Last modified April 2015
How our Subscription Service Works
We use an online subscription service through HubSpot. To understand how HubSpot’s subscription service works, we’re quoting directly from HubSpot’s privacy page regarding this matter (because why re-invent the wheel?):
HubSpot’s agreement with Total Access Medical prohibits us from using the Subscription Service to collect, manage, or process Sensitive Information. “Sensitive Information” refers to credit or debit card numbers, personal financial account information, Social Security numbers, Social Insurance numbers, passport numbers, driver’s license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information (including but not limited to “individually identifiable health information” (“IIHI”) and “protected health information” (“PHI”) as defined by the Health Insurance Portability and Accountability Act of 1996, as amended, and the Health Information Technology for Economic and Clinical Health Act of 2009 (“HITECH”), or other financial or health information.
Information We Collect
While you don’t need to provide any information in order to explore and enjoy our Websites, we do collect Navigational Information.
In addition, we sometimes request that you provide Personal Information when you’re seeking certain things from us (like our guide to: “Is Direct Primary Care Right for You?,” for example).
What Do We Mean by “Navigational Information”?
This refers to information about your computer and your visits to this Website, such as your IP address, geographical location, browser type, referral source, length of visit, and pages viewed.
What Do We Mean by “Personal Information”?
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, credit card information and other information about yourself (including Health Information that you supply to us) or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, or publicly available information that we acquire from service providers.
What do We Mean by “Health Information”?
Use of Patient Portal
Information about Children
Our Websites and Subscription Service are not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us so that we may delete the information.
Applicability of HIPAA
While Total Access Medical is not a covered entity under HIPAA, we are a business associate of the physicians who are affiliated with Total Access Medical. As such, our use and disclosure of PHI is subject to certain requirements that are imposed by HIPAA and HITECH upon the business associates of covered entities (such as the physicians affiliated with Total Access Medical). In addition, please see the Notice of Privacy Practices for each physician associated with us on the individual webpages of such physicians on our Websites for further information on these requirements.
How We Use Your Personal Information
We Never Sell Your Personal Information
We will never sell your Personal Information to any third party. (Because it is unprofessional, unethical, and wouldn’t be a very nice thing to do, would it?) We maintain a strict “no-spam” policy, and your e-mail address will not be sold to a third party if you sign up to our Subscription Service.
We Use Your Personal Information for Your Interaction with Total Access Medical
We may collect and use your Personal Information for one or more of the following purposes:
- To make your web experience better by personalizing the Websites and improving the Subscription Service to make your browsing experience better.
- To track usage.
- To process your credit card or other forms of electronic payment.
- To provide you with information about Total Access Medical (such as the addition of new providers, the addition of new locations or the provision of new services and/or special offers) as permitted by HIPAA and HITECH.
- To send to you information that you have requested.
- To analyze the overall information submitted to us in order to improve our Websites, services and promotion.
- To comply with HIPAA, HITECH and other federal and state legal requirements.
- Additional uses that are necessary or useful for Total Access Medical to conduct its business, to the extent permitted by law.
We Ask Permission Regarding Your Personal Information
If you choose to download something from our site (or some similar action), you will need to provide, at the very least, an email address. We will use this email address to deliver the item you’ve asked for or to provide further directions on how to obtain it. You might receive further communications such as marketing communications (as permitted by HIPAA and HITECH) from Total Access Medical.
That said, you are always in control and can unsubscribe yourself from these communications at any time by clicking on the “unsubscribe” link at the bottom of every email or contacting us via phone, email, snail mail, or through our contact page.
We do this for two reasons: first, it’s just proper and polite, and, second, because we strive to be in compliance with the United States’ CAN-SPAM Act. Any marketing information provided to you will be provided as permitted by HIPAA and HITECH, where applicable.
Bottom line: you can opt-out, unsubscribe, or update your preferences at any time you want.
Your Opt-Out Rights Regarding Your Personal Information
If you provide us with your Personal Information, you have the following rights with respect to that information:
- To review the user information that you have supplied to us
- To request that we correct any errors, outdated information, or omissions in user information that you have supplied to us
- To request that your user information not be used to contact you
- To request that your user information be removed from any solicitation list that we use
- To request that your user information be deleted from our records
In addition, where your Personal Information is Health Information, you will also have the rights under HIPAA that are set forth in Notice of Privacy Practices applicable to your Total Access Medical physician, which is located on his or her individual website that is incorporated herein.
To exercise any of these rights, please contact us. We will change, correct, or delete your information as appropriate (and as may be legally required) and notify you of the action we have taken.
To Unsubscribe from Our Communications
You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails or by contacting us. Customers cannot opt out of receiving transactional emails related to their accounts.
To Update Your Preferences Regarding Our Communications
To view and update your preferences, including any lists you’re subscribed to, simply click on the “email preferences” link at the bottom of every email.
Who Has Access to Your Personal Information?
On rare occasions, a trusted third party might ask us about the demographic makeup of our contact database. In these instances, we might provide statistical information about our database, but never any information that could be used to identify any individual user.
We Keep your Personal Information Secure
Retention of Personal Information
We retain Personal Information that you provide us as long as we consider it potentially useful in contacting you about the Subscription Service or our other services, and then we securely delete the information. We will delete this information from the servers at an earlier date if you so request, as described in the opting out and unsubscribing sections above. Total Access Medical physicians will retain Health Information for the minimum period of time required by federal and/or state law.
What Happens if We Go Away?
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy, or otherwise, that company would receive all information gathered by our Websites and the Subscription Service.
Important! Compelled Disclosure
We reserve the right to use or disclose your Personal Information if required by law (such as HIPAA) or if we reasonably believe that use or disclosure is necessary to protect our rights or to comply with a law, court order, or legal process (as permitted or required by HIPAA or applicable state law).
Your Personal Information and Social Media, External Websites, and Public Forums
Our Websites occasionally provide links to other websites. We’re not in control of these websites, so we’re not responsible for the content and privacy practices of these websites. We encourage you to review the policy statements of these external sites for assurance that they adequately safeguard your privacy. These links don’t constitute our endorsement of these other websites, their content, their owners, or their practices.
We offer a public blog where people can leave comments. You should not at any time post your Personal Information or your Health Information in these public forums. Please keep in mind that if you directly disclose any information through this commenting function, this information may be collected and used by others. We will delete any information you have posted on the public blog portion of Websites if you so request, as described in the opting out and unsubscribing sections above.
How We Use Navigational Information
The short of it goes like this: we use Navigational Information to operate and improve the Websites and the Subscription Service, as well as to improve your experience on our Websites. Read below for nitty-gritty specifics.
We use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a Web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize pages on our Websites, or register for the Subscription Service, a cookie helps us to recall your specific information on subsequent visits. When you return to the same Website, the information you previously provided can be retrieved, so you can easily use the customized features.
Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience interactive features on our Websites or Subscription Service. We keep track of pages you visit in order to determine the most popular or most used. This data is used to deliver better customized content and promotions. Please note that activation of settings or other mechanisms to block cookies or other tracking technologies will not affect the collection or use of Personal Information as described elsewhere in this Policy.
We may collect demographic information, such as your ZIP code, Postal code, age, gender, preferences, interests, and favorites using log files that are not associated with your name or other personally identifying information.
There is also information about your computer hardware and software that we automatically collect. This information can include your IP address, browser type, domain names, access times, and referring website addresses. For these purposes, we do link this automatically-collected data to Personal Information, such as name, email address, address, and phone number.
In addition to the uses described above, we may use this Navigational Information to improve the Websites (including but not limited to their functionality, ease of use, etc.) and the services that Total Access Medical offers, analyze the demographic information of the Websites’ users and their activity on the Websites, track usage of certain functions and information accessed on the Websites, improve our marketing and outreach efforts and to develop reports enabling us to analyze and improve the Websites.
Third Party Tracking Technologies
Although we maintain reasonable safeguards designed to protect the information that you supply to us through our Websites, please realize that data transmitted over the internet cannot be guaranteed to be absolutely secure. As such, despite the protections that we have put into place, we cannot guarantee the security of our Websites or of any information you transmit or receive from us. The information that you supply to us through these Websites or via e-mail may be intercepted and/or hacked, and we are not responsible or liable for the illegal or unethical actions of third parties such as hackers. If you send us e-mail messages or submit information to us on the Websites, you are accepting the risk that such information could be intercepted by a third party.