Information from You

We collect information about you so we can continue to provide and improve our Services to you and other users of the Site.  The information collected directly by Capitol Bridge through the Site may include items such as your name, e-mail address, mailing address, phone number, facsimile number, business size, industry type, personal health and social information as well as other information that may or may not specifically identify you.  The information collected on the Site may be stored at servers, computers, or other media located in or outside the United States.

Information for Health Information Exchange

In some situations, Capitol Bridge serves as a health information exchange (“HIE”).  HIE applies when Capitol Bridge aggregates health information from multiple organizations to facilitate the sharing of the information across those organizations.  This exchange of data can improve the ability of our clients to provide services to you.  The information provided to Capitol Bridge for the purposes of an HIE may include your name and demographic information, your health information such as dates of service, medical conditions, and medical services provided, and information related to your eligibility for or receipt of social services that impact your health care.

Third-Party Sources

We may obtain personal and non-personal information about you from other third-party sources.  This information may be utilized, analyzed, and/or compared with information that we have collected from you or that you have submitted to the Site.  Such third parties may include but are not limited to our third-party partners and Google.  If Capitol Bridge obtains information from third-party sources, Capitol Bridge takes commercially reasonable measures to ensure the third parties lawfully obtained and provided the information to us.  If the third parties unlawfully obtained and/or provided the information to us despite our reasonable measures to ensure the third parties complied with all legal requirements in obtaining and providing the information to us, you understand, agree, and acknowledge that your sole legal remedy is against the third party that engaged in the unlawful activity and that you will not assert any cause of action, claim or demand against us.

Information Collection Technology (Web Beacons and Cookies)

We may use various technologies to collect information from your electronic device about your activities on the Site.  We may collect and store non-personally identifying information through cookies, log files, clear gifs (commonly known as “web beacons”), and third parties to profile user activity and preferences.  Technical and specification information about your browser and computer is automatically collected when you use or visit the Site.  This information may include but not be limited to your Internet Protocol (“IP”) address, your browser type, operating system, geographic location, access time(s), the content of previously accepted “cookies” from us, and the website address that referred you to the Site.

A cookie is data stored on your computer that tracks non-personal information about you.  When you use the Site, we may assign your computer one or more cookies that enable us to improve the quality of the Services and to personalize your experience.  Cookies allow us to automatically collect information about your activity on the Site, such as the content you access while on the Site, the links you click, and other activity you conduct while using the Site.  You may choose to modify your web browser’s setting to disable cookies or limit their use.  If you choose to disable or limit cookies, you are still able to access the Site, but you may be unable to use all of the features on the Site.  Additional information about cookies may be found at: https://support.microsoft.com/en-us/help/260971/description-of-cookies.

The Site may contain web beacons (also known as “clear gifs”) or similar technologies that gather non-personally identifiable information about your use of the Site.  Such technology may also be contained in e-mail messages or newsletters from us that allow us to determine whether messages have been accessed.  The purpose of our use of this technology is so that we may analyze the effectiveness of our marketing efforts, the quality of the Site, and the Services we provide.

Personal Information About Users Under 18 Years of Age Not Collected

The Site is meant for adults and those who have reached the age of majority as defined by the laws of their domicile.  The Site is not meant for individuals under the age of eighteen (18) or those defined by the laws of their domicile as minors.  Nonetheless, this Privacy Policy is still designed to comply with the Children’s Online Privacy Protection Act (“COPPA”) to the extent COPPA applies.  Accordingly, we do not knowingly collect or retain any personal information about users under the age of thirteen (13).  If we obtain actual knowledge that we collected or retained personal information about a child under the age of thirteen (13), that information will be promptly deleted from our database, servers, and all other media.  Since we do not collect information from users under 13 years old, no such information is disclosed to third parties.

If parents or guardians wish to create an account for, and provide information related to, their child who is under the age of eighteen (18), the parent or guardian may do so, but assumes full responsibility for ensuring that the information is kept secure and that the information submitted is accurate.  In creating such an account, the parent or guardian accepts that this Privacy Policy will apply to the minor child’s information.

Information Others May Collect

To enhance security and promote operational efficiency, the Site utilizes the resources of reputable hosting facilities that are controlled by third parties.  Capitol Bridge is unable to provide any guarantees or warranties about these third parties’ retention or usage of your information.

Information Use and Sharing

We may use and share your information for any legally permissible purpose.  We may match, use, and share any of the information we collect from you to any personally identifiable information we obtain from clients or third parties.  Examples of some ways we may use or share information that we collect about you include:

• providing you with products or services;

• providing products or services to our clients;

• providing you with customized content and services;

• providing customer support;

• communicating with you by e-mail, United States mail, telephone, text message, and/or mobile devices about products or services that may be of interest to you either from us, or from any of our affiliates, sponsors or other third parties;

• compliance with applicable law;

• working with our advertising partners;

• enforcing the TOCs or our other terms and conditions, or otherwise managing our business;

• performing functions as otherwise described to you at the time of payment collection;

• internal record keeping;

• to contact you, a family member, or caregiver;

• for referrals for treatment, care coordination, and case management;

• for qualification for benefits; and

• for payment of services.

In order to perform certain services on your behalf, we may publish certain information that you provide.  You agree that any testimonial feedback or other comments provided by you to Capitol Bridge becomes the sole and exclusive property of Capitol Bridge and that such information may be used by Capitol Bridge for any legally permissible purpose, including but not limited to marketing and advertising its services and products.

You acknowledge and agree that Capitol Bridge may use and disclose your personal and non-personal information to public or private third parties: (i) to provide products or services to you or our clients; (ii) to comply with requests for inspection by law enforcement officials (including potential criminal activity); (iii) to respond to cease and desist letters, arbitration proceedings, legal actions and suits, criminal and civil subpoenas, or any court orders; (iv) to enforce or apply the terms of this Privacy Policy or any other agreement between us, including the Terms of Use; and (v) to protect our rights, property, or safety, as well as the rights, property, or safety of our users, or others, whether during or after the term of your use of the Site or any Services.

Personal Health Information Sharing and Exchange

We may use or disclose your personal health information to provide services to you and our clients, consistent with the applicable client’s Notice of Privacy Practices, the Health Insurance Portability and Accountability Act and its implementing regulations (“HIPAA”), and other applicable law.  In most situations, this use and disclosure of your information is for the treatment, payment, or health care operations of our clients.

Some of the Services provided by Capitol Bridge to its clients are considered “Health Information Exchange” or “HIE” under applicable state law.  The information maintained in the HIE may be available to health care providers, health plans, personal care providers, or community organizations that may provide services to you.  Depending on your state law, the organization disclosing your information to or obtaining your information from Capitol Bridge for the HIE may be required to first obtain your consent.  In other cases, the exchange of this information is permitted unless you object.  Your state law may allow you to opt out of participation in an HIE, described more fully below.

Communications from Us

Unless you opt out of certain communication features, we may use your information to communicate with you, such as through e-mail, newsletters, and telephone.  You may opt out and/or unsubscribe to communications from Capitol Bridge at any time.  See the Opt-Out Provisions and Updating Your Information section below for applicable contact information and directions.

Your Information Will Not Be Sold

We will not sell any information you submit to us to any third party without prior written notice to you and an opportunity for you to opt-out of such sale, provided, however, that we are permitted to sell your information if all or substantially all of our assets are sold as part of a merger or acquisition transaction.  However, you agree that we are able to sell aggregated and/or deidentified information that we may collect related to you and your use of the Site.

Legal Process and Investigation Issues

From time to time, Capitol Bridge may be required to respond to a subpoena, a court order or similar investigative demand from law enforcement, a government agency, or a private litigant.  Capitol Bridge reserves all rights to defend, within its sole discretion, against such legal requests, demands, and claims.  For instance, Capitol Bridge may raise or waive legal objections or rights.  Capitol Bridge also reserves the right to disclose your information, as allowed by applicable law, when we believe it is reasonably appropriate based on the situation.  Such disclosure may occur, but is not limited to, disclosing your information in connection with efforts to:  (i) investigate, prevent, or commence other actions regarding suspected illegal activity or other wrongdoing; (ii) protect or defend the rights, property or safety of our company, our users, our employees, or others; (iii) comply with applicable law or cooperate with law enforcement; or (iv) enforce the TOS or other agreements or policies related to the Site or the Services.

Notice about Social Security Numbers

We do not collect social security numbers of customers or other users, and you should not provide such information to Capitol Bridge.  Nonetheless, if Capitol Bridge comes into possession of users’ social security numbers or collects such information in the future, the information will be treated confidentially and not shared with third parties unless allowed by law.  Additionally, Capitol Bridge will take reasonable steps to limit the access to such social security numbers and take legally required steps to secure the transmission of the data containing such social security numbers.

Third Party Privacy Policies May Be Applicable

This Privacy Policy does not cover any client’s or third party’s use or handling of your information once it is shared.  Instead, the privacy policies of the client or third party(ies) will govern.  We encourage you to visit the websites of those third parties and fully read and understand their privacy policies.  Some of these entities or their servers may be located outside the United States.

Links

The Site may contain links to other websites.  Capitol Bridge disclaims any responsibility for the privacy practices of third parties that may have links to or from our website, or any framed content on our website.  We encourage you to review the privacy policies/statements of every website that you visit that collects personally identifiable information.

DO NOT TRACK REQUESTS

In some states, users may be entitled to know how we respond to “Do Not Track” browser settings.  There is little consensus in the industry about what “Do Not Track” means; however, we recognize “Do Not Track” signals as an opt-out for the sharing of your data with third parties.  We take good faith efforts to comply with any “Do Not Track” request; however, you may still need to contact any third-party companies (including those who may have cookies or beacons on the Site) to direct them to not share your data with third parties. To learn more or opt-out from data collection by third-party companies you can visit: http://www.networkadvertising.org/choices.

Opt-Out Provisions and Updating Your Information

We value our users’ privacy and provide them with the option to “opt-out” of having their information used for purposes not directly related to the Site or our services for clients.  The opt-out option is available at the time you sign up for your account on the Site.  If you wish to change your opt-out preference or update your information after you initially sign up for your account, you can opt-out by any of the following means:

• Send a written request to: Capitol Bridge LLC, 671 Glebe Road, Suite 1600, Arlington, VA 22203

• E-mail compliance@capitolbridge.com

Your request will generally be responded to within three (3) business days if your request is via e-mail, or thirty (30) days if your request is via United States mail.

Your state law may provide you the right to “opt-out” of the HIE functions provided by Capitol Bridge.  For Arizona residents, this right is provided under Article XXVII, Section 2 of the Constitution of Arizona.  To opt-opt out of HIE functions, please contact compliance@capitolbridge.com.   In some cases, we may direct you to contact your health care provider regarding your HIE opt out request.

Please note that changing your opt-out preference will only affect future activities or communications from us.  In other words, if we already provided your information to a third party before you changed your opt-out preferences, you will need to contact the third party directly.  If we maintain your information on behalf of a client, that client may control the decision regarding how we handle your information.  To opt-out of communications from our clients or third-party business partners, if any, please contact them directly.

Information Retention and Security