Last modified: February 2021
ILDP LLC (“Company,” “us” or ”we”) respects your privacy and share this Privacy Statement (the “statement” or “policy”) as an indication of our commitment to protect it.
This policy describes the types of information that you (“you” includes your patients, service providers, employees and/or agents, as applicable) may provide or we may collect when you visit domains controlled by the Company (our “Website”) and our practices for collecting, maintaining, using, protecting and disclosing that information.
This policy applies to information we collect:
- On this Website;
- In e-mail, text and other electronic messages between you and us through this Website; or
- Through mobile and desktop applications you download from this Website, which enable interaction and communications between you and this Website.
It does not apply to information:
- collected by us offline or through means other than this Website;
- collected by any third party (including our affiliates and subsidiaries); or
- that comprises health information covered by HIPAA.
Information We Collect About You and How We Collect It
We may collect various types of information from and about users of our Website, including:
- your name and other information by which you may be personally identified, such as mailing address, e-mail address, telephone number, or any other information by which you may be identified personally (“personal information”);
- information that is about you but does not individually identify you, such as a classification (e.g., patient, caregiver, healthcare provider etc.) or certain medical information (e.g., treatment types); and/or
- information about your Internet connection, the device(s) and equipment you use to access our Website and your usage details.
We collect this information:
- Directly from you — i.e., when you provide it to us; and/or
- Automatically, as you navigate through the Website. Information collected automatically may include IP addresses and navigation and usage details, such as information collected through cookies, web beacons and other tracking technologies.
Information You Provide to Us.
The information we collect on or through our Website may include:
- Information (including personal information) that you provide by registering, creating an account or filling in forms on our Website, including at the time of subscribing to our services or requesting further services, such as name (first and last), ‘user name,’ email address, zip code, date of birth, last 4 digits of Social Security number and answers to security questions;
- Information (including personal information) collected when you report an issue or problem with the Website;
- Records and copies of your correspondence if you contact us (including e-mail addresses, attachments, etc.); and/or
- Details of transactions you carry out through our Website, including the fulfillment of prescriptions or orders (which may require certain financial information to be provided before an order is placed through the Website).
Information We Collect Through Automatic Data Collection Technologies.
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and usage patterns, including:
- Details of your visits to our Website, including frequency, traffic data, location data, logs and other communication data and the resources that you access and use on the Website.
- Information about your computer and Internet connection, including your IP address, operating system and browser type.
The information we collect through automatic data collection technologies is generally statistical data and does not include personal information. It helps us to improve our Website and to deliver a better and more customized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about user preferences, allowing us to customize our presentation of the Website according to patterns of user interests.
- Speed up your searches.
- Recognize users when they return to our Website.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see ‘Choices about How We Use and Disclose Your Information’.
- Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain content and verifying system and server integrity).
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from some third-party providers, see ‘Choices About How We Use and Disclose Your Information’.
How We Use Your Information
We use information that you provide to us or that we collect about you, including any personal information:
- To present our Website and its contents to you;
- To provide you with information, products or services that you request from us or through the Website;
- To provide you with notices about your account, including expiration and/or renewal notices;
- To fulfill our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- To notify you about changes to our Website or any products or services we offer or provide though it;
- In other ways we may describe when you provide the information; and
- For other purposes with your consent.
We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, you are invited to advise us accordingly. For more information on expressing your preferences in that regard, see ‘Choices About How We Use and Disclose Your Information’.
Disclosure of Your Information
We may disclose aggregated information about our users without restriction.
- To our subsidiaries and affiliates;
- To vendors or providers of products or services you have requested in order to provide such products or services to you, or that offer products or services we believe may interest you;
- To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of ILDP LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by ILDP LLC about our Website users is among the assets transferred;
- To fulfill the purpose for which you provide it;
- For any other purpose disclosed by us when you provide the information; or
- With your consent.
We may also disclose your personal information:
- To comply with any court order, subpoena, law or legal process, including to respond to any government or regulatory request;
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ILDP LLC, our customers or others.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding how we use and disclose the personal information you provide to us. The following mechanisms can allow you to exercise certain controls over your personal information:
Promotional Offers from the Company. If you do not wish to have your contact information used by us to promote our own or third parties’ products or services, you can decline or “opt out” by indicating as such on the applicable order form/registration form or at any other time by sending an e-mail to firstname.lastname@example.org stating your request. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions. This opt-out does not apply to information provided to the Company in connection with or as a result of a product purchase, service experience or other transactions.
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by sending an e-mail stating your request to email@example.com.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads using cookies from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
Accessing and Correcting Your Information
If you have created an account on or through the Website, you can review and update your personal information by logging in and visiting your account profile page.
You may also send an e-mail to firstname.lastname@example.org to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Website who are California residents and have provided personal information to us to request annually certain information regarding our disclosure of such personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to email@example.com.
We have implemented various measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.
Unfortunately, as you know, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. Any transmission of personal information is at your own risk.
All information we collect on this Website that is deemed to be protected health information of an individual will be maintained in accordance with Federal HIPAA privacy laws and subject to the terms of our HIPAA Statement set forth below.
YOUR INFORMATION. YOUR RIGHTS. OUR RESPONSIBILITIES.
Your privacy is very important to us, and we will do everything possible to safeguard your personal health information. We are fully compliant with all state and federal privacy laws. This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully.
Your Rights. You have the right to:
- Get a copy of your paper or electronic medical record
- Correct your paper or electronic medical record
- Request confidential communication
- Ask us to limit the information we share
- Get a list of those with whom we’ve shared your information
- Get a copy of this privacy notice
- Choose someone to act for you
- File a complaint if you believe your privacy rights have been violated
Your Choices. You have some choices in the way that we use and share information as we:
- Tell family and friends about your condition
- Provide disaster relief
Our Uses and Disclosures. We may use and share your information as we:
- (i) treat you; (ii) run our organization; (iii) bill for your services; (iv) help with public health and safety issues; (v) do research; (vi) comply with the law; (vii) work with a medical examiner or funeral director; (viii) address workers’ compensation, law enforcement, and other government requests; (ix) respond to lawsuits and legal actions
Your Rights. When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.
- Get an electronic or paper copy of your medical record. You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you. Ask us how to do this. We will provide a copy or a summary of your health information, usually within 30 days of your request. We may charge a reasonable, cost-based fee.
- Ask us to correct your medical record. You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this. We may say “no” to your request, but we’ll tell you why in writing within 60 days.
- Request confidential communications. You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address. We will say “yes” to all reasonable requests.
- Ask us to limit what we use or share. You can ask us not to use or share certain health information for treatment, payment or our operations. We are not required to agree to your request, and we may say “no” if it would affect your care. If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurer. We will say “yes” unless a law requires us to share that information.
- Get a list of those with whom we’ve shared information. You can ask for a list (accounting) of the times we’ve shared your health information for six years prior to the date you ask, who we shared it with, and why. We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.
- Get a copy of this privacy notice. You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.
- Choose someone to act for you. If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information. We will make sure the person has this authority and can act for you before we take any action.
- File a complaint if you feel your rights are violated. You can complain if you feel we have violated your rights by contacting us using the information below. You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/. We will not retaliate against you for filing a complaint.
Your Choices. For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions.
In these cases, you have both the right and choice to tell us to:
- Share information with your family, close friends, or others involved in your care
- Share information in a disaster relief situation
If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.
Our Uses and Disclosures. How do we typically use or share your health information?
We typically use or share your health information in the following ways:
- Treat you. We can use your health information and share it with other professionals who are treating you. Example: A doctor treating you for an injury or medical condition can ask us a specific question about your prescription record.
- Run our organization. We can use and share your health information to run our pharmacy, improve your care, and contact you when necessary. Example: We use health information about you to manage your treatment and services.
- Bill for your services. We can use and share your health information to bill and get payment from health plans or other entities. Example: We give information about you to your health insurance plan so it will pay for your services.
How else can we use or share your health information? We are allowed or required to share your information in other ways – usually in ways that contribute to the public good, such as public health and research. We have to meet many conditions in the law before we can share your information for these purposes. For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html.
Help with public health and safety issues. We can share health information about you for certain situations such as:
- Preventing disease
- Helping with product recalls
- Reporting adverse reactions to medications
- Reporting suspected abuse, neglect, or domestic violence
- Preventing or reducing a serious threat to anyone’s health or safety
- For health research
- If state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we’re complying with federal privacy law.
- If a coroner, medical examiner, or funeral director requests it when an individual dies.
- To address workers’ compensation, law enforcement, and other government requests.
- In response to a court or administrative order, or in response to a subpoena.
Our Responsibilities. We are required by law to maintain the privacy and security of your protected health information. We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information. We must follow the duties and privacy practices described in this notice and give you a copy of it.
We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind. For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.
Changes to the Terms of this Notice. We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our office, and on our web site.