This Privacy Policy outlines how Salus EMR ("we," "our," "us") collects, uses, and shares personal data of its users (“users”, “you”) through its website / web application (salusemr.com) / mobile application and its software-as-a-service platform, which provides intake forms and practice management software (collectively referred to as the "Services"). Our clients primarily include healthcare and wellness providers ("Providers"). This policy pertains to personal information shared or submitted through our Services, and explains your options concerning the treatment of this data/information provided or collected on application we make available to third-parties or platforms if disclosed to you in connection with use of the application. It does not apply to information handled by Providers or third parties, and you should contact them directly for information on how they use your data. We follow this privacy policy in accordance with the federal and local laws governing us including in strict compliance of Health Insurance Portability and Accountability Act of 1996 (HIPAA) , Regulation (EU) 2016/679 (General Data Protection Regulation) (GDPR) and the provisions of the Personal Information Protection and Electronic Documents Act (PIPEDA) and its corresponding rules and regulations, as may change from time to time.
In the course of delivering our Services, we may receive protected health information (PHI) from your Provider under the Health Insurance Portability and Accountability Act (HIPAA) or under any law for the time being in force. Your Provider's terms and privacy practices regulate how your PHI is collected, used, and shared. Any inquiries regarding your PHI should be directed to your Provider.
1. Types of Information We Collect
1.1. We collect two basic types of information – personal information and anonymous information – and we may use personal and anonymous information to create a third type of information, aggregate information. We collect the following categories of information:
1.1.1. Registration information you provide when you create an account, including your first name and surname, country of residence, address, sex, date of birth, email address, username, password and your clinical inputs entered to generate the electronic records including the patient’s health information.
1.1.2. Transaction information you provide when you request information or purchase a service from us, whether on our mobile application / web application, including your postal address, telephone number and payment information.
1.1.3. Information you provide in public forums and information you provide to us when you use mobile application / web application, our applications on third-party sites or platforms such as social networking sites or link your profile on a third-party site or platform with your registration account.
1.1.4. Information sent either one-to-one or within a limited group using our message, chat, post or similar functionality, where we are permitted by law to collect this information.
1.1.5. Location information when you visit our mobile application / web application, including location information either provided by a mobile device interacting with one of our sites or applications, or associated with your IP address, where we are permitted by law to process this information.
1.1.6. Usage, viewing and technical data, including your device identifier or IP address, when you visit our mobile application / web application, use our applications on third-party sites or platforms or open emails we send.
2. How We Collect Your Information
2.1. We collect information you provide to us when you enter your clinical inputs to generate the electronic records, or register with us, participate in other activities on our mobile application / web application, respond to customer surveys, or otherwise interact with us. Please keep in mind that when you provide information to us on a third-party site or platform (for example, via our applications), the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this privacy policy and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications.
2.2. We collect information through technology, such as cookies, Flash cookies and Web beacons, Pixel Tags (i.e. tracking pixel, clear gif, etc.), including when you visit our mobile application / web application.
2.3. Software Development Kits: SDKs are external code components that we may include in our mobile apps for various reasons, such as offering analytics on app usage, integrating with social media, enhancing app features, or supporting online advertisements.
2.4. We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically. Local law may require that you authorize the third party to share your information with us before we can acquire it.
3. Use of Your Information by Salus EMR
Salus EMR will be the data controller for your information. Other members of Salus EMR may have access to your information where they perform services (as a data processor) and, unless prohibited under applicable law, for use on their own behalf (as a data controller) for the following purposes:
3.1. Provide you with the services you request.
3.2. Communicate with you about your account or transactions with us and send you information about features on our sites and applications or changes to our policies.
3.3. Consistent with federal and local laws and choices and controls that may be available to you.
3.4. Send you offers and promotions for our services.
3.5. Personalize content and experiences on our mobile application / web application based on your diagnosis.
3.6. Provide you with diagnosis based on your activity on mobile application / web application.
3.7. Optimize or improve our services and operations.
3.8. Detect, investigate and prevent activities that may violate our policies or be illegal.
4. Sharing Your Information with Other Companies
4.1. We will not share your personal information outside the boundaries of Salus EMR except in limited circumstances, including:
4.2. When you allow us to share your personal information with another company, such as:
4.2.1. In the context of aggregation of data culminating in a multicentric publication in a peer reviewed or non-peer reviewed scientific journal.
4.2.2. Directing us to share your personal information with third-party sites or platforms, such as social networking sites.
4.3. Please note that once we share your personal information with another company, the information received by the other company becomes subject to the other company’s privacy practices.
4.4. When we share personal information with third parties in connection with the sale of a business, to enforce our End User License Agreement / Terms of Use or rules, to ensure the safety and security of your patients and third parties, to protect our rights and property and the rights and property of your patients and third parties, to comply with legal process or in other cases where disclosure is required by law.
5. Your Controls and Choices
5.1. We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with local laws, your controls and choices may include:
5.1.1. You may correct, update and delete your registration account.
5.1.2. You may change your choices for subscriptions, newsletters and alerts.
5.1.3. You may choose whether to receive from us offers and promotions for our products and services, or products and services that we think may be of interest to you.
5.1.4. You may choose whether we share your personal information with other companies so they can send you offers and promotions about their products and services.
5.1.5. You may request access to the personal information we hold about you and that we amend or delete it and we request third parties with whom we have shared the information do the same.
5.1.6. You may exercise your controls and choices, or request access to your personal information, by visiting the respective options on our website. Please be aware that, if you do not allow us to collect personal information from you, we may not be able to deliver certain products and services to you, and some of our services may not be able to take account of your interests and preferences.
5.2. If you have questions regarding the specific personal information about you or your patient that we process or retain, please contact us.
6. Data Security, Integrity and Retention
The security, integrity and confidentiality of your information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect your patient’s information from unauthorized access, disclosure, use and modification. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.
7. Changes to this Privacy Policy
From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent.
8. Comments and Questions
If you have a comment or question about this privacy policy, please contact us at legal@salusemr.com . Our mobile application / web application may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our mobile application / web application and to read the privacy policies of other sites that may collect your personal information.