Privacy and Compliance

Information we may collect from you

We collect personal data from:

• Website visitors
• Prospective and current clinicians
• Patients and Prospective employees accessing or creating accounts on one of our portals (as described below).

Any references in this policy to “you” or “your” should be interpreted in the context in which the information is processed.

Our legal bases for processing your personal data include your consent, fullfilment of a contractual obligation, and where we have a legitimate interest to process your personal data, provided that our interests do not outweigh your individual rights and freedoms.

Our legitimate interests include:

• Investigating, preventing, and protecting against fraud, security risks, threats to you and others, and violations of this policy
• Protecting and defending our rights and properties, including intellectual property
• Complying with laws and regulations that apply to us, as well as responding to requests from law enforcement or government authorities or as otherwise required by law
• Improving your experiences with our products and services;
• Understanding and improving our website, user experience, and customer relationships
• Enabling our business operations

Personal Data Collection
We collect personal data that you provide to us directly, as well as information provided by your browser or device when you visit our website. We also collect personal data via the portals connected to our site (as described below).

Personal Data You Submit
We collect personal data only when you submit it to us, such as when you register for or subscribe to certain products or services; create a profile; participate in a sweepstakes, contest or game; take a survey; use an interactive feature (such as chat, chat bot or article sharing options); participate in a community forum; or contact customer service. The Personal Data you submit may include, but is not limited to, your name, postal address (including billing and shipping addresses), telephone number, mobile number, email address, gender, username, or profile picture

Personal Data We Receive From Third Parties
To the extent permitted by applicable law, we may receive Personal Data about you from third parties, such as social media services, commercially available sources, Graham Healthcare Group Affiliates, business partners, and, if applicable to you, the third party provider of your subscription. The Personal Data we receive from third parties may include your name, contact information, or relationships with various product and service providers, and your use of certain applications. For example, if you access a Graham Healthcare Group site or application through a social media service or connect a Graham Healthcare Group to a social media service, the information we collect may also include your user ID and/or user name associated with that social media service, any information or content the social media service will share with us, such as your profile picture, or email address. The information we obtain depends on your privacy settings on the applicable social media service. When you access Graham Healthcare Group through social media services or when you connect a Graham Healthcare Group to social media services, you are authorizing Graham Healthcare Group to collect, store, and use such information and content in accordance with
this Privacy Notice.

Other Information

“Other Information” is any information that is not intended to reveal your specific identity to us, such as browser information, usage data, information collected through cookies and other technologies, demographic information, Protected Health Information, geolocation data obtained with your consent where required by applicable law, and aggregated information.
2.2.1 Other Information You Submit
We collect Other Information when you submit it to us. This may include your password, birthday, education or graduation year, occupation, financial information (such as your experience, professional licensing, and other information), live event accommodations, and interests.

2.2.2 Other Information We Receive From Third Parties
We may receive Other Information about you from third parties, including, for example, demographic data, social media account number, information about your interests, and information about your activities on other websites.

2.2.3 Other Information Collected Automatically
Our services use cookies and other tracking technologies to function effectively and deliver certain features. For more information about how we use cookies and tracking technologies.

Graham Healthcare Group may also be linked to sites or apps operated by third parties, and may carry advertisements or offer content, special offers, functionality, games or applications developed and maintained by third parties, using iframes, tools, or plug-ins (“Linked Services”). These third party Linked Services may use automated means to collect information about you and your use of these features. Some of these third party sites may be co-branded with a Graham Healthcare Group or subsidiary logo, even though they are not operated or maintained by us.

Graham Healthcare Group is not responsible for the privacy practices of such third parties, and once you leave a Graham Healthcare Group or subsidiary site or click an advertisement, or sign up for a special offer, you should check the applicable third party privacy notice.

HOW WE USE YOUR PERSONAL DATA AND OTHER INFORMATION
We may use the Personal Data we collect from and about you for the purposes set forth below. We may use and disclose Other Information for any purpose, except if it is considered Personal Data under applicable law. If we combine Other Information with your Personal Data, we treat the combined information as Personal Data.

To improve the quality of our products and services and to personalize your experience by presenting content, products and offers tailored to you, we may also combine the Personal and Other Information we collect with information relating to your use of other Graham Healthcare Group products, services and websites. In addition, we may supplement the Personal Data and Other Information we collect with information from other sources, such as publicly available information from social media services, commercially available sources, and information from Graham Healthcare Group Affiliates or business partners.

Through third party analytics providers, ad networks, and advertisers, we can track your online activities over time and across third party websites, apps and devices, by obtaining information through automated means.

This information, along with information you submit, can be used to understand use across sites and devices to help improve our products, remember your preferences, provide content recommendations, and show you advertisements on the Graham Healthcare Group or other third party websites and apps that may be tailored to your individual interests.

3.1 To Provide, Measure And Improve Our Products And Services
We use the information we collect from and about you to provide our products, services and features to you, including: to process and fulfill your subscription, to create and manage your accounts, to send you information about your relationship or transactions with us, to measure and improve services and features, to allow you to engage with us (e.g., to comment on content and participate in online games, contests, promotions, special events, rewards programs, surveys or market research), to use collaboration tools to share content and collaborate with other users, to conduct research for potential articles if you choose to respond to a journalism survey, to provide you with customer support, including online chat or chat bot, and to respond to inquiries. If you choose to use the collaboration tools, some of your Personal Data may be included in a directory that can be viewed and used by other users of these collaboration tools.

3.2 To Deliver Relevant Content And Recommendations
To make your experience more interesting and personalized, we may use any of the Personal Data and Other Information we collect to assist us in delivering content on any Graham Healthcare Group  or subsidiary services.

3.3 To Deliver Advertising And Interest-Based Advertising
Graham Healthcare Group and our service providers may use any of the information we collect from and about you (in certain cases, such as with respect to financial information, only with your express permission) to assist us in delivering ads about products and services tailored to your individual interests to you when you use the Graham Healthcare Group or another service provided by Graham Healthcare Group, Graham Healthcare Group Affiliates, or unaffiliated third parties. (See What We Collect, above, for details on the types of information we may use.) We may work with third party online advertising companies, advertisers and ad networks who help deliver these ads to you. These third parties may collect and use information about your activities on our Graham Healthcare Group and on other websites, and Other Information about you which may include offline purchases, to limit the online ads you encounter to those we believe are consistent with your interests.

To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising. To learn how to opt out of online interest-based advertising, please follow the instructions in the Your Rights and Choices section below.

If you provide your mobile phone number to us, we may ask for your consent to receive text message alerts from us containing product, event, or promotional information in a text or SMS message (“Text Messages”). Your consent to receive Text Messages is not required to purchase goods or services from us.

3.4 To Allow Social Sharing Functionality
If you log in with or connect a social media service account with a Graham Healthcare Group or one of it’s subsidiaries, we may use Personal Data and Other Information to facilitate your sharing of information between the Graham Healthcare Group and your social media service.

3.5 To Contact You
Graham Healthcare Group and Graham Healthcare Group Affiliates may periodically send promotional materials, with your permission where required, surveys, market research, contest or promotional awards, or notifications related to our products and services. To help make these materials more relevant to you, we may use and combine any of the Personal Data and Other Information we collect to assist us in sending you these materials. We may also use your information (including a telephone or mobile number you may have provided for this purpose) to contact you, including to respond to your comments, inquiries or requests. If you want to stop receiving these materials, please follow the instructions in the Your Rights and Choices section below .

3.6 To Protect The Rights Of Graham Healthcare Group And Others
Graham Healthcare Group may use your Personal Data as we believe to be necessary or appropriate in order to: protect, enforce, or defend the legal rights, privacy, safety, or property of Graham Healthcare Group, our Graham Healthcare Group Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); protect the safety, privacy, and security of users of our products and services or members of the public; protect against fraud and other unlawful activity or for risk management purposes; comply with and enforce the law or legal process, including laws outside your country of residence, contractual obligations, and our policies; or respond to requests from public and government authorities, including public and government authorities outside your country of residence, to the extent permitted by applicable law.

Lawful basis/es: The processing is necessary for our legitimate interests, or the legitimate interests of a third-party.

Register for Updates
If you choose to register for updates from Graham, we collect information for the purpose of providing you with periodic updates regarding new product offerings, job opportunities, clinical research and product or company updates.

Lawful basis/es: You must have provided your clear consent to us processing your personal data for a specific purpose.

Personal Data Collected via Our Website Portals

Submit a Job Application
Any personal information, including the submission of your  resume and/or cover letter, will be used to evaluate your candidacy for employment, as well as contact you regarding your application.

Lawful basis/es: The processing is necessary for our legitimate interests, or the legitimate interests of a third-party. In some instances, the processing is necessary for a contract that we have with you, or because we need to take steps to enter into a contract with you.

Personal Data Collected via Web-Based Technologies

Browser or Device Information
When you use the website, we automatically receive certain information provided by the interaction of your mobile phone or web browser and the website. This information includes your internet website provider name, web browser type, type of mobile device (if applicable), and computer operating system. We use this information to analyze trends among our Users to help improve the Website. Such information is collected in anonymous, aggregate form and is typically not considered personal data.

We also collect information on computer operating system, your IP address, the web browser, and information about the websites visited before accessing the website.

We collect this data for the following general purposes:

• Customizing your user experience
• Fulfilling your requests for products and services
• Promoting and improving services.

Lawful basis/es: You must have provided your clear consent to us processing your personal data for a specific purpose.

Cookies and Web Beacons
The website uses “cookies” to identify the areas of the website that you have visited.

A cookie is a small piece of data stored on your computer or mobile device by your web browser and is often used to make websites work, as well as provide information to the website operator.

We may use cookies to personalize the content that you see on our website, analyze our web traffic, and improve your experience while visiting the website. Most web browsers can be set to disable the use of cookies.

Communications you receive from us, as well as pages of our website, may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that enable us to analyze email and website statistics, including visits and click-through rates. The web beacons only collect aggregate, anonymous data and cannot be traced back to you individually.

Lawful basis/es: You must have provided your clear consent to us processing your personal data for a specific purpose.

Third-Party Cookies and Web Beacons
Some content or applications on our website are served by third parties, including content providers and application providers. Our third-party partners may use cookies alone or in conjunction with web beacons or other tracking technologies already in your browser to collect information about you when you visit our website. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites and other online services.

Third-party cookies and web technologies are controlled by our advertising partners and not subject to this privacy notice. If you have any questions about the practices of such third party, you should contact the responsible third-party directly.

Lawful basis/es: You must have provided your clear consent to us processing your personal data for a specific purpose.

Conduct Marketing and Advertising
If you request to be updated about our products, services, company news, or other information, we will use the contact information you provided to send you the requested information, to provide you with marketing communications, and to keep you informed about product updates, events, webinars, or other materials.

Lawful basis/es: You must have provided your clear consent to us processing your personal data for a specific purpose.

Third-Party Advertising
We may use Google Ads, LinkedIn, Facebook/Instagram, and other third-party platforms to advertise across the Internet. We share anonymous, aggregate information regarding visitors to our website with some of the platform’s third-party website analytics tools. These companies use this aggregate data, which has been stripped of any personally identifying information about you, to provide us with insight regarding our web usage patterns. As we only share anonymous, aggregate data, this information cannot be traced back to you individually by either us or the website analytics vendors.

Meet Legal and Regulatory Obligations
In certain circumstances, we use your personal data if we are required to by law or legal proceeding. We will only share the information we are required to disclose by law and only when we are required to do so, including to meet national security or law enforcement requirements.

Lawful basis/es: The processing is necessary for us to comply with the law.

Security and Fraud Prevention
When necessary, we will use your personal data to preserve the security of our website, systems, and personal data in our control. If necessary, we will also use your personal data to investigate possible fraud, to identify violations of this Privacy Policy and our Legal Terms, and to prevent any attempted harm to you and other Members.

Lawful basis/es: The processing is necessary for our legitimate interests, or the legitimate interests of a third-party.

Personal Data Sharing and Disclosure
We share your personal data when you have granted us permission to do so, when it is necessary to fulfill our obligations to you, or when it is in the legitimate interest of our business to do so, provided that our interests do not outweigh your individual rights and freedoms.

Website Analytics Companies
We may share anonymous, aggregate information regarding visitors to our website with third-party website analytics companies. These companies use this aggregate data, which has been stripped of any personally identifying information about you, to provide us with insight regarding our web usage patterns. As we only share anonymous, aggregate data, this information cannot be traced back to you individually by either us or the website analytics vendors.

Legal Requirements
We may be legally required to disclose your personal data, if such disclosure is:

• required by subpoena, law, or other legal process;
• necessary to assist law enforcement officials or government enforcement agencies; and/or
• necessary to protect us from legal action or claims from third parties including you and/or other Members.

Security and Fraud Prevention Efforts
When necessary, we will share your personal data to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations or suspected violations of this Privacy Policy, our agreements or arrangements with you or other policies in effect from time to time to which you are subject, or as otherwise required by law.

SMS Terms and Conditions

We value your privacy and want to ensure that you are fully informed about the types of communications you may receive from us. By signing this consent form, you are agreeing to receive promotional information and updates from Graham Healthcare Group via SMS text messages to the phone number you have provided.

Types of Information You May Receive:

• Special Offers and Promotions
• Health Tips and Wellness Information
• Updates on New Services and Products
• Appointment Reminders
• Invitation to Events and Seminars

Terms and Conditions:

1. Voluntary Consent: Your consent to receive SMS text messages is voluntary. You have the right to refuse and it will not affect your ability to obtain treatment or benefits.
2. Message Frequency: You may receive periodic messages based on the information and promotions we believe are relevant to you. Message frequency may vary.
3. Data Usage: Standard message and data rates may apply to any messages sent from us. Check with your mobile provider for details on your service plan.
4. Opt-Out Option: You may opt-out of receiving SMS text messages at any time by replying “STOP” to any message you receive
5. Privacy: We will protect your personal information in accordance with our Privacy Policy. Your phone number will not be shared with third parties for marketing purposes without your explicit consent.

We do not guarantee the successful delivery of text messages by your wireless provider. Messages sent by text may not be delivered if the mobile device is not in range of a transmission site, or if the network is down. Factors beyond the power of wireless carriers may get in the way of message delivery. This may include the terrain, how close you are to buildings, foliage, weather, and your equipment. We and your wireless provider will not be liable for losses or damages that come from:

• a message not delivered, a message delivered late, or
• a message that goes to the wrong number; or
• inaccurate or incomplete content in a text message.

We are not liable for your use or reliance on the content of any text message.

We can deliver messages to the following mobile phone carriers: Major carriers: AT&T, Verizon Wireless, Sprint, T-Mobile, MetroPCS, U.S. Cellular, Alltel, Boost Mobile, Nextel, and Virgin Mobile. Minor carriers: Alaska Communications Systems (ACS), Appalachian Wireless (EKN), Bluegrass Cellular, Cellular One of East Central IL (ECIT), Cellular One of Northeast Pennsylvania, Cincinnati Bell Wireless, Cricket, Coral Wireless (Mobi PCS), COX, Cross, Element Mobile (Flat Wireless), Epic Touch (Elkhart Telephone), GCI, Golden State, Hawkeye (Chat Mobility), Hawkeye (NW Missouri), Illinois Valley Cellular, Inland Cellular, iWireless (Iowa Wireless), Keystone Wireless (Immix Wireless/PC Man), Mosaic (Consolidated or CTC Telecom), Nex-Tech Wireless, NTelos, Panhandle Communications, Pioneer, Plateau (Texas RSA 3 Ltd), Revol, RINA, Simmetry (TMP Corporation), Thumb Cellular, Union Wireless, United Wireless, Viaero Wireless, and West Central (WCC or 5 Star Wireless). ***Carriers are not liable for delayed or undelivered messages***

If you have any questions about your text plan or data plan, it is best to contact your wireless provider. If you have questions about services or your plan, call the toll-free member number on your ID card.

Privacy & security

Please update us right away if your mobile number changes. It is your responsibility to give a correct mobile number and to update any changes. If you don’t give us your new mobile number, we are not responsible for any text message sent to the wrong number.

We recommend you use a password to open your mobile device. Text messages may include protected health information (PHI). Since text messaging is unencrypted, there is a risk that this PHI could be intercepted or viewed by third parties, including others who look at your device. When you choose to get text messages from us, you do so at your own risk. The use and disclosure of PHI in text messaging may be governed by other privacy notices, including applicable HIPAA Notice of Privacy Practices.

California Online Privacy Protection Act Compliance

Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent.

Third-Party Websites
The website may contain links to other websites that are not under our direct control. This Privacy Policy applies only to our websites and not to any third-party websites, which may have their own policies regarding privacy. We have no control of or responsibility for linked websites and provide these links solely for the convenience and information of our visitors. You access such linked websites at your own risk.

You should check the privacy policies, if any, of those individual websites to see how the operators of those third-party websites will utilize your personal information. In addition, these websites may contain a link to websites of our affiliates. The websites of our affiliates are not subject to this Privacy Policy, and you should check their individual privacy policies to see how the operators of such websites will use your personal information.

Security
We have implemented organizational and technical safeguards for protecting the personal data you share with us. These measures include secure infrastructure, carefully configured access to resources, and best practices around data safety and retention.

HOW WE PROTECT AND RETAIN PERSONAL DATA

Graham Healthcare Group uses a combination of administrative, technical, personnel and physical measures to safeguard Personal Data in its possession against accidental, unlawful or unauthorized loss, use, access, disclosure or modification. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of Personal Data. However, no one can guarantee the complete safety of your information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting Customer Service in accordance with the instructions below.

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or allowed by law.

Children Under the Age of 16
We do not knowingly collect personal data from individuals under the age of 16. Our website is not intended for anyone under the age of 16, and no one under the age of 16 may provide information on this website.

Privacy Notice Changes
We reserve the right to modify this privacy notice at any time. You can find the most current version of our privacy notice at any time by clicking on the “privacy notice” link at the bottom of our website. If we make material changes to this policy, we may notify you on our Website, by a blog post, by email, or by any method we determine. The method we chose is at our sole discretion. Any changes we make to our privacy notice are effective as of this Last Updated date and replace any prior privacy notices.

CONTACT US

If you have questions about this Privacy Notice or how we handle your Personal Data, please contact our Compliance Department at 1-800-961-3575 or by email at Compliance@grahamhealth.com.

Or you may write to:
Attention: Privacy
Graham Healthcare Group
5440 Corporate Dr., Suite 400
Troy, MI 48098

We will respond to your questions and complaints about our processing of your Personal Data. If you are not satisfied with our response, depending on where you are located you can contact a supervisory authority or your state’s attorney general. Please do not disclose any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, or trade union membership), social security numbers, or criminal background information when contacting us.