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Website Privacy Policy

United Concierge Medicine, PLLC and United Concierge Management, LLC Privacy Policy

Privacy Policy Summary

Commitment

United Concierge Medicine, PLLC and United Concierge Management, LLC(“Company”) is committed to the privacy and dignity of our community. We take your privacy seriously and are dedicated to handling any personal information you provide with the utmost care and respect.

Privacy

Company will never share, disseminate, rent or sell your personally identifiable information – including name, postal address, e-mail address and telephone number – with or to third parties, including advertisers or sponsors, except when we have your permission or under the circumstances set forth in detail in our fullPrivacy Policy. Company will use this information to provide you with our services and/or products and to offer you promotional materials from or throughCompany, as well as for operational and administrative purposes.

Advertisements

Company may advertise services and/or products online on behalf of third parties on the Company website and provide you with the opportunity to “opt-in” to and“opt-out” from e-mails from Companyor specifically identified third parties. No personally identifiable information will be shared with these advertisers, sponsors or any other third party that is not an affiliate of Company.

Data Aggregation

Company may combine demographic and other information about our users, obtained from registration forms and/or user profiles, to create “aggregate data.” All personally identifiable information will be removed from this data before disclosing such data to third parties. Aggregate data disclosed to third parties will not contain any information that can be used to identify or contact our users.

Website Usage Tracking

Please note that Company may contract with a third party to help manage and optimize our Internet business and communications. Website usage tracking serviceshelp websites measure how visitors use and navigate a site and the effectiveness of advertising by using web beacons and/or cookies. The type of data that may becollected includes, but is not limited to, the pages visited and links clicked by users. Although such a third-party company would log the information coming from our site on our behalf, we would control how that data may and may not be used.

Protection of Protected Health Information (“PHI”)

Company is committed to protecting your PHI. PHI is information about you that may be used to identify you (such as your name, social security number or address), and that relates to (a) your past, present or future physical or mental health or condition, (b) the provision of health care to you, or (c) your past, present, or future payment for the provision of health care. In conducting its business, Company will receive and create records containing your PHI. Company is required by law to maintain the privacy of your PHI and to provide you with notice of its legal duties and privacy practices with respect to your PHI. Note that Company’s full Privacy Policy explains your rights concerning PHI and circumstances where Company may disclose your PHI or seek your permission to disclose your PHI.

FULL PRIVACY POLICY

Privacy Policy

United Concierge Medicine, PLLC and United Concierge Management, LLC (“Company”) is committed to the privacy and dignity of our community. We take your privacy seriously and are dedicated to handling any personal information you provide with the utmost care and respect.

This Privacy Policy is designed to answer questions you may have regarding our privacy policy and principles. Please read the following to learn more about our privacy policy.

What type of information does the Privacy Policy cover?

As used in this Privacy Policy, “Company” includes www.upstatevipmedicine.com, United Concierge Medicine, PLLC and United Concierge Management, LLC, its subsidiaries/affiliated/contracted entities, contracted physicians, other health care professionals, employees, and contractors, including any professional entity that may render services related to our website(s), and all of their subsidiary and affiliated entities and companies. This policy does not apply to the practices of companies that Companydoes not own or control or to people that Company does not employ or manage. Company is referred to in this Privacy Policy as “we,”“us,”“our” and “ourselves.” Users of this website and our services may be referred to in this Privacy Policy as “users,”“you” or “your.”

Unless otherwise stated, this Privacy Policy applies only to personally identifiable information collected on the Company website,through Company’s e-mail system, through audio and/or video teleconferencing services, two-way audio and/or video consultation, and/or through any and all other electronic means of communication utilized by Company in relation to its online services. It does not apply to any other information collected by Companyby any other means.

This Privacy Policy applies to personally identifiable information collected on and after the date that this Privacy Policy is posted. However, for any Company users who visited, accessed or reviewed our website prior to this date, we will apply this Privacy Policy to personally identifiable information associated with that user only if the user accepts the terms and conditions of this Privacy Policy.

The term “personally identifiable information” means information that identifies a particular individual or enables a party to contact an individual, and includes the individual’s name, postal address, e-mail address and telephone number. Personally identifiable information is sometimes referred to in this Privacy Policy as “personal information.”

The terms of this Privacy Policy are subject to all applicable laws and regulations.

How do we collect the personally identifiable information of our users?

Company may collect certain personally identifiable information through a variety of means and sources about users who visit, submit information through or otherwise use the Company website or services. We collect such information in the following manners:

Information You Provide to Us

Much of the personally identifiable information we receive comes directly from users who are interested in signing up with the website services or obtaining information from and/or setting up an appointment with us in connection with the services we offer. We collect personal information when you complete and submit a form through the Company website in order to contact us for an appointment or general inquiry, or when you e-mail us. We will also collect information as part of the services or information provided during the audio and/or video teleconference consultation itself, and, to the extent applicable, through other telephonic communications. You are responsible for ensuring the accuracy of the personally identifiable information that you submit to us. Inaccurate information will affect your experience when using the Company website or our services and our ability to contact you as described in this Privacy Policy. We may also collect other types of information (non-identifiable information), such as gender, age, personal interests and medical or health-related information that we may associate with personally identifiable information.

Information Collected Through Technology

We may collect information through technology to make our website more useful to you and to track user web activity and interests. Our website may use “cookies,” which are pieces of information a website sends to your computer while you are viewing the website, for a variety of purposes. For example, when you return to our website after logging in, cookies may provide information to the site so that the site will remember who you are.We may also use information collected through web beacons, which are small pieces of data that are embedded in images on the pages of websites, to analyze the traffic patterns on our website, such as the frequency with which our users visit various parts or pages of our website. We may also use these technical methods in HTML e-mails that we send to our users to determine whether our users have opened those e-mails and/or clicked on links in those e-mails.

You may engage in certain transactions without submitting an inquiry, consultation request forms or emails through our website. In such cases, we may gather personally identifiable information, which may include, but is not limited to, your computer’s IP address.

We may manage and place advertisements on our website on behalf of third parties referred to herein as “network advertisers.” We may also use cookies and other technology to collect information when you click on or move your cursor over one of these banner advertisements.

Please note that once you have clicked on any such advertisement and have left our website, our Privacy Policy no longer applies and you must read the privacy policy of the advertiser to see how your personal information will be handled on its website. Advertisers or other third party companies will not have access to our cookies or other information-gathering technology.

Information That We Collect from Others

We may supplement personally identifiable information that we have collected directly from our users with other information that we obtain from third parties. If and when we associate any information that we obtained from third parties with personally identifiable information that we have collected under this Privacy Policy, we will treat the acquired information exactly like the information that we collected ourselves.

How is personally identifiable information used?

We will never rent, sell, disseminate or share personal information about you with non-affiliated companies or third parties, except when we have your permission or under the circumstances set forth in detail below.

Personally identifiable information collected may be shared within and used by Company for several purposes. For example, Company may use your personal information to send you promotional materials about goods and services, including special offers and promotions, either offered by Company or offered by third parties (sent by Company on behalf of these third parties). These promotional materials may be sent to you by postal mail, e-mail or other means. We may also use your personal information for “Operational Uses,” such as to complete transactions requested by you (for example, your purchase of our services) or to send you administrative communications. Finally, Company may take your personally identifiable information that is associated with other information about you (i.e. demographic information including age, sex, etc.) and make it non-personally identifiable (“non-identifiable”) by removing all personally identifiable characteristics, such as your name and e-mail address.

At times, Company may engage or otherwise contract with companies to help deliver products or services that you request from Company. Examples of these companies may include packaging, printing, mailing or delivery companies. In these instances, there may be a need to share your information with these companies to fulfill your requests. Unless stated otherwise, these companies are allowed to gather, receive and use your information only for the purposes described in this paragraph or as required by law.

Company may contract with a third party to help manage and optimize our Internet business and communications. Website tracking services help websites to measure the effectiveness of advertising and how visitors use awebsite through the use of web beacons and cookies provided by such company. The type of information we may collect includes, but is not limited to, the pages visited and links clicked by users. By supplementing our records, this information would help us to learn things such as what pages are most useful and attractive to our visitors and which of our tools and information most interest our visitors. Although the third party company would log the information coming from our website on our behalf, we would control how that data may and may not be used.

Company will disclose personal information when it believes in good faith that such disclosures (a) are required by law, such as to comply with a court order or subpoena; or (b) will help to enforce any of our Terms of Use, protect your safety or security, including the safety and security of property that belongs to you, and/or protect the safety and security of our website, or the Company, and/or third parties, including the safety and security of property that belongs to professional entities rendering services related to Company’s websiteor third parties.

What choices do you have about the collection and use of your personally identifiable information?

With regard to personal information that you have provided under this Privacy Policy, you may exercise your opt-out choices available to you (if any and where applicable)by contacting us directly as described below.

Please keep in mind that any opt-out choices you make will not apply in situations where: (a) you either have made, simultaneously make or later make a specific request for information from Company’s website; (b) Company uses your personal information for “Operational Uses” (as described above);or (c) Company collects your personally identifiable information under any of the provisions above.

If you do not exercise your opt-out choices upon sign up/registration or initial log-in at our website, it may take up to ninety (90) days for your opt-out choices to be fully effective. Our systems may require time to update, and promotional mailings, by e-mail or otherwise, using personal information shared before your opt-out may already be in process. Thus, you might continue to receive promotional materials from Company based upon the personal information you have provided under this Privacy Policy for up to ninety (90) days.

What kinds of security measures do we take to safeguard your personally identifiable information?

The security and confidentiality of your information is of utmost importance to us. We have implemented technical, administrative and physical security measures to protect user information from unauthorized access and improper use. For example, we limit access to personal information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs. From time to time, we review our security procedures in order to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.

Children

We are committed to protecting the privacy of children. The Company website is not designed or intended to attract children under the age of 18. Company does not collect personal information from any person we actually know is under the age of 18. The parent or guardian is solely responsible for providing supervision of the minor’s use of Company and its website. The parent or guardian assumes full responsibility for ensuring that any registration information is kept secure and that the information submitted is accurate. The parent or guardian also assumes full responsibility for the interpretation and use of any information or suggestions provided through Company or its website for the minor.

How can you ask questions or send comments to us about this Privacy Policy?

If you have any questions or wish to send us comments about this Privacy Policy, you can e-mail us directly at customersupport@upstateVIPmedicine.com. You can also write to us at the following address:

Attn: Customer Support
Upstate VIP Medicine
5 South Side Dr., Ste. 11-164
Clifton Park, NY 12065
How will you know if we amend this Privacy Policy?

We may amend this Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will notify you by prominently posting notice of the changes on the website covered by this Privacy Policy. Please note that, at all times, you are responsible for updating your personal information to provide us with your current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any other reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. In any event, changes to this Privacy Policy may affect our use of personal information that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your information, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us.

Information for California Residents

California residents have the right to request in writing from businesses with whom they have an established business relationship (1) a list of the categories of personal information, such as name, address, e-mail address and the type of services provided to that customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. Though we do not share information with third parties for their direct marketing purposes unless you first affirmatively agree to such disclosure, you can request information by writing to us at:

Attn: Customer Service
Upstate VIP Medicine
5 South Side Dr., Ste. 11-164
Clifton Park, NY 12065

We will respond to such written requests within thirty (30) days following receipt at the mailing address above. We reserve the right not to respond to requests submitted other than to the address specified above or as otherwise exempted by law.

We do not maintain a process for an individual to review and/or request changes to his or her personally identifiable information that is collected through Company.

United Concierge Management’s Commitment to Your Protected Health Information

United Concierge Management is dedicated to maintaining the privacy of your protected health information (‘PHI’). PHI is information about you that may be used to identify you (such as your name, social security number or address), and that relates to (a) your past, present or future physical or mental health or condition, (b) the provision of health care to you, or (c) your past, present, or future payment for the provision of health care. In conducting its business, United Concierge Management will receive and create records containing your PHI. United Concierge Management is required by law to maintain the privacy of your PHI and to provide you with notice of its legal duties and privacy practices with respect to your PHI.

United Concierge Management must abide by the terms of this Notice while it is in effect. This current Notice takes effect on June 1, 2014, and will remain in effect until United Concierge Management replaces it. United Concierge Management reserves the right to change the terms of this Notice at any time, as long as the changes are in compliance with applicable law. If United Concierge Management changes the terms of this Notice, the new terms will apply to all PHI that it maintains, including PHI that was created or received before such changes were made. If United Concierge Management changes this Notice, it will post the new Notice on its Web site and will make the new Notice available upon request.

Uses and Disclosures of PHI

United Concierge Management may use and disclose your PHI in the following ways:

  1. Treatment, Payment and Health Care Operations. United Concierge Management is permitted to use and disclose your PHI for purposes of (a) treatment, (b) payment and (c) health care operations. For example:
    • Treatment. United Concierge Management may disclose your PHI to another physician or health care provider for purposes of a consult or in connection with the provision of follow-up treatment.
    • Payment. United Concierge Management may use and disclose your PHI to your health insurer or health plan in connection with the processing and payment of claims and other charges.
    • Health Care Operations. United Concierge Management may use and disclose your PHI in connection with its health care operations, such as providing customer services and conducting quality review assessments. United Concierge Management may engage third parties to provide various services for United Concierge Management. If any such third party must have access to your PHI in order to perform its services, United Concierge Management will require that third party to enter an agreement that binds the third party to the use and disclosure restrictions outlined in this Notice.
  2. Authorization. United Concierge Management is permitted to use and disclose your PHI upon your written authorization, to the extent such use or disclosure is consistent with your authorization. You may revoke any such authorization at any time.
  3. As Required by Law. United Concierge Management may use and disclose your PHI to the extent required by law.
Special Circumstances

The following categories describe unique circumstances in which United Concierge Management may use or disclose your PHI:

  1. Public Health Activities. United Concierge Management may disclose your PHI to public health authorities or other governmental authorities for purposes including preventing and controlling disease, reporting child abuse or neglect, reporting domestic violence and reporting to the Food and Drug Administration regarding the quality, safety and effectiveness of a regulated product or activity. United Concierge Management may, in certain circumstances disclose PHI to persons who have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition.
  2. Workers’ Compensation. United Concierge Management may disclose your PHI as authorized by, and to the extent necessary to comply with, workers’ compensation programs and other similar programs relating to work-related illnesses or injuries.
  3. Health Oversight Activities. United Concierge Management may disclose your PHI to a health oversight agency for authorized activities such as audits, investigations, inspections, licensing and disciplinary actions relating to the health care system or government benefit programs.
  4. Judicial and Administrative Proceedings. United Concierge Management may disclose your PHI, in certain circumstances, as permitted by applicable law, in response to an order from a court or administrative agency, or in response to a subpoena or discovery request.
  5. Law Enforcement. United Concierge Management may, under certain circumstances, disclose your PHI to a law enforcement official, such as for purposes of identifying or locating a suspect, fugitive, material witness or missing person.
  6. Decedents. United Concierge Management may, under certain circumstances, disclose PHI to coroners, medical examiners and funeral directors for purposes such as identification, determining the cause of death and fulfilling duties relating to decedents.
  7. Organ Procurement. United Concierge Management may, under certain circumstances, use or disclose PHI for the purposes of organ donation and transplantation.
  8. Research. United Concierge Management may, under certain circumstances, use or disclose PHI that is necessary for research purposes.
  9. Threat to Health or Safety. United Concierge Management may, under certain circumstances, use or disclose PHI if necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public.
  10. Specialized Government Functions. United Concierge Management, may in certain situations, use and disclose PHI of persons who are, or were, in the Armed Forces for purposes such as ensuring proper execution of a military mission or determining entitlement to benefits. United Concierge Management may also disclose PHI to federal officials for intelligence and national security purposes.
Your Rights Regarding Your PHI

You have the following rights regarding the PHI maintained by United Concierge Management:

  1. Confidential Communication. You have the right to receive confidential communications of your PHI. You may request that United Concierge Management communicate with you through alternate means or at an alternate location, and United Concierge Management will accommodate your reasonable requests. You must submit your request in writing to United Concierge Management.
  2. Restrictions. You have the right to request restrictions on certain uses and disclosures of PHI for treatment, payment or health care operations. You also have the right to request that United Concierge Management restrict its disclosures of PHI to only certain individuals involved in your care or the payment of your care. You must submit your request in writing to United Concierge Management. United Concierge Management is not required to comply with your request. However, if United Concierge Management agrees to comply with your request, it will be bound by such agreement, except when otherwise required by law or in the event of an emergency.
  3. Inspection and Copies. You have the right to inspect and copy your PHI. You must submit your request in writing to United Concierge Management. United Concierge Management may impose a fee for the costs of copying, mailing, labor and supplies associated with your request. United Concierge Management may deny your request to inspect and/or copy your PHI in certain limited circumstances. If that occurs, United Concierge Management will inform you of the reason for the denial, and you may request a review of the denial.
  4. Amendment. You have a right to request that United Concierge Management amend your PHI if you believe it is incorrect or incomplete, and you may request an amendment for as long as the information is maintained by United Concierge Management. You must submit your request in writing to United Concierge Management and provide a reason to support the requested amendment. United Concierge Management may, under certain circumstances, deny your request by sending you a written notice of denial. If United Concierge Management denies your request, you will be permitted to submit a statement of disagreement for inclusion in your records.
  5. Accounting of Disclosures. You have a right to receive an accounting of all disclosures United Concierge Management has made of your PHI. However, that right does not include disclosures made for treatment, payment or health care operations, disclosures made to you about your treatment, disclosures made pursuant to an authorization, and certain other disclosures. You must submit your request in writing to United Concierge Management and you must specify the time period involved (which must be for a period of time less than six years from the date of the disclosure). Your first accounting will be free of charge. However, United Concierge Management may charge you for the costs involved in fulfilling any additional request made within a period of 12 months. United Concierge Management will inform you of such costs in advance, so that you may withdraw or modify your request to save costs.
  6. Breach Notification. You have the right to be notified in the event that United Concierge Management (or a United Concierge Management Business Associate) discovers a breach of unsecured PHI.
  7. Paper Copy. You have the right to obtain a paper copy of this Notice from United Concierge Management at any time upon request. To obtain a paper copy of this notice, please contact United Concierge Management by calling 1.800.United Concierge Management.
  8. Complaint. You may complain to United Concierge Management and to the Secretary of the Department of Health and Human Services if you believe that your privacy rights have been violated. To file a complaint with United Concierge Management, you must submit a statement in writing to United Concierge Management 5 Southside Drive, Suite 11-164, Clifton Park, NY 12065. United Concierge Management will not retaliate against you for filing a complaint.

Further Information. If you would like more information about your privacy rights, please contact United Concierge Management by calling To the extent you are required to send a written request to United Concierge Management to exercise any right described in this Notice, you must submit your request to United Concierge Management at 5 Southside Drive, Suite 11-164, Clifton Park, NY 12065.

Special Note to International Users

This website is hosted in the United States and is intended for and directed to users in the United States. If you are a user accessing the website from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use and/or disclosure, that differ from United States laws or regulations, please be advised that through your continued use of this website, which is governed by U.S. law and regulation, this Privacy Policy, and our Terms of Use, you are transferring your personal information to the United States and you consent to that transfer.

Revised: September 11, 2014
4827-4410-5244, v. 2

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