PRIVACY POLICY

Aledade, Inc.

Last revised:  January 2020

We take privacy seriously and this Privacy Policy is intended to describe the personal information Aledade (“Aledade,” “we,” “our,” “us”) collects, including through our website (“Website”); how we use and share it; and rights you may have regarding this information.  There are some important exceptions.  In particular, much of the personal information Aledade obtains and maintains about individuals is information that we collect and maintain on behalf of our Accountable Care Organizations (“ACOs”), which is covered by the Health Insurance Portability and Accountability Act, or HIPAA (“Client Data”).  Client Data is not described in or covered by this Policy.  If you are a patient of a practice that participates in one of Aledade’s ACOs, you can find out more about their privacy practices from them.  This Policy also does not apply to information we collect about our employees in the employment context and which is governed by different policies.  By using the Website and our services, you consent to our collection and use of your information as described in this Policy.

 

1. Changes to This Privacy Policy

We reserve the right to amend, alter, or otherwise change this Privacy Policy at our sole and absolute discretion.  If we make material changes to this Privacy Policy, we will post notice that the Policy has been updated.  For material retroactive changes, we will notify you consistent with the law.  Further use of the Website following any changes to it constitutes your agreement to follow and to be bound by the amended Privacy Policy, so we encourage you to check for updates.

 

2. Types of Personal Information We May Collect and Use

This section describes the categories of personal information we may have collected about you in the past 12 months.  It also describes the categories of personal information we may continue to collect.  (Please note that the types of personal information listed in each category are examples only; they are not exhaustive.)  

For purposes of this Policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  It does not include de-identified or aggregate information, or public information lawfully available from governmental records.

  • Personal identifiers and contact information, such as name, date of birth, postal and email address, telephone and fax number, National Provider Identifier (“NPI”) number, Group Practice Number, state medical license number, tax identification number, and other unique identifiers
  • Internet or other electronic network activity information, such as IP address, device identifiers and other online identifiers, data related to your browser, and browsing and search history
  • Demographic information, such as gender, military service and other protected class information that you may choose to provide us to the extent permitted by law 
  • Commercial and financial information, such as accounts payable information relating to our service providers, vendors, and contractors
  • Educational, professional, or employment-related information, such as information about where you work and your company’s name, your position, what certifications or degrees you have obtained, or your educational, professional and employment history, and resume information (e.g., from job applicants)
  • Audio and visual information, such as the sound of your voice, or your image, if you attended and spoke at a webinar that we hosted or attended an event with us or left us a voicemail
  • Geolocation information, as it can be derived from your IP address
  • Other information you or others provide us:  You may provide us with other personal information in communicating or otherwise interacting with us, such as information about your family and associations or information about your interests and preferences or health information about yourself.

 

3. Sources From Which We Collect Personal Information

We collect the categories of personal information described above from data that you or others give to us directly (e.g., by communicating with us, submitting information through our Website, registering for a webinar, or applying for a job with us), from our practices that participate in our ACOs, from business contacts (e.g., a referral for a job candidate), or by purchasing the information from data collection and aggregation services that, in turn, obtain this data from publicly available sources.  We also obtain some of this information from proprietary databases and through automated collection, such as through Website analytic services and cookies.

 

4. Purposes for Which We May Use the Personal Information

We collect each of the categories of personal information above for a variety of purposes, including:

  • To contact you, including to respond to your inquiries and questions and to contact you with information about services and promotional or other information that may be of interest to you, to consider you for employment (either at Aledade or to provide that information to a practice that participates in one of our ACOs)
  • To operate our business and offer or provide services and products (including client services, events, and information and fulfilling our contractual obligations)
  • To identify individuals, practices, or groups that might work with us, and pay you for, or communicate with you about, products or services you provide to us
  • To identify potential practices that may want to participate in one of our ACOs  
  • To understand what information and services you may be interested in
  • To improve our Website and the services that we offer, and to give us insights on how you and other users utilize the Website
  • To facilitate marketing or re-marketing our services to you, including to track and associate Internet search and browsing behavior with our advertisements
  • For statistical, analytical, and business operations and planning purposes 
  • To satisfy legal and regulatory requirements, defend our legal interests, or to respond to valid legal requests

Additional Information About Our Collection and Uses of Personal Information

With respect to each of the categories of data above, we may also share personal information with any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger, or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or to any person who is otherwise deemed to be our successor or transferee.  We may also collect and use information as described to you when collecting the information.

 

5. Categories of Entities with Which We Share Personal Information.

We do not share any of the personal information we collect from you with third parties for marketing purposes without your consent.  We have in the last 12 months disclosed each of the categories of personal information above with third parties for a business purpose and may continue to do so.  The categories of third parties with which we share personal information include:

  • Service providers, such as information technology providers, Website analytics and cookie providers, recruiting and hiring vendors and other contractors
  • Practices that participate in our ACOs and other business contacts.  (Please note that this Privacy Policy does not apply to the use of information by Aledade’s participating practices)

In addition, the information we collect that is covered by this Policy is considered an asset of ours, and if that asset is acquired by a third party, either through sale or bankruptcy, your personal information will be transferred to the entity acquiring the asset.  By using our Website, you agree that, in the event a transfer such as a merger, acquisition, or sale of assets takes place any such assets (including your personal information) may continue to be used by the acquirer or its successors as set forth in this Policy.  We may also share information that we collect with Governmental authorities, such as courts or regulators, or other third parties in response to a valid legal request or to protect our rights and property or the rights, property or safety of others.  

 

6. Marketing, Cookies and Analytics

Website Analytics We use Google Analytics and other cookies and similar technologies to evaluate the use of our Website. Google Analytics’ data practices are governed by the Google Analytics Terms of Service and the Google Privacy Policy, as they may be amended from time to time.  For more information about Google Analytics and the information it collects, you can visit Google Analytics’ policies here. You can view the Google Analytics’ Opt-Out Browser Add-On here.  We also use Pardot to learn more about how you use the Website.  Pardot sets a cookie on your browser to remember your preferences when you return to our site; these cookies store a unique identifier.  To learn more about the cookies that Pardot sets, you can visit Pardot’s website here.

MarketingWe may use data collected from our Website to make you personalized offers relating to our products and services on our site or on third-party sites that you visit (e.g., Facebook, Twitter, and LinkedIn) through the use of cookies in conjunction with other parties. We also deploy a pixel from AdRoll to track your behavior on our site and facilitate re-marketing of our products and services on other third-party sites that you visit later. For a list of third-party sites where we may re-market our product and services to you via the AdRoll pixel, please click here.  For information about AdRoll’s California Consumer Privacy Act (“CCPA”) disclosures, please click here.  If you are interested in learning more about online behavioral advertising, and your ability to opt out of this type of advertising, sometimes called interest-based advertising, we encourage you to visit one of the advertising industry-developed opt-out pages, such as https://youradchoices.com/ or http://www.aboutads.info/.  Please note that while we provide these links for your convenience, these are third-party sites that we do not control (see below).  

How We Protect Personal Information.  We are committed to protecting the privacy and confidentiality of your personal information.  While we implement reasonable security measures to help safeguard your data, no security system is impenetrable.  We cannot and do not guarantee the security of our servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet.  Please use caution any time you provide information over the Internet.

 

7. Children under 18.  Our Website is not intended for users under the age of 18, and we do not knowingly collect personal information through this Website from children under 18.  If we learn that we have done so, we will take steps to delete such information from our files as soon as possible.  We do not sell information regarding children under 18.

 

8. Do-Not-Track Requests.  Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates.  We currently do not take action in response to these signals.

 

9. Third-Party Links.  Our Website contains links to websites operated by third parties over which we have no control.  Should you click on a link to a third-party website, the privacy policy of that website will apply instead of our Privacy Policy.  We are not responsible for the content or security of third-party websites.

 

10. Your Rights in Relation to the Personal Information We Hold About You

A. Your Email Address.  One of the elements of personal information that you may provide is your email address.  You may stop receiving emails from us by selecting the “unsubscribe” link included in all commercial emails you receive from us.

B. For California Users.  Under California Civil Code section 1798.83, California residents may request information regarding the types of personally identifiable information we share with third parties for direct marketing purposes, and the identities of the third parties with whom we have shared such information during the immediately preceding calendar year.  We do not provide personal information to third parties for their direct marketing purposes.

C. Additional Rights for California Residents Under the CCPA.  Because Aledade operates as a business associate under the Health Insurance Portability and Accountability Act to other entities with respect to most of the personal information it holds, only limited categories of the personal information Aledade maintains may be subject to the CCPA.  With respect to this data, if you are a California resident whose information is covered by the CCPA, you may have the rights described in this section. 

Right to request disclosure of information we collect and share about you

You can submit a request to us for the following personal information we have collected:

  • The categories of personal information we’ve collected about you
  • The categories of sources from which we collected the personal information
  • The business or commercial purposes for which we collected or sold the personal information
  • The categories of third parties with which we shared the personal information
  • The specific pieces of personal information we collected

You can also submit a request to us for the following information:

  • The categories of personal information (if any) that we have sold about you, the categories of third parties to which we sold that information, and the category or categories of personal information sold to each third party
  • The categories of personal information that we disclosed about you for a business purpose

Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.  Note that requests can be submitted on behalf of yourself individually or on behalf of your household, provided that we can verify that the request comes from each member of your household.

Right to request the deletion of personal information we have collected from you

You also have the right to request the deletion of personal information we have collected.  After receiving and appropriately verifying a request to delete your information, we will delete the personal information we have collected about you, except for situations where specific information is necessary for us to:  provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law.  We may also retain information where another exception to the deletion requirements in California Civil Code § 1798.105(d) applies.  In addition, the law permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us.

Sales of personal information

We have not sold personal information in the last 12 months.  We do not and will not sell your personal information.  

How to exercise your rights

To exercise your right to request the disclosure of your personal information that we collect or share, or to ask us to delete your information, either email us at ccpa@aledade.com or contact us at 866-252-0873.  Depending on the nature of your request, we may ask you for additional information to verify your request and identity and a declaration attesting to your identity, signed under penalty of perjury.  We will respond to requests for access or deletion as soon as practicable and, in any event, generally not more than within 45 days after receipt of your request.  We may extend this period to 90 days in some cases.  Please note that you may designate an agent to submit requests on your behalf.  We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations.  

We are committed to honoring your rights

We are committed to complying with the law.  If you exercise any of the rights explained in this policy, we will continue to treat you fairly.  Consistent with California Civil Code § 1798.125, we will not discriminate against you because you exercised any of your CCPA rights, including by denying you goods or services, charging different prices or rates for goods or services, providing a different level or quality of goods or services, or suggesting that you will receive a different price or rate or level or quality for goods or services.

Accessibility

We are committed to ensuring that our communications are accessible to people with disabilities.  To make accessibility-related requests or report barriers, please contact us toll free at 866-252-0873 or send an email to disabilityaccess@aledade.com.  

 

11. International Users  

Our Website is hosted in the United States and is intended for access and use by individuals located in the United States only.  By using our Website or our products and services, you consent to the transfer of your personal information to the United States as described in this Privacy Policy.  Please do not use the Website, our products, or our services if you do not agree to the transfer and processing of your personal information in the United States or if it is illegal to do so in your home country.

 

12.Contacting Us

If you have questions on the processing of your personal information, would like to exercise any of your rights, or are unhappy with how we’ve handled your information, please contact us here:  Aledade, Inc., 4550 Montgomery Avenue, Bethesda, MD, 20814, attn: Privacy Officer or email us at privacy@aledade.com.

If you would like to assert your privacy rights, you may also call us toll free at 866-252-0873 or submit a request via email at ccpa@aledade.com.