Critical Health Systems Privacy Policy

Critical Health Systems, Inc. "Critical Health Systems" respects your personal privacy and is committed to adhering to federal and state privacy laws and industry guidelines in order to protect you and your identity. This privacy policy ("Privacy Policy") describes how we handle the personal information that you provide to us on the Critical Health Systems web site (the "Web Site"). This Privacy Policy applies only to this Web Site, not to any other third party sites that may be accessible from here or any other web site operated by Critical Health Systems.

After reading this Privacy Policy, which is incorporated into and is a part of this Web Site's terms and conditions, you will know:

1. what information Critical Health Systems collects from you;
2. how Critical Health Systems uses your information;
3. what choices you have about how Critical Health Systems treats your information;
4. how Critical Health Systems protects your privacy;
5. Critical Health Systems' HIPAA Privacy Policy;
6. what Critical Health Systems does about children visiting this Web Site;
7. how you can contact Critical Health Systems.

Please be sure to read this Privacy Policy before using this Web Site or submitting information to us. Our Privacy Policy may change from time to time and your continued use of this Web Site is acceptance of such changes, so please check this area periodically for updates to this Privacy Policy.

1. INFORMATION CRITICAL HEALTH SYSTEMS COLLECTS FROM YOU

Active Information Collection
Like many other web sites, we actively collect information from our visitors both by asking specific questions on this Web Site and by permitting you to communicate directly with us via e-mail. Some of the information that you submit may be personally identifiable (that is, information that can be uniquely identified with you, such as your name, address, e-mail address, phone number, etc.). Remember, if you send us an e-mail message, you provide us with your e-mail address.

Passive Information Collection
As you navigate through a web site, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as navigational data collection. Like most web site operators, we track IP addresses, use both session and persistent cookies, and assign Internet tags. Our system also automatically gathers information about the areas you visit on this Web Site and collects operational information about the technology you use, such as your browser, type of computer, operating systems, and Internet service providers.

We passively collect information to understand what areas of this Web Site are most popular, which areas may require improvement, and what technologies are being used by our visitors. This information helps us to update and improve this Web Site. We also use this information for security purposes, to detect and to block security breaches and to provide you with a safe online environment.

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2. HOW CRITICAL HEALTH SYSTEMS USES YOUR INFORMATION

Critical Health Systems uses your personal information to provide you with requested information, enhance the operation of this Web Site and allow you to use all of its features. Critical Health Systems may contact you about new features or products in which it believes you may be interested. Critical Health Systems may provide aggregate statistics about users of our Web Site, online traffic patterns and related information to reputable third parties, but these statistics will not include any personally identifying information. Critical Health Systems also will disclose any information that it is required to disclose by law or by an appropriate government authority.

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3. CHOICES YOU HAVE ABOUT HOW CRITICAL HEALTH SYSTEMS USES YOUR INFORMATION

We strive to provide you with as many choices and as much control as possible regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

You may also send us an e-mail message at webmaster@criticalhealthsystems.com, to request access to, correct, or delete any personal information that you have provided to us. You may also opt out of receiving marketing messages from Critical Health Systems by notifying us at webmaster@criticalhealthsystems.com.

If you do not wish us to collect cookies, you may set your browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of this Web Site may then be inaccessible or not function properly.

You should review this Privacy Policy carefully, because if you do not agree with our practices, your ultimate choice is not to use this Web Site. Remember, by using any part of this Web Site, you accept and agree to our privacy practices. If we update this Privacy Policy, your continued use of this Web Site (following the posting of the revised Privacy Policy) means that you accept and agree to the terms of the revised Privacy Policy.

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4. HOW CRITICAL HEALTH SYSTEMS PROTECTS YOUR INFORMATION

We work hard to protect your personal information. We use both technical and procedural methods to maintain the integrity and security of our databases, including firewalls and restricted access to data.

This Web Site contains links to other web sites operated by third parties that may be of interest to you. We cannot control these third party sites, which may collect personal information from you. When you follow a link and leave this Web Site, you do so at your own risk.

For information on the confidentiality of protected health information, please see our HIPAA Privacy Policy below.

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5. CRITICAL HEALTH SYSTEMS' HIPAA PRIVACY POLICY

Although technically not a Covered Entity under the Health Insurance Portability and Accountability Act (HIPAA), it is the policy of our company that all employees and owners comply with the rules and regulations of the HIPAA to preserve the integrity and confidentiality of protected health information (PHI) pertaining to our clients’ patients.  The purpose of this policy is to ensure that our company has the necessary medical and PHI to provide a superior service while protecting the confidentiality of the PHI of our clients’ patients.  Our clients and their patients should not fear to provide information to us for purposes of payment and healthcare operations.  To that end, our company and its employees and owners will:

• Adhere to the standards set forth in our clients’ Notice of Privacy Practices.
• Collect, use and disclose PHI only in conformance with state and federal laws and current patient covenants and/or authorizations, as appropriate.  Our company will not use or disclose PHI for uses outside the scope of our agreements with our clients, such as marketing, employment, life insurance applications, etc. without an authorization from the client and/or the patient.
• Recognize that PHI collected about patients must be accurate, timely, complete and available when needed.  Our company and employees and owners will:
  • Implement reasonable measures to protect the integrity of all PHI maintained about patients on behalf of our clients

• Recognize that patients have a right to privacy.  Our company and our employees and owners respect the patient's individual dignity at all times.  Our company will respect patient's privacy to the extent consistent with providing a superior service to our clients.
• Act as responsible information stewards and treat all PHI as sensitive and confidential.  Consequently, our employees and owners will:
  • Treat all PHI data as confidential in accordance with professional ethics, accreditation standards, and legal requirements.
  • Not disclose PHI data unless the patient (or his or her authorized representative) has properly consented to or authorized the release or the release is otherwise authorized by law.

• Recognize that, although our company maintains copies of anesthesia and/or pain management records on behalf or our clients, and although the facility the client provides professional services in “owns” the complete medical record, the patient has a right to inspect and obtain a copy of his/her PHI maintained by us on behalf of the client.  In addition, patients have a right to request an amendment to his/her records if he/she believes his/her information is inaccurate or incomplete.  Our company and our employees and owners will:
  • Permit patients to access their records when the client approves their written requests.
  • The company will maintain a list of all disclosures of PHI for purposes other than TPO for each patient.  We will provide this list to patients upon request, so long as their requests are in writing.
  • All employees and owners of our company will adhere to any restrictions concerning the use or disclosure of PHI that patients have requested and have been approved by the client and communicated appropriately to us.
  • All employees and owners of our company will promptly and accurately report any violations of this Privacy Policy to their supervisor or the President/CEO.
  • All employees and owners of our company must adhere to this policy.  Our company will not tolerate violations of this policy.  Violation of this policy is grounds for disciplinary action, up to and including termination of employment in accordance with our company’s personnel rules and regulations, as well as possible civil or criminal legal penalties and/or professional sanctions.
  • Our company may change this Privacy Policy in the future.  Any changes will be effective upon the release of a revised Privacy Policy and will be made available upon request

6. WHAT CRITICAL HEALTH SYSTEMS DOES ABOUT CHILDREN VISITING THIS WEB SITE

This Web Site is not intended for children under the age of 13. We will not knowingly collect information from Web Site visitors in this age group. We encourage parents to talk to their children about their use of the Internet and the information they disclose online.

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7. HOW YOU CAN CONTACT CRITICAL HEALTH SYSTEMS

If you have any questions, comments, or concerns about this Privacy Policy or the information practices of this Web Site, please contact us at:

Critical Health Systems, Inc.
P.O. Box 18139
Raleigh, NC 27619
1-888-280-9533
webmaster@criticalhealthsystems.com

CH01/12262863.1

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