This policy was revised on June 27, 2014.
WHAT INFORMATION PMD COLLECTS AND HOW IT COLLECTS IT
Generally. When you use the Services, we collect different information:
- Directly from you (through email, web inquiry forms, the pMD Secure Messaging application (the App), or off-line or telephonic correspondence between us) to set up an account for pMD Secure Messaging, to complete your account profile, and to enable us to assist you in questions you have about the Services, and
- Indirectly through your use of the Services, which allows us to provide, administer, and improve upon features and functions of the Services.
Personal Information you provide us directly through the Services. When you sign up to use pMD Secure Messaging, we ask for the following types of personal information:
- legal name,
- email address,
- mobile telephone number, and
- National Provider Identifier number (if applicable)
All of this information is used to set up your pMD Secure Messaging account. From time to time we may ask you to provide voluntarily other information and you may decide to add information in your pMD Secure Messaging profile or account information, which may be accessible to other users of pMD Secure Messaging based on permissions you set. You may also provide us information by completing web forms and by communicating with us through email or off-line means. All of this information that is defined as “personal“ or “personally identifiable information” under an applicable law is referred to as Personal Information. You can always decide not to provide us any Personal Information; however, certain Personal Information is required by us to provide you the features and functions of pMD Secure Messaging. If you opt to not provide this information, we may not be able to provide you pMD Secure Messaging or certain features of the service.
We may also access and use – but only with your explicit permission -- your contact list or address book information to allow us to identify registered users of pMD Secure Messaging.
Finally, we may ask you to verify your interests in our organization or our service and product offerings by providing your email address and responses to other questions. We do this so that we may tailor future updates and responses to you. At any time you have the option to "opt out" and be removed from this source by sending an email to firstname.lastname@example.org.
Information we collect as you use the Services. When you download the App, or use pMD Secure Messaging through the App or the Site, certain technical information is collected or verified. This includes:
- information on the type and model of the device (phone or personal computer) you are using to access the service,
- the operating system of the device (e.g., iOS, Android, Windows, OS X),
- the browser used to access pMD Secure Messaging through the Site, and
- other unique device and message identifiers (such as push token pins or UDID device identifiers, among others).
All of this information (Usage Data) is collected and used by us to associate messages sent by specific users, to route messages transmitted to and from you securely and accurately, to enable us to understand errors that users may experience with pMD Secure Messaging, and to improve upon pMD Secure Messaging. Usage Data may also include metadata and other information associated with other files stored on your mobile or computer device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
Neither the App nor the Site collects information about the real-time location of your device.
If you do not want pMD to collect and store Usage Data, do not download the App or delete it from your device and stop using the Services.
When you send or receive messages using pMD Secure Messaging, we collect, process, and store the text of the message and the content of any attachments included in the message (the Secure Message Data), date and time log files, sender and receiver identifiers, read receipts, message transmittal success, and failure information (the Other Message Data). The Secure Message Data is transmitted to the receiving Secure Message Service user through an HTTPS web connection and a copy of the Message Data is stored on dedicated servers within our Secure Message Service system in encrypted form. At the same time that the Secure Message Data is being communicated, the service will also send to the receiving user a notification alerting the user that a secure message has been received and can be retrieved by accessing the user's account throughout the web or the mobile application. This notification is transmitted through other, generally non-secure channels, such as the push notification frameworks of Apple (for iPhone®) and Google (Android™) mobile phones or a mobile operator SMS text message service. Both Secure Message Data and Other Message Data will reside on our servers indefinitely until deleted by us in the ordinary course of erasure and deletion of Services records and information. But see below for HOW WE PROTECT YOUR INFORMATION.
When you visit or browse the Site, we collect certain information relating to your use of the Services including :
- the type of web browser you use,
- the operating system of your computer,
- your IP address,
- your Internet services provider,
- the pages you view,
- when and for how long you visit the Site, and
- log files that identify when the site does not work properly.
We use this information, which is not personally identifiable, to administer the Services, troubleshoot user problems, and to optimize and improve the Services.
- to track unique visitors and help us understand who visits our Site and which pages they were visiting through the use of technology provided by Google Analytics™; and
- to identify you as a registered user of the web-based pMD Secure Messaging and automatically expand the "Login" button to show username and password text input boxes, as a shortcut for registered users.
- to recognize you as being logged in as a registered user of the Secure Messaging Service.
At present, we have not established the means to honor a request to “Do Not Track” as a privacy preference. Therefore, if you do not set your privacy preference to block the cookies from our Site, but request that we Do Not Track, the non-personally identifiable information about your use of the Site will be collected and used, and the cookie that identifies you as a registered user will be retained on your mobile phone or computer web browser (although, it is not stored on our servers).
HOW WE USE THE INFORMATION
We use information that we collect about you or that you provide to us, including Personal Data, to:
- provide you with the Services and any other information, products, or services that you request from us or that you might be interested in, including sending you information through the Secure Messaging Service,
- fulfill any other purpose for which you provide it,
- give you notices about your account,
- carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection, and
- notify you when App updates are available, and of changes to any products or services we offer or provide through it.
For more information, see YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION.
The Usage Data we collect enables us to deliver the features and functions and helps us to improve our pMD Secure Messaging by enabling us to:
- route messages transmitted to and from you securely and accurately,
- enable us to understand errors that users may experience with the Securing Messaging Service and improve upon pMD Secure Messaging, and
- recognize you when you use pMD Secure Messaging through the App or the web.
HOW WE SHARE AND DISCLOSE THE INFORMATION
We may disclose aggregated information about our users and information that does not identify any individual or device without restriction.
We do not disclose any Personal Data or Usage Data, except
- 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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about users of our Services is among the assets transferred
- to fulfill the request you made when you provided the information
- for any other purpose disclosed by us when you provide the information
- with your consent
- to comply with any court order, law or legal process, including to respond to any government or regulatory request
- to enforce our rights arising from any contracts entered into between us, including the App, Site, or any Service terms of service, and for billing and collection, and
- if we believe in good faith that disclosure is necessary or appropriate to protect the rights, property, or safety of pMD, our customers, or others
We do not disclose any Secure Message Data or any Non-sensitive Message Data to any third party, other than if compelled to do so by court order, law or legal process, and to respond to any government or regulatory request in accordance with law.
YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
Noting your preferences. You will always have a choice about the Personal Data you provide to us and the other information that we collect from you and from your use of the Services. If you do not want us to contact you to promote our own products or services using the email address and other contact information you provide to us, you can opt out by emailing us at email@example.com.
Accessing, Correcting or Deleting Your Personal Data. You can review and change your personal information by logging into the App and reviewing your profile or visiting your account profile page through pMD Secure Messaging web page. You may also send us an email at firstname.lastname@example.org to request information on or correct any Personal Data that you have provided to us. We will honor all requests unless we believe such a change will violate any law or legal requirement or cause the information to be incorrect. You may ask us to delete your Personal Data, but we can only do so by closing your pMD Secure Messaging account; we will retain in our archives but will not access or use your Personal Data except to enforce our rights arising from any contracts entered into between us and for legal compliance purposes.
Specific California Privacy Rights. California law allows residents to request information identifying the categories of Personal Information that we share with third parties for marketing purposes. If you are a California resident, and you would like to request this information, please send us an e-mail at email@example.com.
SPECIAL INFORMATION TO PERSONS RESIDING OUTSIDE THE UNITED STATES
The Services are hosted in the United States and are intended for users in the United States. If you reside outside of the United States, your Personal Data and Secure Message Data will be transferred to, and processed and stored in, the United States. By using the Services, you agree to the collection, use, transfer, and disclosure of your Personal Data and all message data and communications will be governed by United States laws.
HOW WE PROTECT YOUR INFORMATION
In order to provide pMD Secure Messaging, we have designed and built the App, pMD Secure Messaging web page, and the computing and storage infrastructure that supports pMD Secure Messaging to provide a secure environment for the transmission and storage of your Personal Data and Secure Message Data and to minimize the risk that any such data would be subject to accidental loss or unauthorized access, use, alteration, and disclosure. The service uses encryption for local and datacenter storage and SSL/TLS encrypted data streams for securing the transmission of the Secure Message Data.
The App and pMD Secure Messaging web login page are both protected by a username and password authentication protocol. It is up to you to secure access to your account by not sharing or disclosing your authentication information. The safety and security of your information therefore also depends on you.
You understand that the Internet is inherently insecure and therefore the secured nature of your communications on the Service cannot be guaranteed. Despite the security mechanisms (such as encryption technologies) that we have implemented to protect the Secure Message Data you send and receive through pMD Secure Messaging, it is still possible that messages could be intercepted or read without permission by another person. Although we do our best to protect your information, we cannot guarantee the security of your information transmitted through our App. Any transmission of Secure Message Data or Personal Data is at your own risk.
Last modified: July 24, 2014