1. Types of Information Collected.

a. Traffic Data Collected. We automatically track and collect the following information when you use our Product, including your: (i) IP address; (ii) domain server; (iii) type of computer; (iv) type of web browser; and (v) information on your usage of the Product, including Courses completed or not completed and your performance on our Assessments (collectively, "Traffic Data"). Traffic Data is anonymous information associated with you that identifies you and is helpful for reporting purposes or for improving your experience with the Product.

b. Personal Information Collected. In order for you to access the Products, we require you to provide us with information that personally identifies you ("Personal Information"). Personal Information may include: (i) Contact Data (such as your name and email addresses); and (ii) Demographic Data (such as your ZIP code). If you communicate with us by email, post messages to any of our chat groups, or otherwise complete online forms or surveys, any information provided in such communication may be collected as Personal Information.

2. Uses of Information Collected.

We use Contact Data to contact you if necessary.

3. Confidentiality and Security of Personal Information.

Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce our Terms of Use Agreement. Your Personal Information is stored on secure servers that are not accessible by third parties. We will never disclose the entries to your personal online "Journal" to any third parties. Only you and the Asset Health staff will have access to these entries. The Asset Health staff has access to these entries solely for the purpose of properly administering the Product.

4. Lost or Stolen Information.

You must promptly notify us if your user name or password is lost, stolen or used without permission. In such an event, we will cancel that user name or password, issue you a new user name and password, and update our records accordingly.

5. Other Limits to Your Privacy.

The Product contains links to other websites. We are not responsible for the privacy practices or the content of such websites. We may also make chat rooms, news and other services available to you. Understand that any Information you disclose in these areas becomes public information. We have no control over its use, and you should exercise caution when deciding to disclose your Personal Information.

How We May Use and Disclose Your Protected Health Information

We will not use your confidential information or disclose it to others without your written authorization, except for the purposes, listed in this section. When required by law, we will restrict disclosures to the Limited Data Set, or otherwise as necessary, to the minimum necessary information to accomplish the intended purpose.
 

• Treatment. We may disclose your PHI to your health care provider for the provision, coordination or management of your health care and related services. For example, we may disclose your PHI to a health care provider when the provider needs that information to provide treatment to you.
   
• Disclosures to the Plan Sponsor. We may only disclose aggregate summary health information to the Plan Sponsor, but not personally identifiable information.
   
• Disclosures to Business Associates. We contract with individuals and entities (“business associates”) to perform various functions on our behalf or provide certain types of services. To perform these functions or provide these services, our business associates will receive, create, maintain, use or disclose PHI. We require the business associates to agree in writing to contract terms to safeguard your information, consistent with federal law.
   
• Disclosures to Family Members or Others. Unless you object, we may provide relevant portions of your PHI to a family member, friend or other person you indicate is involved in your health care. If you are not capable of agreeing or objecting to these disclosures because of, for example, an emergency situation, we will disclose limited PHI, only to resolve the emergency. After the emergency, we will give you the opportunity to object to future disclosures to family and friends.
   
• Other Uses and Disclosures. The law allows us to disclose PHI without your prior authorization in the following circumstances:
   
• Required by law. We may use and disclose your PHI to comply with the law.
   
• Public health activities. We will disclose PHI when we report to a public health authority for purposes such as public health surveillance, public health investigations or suspected child abuse.
   
• Reports about victims of abuse, neglect or domestic violence. We will disclose your PHI in these reports only if we are required or authorized by law to do so, or if you otherwise agree.
   
• To health oversight agencies. We will provide PHI as requested to government agencies that have the authority to audit or investigate our operations.
• Lawsuits and disputes. If you are involved in a lawsuit or dispute, we may disclose your PHI in response to a subpoena or other lawful request, but only if efforts have been made to tell you about the request or obtain a court order that protects the PHI requested.
   
• Law enforcement. We may release PHI if asked to do so by a law enforcement official in the following circumstances: (a) to respond to a court order, subpoena, warrant, summons or similar process; (b) to identify or locate a suspect, fugitive, material witness or missing person; (c) to assist the victim of a crime if, under certain limited circumstances, we are unable to obtain the person's agreement; (d) to investigate a death we believe may be due to criminal conduct; (e) to investigate criminal conduct; and (f) to report a crime, its location, or victims, or the identity, description or location of the person who committed the crime (in emergency circumstances).
   
• Medical research. We may disclose PHI for medical research projects, subject to strict legal restrictions.
• Serious threat to health or safety. We may disclose your PHI to someone who can help prevent a serious threat to your health and safety or the health and safety of another person or the general public.

Right to correct or update your protected health information. If you believe that the PHI we have is incomplete or incorrect, you may ask us to amend it. Your request must be made in writing and must be addressed to the Privacy Officer. To process your request, you must use the form we provide and explain why you think the amendment is appropriate. We will inform you in writing whether the amendment will be made or denied. If we agree to make the amendment, we will make reasonable efforts to notify other parties of your amendment. If we agree to make the amendment, we will also ask you to identify others you would like us to notify.

We may deny your request if you ask us to amend information that:

 

• Was not created by us, unless the person who created the information is no longer available to make the amendment;
• Is not part of the PHI we keep about you;
• Is not part of the PHI that you would be allowed to see or copy; or
• Is determined by us to be accurate and complete.

If we deny the requested amendment, we will notify you in writing how to submit a statement of disagreement or complaint, or request inclusion of your original amendment request as part of your PHI.