agree to both the Privacy Policy and Terms of Service.

We reserve the right, at Company’s sole discretion, to modify or replace this Privacy Policy at any time in accordance with the ‘Changes to Company’s Privacy Policy’ section below.  If you have questions about this Privacy Policy, please contact Company per the information listed in ‘Contact Information’ below.

Information We Collect and How We Collect It

We collect information from and about users of the Services and/or Sites:

  • Directly from you when you are using the Services and/or Sites.
  • Automatically when you use the Services and/or Sites.
  • From third-parties.
Information You Provide

When you use the Services and/or Sites, We may ask you to provide certain personal information such as name, address, e-mail address, location, and/or telephone number (“Personal Information”). This information includes, but is not limited to:

  • Information that you provide when registering to use the Services and/or Sites.
  • Records and copies of your communications (including e-mail addresses and phone numbers) if you contact us.
  • Information transmitted between you and other individuals while using the Services and/or Sites.
Information That May Be Automatically Collected

IF YOU DO NOT WANT MD TECH TO COLLECT AND STORE USAGE DATA OR INPUT DATA, DO NOT DOWNLOAD OR USE THE SERVICES AND/OR SITES OR DELETE IT FROM YOUR DEVICE AND STOP USING THE SERVICES AND/OR SITES. The Services and/or Sites may use technology to automatically collect certain information, including but not limited to:

  • Usage Details (e.g. certain details of your access to and use of the Services and/or Sites); and
  • Device Information (e.g. information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number).
Information Collection and Tracking Tools

The technologies We use for automatic information collection may include, but are not limited to:

  • Cookies: A cookie is a small file placed on your smartphone or computer. It may be possible to refuse to accept cookies by activating the appropriate setting on your device. However, if you select this setting you may be unable to access certain parts of the Services and/or Sites.
  • Web Beacons: Pages of the Services and/or Sites may contain small electronic files known as Web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit MDTech, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
Information Third Parties Provide About You

We may, from time to time, receive information about you from third-parties for various purposes, including enhancing MDTech’s ability to serve you, tailoring MDTech content to you and offering you opportunities that may be of interest to you.

Protected Health Information

To the extent that We receive, transmit, create or maintain any patient health information, We will comply with any and all applicable privacy and confidentiality laws, including without limitation the Health Insurance Portability and Accountability Act of 1996 and its regulations (“HIPAA”), with respect to any protected health information received, transmitted, created or maintained by Company from time to time.  We are a Business Associate of some users of the Services and/or Sites and are bound by certain contractual and regulatory duties to safeguard any such information.

How We Use Your Information

We use information that We collect about you or that you or a third-party provides to MDTech, including any personal information, to perform certain functions such as:

  • Providing you with the Services and/or Sites.
  • Giving you notices about your account.
  • Carrying out Company legal obligations and enforcing MDTech rights.
  • Notifying you of changes to any Services and/or Sites We offer.

The usage information We collect helps us to improve Company Services and/or Sites and to deliver a better and more personalized experience by enabling us to:

  • Store information about your preferences, allowing Company to customize Company Services and/or Sites.
  • Enhance communication.
  • Recognize you when you use the Services and/or Sites.
Disclosure of Your Information

We may disclose aggregated information about Company users, and information that does not identify any individual. In addition, in compliance with applicable law, We may disclose personal information that We collect or you provide:

  • To Company affiliates.
  • To contractors, service providers and other third parties We use to support Company business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which We disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Company’s assets, in which personal information held by us about Company’s Services and/or Site users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.
  • To enforce Company’s rights arising from any contracts entered into between you and Company.
  • If We believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, Company’s customers or others.

We do not disclose any personal information to any third-party for marketing purposes.

Your Choices about Company’s Collection; Use and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to Company. This section describes mechanisms We provide for you to control certain uses and disclosures of your information.

  • Tracking Technologies: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, note that some parts of the Services and/or Sites may then be inaccessible or not function properly.
  • Location Information: You can choose whether or not to allow the Services and/or Sites to collect and use real-time information about your device’s location through the device’s privacy setting. If you block the use of location information, some parts of the Services and/or Sites may then be inaccessible or not function properly.
Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, and disclosure. The safety and security of your information also depend on you. Where We have given you (or where you have chosen) a password for access to certain parts of the Services and/or Sites, you are responsible for keeping this password confidential.

Pursuant to various state and federal laws, We may be required to send you notice of security breaches or suspected security breaches that impact your personal information and protected health information. We will send you any security breach notices to the email address contained in your account information or that We otherwise have on file.

Children under the age of 13

The Services and/or Sites are not intended for children under 13 years of age, and We do not knowingly collect personal information from children under 13 without parental consent. If We learn We have collected or received personal information from a child under 13 without verification of parental consent, We will delete that information. If you believe We might have any information from or about a child under 13, please contact us as provided below.

Children over the age of 13 and under the age of 18

The Services and/or Sites are only available for individuals aged 13 years or older. If you are 13 or older but under the age of 18, you should review this Privacy Policy with your parent or guardian to make sure that you and your parent or guardian understand it.  Note that parental consent may be required to access or use the Services.

Changes to Company’s Privacy Policy

We may update Company’s Privacy Policy from time-to-time. If We make material changes to how We treat Company’s users’ personal information, We will post the new Privacy Policy on this page.

California Residents

Please see our Addendum below to this Policy for such residents.

Contact Information

To ask questions about this Privacy Policy or Company’s privacy practices, contact us at compliance@mdtech.com

For California Residents To The Extent That The California Consumer Privacy Act applies to the Company:

This Privacy Policy Addendum supplements the and describes additional rights of residents of the State of California.

California Consumer Privacy Act:

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as Well as rights to know/access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information We collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by specific federal privacy law, such as the Health Insurance Portability and Accountability Act.

To the extent that We collect Personal Information that is subject to the CCPA, that information, Company’s practices, and your rights are described below.

Right to Notice at Collection Regarding the Categories of Personal Information Collected.

You have the right to receive notice of the categories of Personal Information We collect, and the purposes for which those categories of Personal Information will be used. The categories We use to describe the information are those specified in the CCPA.

  • Identifiers:We may collect information such as your name, phone number, contact address and e-mail address when you use the Services and/or Sites. We use this information to manage and provide the Services and/or Sites that you request, respond to your requests, and to communicate with you about the Services and/or Sites.
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code
  • 1798.80(e)).In addition to the identifiers in the above section, We may collect payment information to provide you with requested Services and/or Sites.
  • Internet or other similar network activity:We may automatically collect information about your browsing history and your interaction with the content of the Services to measure activity, determine the effectiveness of the Services and/or Sites, and improve them.
  • Sensory Data:We may collect your audio or voice recordings to provide you with Services and/or Sites.

We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.

Right to Know/Access Information.

You have the right to request access to Personal Information collected about you over the past 12 months and information regarding the source of that information, the purposes for which We collect it, and the third-parties and service providers with whom We share it. You may submit such a request as described below. To protect Company’s users, We are required to verify your identity before We can act on your request.

Right to Request Deletion of Information.

You have the right to request in certain circumstances that We delete any Personal Information that We have collected directly from you. You may submit such a request as described below. To protect our users, We are required to verify your identity before We can act on your request. We may have a reason under the law why We do not have to comply with your request, or why We may comply with is in a more limited way than you anticipated. If We do, We will explain that to you in Company’s response.

How to Submit a Request.

You may submit a request to exercise your rights to know/access or delete your Personal Information through any of the following means:

Only you or your authorized agent may make a verifiable consumer request related to your personal information.  If you use an authorized agent to submit a request on your behalf, We may require that you (1) provide the authorized agent written permission to do so, and (2) provide a copy of the authorization or provide a copy of a power of attorney that complies with state law so that We can verify the identity of the authorized agent.

If We suspect fraudulent or malicious activity on or from the password-protected account, We may decline a request or request that you provide further verifying information.

You may only make a verifiable consumer request twice within a 12-month period. Making a verifiable consumer request does not require you to create an account with the Company.  We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request.

Right to Opt Out of Sale of Personal Information to Third Parties.

You have the right to opt out of any sale of your Personal Information.  We do not sell information to third-parties.

Right to Information Regarding Participation in Data Sharing for Financial Incentives.

You have the right to be free from discrimination based on your exercise of your CCPA rights.  We do not discriminate against anyone who chooses to exercise their CCPA rights.

Document History & Approval

Category: General Compliance
Date 1st Drafted: 05/20/2020
Current Revision: 01.09 – GC – 1.3
Supersedes: 01.09 – GC – 1.2
Last Reviewed Date: 07/13/2020
Authorities & References: NA
 

Approved By:

 

 
Micah Grossman
Title: Chief Operating Officer
Date: 07/06/2020