PRIVACY POLICY

Aledade, Inc.

Last revised: July 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 the terms of this Policy and to our collection, use, and dissemination of your information as described in this Policy.

 

1. Changes and Updates

We reserve the right to amend, alter, or otherwise change this Privacy Policy at our sole and absolute discretion. If we amend this Policy, we will post any changes on this page and update the date at the top; so be sure to check back periodically. Your continued use of the Website after changes have been posted will constitute your acceptance of this Privacy Policy and any changes.

 

2. Personal Information We Collect and Use

For purposes of this Privacy 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 individual or household. It does not include deidentified or aggregate information, or public information lawfully available from governmental records.

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

  • 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, citizenship status 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
  • Location 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

 

3. Sources From Which We Collect Personal Information

The categories of sources from whom we may collect personal information include the following:

  • Information 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, and from business contacts (e.g., a referral for a job candidate)
  • Third party sources, including data collection and aggregation services that, in turn, obtain this data from publicly available sources. We also obtain information from proprietary databases
  • Automated collection, such as through website analytic services and cookies
  • Our service providers, which includes technology/website hosting providers, analytics providers, and systems administrators

 

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 offer, maintain, and improve our Website and the services that we provide or make available, including troubleshooting, 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, protect health and safety, defend our legal interests, or to respond to valid legal requests

 

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

In the last 12 months, we may have 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 (e.g. we use Lever to assist with our employee recruitment and hiring process. You can review Lever’s privacy policy at https://www.lever.co/privacy-policy)
  • 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)
  • Law enforcement, governmental authorities, or other third-parties as required by law, in response to legal requests, to protect our rights and interests, or for the protection of others
  • Third parties who may acquire all or part of our business or assets or act as successors in interest to our business or to whom we transfer any of our rights or obligations
  • As described to you when collecting the information

By using our Website or our services, you agree that, in the event of a transfer such as a merger, acquisition, or sale of assets, your personal information and any other assets may continue to be used by the acquirer or its successors in a manner consistent with this Policy.

 

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).  

 

7. How We Protect 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.

 

8. Children under 18.  The Website is not designed for, directed to, or intended to be used by children under the age of 18. If we obtain actual knowledge that a child under the age of 18 is using the Website, we will take steps to delete such information as soon as possible.

 

9. 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.

 

10. Third-Party Links.  Our Website may contain third-party content and links to websites operated by third parties over which we have no control. We are not responsible for the content or security of third-party websites. Such third-party content and links are included solely for your convenience and do not constitute Aledade’s approval, endorsement or warranty of any third-party website or content. We are not responsible for the accuracy, completeness or reliability of the information, products or services offered or sold through any linked websites. You use them at your own risk. 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 recommend you review that website’s privacy policy and terms of use before using them

 

11. 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 to other entities under the Health Insurance Portability and Accountability Act 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. In addition, at this time, the CCPA includes exemptions for certain information processed exclusively in the business-tobusiness context (e.g., information about an individual acting in his or her capacity as an employee of an entity providing or receiving a service from the relevant business). If you are a California resident whose information is covered by the CCPA, you may have the rights described in this section of this Privacy Policy.

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

Individuals whose personal information is covered by the CCPA have a right to request that Aledade provide the following information:

  • The categories of personal information Aledade collected about you
  • The categories of sources from which Aledade collected the personal information
  • The business or commercial purposes for which Aledade collected and/or sold the personal information
  • The categories of third parties with which Aledade shared the personal information
  • The specific pieces of personal information Aledade collected over the past 12 months

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

  • The categories of personal information, if any, Aledade has sold about you, categories of third parties to which Aledade sold that personal information and the categories of personal information sold to each type of third party
  • The categories of personal information that Aledade has disclosed for a business purpose

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 do not sell 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, as described more fully below. 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.  

Our process for responding to CCPA requests

  • Requests for Specific Pieces of Personal Information: If you submit such a request, we may ask you for three pieces of personal information for verification purposes. Additionally, we may also ask you for a declaration attesting to your identity, signed under penalty of perjury.
  • Requests for Categories of Personal Information: If you submit such a request, we may ask you for at least two pieces of personal information for verification purposes.
  • Requests for Deletion of Personal Information: If you submit such a request, we may ask you for at least two pieces of personal information for verification purposes.
  • Requests for Household Information: There may be some types of personal information that can be associated with a household. Requests for access or deletion of household personal information must be made by each member of the household.
  • Denials: If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. In that case, or if we are denying your request for another reason, including because we serve as a service provider to another entity to which your request should be submitted, we will notify you.
  • Timing: 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.
  • Designating an Agent: Please note that you may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State. If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process. Please contact us at ccpa@aledade.com or 866-252-0873 for more information.

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, please contact us toll free at 866-252- 0873 or send an email to disabilityaccess@aledade.com.  

 

12. 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.

 

13. 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 ccpa@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 atccpa@aledade.com.