Effective: July 2015
Our policy regarding the collection and use of
your information via the WriteTouchHealth
website portal ("Portal") is set forth below. The Portal is committed
to disclosing its privacy and data security policies.
Agreement to Privacy
YOUR ACCESS AND USE OF THIS WEBSITE AND PORTAL
IS SUBJECT TO YOUR AGREEMENT WITH THE BELOW POLICY, ALONG WITH THE WRITETOUCHHEALTH TERMS & CONDITIONS OF USE AND YOUR PATIENT
REGISTRATION AGREEMENT OR PRACTICE ACCESS AGREEMENT, AS
APPLICABLE. BY USING THIS WEBSITE, YOU EXPRESSLY AGREE TO THE TERMS OF THIS
IF YOU ARE A PATIENT, OR THE LEGAL
REPRESENTATIVE OF A PATIENT, AND YOU CHOOSE TO REGISTER TO ACCESS THE PRIVATE PORTAL, YOU WILL BE
CONFIRMING THAT YOU HAVE INITIATED THE WRITETOUCHHEALTH PATIENT PORTAL ACTIVATION
REQUEST IN CONJUNCTION WITH YOUR PHYSICIAN’S OFFICE AND YOU WILL BE REQUIRED TO
VIEW AND AGREE TO THE WRITETOUCHHEALTH PORTAL PATIENT
REGISTRATION AGREEMENT IN ORDER TO FINALIZE
IF YOU DO NOT AGREE WITH THE BELOW POLICY, PLEASE
DO NOT USE OR ACCESS THIS PORTAL (OR THE WEBSITE) FOR ANY PURPOSE. PLEASE PRINT
Modifications to Privacy
WRITETOUCHHEALTH MAY REVISE THIS POLICY
REGARDING THE COLLECTION OF INFORMATION AT ANY TIME. SHOULD ANY NEW POLICY TAKE
EFFECT, WRITETOUCHHEALTH WILL GIVE NOTICE TO YOU AND ALL USERS BY POSTING THE
NEW POLICY ON THIS WEBSITE, AND THE NEW POLICY WILL APPLY ONLY TO INFORMATION
BY ACCESSING OR USING THIS WEBSITE AFTER SUCH CHANGES
ARE POSTED, YOU AGREE AND CONSENT TO ALL SUCH CHANGES.
Applicability of this
and provides you information on the specific information that WRITETOUCHHEALTH
may collect from you via the Portal and how WRITETOUCHHEALTH may use it in
connection with this Portal, whether you are using the Portal as a patient or a
If you are a patient or legal representative,
your physician's use and disclosure of your identifiable health information is
subject to your physician's Notice of Privacy Practices. We cannot control any
physician's use of a patient's identifiable health information. If you are a
patient or legal representative of a patient, please contact your physician for
a copy of their Notice of Privacy Practices. WRITETOUCHHEALTH provides this
Portal on behalf of your physician and therefore protects identifiable health
information as required by the applicable agreement between WRITETOUCH HEALTH
and your physician and in accordance with applicable law. If you have any
issues with the identifiable health information managed by your physician’s
practice, please contact them directly, as we have no ability to change the
information you have provided them.
Whether you are a patient or a physician, if we
collect information from or about you via the Portal, we will tell you what
information we are collecting. The amount and type of information that we
receive depends on how you use this Portal and the information you choose to
submit to us via the Portal.
Whether you are a physician or patient user, we
may track use of your user name and may also capture the paths taken as you
move from page to page (i.e., your "click
stream" activity). When you log in, your user name and encrypted password
will be logged by our system in an audit log but will not be used by us.
As a user of the Portal and if available, you may also choose to use the secure messaging
feature of the Portal which will allows the exchange of communications between
patients and the clinicians who treat them and which may contain identifiable
health information. Communications sent via this feature are recorded and
maintained by WRITETOUCHHEALTH. Portal users have the ability to view the trail
of messages received and sent via their Portal account. WRITETOUCHHEALTH does not edit the content of the communications between
patients and physicians.
You are not required to provide identifiable
health information to visit this Website. However, if you are a patient or the
legal representative of a patient, you must provide certain identifiable health
information in order to complete your registration for the non-public Portal to
access the health records maintained by your physician.
If you are a patient (or the legal
representative of a patient), we will collect identifiable health information
from you with your knowledge during the registration process and in the event
you request information or services. We may collect any identifiable health
information that you provide to us, such as your name, address, e-mail address,
gender, birth date and phone number. If you access the Portal patient registration
via the link provided by your physician, certain basic information may be pre-filled into your Portal registration,
which you will need to verify.
When you register for the Portal via the Website, the
registration process requires you to choose an email (to be used as your
username) and password for your account, which you
should keep and maintain as confidential. If you choose to share your user name
and password you understand that those individuals to whom you share that
information will have access to your identifiable health information and will
be able to add to your identifiable health information as though they were you.
You will be responsible for all activities by users resulting from sharing or
not maintaining the confidentiality of your user name or password.
If you are a registered patient user of the
Portal, your identifiable health information (or that of the patient for whom
you are the legal representative) currently stored electronically in your
physician records will become accessible to WRITETOUCHHEALTH
in order to provide you access to such information through the Portal. Your
electronic health records are not permanently stored in the Portal or Website,
but a temporary copy of them is displayed via the Portal when you are logged in
with your user name and password.
Either WRITETOUCHHEALTH or our third web
statistics vendor on behalf of WRITETOUCHHEALTH may also collect
non-identifiable information, which is automatically collected as you browse or
otherwise access this Website and Portal. We may collect such information by
tracking, or asking our third party vendor to track, your click-stream activity
when such information is not tied to a user ID through the use of
"cookie" technology or by tracking internet protocol (IP) addresses,
as explained below.
Like many companies, we may use
"cookie" technology on and off of the Website and Portal. “Cookies”
are small pieces of information that are stored by your browser on your
computer’s hard drive. They enhance your online experience by saving your
preferences while you are visiting a particular website. The cookies do not
contain any identifiable health information and cannot profile your system or
collect information from your hard drive.
When you view our Website or Portal we may place
a cookie on your computer, which may be either temporary or permanent.
Temporary cookies are used to complete transactions with this Website or Portal
and for other purposes such as counting the number of visits to our certain web
pages. These temporary cookies are eliminated when you exit your browser.
A permanent cookie may also be stored on your
computer by your browser. When you log in, this type of cookie tells us whether
you've visited us before or if you are a new visitor. The cookie doesn't obtain
any identifiable health information about you or provide us with any way to
contact you, and the cookie doesn't extract any information from your computer.
The "help" portion of the toolbar on
most browsers will tell you how to prevent your browser from accepting certain
types of cookies, how to have the browser notify you when you receive a new
cookie, or how to disable cookies altogether. Please note that disabling
temporary cookies may prevent you from using and accessing this Website and
Portal. Disabling permanent cookies may also impact your use and access of the
Website and Portal and in particular will not allow you to see any
personalization (including your health record) on the Website or Portal that
you may activate.
In addition, if you visit our Website again
after deleting a cookie, a new cookie may be activated.
Since third parties may use their own cookies
when you click on a hypertext link to their site or service, you should
We may also log and track IP addresses for
systems administration purposes and for reporting usage trends. Your IP address
is usually associated with the physical place from which you enter the
Internet, the name of the domain and host from which you access the Internet,
the browser software you use and your operating system, and the date and time
you access the Website or Portal. By collecting your IP address, we may record
the page that linked you to this Website, the web pages you visit, the ads you
see or click on, and other information about the type of web browser, computer,
platform and settings you are using, and any search terms you enter on this
Website or Portal. IP addresses are not used to track an individual user’s
session. This information only helps us determine how often different areas of
our Website and Portal are visited.
We may combine non-identifiable information
collected automatically (such as through IP addresses, cookies or click-stream
monitoring) with any previously submitted personal information that we may have
received from you.
We may collect your geographic location based on
your IP address and other location-based data.
We may also use various third party internet
vendors to collect, track and analyze track analytical data regarding Website
usage and trends.
Users of the Portal may have the opportunity to
participate through the Portal in various WRITETOUCHHEALTH surveys depending on
the survey and as permitted by law.
Any survey responses that you choose to submit
may be aggregated, de-identified and provided or sold to third parties as set
How Will Your
Information Be Used And Disclosed?
We will not sell, share or rent the information
that is collected via the Portal to others in ways that differ from what is
We may use any identifiable health information
or other information that you voluntarily provide us in order to provide you
with information, products or services that you may request from WRITETOUCHHEALTH.
If you are a patient or the legal representative
of a patient, any identifiable health information that you share via the Portal
will be made accessible to your physician and will become a part of the records
maintained by your physician, which records are subject to your physician's
Notice of Privacy Practices. WRITETOUCHHEALTH has no control over or
responsibility for your physician's use or disclosure of information that you
may provide via the Portal or Website.
To the extent permitted by applicable law, WRITETOUCHHEALTH may use your participation in the Portal to
communicate to you special offers and featured items as well as special offers
and featured items from third parties, WRITETOUCHHEALTH, WRITETOUCHHEALTH's
affiliates, and/or other suppliers and vendors. If you are receiving additional
communications and special offers, you may revoke your authorization to receive
such materials from WRITETOUCHHEALTH via the Portal at any time by contacting
us using the contact information below or as outlined
in the applicable communication. We will implement your revocation as soon as
is commercially reasonable. WRITETOUCHHEALTH cannot control any communications
and other materials that you may receive directly from third parties.
We will also use your information to customize
your browsing experience and communicate with you and otherwise respond to your
questions and suggestions regarding use of the Portal as may be permitted by
We may share your information only with our
suppliers and vendors to the limited extent permitted by applicable law. We
require those suppliers and vendors to comply with all applicable data privacy
laws and regulations, including HIPAA. We do not sell, lease or rent your
identifiable health information. We may also use your geographic location to
provide you with specific content and direct you to your closest service
providers to the extent permitted by applicable law.
The non-identifiable, aggregated health
information we collect may be shared with our suppliers and vendors and used in
the aggregate to create summary statistics that help us analyze website usage
trends, assess what information is of most and least importance, determine technical
design specifications, arrange the Website in the most user-friendly way, and
identify system performance or problem areas.
We may aggregate and de-identify in accordance
with HIPAA identifiable health information, either alone or with other data to
create anonymous "aggregate data" regarding the users of our Website
and Portal. Aggregate and de-identified data is information that describes the
habits, treatment plans, usage patterns, other medical record data and/or
demographics of users as a group but does not reveal the identity of particular
users. This data will not identify you, but will be used as statistical
information to determine such things as user demographics and usage patterns of
our Website and Portal. WRITETOUCHHEALTH may use aggregate data to understand
the needs of our community of users and determine what kinds of programs and
services we can help provide. Aggregate data may also be provided or sold to
third parties, including for the purpose of getting targeted content to you by
third party vendors, suppliers, business partners and/or affiliates a picture
of our community and services and/or participation in surveys or receipt of
emails from third parties.
Use and Ownership
We also reserve the right to share your
information collected from this Website or Portal with third parties to the
extent permitted by applicable law including but not limited to the
requirements under HIPAA, and, in the case of identifiable health information,
pursuant to WRITETOUCHHEALTH's business associate agreement with the applicable
WRITETOUCHHEALTH maintains full rights to any
information collected on this Website or Portal, and may freely collect, use
applicable law as stated above.
While no web site can guarantee security, we
maintain physical, administrative, electronic, technical and procedural
safeguards to help protect your personal information collected via the Portal
as required by applicable law. While we cannot guarantee that loss, misuse or
alteration to data will not occur, we use industry
standards, such as Secure Socket Layers ("SSL") technology, to help
safeguard against such occurrences. In certain areas, the information passed
between your browser and our system is encrypted with SSL technology (which
covers any messages, PII or communications a person directs to WRITETOUCHHEALTH
or the clinician team) to create a protected connection between you and our
website to ensure confidentiality.
Our data is both physically and electronically secured and
is protected from open access to the Internet by using firewall and encryption
technology. We limit access to personally identifiable information
about you to our employees and third-party agents, who we reasonably believe
need to have access to your information to provide you with the information or
services you request via the Portal.
In the event that a breach in our security
systems occurs and there is a possibility that an unauthorized person acquires
your personal information, we will notify you of such a breach as may be
required by applicable law.
In order to help maintain security, you should
never share your user ID or password and should always sign out when you are
finished using the Portal.
We will maintain your information and allow you
to request updates at any time by logging into your Portal account to access
your information. We will also take steps to make sure that any updates that
you provide are processed in a timely and complete manner.
Third Party Websites
If you use the Portal to link to another web
site, which is not controlled or maintained by WRITETOUCHHEALTH, you may decide
to disclose personal information at that web site. For example, you might
provide your contact information to obtain an information packet from an
organization. Please be aware that in contacting that site, or in providing
information on that site, that third party may obtain personal information
to a third party web site from the
Portal. We structure the Service so that no personal or health information goes
in the search string or URL when you move from the Portal to a linked web site.
We encourage you to be aware when you leave our Service and to read the privacy
statements of each and every site that collects personally identifiable information.
What if I am accessing
this Portal from outside of the United States?
If you are visiting our Website or Portal from
outside the United States, please be aware that your information may be
transferred to, stored or processed in the United States. The data protection and other laws of the United States and other
countries might not be as comprehensive as those in your country, but please be
assured that we take steps to protect your privacy. By using the Website or
Portal, you understand that your information may be transferred to our
facilities and those third parties with whom we share it as described in this
Transfer of Data
In the event of a change in control of WRITETOUCHHEALTH
or sale by WRITETOUCHHEALTH of substantially all of its assets or other
acquisition, merger or reorganization, any information owned by or in the
control of WRITETOUCHHEALTH may be transferred to such WRITETOUCHHEALTH
Important Note Regarding
This Website and Portal is not directed toward
children under 18 years of age and WRITETOUCHHEALTH does not knowingly collect
or use information from children under 18 through this Website or Portal. Any
information submitted via the Portal regarding a minor under the age of 18 must
be submitted by the minor's legal representative. To the extent permitted by
applicable state law, minors may access their identifiable health information
through their physician.
What if I have questions
If you have any questions about this Privacy
Policy or the use of your information by WRITETOUCH HEALTH please contact us
McHeyzer Management, Inc.
4823 Broadway Street, Addison TX 75001