1. PERSONAL INFORMATION
A. Personal Information Collected
TPN.health (“Trusted Provider Network”) collects publicly available information about physicians, mental health professionals, treatment facilities, and other clinical professionals in a database to provide a directory and referral service to other healthcare professionals. This information includes their name, office address, office phone and fax numbers, specialty, and other information in public domain. If you choose to apply to become a “User”, you will verify that the information that we have collected about you is accurate.
B. Personal Information is Collected at Various Times
The following fields are required during the application process: name, address, specialty, office phone, email address, institutional capacticy and contact name. During the application process, you will be sent a questionnaire that will be used by TPN.health to complete your registration and verify various aspects of your available treatment options. Once you have completed the registration process, you may at any time provide additional information to your Profile. Such information includes: Interventions, Modalities, Licensure, Focus Issues, Profile Videos, Presentations, and other materials that you believe characterize your services to potential clients. Providing additional information is entirely optional, but it enables you to better identify yourself to other Users of TPN.health. All information voluntarily provided will be part of your Profile, which is accessible to anyone browsing the TPN.health directory. Any information you provide to us, whether during the registration process or as an update to your Profile, may be used in the same manner and extent to which other information is permitted to be used hereunder, including for the purpose of serving advertisements through the service.
If you wish to invite your colleagues to become TPN.health Users, you can send emails to colleagues within the platform. In this case, no additional information about you or your colleagues is collected. Alternatively, you may enter their names and email addresses, which TPN.health will use to send your invitation including a message that you write. The names and email addresses of people that you invite will be used only to send your invitation and reminders. TPN.health may collect information through our website or through Customer Support to, among other things, accurately categorize and respond to your inquiry and deliver appropriate service levels.
D. Log files, IP addresses and information about your computer and mobile device
Due to the communications standards on the internet, when you visit the TPN.health we automatically receive the URL of the site from which you came and the site to which you are going when you leave TPN.health. TPN.health also receives the internet protocol (“IP”) address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, email patterns, mobile device operating system (if you are accessing TPN.health using a mobile device), as well as the name of your ISP or your mobile carrier. We use this information to analyze overall trends to help improve the service. The linkage between your IP address and your personally identifiable information is not shared with third parties without your permission, except as described in Section 2 (“Legal Disclaimer and Disclosures to Others”), below.
E. Consent to TPN.health Processing Information About You
F. Rights to Access, Correct and Eliminate Information About You
You have a right to access, modify, correct, and eliminate the data about you, which has been collected pursuant to your decision to become a User. If you update any of your information, we may keep a copy of the information which you originally provided to us in our archives for uses documented herein. We take your rights seriously and encourage you to use them if you deem this to be appropriate. You may exercise these rights by emailing us at [email protected] or by contacting us at:
757 St. Charles Avenue Suite 306
New Orleans, LA 70130
2. USES OF PERSONAL INFORMATION
A. Access by Other TPN.health Users
TPN.health is an online service dedicated to helping TPN.health Users more effectively connect with one another. The information you choose to provide about your treatment facility(s) on our service is used to help you describe yourself to other Users. If you close your TPN.health account, we will remove all of the personal information that you have provided to TPN.health from our publicly viewable database, as well as any non-publicly available Profile information that you have stored with us. We will retain the publicly available data in the database, including the information about you that was available on our database prior to your joining the TPN.health network. Other information, that does not personally identify you as a treatment facility, is collected by TPN.health from Users (such as, for example, patterns of utilization) and is exclusively owned by TPN.health. This information can be utilized by TPN.health in such manner as TPN.health, in its sole discretion, deems appropriate.
B. TPN.health Communications to You
TPN.health will communicate with you through email, fax and notices posted on the TPN.health website or through other means available through the service, including text and other forms of messaging. If we send any communications to you via the carrier service with which you have a mobile communications subscription or otherwise have access, you understand you will pay any service fees associated with any such access (including text messaging charges for messages to your mobile device). Our communications to you include emails which help inform Users about various features of the service. TPN.health may send you promotional information unless you have opted out of receiving such information. You can change your email and contact preferences at any time by sending a request to [email protected] or by updating your Profile information.
C. Customized Content
Information provided to TPN.health (or to third parties with whom it offers combined services) is also used to customize your experience on our website. For example, you can store “favorite” phone numbers for easy reference.
D. Sharing Information with Third Parties
TPN.health takes the privacy of Users very seriously. We do not sell, rent, or otherwise provide your private information to third parties for marketing or other purposes. We may provide data about the usage of our services with third party service providers with whom we contract to help us provide our Services. For example, we may work with vendors, consultants or other third parties to host and maintain our data and website properties, analyze our data, or provide marketing assistance. All contracted third parties must agree not to use your personal information and communications other than to fulfill their responsibilities to us and are bound by confidentiality agreements about their use of such information. We may provide aggregated anonymous data about the usage of our services to third parties for such purposes as we deem, in our sole discretion, to be appropriate, including to prospective investors in TPN.health. We may segment our Users by specialty, education, alumni groups, training, research, grants, trials, geographic location, or other similar information and provide information from your public Profile as part of our Services and product offerings. If you would like to be excluded from the aggregated research or products based upon aggregated or segmented data and Users’ activities on the site, please email [email protected]. As part of our Services, we may be required to share personal information with accredited Continuing Medical Education (CME) and Continuing Education (CE) providers who certify CME and CE activities, to process CME or CE activities you may choose to take through our Service.
When you choose to engage with a sponsored program, such as engaging with a commercial client’s sponsored news alert, we may provide our commercial clients with your identifiable information and information about the type of engagement (e.g., whether you viewed, interacted with or requested information about such promotional content). We will only share your identifiable information with clients who have agreed to use such information solely for authorized purposes.
To confirm, we will not provide your personal contact information such as email, phone, fax, or postal address as part of our Services. You may revoke your authorization to participate in these features of our Services at any time. If you would like to be excluded from the accredited bodies, leading publications or commercial features of our Services, please email [email protected]th.
E. Finding Colleagues
We use your information, including the addresses you import through our contact importers, to make suggestions to you and other Users on TPN.health. For example, if another User imports the same email address as you do, we may suggest that you add each other as colleagues. To help your friends find you, we allow other Users to use contact information they have about you, such as your email address, to find you, including through contact importers and search.
We offer search services to help you find information and learn more about other Users (for example, you can search for Users with specific expertise, or that you may know through industry interaction). We use information from User Profiles and other contributions to TPN.health to inform and refine our search service.
G. Surveys and Polls
As a User, you may receive requests to participate in market research including polls and surveys submitted by other TPN.health Users. If you participate in surveys and polls offered through our website, the information you provide may be visible to others using the TPN.health website. You may opt-out of participating by emailing [email protected] to stop receiving these inquiries and requests.
H. Communications to Other Users
Communications you initiate through TPN.health, such as a colleague invitation sent to a non-User, will not list your name in the message, or your current office address and phone/fax numbers. No other contact information will be included in the message. TPN.health Users may communicate with one another using the TPN.health messaging feature. Messages may only be initiated between two users who have connected within the TPN.health network. In the case where a User has initiated a group message to two or more of his or her colleagues, recipients of this group message may “reply all” to the recipients of this group message, even though they are not all colleagues.
Users will not upload or provide to TPN.health any personal financial information or medical information of any nature or any Protected Health Information (“PHI”) or Electronic Protected Health Information (“ePHI”), as defined under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). PHI means individually identifiable information relating to the past, present, or future health status off an individual and may include the first name and last name or first initial and last name of any natural person in combination with any of the following elements that relate to that natural person: a social security number; geographic identifiers, diagnoses, treatment information, medical test results, and prescription information are considered protected health information under HIPAA, as are national identification numbers and demographic information such as birth dates, gender, ethnicity, and contact and emergency contact information. PHI relates to physical records, while ePHI is any PHI that is created, stored, transmitted, or received electronically. User will remove such information immediately if accidentally uploaded or provided to TPN.health, or TPN.health may purge such information from the Services.
J. Legal Disclaimer and Disclosures to Others
It is possible that we may need to disclose personal information when required by law, such as responses to civil or criminal subpoenas, or other requests by law enforcement personnel. We will disclose such information when we have a good-faith belief that it is necessary to comply with a court order, ongoing judicial proceeding, subpoena, or other legal process or request to TPN.health brought in any country throughout the world, or to exercise our legal rights or defend against legal claims. We may also disclose your personal and other information you provide, to another third party as part of a reorganization or a sale of substantially all the business of TPN.health. Any third party to which we transfer or sell TPN’s assets will have the right to continue to use the personal and other information that you provide to us.
3. YOUR INFORMATION CHOICES
A. Accessing and Changing Your Account Information
You can review the personal information you provided us and make any desired changes to the information you publish, or to the settings for your TPN.health account, including your email and contact preferences, at any time by emailing [email protected]. You can also make these changes on the TPN.health website by updating your Profile. Please be aware that even after your request for a change is processed, TPN.health may, for a time, retain residual information about you in its backup and/or archival copies of its database.
B. Closing Your Account
You can also close your account at any time by emailing [email protected]. If you close your TPN.health account, we will remove all of the information that you have provided to TPN.health from our publicly viewable database, as well as any private profile information that you have stored with us. We will retain the publicly available data in the database, including all of the information about you that was available on our database prior to your joining the TPN.health network. We may also retain certain data contributed by you if we believe it may be necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, or if required by law.
TPN.health may also retain and use your information if necessary to provide the Services to other Users. For example, just as an email you may send to another person through an email service provider resides in that person’s inbox even after you delete it from your sent files or close your account, communications to other Users, as well as your contributions to the online discussion or other communications, may remain visible to others after you have closed your account. Similarly, other information you have shared with others, or that other Users have copied, may also remain visible. This includes personal health information that you communicate through the TPN.health Services. TPN.health disclaims any liability in relation to the deletion or retention (subject to the terms herein) of information or any obligation not to delete the information. TPN.health does not control when search engines update their cache, which may contain certain public profile information that has since been removed from TPN.health publicly viewable database. To request that we close your account and remove your information from the TPN.health website, please send your request to [email protected]. Please send your request using an email account that you have registered with TPN.health under your name. You will receive a response within five business days of its receipt.
C. Memorializing Accounts
If we learn that a User is deceased, we may memorialize the User’s account. In these cases we may restrict profile access, remove messaging functionality, and close an account if we receive a formal request from the User’s next of kin or other proper legal request to do so.
4. YOUR OBLIGATIONS
A. User Responsibilities
As a User, you have certain obligations toward the other Users with whom you will be communicating. Certain of these obligations are imposed by applicable law and regulations, and others have become commonplace in user-friendly communities of like-minded members, such as TPN:
- You must not download or otherwise disseminate any information which may be deemed to be injurious, defamatory, violent, offensive, racist, sexist or xenophobic, or which may otherwise violate the purpose and spirit of TPN.health and its community of Users.
- You must not provide information to TPN.health and /or other Users which you believe might be injurious or detrimental to your person, professional or social status.
- You must use our free peer-to-peer invite and secure message system for clinical, not commercial use. While we do allow selected client outreach for partner information, market research, expert witness, and career opportunities, these messages have a distinct format and channel-level opt-outs to protect our members. Those found soliciting, scamming, or spamming other members will be removed or suspended from the network at our sole discretion.
- You must refrain from posting PHI, ePHI, using TPN.health for any purpose which would violate the Stark Law, Anti-Kickback Statute, False Claims Act, or furthering any activities which would violate Federal, State or Local law.
Any violation of these guidelines may lead to the restriction, suspension or termination of your account by TPN.health, as we take these principles seriously and consider them to be the basis on which our Users adhere to the TPN.health website and the services which it offers.
5. IMPORTANT INFORMATION
A. Insurance Data
Insurance data on TPN.health is offered for informational purposes only, should not be relied upon, and users agree to hold harmless TPN.health and its data suppliers for use of the data.
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page. We generally post updates to this policy once per year or as applicable. By continuing to use the TPN.health service after notice of changes have been sent to you or published on the TPN.health website, you are consenting to the changes. If you use the TPN.health service after notice of these changes have been posted, you are providing your consent to the changed practices.
To secure your personal information, access to your data on TPN.health is password-protected. It is your responsibility to protect the security of your login information.