Privacy Policy

Privacy Policy for Web Portal of PEL/VIP

Last updated: August 18th, 2016

This Privacy Policy describes the privacy policy of PEL/VIP and its Web Portal for the Outcome Management Program (the “Web Portal”). PEL/VIP means Pulmonary Exchange, Inc., an Illinois corporation, its shareholders, officers, agents, employees, successors, and assigns (referred to hereafter as “we” or “us” or “PEL/VIP”). By accessing or otherwise using the Web Portal or by agreeing to the PEL/VIP Outcome Management Program License Agreement (“Outcome Management License”), you agree to the terms and conditions of this Privacy Policy. If you do not agree, to the terms of this Privacy Policy, exit this page and do not access or use the Web Portal
Types of Information about Users Gathered by PEL/VIP
The information we gather through this Web Portal enables us to provide you with the services you seek and helps us to personalize and continually improve our service to you. Here are the types of information we gather:
· Information You Give Us: We receive, analyze, and may store any information you enter on the Web Portal or provide us in any way. For example, you provide us with information when you agree to the Outcome Management License, log into the Web Portal, answer the questions in the online outcome tracking forms, or interact with the Web Portal in other ways. We will ask you to input certain resident health information and may ask you to input information that identifiers caregivers
· Automatic Information: We receive, analyze, and store certain types of information whenever you interact with the Web Portal. For example, we may collect the Internet Protocol (IP) address used to connect your computer to the Internet; your login information; information about your browser and operating system; the Uniform Resource Locators (URLs) of the websites you visit before and after our Web Portal; and information about how you move around our Web Portal. We may place cookies and other anonymous identifiers on your computer to prevent fraud, to personalize your experience on our Web Portal, and to collect and store this information so that we can improve our services. A cookie is a small piece of information that a website can send to your browser and may then be stored on your computer’s hard drive. An anonymous identifier is a random string of characters that is used for the same purposes as a cookie on platforms where cookie technology is not available. You may be able to block, delete, or disable cookies, but doing so may prevent you from using some or all of the Web Portal services.
· Information from Other Sources: We may combine information you provide us with information from other PEL/VIP customers in order to provide aggregate comparisons or to enhance our services. If Facility and other specific PEL/VIP customers request in writing that PEL/VIP identify their data for each other as part of a benchmark program, PEL/VIP may then provide specific comparison performance data.

How PEL/VIP Shares the Information It Receives
Information that you enter is a critical part of our business. We will not sell that information to others, but we may share user information with others in the following ways:
· With Authorized Third Party Service Providers: We employ other companies and individuals to perform functions on our behalf, such as analyzing data, providing marketing assistance, and operating or hosting our Web Portal, and we may share the information you provide us with these parties. We encourage our Third Party Service Providers to adopt and post privacy policies, and the use by such parties of the information you enter is subject to their privacy policies and is not subject to our control.
· Through Google Docs/Drive: You will be entering information through the Google Docs platform; therefore, Google may have access to and store the information you provide subject to Google’s Privacy Policy
· With Other PEL/VIP Customers: We may provide our customers with aggregate information from other customers, including you, to make comparisons in order to improve services. This comparison information is provided in the aggregate and does not identify individual residents, caregivers, or facilities. If Facility and other specific PEL/VIP customers request in writing that PEL/VIP identify their data for each other as part of a benchmark program, PEL/VIP may then provide specific comparison performance data that identifies the facilities that have approved such comparisons.
· To Parent or Affiliated Companies: While we currently do not have a parent company, subsidiaries, or any other companies under a common control, we may in the future, and we may share the information you provide to us with these companies, in which case we will require them to honor this Privacy Policy.
· In a Change of Ownership: As we continue to develop our business, we might merge with or be acquired by another company. If this happens, the successor company could acquire the information we maintain, but the information you provide to us would remain subject to this Privacy Policy.
· For PEL/VIP’s Protection or the Protection of Others: We may disclose the information you provide to us if we believe in good faith that such disclosure is necessary to comply with the law or a court order; enforce our Outcome Management License with you; or protect the rights, property, or safety of PEL/VIP, our customers, or others.

Security of Your Information
When PEL/VIP collects and stores the information you provide to us, as outlined above, we use tools such as encryption, passwords, and physical security to protect that information against unauthorized access and disclosure. When you provide us with personally identifiable information, however, you acknowledge that, even with industry standard security measures in place, third parties might unlawfully intercept or access transmissions or private communications. To protect the security of your personally identifiable information during transmission, we use Secure Sockets Layer (SSL) software, which encrypts this information. It is also important for you to protect against unauthorized access to both your password and your computer and to sign off when you finish using a shared computer. To the extent that PEL/VIP may be considered a “covered entity” under the Health Insurance Portability and Accountability Act (HIPAA), PEL/VIP agrees to comply with all applicable HIPAA provisions.

Managing Your Information
You have options for managing the information you enter on the Web Portal:
· You can restrict your employees or representatives to whom you provide the username and password to access the Web Portal.
· If the security of the PEL/VIP username or password is compromised, you must promptly notify PEL/VIP to obtain a new username and password.
· If you no longer want to use the PEL/VIP Web Portal, you may cancel your Outcome Management License pursuant to the terms of that agreement. The information you entered may remain in our historical records, but it will no longer be accessible to you and may be shared with others only in aggregate form, as provided above.

Updates to Privacy Policy
We may update or change this Privacy Policy from time to time by posting the revised Privacy Policy on the Web Portal. We will also send notice of an update or change to your email address on file with us. It is your responsbility to ensure that we have your current email address. The revised Privacy Policy is effective immediately upon posting. You agree to be bound by any such revisions. You should periodically visit this page to determine the current terms of our Privacy Policy.

Dispute Resolution
You agree that this Privacy Policy shall be interpreted under the laws of the State of Illinois without reference to its conflict of laws provisions. You agree that, as to any dispute arising out of or related to this Privacy Policy, the parties shall submit such dispute to an impartial mediator located in Cook County, Illinois, for resolution. If the parties are unable to resolve the dispute by mediation, then the parties may bring an action in a court located in Cook County, Illinois or, if a federal action, in the Northern District of Illinois. You hereby consent and agree to submit to the jurisdiction of and venue in such courts and waive any argument of forum non conveniens.

Contacting Us
You may contact us at any time about this Privacy Policy by