Effective Date: August 1, 2021
The University of North Carolina at Chapel Hill (“UNC,” “the Company.” “we,” “us,” or “our”) is committed to privacy and data protection. This Privacy Policy Applies to personal data UNC collects from you, through our interactions with you and through the CMM Patient Care Process Self-Assessment, the CMM Practice Management Assessment Tool, and the MTP Documentation Tool (the “App” or “Services”).
YOUR PRIVACY IS IMPORTANT TO US. PLEASE READ THIS PRIVACY POLICY TO LEARN ABOUT THE INFORMATION THAT UNC COLLECTS FROM YOU AND HOW UNC USES THAT INFORMATION.
BY USING THE SERVICES YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, THEN PLEASE DO NOT USE THE SERVICES.
This Privacy Policy does not Apply to any third-party Applications or software that integrate with our Services, or any other third-party products, Services or businesses (collectively, “Third Party Services”). Third Party Services are governed by their own privacy policies. We recommend you review the privacy policy governing any Third Party Services before using them.
This Privacy Policy does not apply to any service that does not display, reference, or link to this Privacy Policy.
This Privacy Policy is incorporated into and made a part of UNC’s Terms and Conditions. If you have not done so already, please also review the Terms and Conditions.
UNC collects data to provide the Services, ease your navigation on our Services, communicate with you, and improve your experience using the Services. Some of this information is provided by you directly, such as when you create an account to use the Services. Some of the information is collected through your interactions with our Services. We collect such data using technologies like cookies and other tracking technologies, error reports, and usage data collected when you interact with the Services.
The data we collect depends on the Services and features thereof that you use, and includes the following:
Name and contact data. We collect your first and last name; email address; name of clinic, healthcare organization, and/or pharmacy within which you work; and other similar contact data.
Credentials. We process passwords and related security information used for authentication and account access and information security purposes.
Health and Medical data. If you use the Services, we collect information regarding your patients’ health including but not limited to gender, medication names & dosages, medical conditions, disease state metrics (e.g., HgA1c, blood pressure readings), medication-related problems and recommended interventions, and other similar data. We will not collect patient-identifiable information such as name, date of birth, medical record number (MRN), address, phone, email address, or other similar data.
Usage data. We collect personalized information about your use of our Services, to better understand uses thereof and identify potential improvements, as well as to send you promotional communications or offers tailored to your use of our Services and interest thereto.
Examples include:
Location data. We collect your IP address and infer location such as city or postcode therefrom, when necessary in order to provide you with the Services or to send you promotional communications or for customer relationship management purposes.
Content. We may collect the content of messages you send to us, such as feedback or questions you ask our technical support representatives, when necessary to provide you with the Services you use. We will collect and utilize any data files you send to us for troubleshooting and improving our Services.
Surveys and Studies. Users of the Services will be asked to respond to periodic information requests via surveys or questionnaires as part of use of the Services. Participation is voluntary, and you have the choice of whether to disclose any requested information.
We will only use your personal data when the law allows us to. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
UNC uses information that we collect from customers and visitors for the purposes of:
Examples of the uses of information include:
Providing Services. We use data to provide Services to you. Often, this includes personal data such as email, name, and address. We may collect additional information when you register to use the Services, including contact information and credentials. We may use this data to identify and address problems and provide other support Services
Improving Product and Services. We use data to continually improve our Services, including adding new features or capabilities. Data is collected throughout your interactions with our Services that enable us to understand customer usage and tailor future capabilities.
We track general, non-personalized information (e.g., operating system, browser version and type of device being used) to know how many people visit specific pages of our Services or utilize specific areas of our Services so that we may improve those Services. We may use your IP address to customize Services to your location, such as the language displayed on our Services.
Please note that we use IP addresses on a restrictive basis to analyze trends, to administer the site, and to collect general information for aggregate use.
Service Communications. We use data we collect to deliver and personalize our communications with you. For example, we may contact you by email or other means to notify you of changes in information and updates to our Services or to our Privacy Policy.
It is the policy of UNC and its subsidiaries to protect users' information both online and off-line. Access to our users' information is restricted to only those employees or agents, contractors or subcontractors of UNC who have valid reasons to access this information to perform any service you have requested or authorized, or for any other purpose described in this Privacy Policy. The information you provide will not be sold or rented to third parties.
We may provide your personal data to:
UNC may share personal data if UNC is involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control (in whole or in part). UNC requires that the shared personal data remain subject to the promises made in the then-current Privacy Policy, unless and until you agree to a new privacy terms.
We will access, disclose and preserve personal data when we have a good faith belief that doing so is necessary to:
Please note that some of our Services may direct you to Services of third parties whose privacy practices differ from UNC’s. If you provide personal data to any of those Services, your data is governed by their privacy statements or policies. UNC and our subsidiaries are not responsible for the privacy practices of these other websites. Please review the privacy policies for these websites to understand how they process your information.
Security of Personal Data
UNC is committed to protecting the security of your personal data. Depending on the circumstances, we may hold your information in hard copy and/or electronic form. For each medium, we use technologies and procedures to protect personal data. We review our strategies and update as necessary to meet our business needs, changes in technology, and regulatory requirements.
These measures include, but are not limited to, technical and organizational security policies and procedures, security controls and employee training.
You are responsible for maintaining the security of your account credentials for the Services. UNC will treat access to the Services through your account credentials as authorized by you. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
If we become aware of a breach that affects the security of your personal data, we will provide you with notice as required by Applicable law. To the extent permitted by Applicable law, UNC will provide any such notice that UNC must provide to you at your account’s email address. By using the Services, you agree to accept notice electronically.
Storage and Transfer of Personal Data
Personal data collected by UNC may be stored and processed in your region, in the United States or in any other country where UNC, its affiliates or contractors maintain facilities. We take steps to ensure that the data we collect under this Privacy Policy is processed pursuant to the terms hereof and the requirements of Applicable law wherever the data is located.
UNC also collaborates with third parties such as cloud hosting Services and suppliers located around the world to serve the needs of our business, workforce, and customers. In some cases, we may need to disclose or transfer your personal data within UNC or to third parties in areas outside of your home country. When we do so, we take steps to ensure that personal data is processed, secured, and transferred according to Applicable law.
If you would like to know more about our data transfer practices, please contact us at [optimizingmeds@unc.edu].
Retention of Personal Data
UNC retains personal data for as long as necessary to provide the Services and fulfill the transactions you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We are required by law to keep some types of information for certain periods of time (e.g. statute of limitations). If your personal data is no longer necessary for the legal or business purposes for which it is processed, we will generally destroy or anonymize that information.
UNC respects your right to access and control your personal data. You have choices about the data we collect. When you are asked to provide personal data that is not necessary for the purposes of providing you with our Services, you may decline. However, if you choose not to provide data that is necessary to provide a Service, you may not have access to certain features of the Services.
If you use the App, you can stop all collection of information by the App by uninstalling it. You may use the standard uninstall processes available as part of your mobile device. You can stop collection of information by any of the other Services by ceasing to use such Services
We aim to keep all personal data that we hold accurate, complete and up-to-date. While we will use our best efforts to do so, we encourage you to tell us if you change your contact details. If you believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact us at optimizingmeds@unc.edu.
Access to personal data: In some jurisdictions, you have the right to request access to your personal data. In such cases where such laws apply to the data, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
If you are a corporate user of our Services (which means your employer is a UNC customer of such Services): please first request access to your personal data with your employer. Your employer will then be in touch with us with respect to your request.
Correction and deletion: In some jurisdictions, you may have the right to correct or amend your personal data if it is inaccurate or requires updating. You may also have the right to request deletion of your personal data. Please note that such a request could be refused because your personal data is required to provide you with the products or Services you requested, e.g. to deliver a product or send an invoice to your email address, or that it is required by the Applicable law.
California Shine the Light Law: California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to service@UNChealth.com or write us at: UNC Health LLC 224 N Euclid Ave STE 207, Pittsburgh, PA 15206
UNC uses cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies (“Cookies”) to provide our Services and help collect data. This Cookies Policy how we use Cookies to collect information about the way you use our Services, and how you can control them.
How We Use Cookies
We use Cookies to track how you use the Services by providing usage statistics. Cookies are also used to deliver UNC information (including updates) based upon your browsing history and previous visits to the Services. Information supplied to us using Cookies helps us to provide a better experience to our users.
We may combine the information we collect via Cookies with personal data that we have collected from you to learn more about how you use our Services to improve them.
Types of Cookies
We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on our Services can be grouped into the following categories:
Cookies Set by Third Party Services
To enhance our content and to deliver a better online experience for our users, we sometimes embed images and videos from other websites on the websites. We currently use, and may in future use content from websites such as Facebook, LinkedIn and Twitter. You may be presented with Cookies from these third-party websites. Please note that we do not control these Cookies. The privacy practices of these third parties will be governed by the parties’ own privacy statements or policies. We are not responsible for the security or privacy of any information collected by these third parties, using cookies or other means. You should consult and review the relevant third-party privacy statement or policy for information on how these cookies are used and how you can control them.
Other Similar Technologies
UNC web pages may use other technologies such as web beacons to help deliver cookies on our websites and count users who have visited those websites. We also may include web beacons in our promotional email messages or newsletters to determine whether you open and act on them as well as for statistical purposes.
In addition to standard cookies and web beacons, our Services can also use other similar technologies to store and read data files on your computer. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally.
How to Control and Delete Cookies
Cookies can be controlled, blocked or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific.
If you are using a mobile device to access our Services, you will need to refer to your instruction manual or other help/settings resource to find out how you can control cookies on your device.
Please note: If you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the Services may not operate properly, and you may not have access to certain features of the Services. UNC shall not be liable for any impossibility to use the Services or degraded functioning thereof, where such are caused by your settings and choices regarding cookies.
To learn more about cookies and web beacons, visit www.allaboutcookies.org.
Do Not Track: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including UNC, do not respond to DNT signals.
SERVICES ARE NOT INTENDED FOR CHILDREN
You must be at least the age of majority in your place of residence to use the Services. The Services are not directed to or intended for use by minors. Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act, if we learn that we received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to inform the child (or his or her parent or legal guardian) that he or she cannot use the Services.
California Minors: While the Services is not intended for anyone under the age of 18, if you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: optimizingmeds@unc.edu. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the Content or information. Removal of your content or information from the Services does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; any obligations we have under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.
We may update this Privacy Policy based upon evolving Laws, regulations and industry standards, or as we may make changes to our business including our Services. We will post changes to our Privacy Policy on this page and encourage you to review our Privacy Policy when you use our Services to stay informed. If we make changes that materially alter your privacy rights, UNC will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should discontinue your use of the Services. You may also request access and control of your personal data as outlined in the Your Rights Regarding Personal Data section of this Privacy Policy.
We understand that you may have questions or concerns about this Privacy Policy or our privacy practices or may wish to file a complaint. In such case, please contact us in one of the following ways:
Email: optimizingmeds@unc.edu
Phone: (919) 962-8210