PRIVACY POLICY

 

MetaMe Health, LLC (“MetaMe” or “we” or “our”) operates the website www.metameconnect.com, clinic.metameconnect.com, www.metamehealth.com, and other related websites, applications, and platforms, as applicable, (collectively, “Site”) and through the Site, provides certain telehealth services. This Privacy Policy explains MetaMe’s privacy practices that apply to the Site and is also an agreement between users of the Site and MetaMe.

 

Please read the Privacy Policy carefully so that you can understand how MetaMe collects, uses, and discloses information from and/or about you when you use a Site or the Services.   This Privacy Policy is a part of the MetaMe Patient Terms of Service and Providers Terms of Service (collectively, the “Terms”), so by accepting the Terms, you are consenting to the use and disclosure of your personal information as outlined in this Privacy Policy.

 

SERVICES

The MetaMe platform includes, without limitation, the following services (collectively, the “Services”):

 

·       the facilitation of electronic or telephonic communications with healthcare Providers,

·       appointment scheduling, billing, notifications, and other services related to online therapy for both our registered users and Providers, and

·        the provision of other information about MetaMe and our products and services through the Site.

 

This Privacy Policy applies only to information that you provide to us through the Services or use of the Site. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms.

 

By accepting our Privacy Policy during registration, or by visiting the Site and/or using the Services, you expressly consent to our collection, use, and disclosure of your Personal Information (as defined below) in accordance with this Privacy Policy.

 

As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis, and using or handling information in any way, including, without limitation, collecting, storing, evaluating, modifying, deleting, using, combining, disclosing, and transferring information within our organization or among our affiliates or with Providers.

 

COLLECTION AND USE OF INFORMATION

When using our Services, we will ask you for certain personally identifiable information. This refers to information about you that can be used to contact or identify you, and information on your use or potential use of the Services and related services (collectively, “Personal Information”). Personal Information that we might collect would include things like your name, age, registration information, phone number, gender, occupation, hometown, personal interests, credit card or other billing information, your email address and the email address of your contacts, home and business postal addresses, website addresses, certain health information, and any other information or data that you provide when using the Services. We also collect information you provide voluntarily on or through the Site and through responses to surveys and questionnaires. If you communicate with us by, for example, email, facsimile or letter, any information provided in such communication may be collected as Personal Information.

 

NON-MEDICAL INFORMATION

Some of the Personal Information we collect from you is unrelated to your receipt of therapy services through the Services. Examples of how we may use your Personal Information include, but are not limited to, the following:

 

·       Enable you to easily navigate the Services

·       Resolve service and billing problems via telephone or email

·       Troubleshoot technical problems

·       Resolve billing issues

·       Better understand users’ needs and interests

·       Personalize your experience

·       Detect and protect us against error, fraud, and other criminal activity

·       Enforce our Terms

·       Provide you with system or administrative messages, and as otherwise described to you at the time of collection

·       Provide you with further information and offers from us that we believe you may find useful or interesting

 

MEDICAL INFORMATION

Protected health information (“PHI”) is information about you that may be used to identify you (such as your name, social security number, or address), and that relates to (a) your past, present, or future physical or mental health or condition, (b) the provision of health care to you, or (c) your past, present, or future payment for the provision of health care. In providing the Services, we will receive and create records containing your PHI, and may use it to assist you in scheduling appointments, remind you of upcoming or follow-up appointments, inform you of canceled appointments, bill amounts due for health care services provided by a Provider under the Services or the Site, develop and conduct surveys with you to assist in providing you better Services, conduct our management and administrative activities, and otherwise, as stated in this Privacy Policy.

 

We may also use your de-identified PHI to help us learn from your experience and contribute to research.  We are committed to ensuring the quality and effectiveness of our Services and Site, and therefore periodically evaluate the outcomes and experiences of our clients.  Any information you provide, usage data, or answers you submit to questions in this program may be grouped with information from other users and analyzed in a fully de-identified manner (without your name or other identifying information) to assess the quality of our Services and Site.  This anonymous aggregate information may also be used in scientific research publications and presentations.  We are required by law to maintain the privacy and confidentiality of your PHI, and we operate the Services and Site consistent with applicable federal and state laws governing health information privacy and security.

 

WEB LOG DATA

When you visit the Services, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, or the webpage you were visiting before you came to our Services, pages of our website and Services that you visit, the time spent on those pages, information you search for on our Services, access times and dates, and other statistics. We use this information to monitor and analyze use of the Services and for the Services’ technical administration, to increase our Services’ functionality and user-friendliness, and to better tailor it to our visitors’ needs. For example, some of this information is collected so that when you visit the Services again, it will recognize you and provide information appropriate to your interests. We also use this information to verify that visitors to the Services meet the criteria required to process their requests.

 

Generally, our service automatically collects usage information, such as the numbers and frequency of visitors to our site and its components. MetaMe only uses these data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. These type of aggregate data enable us to figure out how often users use parts of the Site or the Services so that we can improve the Services.

 

COOKIES AND WEB ANALYTICS

We may also use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We may utilize session ID cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage by users of the Services and web traffic routing on the Services. We may work with third parties that place or read cookies on your browser to improve your user experience.

In addition, we may use web beacons, clear gifs, third party tracking service providers, or similar means in connection with the Services to, among other things, track the actions of users and compile usage and response data. 

 

MESSAGES

Comments or questions sent to us using email or secure messaging forms will be shared with our staff who are most able to address your concerns. We may archive your messages once we have made our best effort to provide you with a complete and satisfactory response. However, these communications will not become part of your medical record (or other appropriate treatment record) unless and until you use the Services to secure a Provider.

 

When you use a service on the secure section of the Services to interact directly with the Provider(s), some information you provide may be documented in your medical record or other appropriate treatment record, and available for use to guide your treatment as a patient.

 

INFORMATION DISCLOSURE

We will not rent, sell, or share Personal Information about you with other people or non-affiliated companies except to provide the Services, and except when we otherwise have your permission, or under the following circumstances:

 

·       Providers. When you use the Site to access therapy services, you will be sharing your Personal Information with a Provider via the Services. By using the Services, you expressly consent to sharing your Personal Information with your Provider, and you understand that all information shared with your Provider is subject to your Provider’s professional and legal duties of confidentiality and responsibility, which MetaMe does not control. To increase coordination of care and reduce overhead for you, you authorize the sharing of this information with other Providers on MetaMe who you elect to contact.

·       User Profiles. User profile information, including your name, location, and other information you enter in your profile, may be displayed to your Providers to facilitate user interaction with the Site.

·       Communications in Response to User Submissions. As part of the Site and the Services, you may receive from MetaMe and other users email and other communications relating to your requests, therapy services, and other transactions. When you transmit information relating to your therapy services needs, MetaMe and the Providers you select may send you emails and other communications that they determine in their sole discretion relate to your therapy services needs.

·       Aggregate Information and Non-Identifying Information. We may share aggregated information that does not include Personal Information and we may otherwise disclose non-identifying Information and log data with third parties for industry analysis, demographic profiling, research, and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.

·       Service Providers. We may employ third-party companies and individuals to process your payments, facilitate our Services, to provide the Services on our behalf, to perform Services-related services (including, without limitation, maintenance services, database management, web analytics and improvement of the Services’ features), or to assist us in analyzing how our Services are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

·       Compliance with Laws and Law Enforcement. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of MetaMe or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity. This includes, without limitation, exchanging information with Providers and law enforcement in response to Providers’ professional and legal responsibilities.

·       Business Transfers. We may sell, transfer or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy.

 

CHANGING OR DELETING YOUR INFORMATION

You may review, update, correct or delete some portions of your Personal Information in your registration profile by making the appropriate modifications in your user account settings or by contacting us atadmin@metameconnect.com. Some Personal Information, such as your answers to online assessments, may not be updateable or deleted once submitted. If you delete certain information required to receive Services, such as a credit card on file, then you may no longer be able to receive Services and your account may be deactivated, as applicable. If you would like us to remove your records from our system, please contact us and we will attempt to accommodate your request if we do not have any legal obligation to retain the records.

 

Please note that we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which, irrespective of any efforts by us to delete information, will not be removed from them. We also reserve the right, from time to time, to re-contact former users of the Site. Finally, we are not responsible for removing information from the databases of third parties with whom we have already shared Personal Information about you.

 

SECURITY

We employ administrative, physical, and technical measures designed to safeguard and protect information under our control from unauthorized access, use, and disclosure. These measures include encrypting certain communications by utilizing Secure Sockets Layer (“SSL”) software, and using a secured messaging service when we send your Personal Information electronically. In addition, when we collect, maintain, access, use, or disclose your Personal Information, we will do so using systems and processes consistent with information privacy and security requirements under applicable federal and state laws, including, without limitation, HIPAA. Except when you have contacted us by email with an inquiry or requested us to send emails to you outside of the secure section of our Services and the Site, all electronic PHI will be encrypted when we store it or transmit it, and we will use secure servers.

 

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your Personal Information, including, without limitation, breaches of your unencrypted electronically stored “personal information” (including but not limited to PHI or “medical information” (as defined in applicable state statutes on security breach notification)). To the extent permitted by applicable laws, we will make such disclosures to you without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

 

Despite these measures, the confidentiality of any communication or material transmitted to or from us via the Services by Internet or email, or any electronic storage system, cannot be guaranteed. As a result, although we strive to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to us through or in connection with the Site or that is stored by us. You acknowledge and agree that any information you transmit through the Site or upload for storage in connection with the Site is so transmitted or stored at your own risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Account you might have with us has been compromised), you must immediately notify us of the problem by contacting us. In addition, if you have privacy or data security related questions, please feel free to contact us at the information provided at the end of this Privacy Policy.

 

THIRD PARTY WEBSITES

We may offer you the opportunity to access third-party content, services, or products by linking to a third party’s website. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other services follow different rules regarding the use or disclosure of the Personal Information you submit to them. Our Privacy Policy only applies to the Services and our Site, and we are not responsible for the privacy practices or the content of other websites. You should check the privacy policies of those sites before providing your Personal Information to them.

 

CHILDREN

The Services are not directed to children. We do not knowingly allow or solicit anyone under the age of 18 to participate independently in any of the Services. Minors are not allowed to use the Services and Site. If we become aware that a user of the Services is under the age of 18 and has provided us with Personal Information without verifiable parental consent, we may delete such information from our files and may deactivate the related account.

 

AGREEMENT AND CHANGES

By using the Services, you agree to the current Privacy Policy and our Terms, into which this Privacy Policy is incorporated. We reserve the right, in our sole discretion, to modify, discontinue, or terminate the Services or to modify this Privacy Policy at any time. If we modify this Privacy Policy, we will notify you of such changes by posting them on the Services or Site or by providing you with notice of the modification. We will also indicate when such terms are effective below. By continuing to access or use the Services after we have posted a modification or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Services.

 

CONTACT

We encourage you to contact us at info@metameconnect.com if you have any questions concerning our Privacy Policy or if you have any questions or concerns about our access, use, or disclosure of your Personal Information. Please note that email communications will not necessarily be secure; accordingly, you should not include credit card information, PHI, or other sensitive information in your email correspondence with us. If you would like to contact us via physical mail, our mailing address is:

MetaMe Health LLC

222 Merchandise Mart Plaza Suite 1230

Chicago IL 60657.

Last Revised: August 29, 2016