Privacy Policy

Curaspan Health Group, Inc. Privacy Policy

1. Scope. Curaspan Health Group, Inc. (“Curaspan”) recognizes the importance of maintaining the privacy of all confidential and personal information, and Curaspan appreciates your trust in us. By visiting and/or using our Web sites, you agree to this Privacy Policy. This Privacy Policy provides information about how Curaspan collects, uses and transfers information that includes personally identifiable information (“Personal Information”); provider-specific information (“Provider Information”); and patient-specific information (“Electronic Protected Health Information”) that Curaspan collects from you when you visit and/or use any of the Curaspan public Web sites.

This statement covers only information collected through publicly available Curaspan Web sites, including www.Curaspan.com and any other Web sites that may be accessed without a subscription agreement and that do not require a user name and password (“Web sites”). This Privacy Policy does not cover any other data collection or processing, including, without limitation, data collection practices of Web pages to which the site links or data that Curaspan or its affiliates collect offline or through Web pages that do not display a direct link to this statement. For example, any of the Curaspan secure hosted applications used by our legally, contracted clients at their authorized locations (“Subscribers”) and their authorized users identified in the Scope of Services for the licensed service applications (the “Authorized Users”) and are not covered by this policy.

2. Right to Know. All user activity on our Web sites is tracked. Users of our Web sites are required to confirm that they have a right to know the information whenever they are viewing Electronic Protected Health Information. Curaspan maintains activity logs on all aspects of the Web sites. Curaspan will provide these activity logs to our Subscribers on a need-to-know basis, subject to approval of our Subscriber’s designated administrator (person who signed the contract or his/her delegate), or to legal authorities that are investigating a potential breach of patient privacy. These “activity logs” and patterns of use identified therein, may be used as evidence in a criminal or civil investigation.

3. Types of Data and Collection Methods: Through the Web sites, Curaspan receives data that you actively submit as well as data that Curaspan tracks:

a. Actively Submitted Data: When you voluntarily request information, subscribe to a mailing list or for a service, respond to an online survey or otherwise actively enter data, Curaspan may collect data such as your name, e-mail address(es), mailing address(es), telephone number(s), and certain information related to the business you represent, e. g. number of employees and provider type. In each such instance, you will know what data Curaspan collects through the site, because you actively submit it. You can elect not to provide information by not entering it when asked. If such information is required in order to allow us to respond to your inquiry, you will receive a notice advising you of this.

b. Passively Tracked Data: Curaspan uses tracking technology that has become standard operating procedures employed by many other Web sites including, without limitation, "cookies" or small data files stored on your computer's hard drive, to collect such information. When you visit Curaspan Web sites, Curaspan also passively tracks information from your computer and Internet connection, such as the IP address of your computer and/or Internet service provider, the date and time you access our Web sites, the Internet address of Web sites from which you link to our site, the computer technology you are using and your movements and preferences on our site. In some instances, Curaspan also uses cookies to collect information that on future visits to that Web site, identifies you as a previous visitor, or tracks your activity on our Web sites. If you follow a link to the site from an affiliate or promotion, Curaspan stores information about your arrival from that affiliate or promotion in a “session cookie.” You do not need to have cookies turned on to visit our Web sites. You can refuse cookies by turning them off on your browser. But, if you choose to access Web pages that require registration, you need to accept a mandatory session cookie, which you can delete after you leave the site.

c. Combinations: To the extent permitted by applicable law, Curaspan reserves the right to combine passively tracked data with Personal Information that you actively submit and/or Personal Information that Curaspan has collected about you.

4. Collection, Purposes, Use of Tracked Data: Curaspan collects actively submitted data primarily for two purposes: first, for the purpose for which you originally sent us the data (e.g., to share the information with other health-care professionals regarding your interest in a potential patient placement or to document that you updated your provider profile information with us); and second, for purposes of contacting you to further discuss your interest in Curaspan, the services Curaspan provides and ways Curaspan can improve its services. Curaspan collects passively tracked data primarily for purposes of administering, protecting and improving our Web site and our systems, to better understand the preferences of our Web site visitors, to identify server problems, to compile aggregated statistics about Web site usage, and to help improve your experience on our Web sites.

Curaspan is not in the business of selling or licensing your information to telemarketers and Curaspan does not share your Personal Information with others, except as follows:

• Curaspan freely shares your information within the Curaspan group of companies and Curaspan also may share information with trusted business partners, such as system integrators, distributors, and referral partners and any other party specifically identified on the page on which you submit your information.
• Curaspan may share the Personal Information Curaspan collects with other companies with whom Curaspan has joint marketing arrangements.
• Curaspan may share information with companies that perform services on behalf of Curaspan, such as e-mail delivery or online marketing programs. Curaspan may disclose Personal Information that Curaspan collects about you to these companies to enable them to perform these services, but they are required to safeguard the Personal Information and are not authorized to use it for any purpose other than completing their contractual requirements to Curaspan.
• Curaspan may also disclose information, including Personal Information, Curaspan collects about you in other circumstances as required or permitted by law. For example, Curaspan reserves the right to disclose Personal Information, including account information, when Curaspan believes such disclosure is appropriate to cooperate with an investigation of activities claimed to be unlawful or to protect the rights or property of Curaspan or others.
• In addition, it is possible that in the future another company may acquire Curaspan or its assets. It is also possible that Curaspan may partner with or purchase another company to continue to do business as a combined entity. In the event that this occurs, it is possible that our Subscriber information, including your Personal Information, may be transferred to the new business entity as one of Curaspan’s assets. In such an event, Curaspan will update this policy to reflect any change in ownership or control of your Personal Information.

5. Cookies and Similar Files:   As noted in section 3b above, Curaspan Web sites may use “cookies” and files that are similar to cookies. No Personal Information about you is stored on the cookie. Most Web browsers accept cookies by default, but allow users to reject cookies by changing the browser preferences. If you have set up your browser to reject cookies, some aspects of our Web sites, will not work properly. If you have Macromedia Flash installed on your computer, Curaspan may also use a file called a Flash Object to store your unique Subscriber code and record locater on your computer. Unless deactivated by you, the Flash Object provides us with a backup method for recognizing you in the event that Curaspan is unable to identify your cookies. This Privacy Policy covers the use of cookies and similar files by Curaspan only and does not cover the use of cookies and similar files by any third party advertisers or Web sites linked to the Web sites. Curaspan may use third-party advertising companies to serve ads on our behalf. These companies may use a cookie or an action tag, also known as a Web Beacon or a 1 pixel .gif file, to track your response to their advertisement and to measure the effectiveness of their advertising or to award incentives or points to their members who respond to their advertisements. Curaspan has no access to or control over cookies or action tags used by these third party companies. Curaspan does not receive any Personal Information collected by these advertisers using action tags or cookies nor does Curaspan disclose any of your Personal Information such as your name, telephone number or address with these companies except in accordance with this Privacy Policy.

6. Curaspan Provider Data Bank™. The proprietary Curaspan Provider Data Bank contains detailed information about all hospitals, skilled-nursing facilities, home-care agencies and other post-acute providers in the United States. Listings feature provider contact information, location, levels of care, special services and other features such as religious affiliation and dietary options. Supplemented with data from Centers for Medicare & Medicaid Services (CMS), each entry is Google Map-enhanced. A printable map accompanies each option on a provider-matching list generated by the Curaspan Service Applications, in which this rich database of provider listings is integrated. The provider data bank allows our Subscribers to easily search for and find providers that can help deliver care to their patients requiring transition to another level of care. Curaspan maintains this inclusive database that lists providers that are Curaspan Subscribers as well as other health-care providers that are key partners of our Subscribers.

a. Providers Participating in the Federal Medicare Program. As defined in the Curaspan Provider Data Bank Policy, information about all appropriate health-care organization that participate in the federal Medicare program are obtained directly from the Center for Medicare & Medicaid Services (“CMS”) at www.medicare.gov on a quarterly basis and loaded into the Curaspan Provider Data Bank. Participating Medicare providers that are listed in the Curaspan Provider Data Bank are encouraged to review the information provided by CMS but do not need to do anything in order to be listed. Medicare participating providers may not elect to be removed from the Curaspan Provider Data Bank, because this would limit patient choice for Medicare recipients searching for care providers. If your organization is listed at www.medicare.gov and meets the criteria defined in the Curaspan Provider Data Bank policy, Curaspan maintains your listing in the provider data bank. At the request of an authorized person Curaspan can remove your fax number and request that users of the Curaspan services contact you by phone when they have a patient interested in your organization. In addition, your organization has a right to review the information obtained from CMS and to correct or append to that information. The accuracy of the information in the CMS listing is under the jurisdiction of CMS. Organizations are encouraged to contact CMS to update or clarify their information when it is incorrect.

b. Providers Not Participating in the Federal Medicare Program. Curaspan will list, at no charge, any legal, registered health-care provider that meets the criteria defined in Curaspan Provider Data Bank Policy  servicing the geographic markets where Curaspan has an online presence upon a request from either an authorized Provider representative or an Authorized User of Curaspan. In order to be listed in the provider data bank, an authorized representative of the business or an Authorized User of Curaspan must contact Curaspan at Support@Curaspan.com with the following information:

Name
Address
City, State, ZIP Code
Type of Provider
Services Offered  
Name of Administrator
Administrator’s E-Mail Address
Administrator’s Phone Number

The following information may be provided but is not required:
Provider’s Main Phone Number
Provider’s Monitored Fax Number (number used to accept protected health information)

Providers that do not participate with the federal Medicare program may request to have their fax number removed from the provider data bank and request that users of the Curaspan services contact you by phone when they have a patient interested in your organization. In addition, non-Medicare participating organizations will be required to review the provider information stored by Curaspan at least once every 24 months to remain listed in the Curaspan Provider Data Bank. All non-Medicare participating provider organizations have a right to review and update the profile information maintained in the provider data bank.

7.  Release of Electronic Patient Information. The Electronic Protected Health Information available through Curaspan Web sites has been released by Authorized Users of the Curaspan secure hosted applications. These Authorized Users have released the information based on their organization’s own policies and procedures. Curaspan facilitates the secure distribution of the information, but in no way reviews, endorses, monitors, or approves of the patient information released. If you have any questions about the release and disclosure of information sent to you through our Web sites, please contact the organization and person that released the information to your organization.

8. Links To Third-Party Products and Services: While you are visiting or using Curaspan Web sites, you may be presented with an opportunity to purchase third-party products or services or to make payments to Curaspan via PayPal. These products and services are offered and supplied by independent companies not owned or operated by Curaspan. If you click on one of the presented offers, you will be redirected to the Web site of the third party, and any information you provide in response to the offer will be collected and used by the third party and not by Curaspan. Information you provide to the third party and any dealings you have with third parties will be governed by the privacy and other policies of that third party.

9. Effective Date, Amendments: This statement is effective as of January 1, 2013. Curaspan reserves the right to change, modify, add or remove portions of this statement from time to time and in its sole discretion, but will alert you that changes have been made by indicating on the statement the date it was last updated. When you visit Curaspan Web sites, you are accepting the current version of this statement as posted at that time. Curaspan recommends that users revisit this Privacy Policy statement on a regular basis to learn of any changes.

10. Contact Us: Please contact us with any comments, questions, complaints, or suggestions you might have regarding the privacy policy described in this statement. You may send us an e-mail at Support@Curaspan.com or write to us Curaspan Health Group, Inc., 275 Grove Street, Suite 1-110, Newton, MA  02466; telephone: 800-446-9614, option 4.