PRIVACY AND SECURITY POLICY
This Privacy and Security Policy (the “Policy“) governs the practices of all Websites (each a “Website” and collectively, the “Websites”) that are owned, operated and maintained by Marathon Health, LLC and its affiliated companies. The Website domain is www.marathon-health.com.
We refer to Marathon Health, its affiliated companies such as Marathon Health Physician Group, and its’ service providers and other subcontractors in this Policy as “we,” “us” or “our.” We refer to all applications available through the Websites as “Our Applications.”
PERSONAL INFORMATION WE COLLECT OR MAINTAIN
When we refer in this Policy to “Personal Information,” we mean any information that can be used to identify you. If you register to use Our Applications, we will ask you to provide us with your Personal Information when you register and as our relationship grows. Other Personal Information may be provided by your insurer or other entity that maintains your medical claims history and through eligibility files. Examples of Personal Information include your name, address, email address, telephone number, and social security number. The information will vary depending on which of Our Applications you use.
Your Personal Information will be available for you to access through Our Applications. Any information you provide to Our Applications will also be available for reference by our care managers and your healthcare provider, as applicable.
Our Applications and your Personal Information will be stored on computer servers operated by us or by our service providers.
We retain Personal Information for as long as the information is relevant to our business purposes or until you request that we remove the data by contacting us at firstname.lastname@example.org or write to us at:
Attn: Privacy Officer
20 Winooski Falls Way, Suite 400
Winooski, VT 05404
From time to time, the Marathon Health system may collect anonymous, non-personal information about your use of this site through the use of “cookies.” Cookies are small bits of information that we transfer to your computer’s hard drive that allow us to know how often you visit our Website and the activities you conduct while on our Website (such as the chat rooms you visited). We automatically assign a different cookie to each user. The information collected by cookies helps us generate content and information on web pages specifically designed for you. It also allows us to monitor how many people use this site and for what purpose. We may use cookie information to target certain information to your browser or to determine the popularity of certain content.
OUR INTERNAL PRIVACY AND CONFIDENTIALITY POLICY
We value and respect the privacy and confidentiality of the individuals and organizations that use Our Applications and our Websites and we have placed strict limits on access and disclosure of all Personal Information that is collected and stored in Our Applications. Subject to applicable law, Personal Information is accessed only to maintain and service the Websites and Our Applications and to otherwise deliver our services. Furthermore, our internal security measures protect your information against both unauthorized access and misuse by authorized users. (See “Technical Security Measures” below.)
ACCESS TO YOUR PERSONAL INFORMATION
We will not disclose or provide access to your Personal Information to anyone, unless: (a) we receive your prior consent directly from you or your authorized representative or in the case of children under the age of 18, the child’s parent or guardian, (b) we believe the recipient to be you or your authorized representative, (c) we are required by law to release the information to the recipient. To deliver superior service and to quickly identify and resolve technical and other problems, it may be necessary for our employees or authorized agents to access data stored in Our Applications. If access to your Personal Information is necessary to troubleshoot a problem, our employees or authorized agents will explain to our Privacy Officer or his or her designee what data they need to access and explain how they will address the problem. Our internal procedures require these employees and authorized agents to access only the information necessary to correct the problem. Further, we may work with our business partners or service providers who may perform certain functions on our behalf, such as managing data, hosting the Websites, sending e-mail messages, data analysis, and mailings. These business partners and service providers have access to your Personal Information only to the extent necessary to perform these specific functions and may not use it for any other purpose.
Our employees who are permitted access to your Personal Information have an ethical responsibility not to disclose your Personal Information for any reason. Furthermore, all of our employees, as a condition of employment, are required to sign a confidentiality agreement legally binding them from disclosing any Personal Information with which we are entrusted.
NOTICE OF PRIVACY PRACTICES
Please contact the on-site healthcare facility operated by one of our affiliated companies to receive a copy of the HIPAA Notice of Privacy Practices applicable to such a facility.
TECHNICAL SECURITY MEASURES
Access to Our Applications
Authorized users rely on unique user identifications and passwords to access Our Applications. We assign access privileges to Our Applications on a “need-to-know basis” and access by each user is documented. Please note that you are responsible for taking all reasonable steps to ensure that no unauthorized person has access to your password. We cannot and do not assume any responsibility or liability for the use or misuse by you of the information you transmit or receive while using Our Applications or for the use or misuse of information by third parties to whom you allow access.
We use Secure Socket Layer (“SSL”) encryption technology when transmitting your Personal Information to our servers. SSL helps to ensure the integrity and privacy of your Personal Information during transmission. Encryption involves systematically scrambling numbers and letters, so that even if someone managed to intercept the information, they would not be able to make sense of it. In order to take advantage of this encryption technology, you need to have an Internet browser that will support 128-bit encryption. As an additional security measure, your Personal Information is kept in a database that resides on a server that is physically or logically separate from any other servers at a secure facility.
Firewalls prevent unauthorized system access and are implemented between the Internet and the servers on which Our Applications reside. Access to Our Applications is not permitted without going through firewalls. We currently use industry-standard firewall technology.
Our Facilities and Physical Security
Our web-hosting servers operate from a secure, off-site facility. Physical security safeguards are in place to protect against environmental hazards, such as a fire or a flood, and against theft and unauthorized access to the hardware components of our systems. These safeguards are SAS-70 compliant.
Software discipline measures are in place to ensure the proper functioning and integrity of the software used to support Our Applications. Antivirus technology is used for virus prevention, detection, and removal. Unauthorized software is prohibited from being installed on any system supporting Our Applications.
Our systems create audit trail logs to proactively monitor activities on our systems. All user information, privileges, and date and time of access can be audited routinely to ensure the adequacy of training and compliance with the policy. We can analyze usage patterns and can identify all breaches of information security, leading to corrective action to prevent future occurrences.
CURRENT STANDARDS AND TECHNOLOGIES
We are committed to meeting or exceeding current information security industry standards and any federal legislation. We constantly review the latest standards, technologies, and legislation and modify our practices and software accordingly.
LINKS TO OTHER WEBSITES, CONTENT CONTRACTORS, AND THEIR COOKIES
PRIVACY OF CHILDREN
We encourage parents and guardians to be aware of and participate in their children’s online activities. We strictly adhere to the Children’s Online Privacy Protection Act and will not knowingly collect, use, or disclose Personal Information from any child under the age of 13 in any manner that violates this law.
USE OF DE-IDENTIFIED INFORMATION
Unless provided otherwise in a binding legal agreement to which we are a party, we may at times aggregate de-identified personal information and may compile and distribute statistical analyses and reports utilizing aggregated data derived from this information. We may also share such information with our partners. Any information that can be traced back to an individual, including, for example, name, address, telephone numbers, and e-mail addresses, will not be included in the aggregate data.
CHANGES TO POLICY; CONTACT INFORMATION
Changes to these policies will occur as warranted and will be posted on this page. Please refer to it occasionally to keep up-to-date on our current policies.
If you have any question regarding this Policy, if you want to correct any Personal Information that we have collected, or if you feel that we are not abiding by this Policy, you should contact us as follows:
Attn: Privacy Officer
20 Winooski Falls Way, Suite 400
Winooski, VT 05404
Last updated August 13, 2013