Privacy Policy

Effective date: January 1, 2023

PART 1: Privacy Policy for Users of this Site

THIS PRIVACY POLICY IS PART OF OUR TERMS OF USE, WITH RESPECT TO THE TERMS OF USE AND/OR YOUR USE OF THE SITE AND/OR SUBMISSION OF INFORMATION OR CONTENT TO THE SITE CONSTITUTES YOUR ACCEPTANCE OF AND AGREEMENT WITH THE TERMS OF THIS PRIVACY POLICY AND YOUR CONSENT TO THE COLLECTION AND USE OF YOUR USER IDENTIFIABLE INFORMATION AS DESCRIBED HEREIN.

MDLifespan maintains this information privacy policy explaining how “user identifiable information” provided to MDLifespan via the Site is used and disclosed. “User identifiable information” is information which can be associated with a specific individual or entity, including, for example, personal information such as a user’s name, address, or telephone number, e-mail address, and information about online activities that are linked to them. MDLifespan maintains an additional HIPAA Notice of Privacy Practices which applies to “protected health information” as defined under 45 CFR Section 160.103.

It is common practice and often a necessity for companies or other organizations to collect user identifiable information in order to conduct business and offer services.

General

If you use the Site, we may collect information that you provide to us when you become an authorized user of the Site or otherwise communicate with us. You may be required to provide your name, email address and other information we may request from you to us in order to use the Site.

Additionally, when you use the Site, we may automatically collect certain information that is not user identifiable information, such as your IP address, pages viewed, the date, time and length of time spent on the Site, your computer and connection information such as your browser type and version, operating system and platform, and other transactions performed thereon. If you access the Site through a mobile device, we may also be able to identify the location of your mobile device. You may choose not to share your location details with us by adjusting your mobile device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.

We store and use the foregoing information as necessary for your use of the Site, to diagnose problems with our server, to improve and track the success of the Site and to provide content, products or services of interest to you. We may share the foregoing information with third parties, including our business partners, suppliers, and vendor as necessary for such purposes. We do not provide user identifiable information to third parties for them to contact you to market their products or services to you or otherwise provide user identifiable information to third parties except as described herein or in a separate agreement between you and MDLifespan.

Our Internet service providers may also use other standard web-based technologies to analyze your movements while accessing the Site. The technologies include analytic solutions, web “beacons,” “pixel tags,” and “clear gifs.” These technologies help us ascertain the effectiveness of our service campaigns and marketing programs; allow us to customize the services offered on or through the Site; and help determine the best use for content, and product and service offerings. Some of this information, including the IP address, may be stored on our Internet service provider’s server logs, and may be available for extended periods of time.

Except as described herein or as needed for the operation and use of the Site, MDLifespan will not sell, trade, or disclose to third parties any of your personally identifiable information derived from registration on, or use of, the Site without your consent, except as required by subpoena, search warrant, or other legal process or in the event that You are engaging in unlawful use of the Site or other unlawful activity or activity that violates the Terms. MDLifespan may, however, use and disclose to third party’s user identifiable information and/or other information about you obtained from other sources.

Collection and Use:

MDLifespan may collect and use your user identifiable information for various purposes, including, but not limited to, providing to you access to and use of the Site and anticipating and resolving problems with your use of the Site, or to inform you of upcoming events, new content available via the Site, and other product or service offerings that may be of interest to you. This means that MDLifespan may use your user identifiable information, whether in conjunction with information available from other sources or otherwise, to market to you, and otherwise communicate with you about, products or services that may be of interest to you. MDLifespan may also share user identifiable information about you with and disclose same to other contractors that participate in the provision of such products or services. We may provide user identifiable information about you to third party product or service providers that are not affiliated with us and who provide products or perform services for us or on our behalf, in order for them to provide such products and/or services. By providing user identifiable information via the Site, you agree to this use and disclosure of such information.

Specifically, you agree that MDLifespan can use your user identifiable information to: (i) enable and customize your use of the Site and/or the services provided thereby; (ii) provide you with updates and information about MDLifespan’s products and services; (iii) conduct analysis for MDLifespan’s internal purposes and/or support development of MDLifespan’s products and services; and (iv) create de-identified information and then use and disclose this information in any way permitted by law, including to third parties in connection with their commercial and marketing efforts. You also agree that MDLifespan can disclose your user identifiable information to: (a) third parties assisting MDLifespan with any of the uses described above; (b) a third party as part of a potential merger, sale or acquisition of MDLifespan; (c) our service providers who assist us by performing core services (such as hosting, billing, payment processing, or data storage and security) related to the operation or provision of the site or services provided thereby; and (d) a provider of medical or other emergency services in the event of an emergency. If MDLifespan discloses your user identifiable information, MDLifespan will require that the person or entity receiving your user identifiable information agree to only use and disclose your user identifiable information to conduct its specific business obligations to MDLifespan or for the permitted purpose of the disclosure (as described above). MDLifespan cannot, however, guarantee that any such person or entity to which MDLifespan discloses your user identifiable information or other information will not re-disclose it in ways that you or we did not authorize.

Additionally, notwithstanding any other provision contained herein, to the extent permitted or required by law, regulation or other legal requirement, we will disclose your information to government authorities or third parties if: (i) required to do so by law, or in response to a subpoena or court order; (ii) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or (iii) we believe that you have abused the Site or the services provided thereby by using it/them to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws or in violation of our Terms. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.

Non-U.S. Users:

If you are located outside of the United States and you choose to use the Site or provide your information to us, your information may be transferred to, processed and maintained on servers or databases located in the United States or elsewhere outside of the country where from which you access the Site online. With respect to the Terms represents your consent and agreement to these practices. If you do not want your information transferred to or processed or maintained in the United States, with respect to the Terms and should not access or use the Site. The European Commission and/or other geopolitical regions have determined the United States may not subscribe the same legislative standards for data protection that may be applicable in your country, province, territory or geopolitical region. With respect to the Terms and providing us with your personal information, you are consenting to our use of it in accordance with our privacy practices, including the transfer of your information across international boundaries to jurisdictions anywhere in the world as permitted by local law.

We may share information relating to users of the Site with affiliated or unaffiliated third parties on an anonymous, aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.

User Opt-Out:

You may choose not to receive direct marketing communications from MDLifespan in connection with the Site by providing notification to MDLifespan making such request. If MDLifespan receives such a request from you, MDLifespan thereafter (a) will discontinue contacting you directly with marketing messages about MDLifespan’ products or services, and (b) will not use user identifiable information obtained from your use of the Site to contact you with marketing messages about any MDLifespan products or services. You may choose not to receive such messages by notifying MDLifespan via e-mail or regular U.S. mail. Please note, however, that any such opt out only applies to MDLifespan and will not apply to any other third parties to which MDLifespan has supplied your user identifiable information. Additionally, you acknowledge and agree that such opt-out notification processing may not be immediate, and you agree that should you receive additional communications your rights and remedies are limited to contacting us to reiterate your request to opt-out.

Security:

MDLifespan has implemented technology and security features in an effort to safeguard the privacy of your user identifiable information from unauthorized access or improper use, and MDLifespan will seek to continue to enhance its security procedures as new technology becomes available. However, you acknowledge and agree that perfect security is not possible, and your user identifiable information could still be accessed and used by others without authorization. With respect to the Terms constitutes your agreement that MDLifespan is not and shall not be responsible for any such unauthorized access and use of your user identifiable information.

User Revocation of Authorization; Requests for Access to, Rectification or Erasure of, or Transfer of User Information: The authorization given by you hereunder remains in effect until you provide written notice of revocation to MDLifespan. You can revoke your authorization at any time by providing written notice to MDLifespan by email to legal@mdlifespan.com. A revocation of authorization is effective after you submit it to MDLifespan, but it does not have any effect on MDLifespan’s prior actions taken in reliance on the authorization before revoked and does not affect MDLifespan’s use of information that does not constitute user identifiable information. If you have provided your name and email address to us, you may request that we remove your name and email address from our database by contacting us at legal@mdlifespan.com with the exception that we continue to use your name and email address to contact you with respect to the Site if you are still authorized to access and use the Site. Following receipt of a request from you, we will take reasonable steps to delete your information as requested. MDLifespan honors requests from users to access, rectify, correct, erase, restrict processing of or to transfer their own information and will correct any such information which may be found to be inaccurate.

Cookies:

The Site may use “cookies” for the purpose of facilitating the gathering of non-specific user information. A cookie is a small text file stored on a web site user’s hard disk that allows a web server to recall certain information that the user has already entered previously. If you wish not to utilize cookie technology, this feature may be disabled within your web browser.

Other Web Sites:

MDLifespan’s privacy policy only applies to the Site and MDLifespan’s content, products and services. The Site may link to third party websites and information or service providers that may collect personal information from you in order to provide you with information or services. Advertisements that may appear on pages on the Site may also request user identifiable information or provide you with access to other sites that request user identifiable information. MDLifespan has no control over the privacy policy of any third party or other website. Their privacy policies may differ, or they may have no privacy policies. Please examine the privacy policies of such third parties prior to submitting any personal information, as they may differ from ours.

Advertisements:

Advertisements may appear on pages throughout our Site. Some advertisements may request information directly from our users or take our users to websites that may request personal information. MDLifespan has no control over its advertisers’ privacy policies, so please examine the privacy policy of any third-party advertising on our Site prior to submitting any personal information.

Surveys:

MDLifespan may from time-to-time conduct surveys on the Site. Surveys are conducted at random and are completely voluntary to users of the Site. The survey may require a user to provide user identifiable information. MDLifespan may use this information and share it with its contractors as described above to better tailor its products, services and marketing efforts, including advertising or other content provided on the Site and/or to you in particular.

Additional Privacy Protections for Children Using the Internet

The Site is not available for use by minors. MDLifespan does not solicit or target persons younger than legal age for collection of information online. MDLifespan supports the development of technologies that help parents to control the collection and use of personal information from children who use online services in their households.

Business Transfers:

In the event that MDLifespan or any of its affiliates is acquired (whether by sale of assets or ownership interests) by merger with a third party entity or otherwise, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from our Site visitors and users of the Site as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your user identifiable information is treated, transferred, or used.

Policy Changes:

MDLifespan reserves the right to change its privacy policy by publishing new terms on the Site at least thirty (30) days before the effective date of the changes, and your access and use of the applicable site or service the respective Site thereafter constitutes your acknowledgment and acceptance of same. This privacy policy does not create any legal right for you or any third parties.

Questions?

Please direct any questions or comments regarding our privacy policy to legal@mdlifespan.com

PART 2: HIPAA Notice of Privacy Practices for Patients

Effective date: January 1, 2023

As required by the privacy regulations created because of the Health Insurance Portability and Accountability Act of 1996 (HIPAA). This notice describes how health information about you (as a patient of this practice) may be used and disclosed and how you can get access to your individually identifiable health information.

Our commitment to your privacy:

Our practice is dedicated to maintaining the privacy of your individually identifiable health information (also called protected health information, or PHI). In conducting our business, we will create records regarding you and the treatment and services we provide to you. MDLifespan Enterprises LLC, the parent company of the medical practices of Dr. Paul Savage, is required by law to maintain the confidentiality of health information that identifies you. MDLifespan Enterprises LLC is by law to provide you with this notice of our legal duties and the privacy practices that we maintain in our practice concerning your PHI. By federal and state law, we must follow the terms of the Notice of Privacy Practices that we have in effect at the time.

We realize that these laws are complicated, but we must provide you with the following valuable information:

• How we may use and disclose your PHI,
• Your privacy rights in your PHI,
• Our obligations concerning the use and disclosure of your PHI.

The terms of this notice apply to all records containing your PHI that are created or retained by our practice. We reserve the right to revise or amend this Notice of Privacy Practices. Any revision or amendment to this notice will be effective for all your records that our practice has created or maintained in the past, and for any of your records that we may create or maintain in the future. Our practice will always post a copy of our current Notice in our offices in a visible location, and you may request a copy of our most current Notice at any time.

If you have questions about this Notice, please contact your Patient Liaison or email legal@mdlifespan.com

We may use and disclose your PHI in the following ways:

1. Our practice may use your PHI to treat you. For example, we may ask you to have laboratory tests (such as blood or urine tests), and we may use the results to help us reach a diagnosis. We might use your PHI to write a prescription for you, or we might disclose your PHI to a pharmacy when we order a prescription for you. Many of the people who work for our practice – including, but not limited to, our doctors and nurses – may use or disclose your PHI to treat you or to assist others in your treatment. Additionally, we may disclose your PHI to others who may assist in your care, such as your spouse, children, or parents. Finally, we may also disclose your PHI to other health care providers for purposes related to your treatment.
2. Our practice may use and disclose your PHI to bill and collect payment for the services and items you may receive from us. For example, we may contact your health insurer to certify that you are eligible for benefits (and for what range of benefits), and we may provide your insurer with details regarding your treatment to determine if your insurer will cover, or pay for, your treatment. We also may use and disclose your PHI to obtain payment from third parties that may be responsible for such costs, such as family members. Also, we may use your PHI to bill you directly for services and items. We may disclose your PHI to other health care providers and entities to assist in their billing and collection efforts.
3. Health care operations. Our practice may use and disclose your PHI to operate our business. As examples of the ways in which we may use and disclose your information for our operations, our practice may use your PHI to evaluate the quality of care you received from us, or to conduct cost-management and business planning activities for our practice. We may disclose your PHI to other health care providers and entities to assist in their health care operations.
4. Appointment reminders. Our practice may use and disclose your PHI to contact you and remind you of an appointment.
5. Treatment options. Our practice may use and disclose your PHI to inform you of potential treatment options or alternatives.
6. Health-related benefits and services. Our practice may use and disclose your PHI to inform you of health-related benefits or services that may be of interest to you.
7. Release of information to family/friends. Our practice may release your PHI to a friend or family member that participates in your care, or who assists in taking care of you. For example, a parent or guardian may ask that a babysitter take their child to the pediatrician’s office for treatment of a cold. In this example, the babysitter may have access to this child’s medical information.
8. Disclosures required by law. Our practice will use and disclose your PHI when MDLifespan Enterprises LLC is required to do so by federal, state, or local law.

The following categories describe unique scenarios in which we may use or disclose your identifiable health information:

1. Public health risks. Our practice may disclose your PHI to public health authorities that MDLifespan Enterprises LLC is authorized by law to collect information for the purpose of:
   1. Maintaining vital records, such as births and deaths,
   2. Reporting child abuse or neglect,
   3. Preventing or controlling disease, injury, or disability,
   4. Notifying a person regarding potential exposure to a communicable disease,
   5. Notifying a person regarding a potential risk for spreading or contracting a disease or condition,
   6. Reporting reactions to drugs or problems with products or devices,
   7. Notifying individuals if a product or device they may be using has been recalled,
   8. Notifying appropriate government agency and authority regarding the potential abuse or neglect of an adult patient (including domestic violence); however, we will only disclose this information if the patient agrees or MDLifespan Enterprises LLC is required or authorized by law to disclose this information,
   9. Notifying your employer under limited circumstances related primarily to workplace injury or illness or medical surveillance.
2. Health oversight activities. Our practice may disclose your PHI to a health oversight agency for activities authorized by law. Oversight activities can include, for example, investigations, inspections, audits, surveys, licensure, and disciplinary actions; civil, administrative, and criminal procedures or actions; or other activities necessary for the government to monitor government programs, compliance with civil rights laws and the health care system in general.
3. Lawsuits and similar proceedings. Our practice may use and disclose your PHI in response to a court or administrative order if you engage in a lawsuit or similar proceeding. We also may disclose your PHI in response to a discovery request, subpoena or other lawful process by another party involved in the dispute, but only if we have tried to inform you of the request or to obtain an order protecting the information the party has requested.
4. Law enforcement. We may release PHI if asked to do so by a law enforcement official:
   1. Regarding a crime victim in certain situations, if we are unable to obtain the person’s agreement,
   2. Concerning a death, we believe has resulted from criminal conduct,
   3. Regarding criminal conduct at our offices,
   4. In response to a warrant, summons, court order, subpoena, or similar legal process,
   5. To identify/locate a suspect, material witness, fugitive, or missing person,
   6. In an emergency, to report a crime (including the location or victim(s) of the crime, or the description, identity, or location of the perpetrator).
5. Deceased patients. Our practice may release PHI to a medical examiner or coroner to identify a deceased individual or to identify the cause of death. If necessary, we also may release information for funeral directors to perform their jobs.
6. Organ and tissue donation. Our practice may release your PHI to organizations that oversee organ, eye or tissue procurement or transplantation, including organ donation banks, as necessary to facilitate organ or tissue donation and transplantation if you are an organ donor.
7. Our practice may use and disclose your PHI for research purposes in certain limited circumstances. We will obtain your written authorization to use your PHI for research purposes except when an Internal Review Board or Privacy Board has determined that the waiver of your authorization satisfies all the following conditions:
   1. The use or disclosure involves no more than a minimal risk to your privacy based on the following: (i) an adequate plan to protect the identifiers from improper use and disclosure; (ii) an adequate plan to destroy the identifiers at the earliest opportunity consistent with the research (unless there is a health or research justification for retaining the identifiers or such retention is otherwise required by law); and (iii) adequate written assurances that the PHI will not be re-used or disclosed to any other person or entity (except as required by law) for authorized oversight of the research study, or for other research for which the use or disclosure would otherwise be permitted;
   2. The research could not practicably be conducted without the waiver.
   3. The research could not practicably be conducted without access to and use of the PHI.
8. Serious threats to health or safety. Our practice may use and disclose your PHI when necessary to reduce or prevent a serious threat to your health and safety or the health and safety of another individual or the public. Under these circumstances, we will only make disclosures to a person or organization able to help prevent the threat.
9. Our practice may disclose your PHI if you are a member of U.S. or foreign military forces (including veterans) and if required by the appropriate authorities.
10. National security. Our practice may disclose your PHI to federal officials for intelligence and national security activities authorized by law. We also may disclose your PHI to federal and national security activities authorized by law. We also may disclose your PHI to federal officials to protect the president, other officials, or foreign heads of state, or to conduct investigations.
11. Our practice may disclose your PHI to correctional institutions or law enforcement officials if you are an inmate or under the custody of a law enforcement official. Disclosure for these purposes would be necessary: (a) for the institution to provide health care services to you, (b) for the safety and security of the institution, and/or (c) to protect your health and safety or the health and safety of other individuals.
12. Workers’ compensation. Our practice may release your PHI for workers’ compensation and similar programs.

You have the following rights regarding the PHI that we maintain about you:

1. Confidential communications. You have the right to request that our practice communicate with you about your health and related issues in a particular manner or at a certain location. For instance, you may ask that we contact you at home, rather than work. To request a type of confidential communication, you must make a written request to your Patient Liaison or email legal@mdlifespan.com specifying the requested method of contact, or the location where you wish to be contacted. Our practice will accommodate reasonable requests. You do not need to give a reason for your request.
2. Requesting restrictions. You have the right to request a restriction in our use or disclosure of your PHI for treatment, payment, or health care operations. Additionally, you have the right to request that we restrict our disclosure of your PHI to only certain individuals involved in your care or the payment for your care, such as family members and friends. We are not required to agree to your request; however, if we do agree, we are bound by our agreement except when otherwise required by law, in emergencies or when the information is necessary to treat you. To request a restriction in our use or disclosure of your PHI, you must make your request in writing to your Patient Liaison or email legal@mdlifespan.com Your request must describe in a clear and concise fashion:
   1. The information you wish restricted,
   2. Whether you are requesting to limit our practice’s use, disclosure, or both,
   3. To whom you want the limits to apply.
3. Inspection and copies. You have the right to inspect and obtain a copy of the PHI that may be used to make decisions about you, including patient medical records and billing records, but not including psychotherapy notes. You must submit your request in writing to Paul Savage MD, at 773.640.1400 or admin@mdlifespan.com to inspect and/or obtain a copy of your PHI. Our practice may charge a fee for the costs of copying, mailing, labor, and supplies associated with your request. Our practice may deny your request to inspect and/or copy in certain limited circumstances; however, you may request a review of our denial. Another licensed health care professional chosen by us will conduct reviews.
4. You may ask us to amend your health information if you believe it is incorrect or incomplete, and you may request an amendment for as long as the information is kept by or for our practice. To request an amendment, your request must be made in writing and submitted to your Patient Liaison or email legal@mdlifespan.com. You must provide us with a reason that supports your request for amendment. Our practice will deny your request if you fail to submit your request (and the reason supporting your request) in writing. Also, we may deny your request if you ask us to amend information that is in our opinion: (a) accurate and complete; (b) not part of the PHI kept by or for the practice; (c) not part of the PHI which you would be permitted to inspect and copy; or (d) not created by our practice, unless the individual or entity that created the information is not available to amend the information.
5. Accounting of disclosures. All our patients have the right to request an “accounting of disclosures.” An “accounting of disclosures” is a list of certain non-routine disclosures our practice has made of your PHI for purposes not related to treatment, payment, or operations. Use of your PHI as part of the routine patient care in our practice is not required to be documented – for example, the doctor sharing information with the nurse; or the billing department using your information to file your insurance claim. To obtain an accounting of disclosures, you must submit your request in writing to your Patient Liaison or email legal@mdlifespan.com. All requests for an “accounting of disclosures” must state a time, which may not be longer than six (6) years from the date of disclosure and may not include dates before April 14, 2003. The first list you request within a 12-month period is free of charge, but our practice may charge you for additional lists within the same 12-month period. Our practice will notify you of the costs involved with additional requests, and you may withdraw your request before you incur any costs.
6. Right to a paper copy of this notice. You are entitled to receive a paper copy of our notice of privacy practices. You may ask us to give you a copy of this notice at any time. To obtain a paper copy of this notice, contact your Patient Liaison or email legal@mdlifespan.com.
7. Right to file a complaint. If you believe your privacy rights have been violated, you may file a complaint with our practice or with the Secretary of the Department of Health and Human Services. To file a complaint with our practice, contact your Patient Liaison or email legal@mdlifespan.com. All complaints must be submitted in writing. You will not be penalized for filing a complaint.
8. Right to provide an authorization for other uses and disclosures. Our practice will obtain your written authorization for uses and disclosures that are not identified by this notice or permitted by applicable law. Any authorization you provide to us regarding the use and disclosure of your PHI may be revoked at any time in writing. After you revoke your authorization, we will no longer use or disclose your PHI for the reasons described in the authorization. Please note we are required to retain records of your care.

Again, if you have any questions regarding this notice or our health information privacy policies, please contact your Patient Liaison or email legal@mdlifespan.com