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.
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.
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
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.
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.
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 firstname.lastname@example.org. 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.
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.
THIRD PARTY WEBSITES
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
MetaMe Health LLC
222 Merchandise Mart Plaza Suite 1230
Chicago IL 60657.
Last Revised: August 29, 2016