Lifelink Systems, Inc. ('Lifelink Systems', 'We', 'Us', 'Our'), a Delaware Corporation, is the operator of the www.lifelinksystems.com website, developer of assorted web and mobile applications, and provider of associated software and services ('Software and Services'). The Software and Services enable health care organizations ('Provider', 'Providers') to engage, coordinate care, and communicate with their customers ('User', 'Users').
If You are a California resident or data subject in Europe, please see the California and European Union (EU), United Kingdom (UK), and Switzerland sections, respectively. For protected health information in the U.S., please see the User Protected Health Information section below. If You have any questions or wish to exercise Your rights and choices, please contact us as set out in the Contact section below.
Personal Identification Information
You can visit a Lifelink Systems Site without telling us who You are and without actively revealing any personal information about Yourself except for certain personal information which may be collected as a result of Your visit to the Site. There are times, however, when Lifelink Systems may require Your personal information. Lifelink Systems may ask You for Your personal identification information, including, but not limited to, first and last name, email address, date of birth, mailing address, phone number, and Social Security number (collectively, the 'Personal Identification Information'), when visiting or utilizing the Software and Services. Lifelink Systems will collect Your Personal Identification Information only if You voluntarily consent. If You refuse to supply Personal Identification Information, You may be prevented from engaging in certain activities related to the Software and Services, including, but not limited to, requesting and/or receiving information related to the coordination of care from Providers.
In order to facilitate the coordination of care between Users and Providers, Users may be required to provide Lifelink Systems with information regarding Your medical history, a description of symptoms, lifestyle behaviors, imaging or other diagnostic test results, and other relevant medical information and/or documentation (collectively, the 'Medical Information').
Non-Personal Identification Information
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How Lifelink Systems Collects and Uses Your Information
Lifelink Systems may collect and use Personal Identification Information, Medical Information, and non-Personal Identification Information (collectively, 'Your Information') for the following purposes:
_ To provide the Lifelink Systems Software and Services. Lifelink Systems may request Your Information that is necessary to provide the products and services Lifelink Systems offers.
_ To improve customer service. Lifelink Systems may use Your Information to respond to customer service requests and support needs more efficiently.
_ To manage Customer and Partnership Relationships. If You are a Lifelink Systems customer or partner, or You are working with Lifelink Systems sales personnel on a possible engagement between Lifelink Systems and Your company, We may use Your personal information You provided to Us, particularly Your business contact information and information relevant for the engagement, for the purpose of managing the relationship and in connection with any potential contractual arrangements between Our companies. We also may process Your personal information as a part of a professional services engagement and/or in order to provide You with Our technical support services.
_ To improve the Software and Services. Lifelink Systems may use Your feedback and usage data to improve Lifelink Systems' Software and Services.
_ To process payments. Lifelink Systems may use Your Information to collect and remit payments on behalf of Users and Providers. Lifelink Systems does not share this information with outside parties except to the extent necessary to provide the service.
_ To send periodic emails. Lifelink Systems may use the email address to send Users and Providers information and updates pertaining to the Software and Services.
Lifelink Systems may be legally obligated to disclose information about You to the government or third parties under certain circumstances, such as in connection with illegal activity on Software and Services or to respond to a subpoena, court order, or other legal process. Lifelink Systems reserves the right to release Your Information to law enforcement or other government officials as deemed necessary or appropriate in Lifelink Systems' sole and absolute discretion.
If You access Lifelink Systems' Sites, Software and/or Services outside of the U.S., information that Lifelink Systems collects about You may be transferred to servers inside the U.S. and maintained indefinitely. By allowing Lifelink Systems to collect information about You, You consent to such transfer and treatment of Your data. Where required by applicable law, information that Lifelink Systems collects about You may be required to remain inside the applicable jurisdiction.
How Lifelink Systems Protects Your Information
The Software and Services may require You to create unique identifiers (such as Your name and password) in order to log into some areas of the Software and Services. Lifelink Systems utilizes these unique identifiers to verify Your identity and eligibility in order to protect You from the release of Your Information to unauthorized parties. To help protect the privacy of data transmitted through the Software and Services, where Your Information is requested, Lifelink Systems uses technology designed to encrypt the information before it is sent to Lifelink Systems using Secure Sockets Layer (SSL) technology or similar encryption technology. In addition, Lifelink Systems takes steps to protect Your Information against unauthorized access. These measures include appropriate data collection, storage and processing practices, and security measures to protect against unauthorized access, alteration, disclosure, or destruction of Your personal information, Your name, password, transaction information, and data stored on Lifelink Systems' Software and Services. However, You should keep in mind that Lifelink Systems' Software and Services are run on software, hardware, and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond Lifelink Systems' control.
Lifelink Systems will make every reasonable effort to secure its Software and Services but does not represent, warrant, or covenant anything related to sage, complete, or hack-proof transmissions in transit or at rest within the Software and Services. You assume the risk of any unauthorized disclosure or intentional intrusion, or of any delay, failure, interruption, or corruption of data or other information transmitted or stored at rest in connection with the use of the Lifelink Systems Software and Services.
Sharing Your Information
Lifelink Systems does not sell, trade, or rent Personal Identification Information to others. Lifelink Systems may share generic aggregated demographic information not linked to any Personal Identification Information regarding visitors and users of the Software and Services with Lifelink Systems' business partners, trusted affiliates, and advertisers.
From time to time, We may partner with other companies to jointly offer products or services. If You purchase or specifically express interest in a jointly offered product or service from us, Lifelink Systems may share certain information collected in connection with Your purchase or expression of interest with Our joint promotion partner(s). Lifelink Systems does not control Our business partners' use of the information We share with them, and their use of the information will be in accordance with their own privacy policies. If You do not wish for Your information to be shared in connection with any joint offerings, You may opt not to purchase or specifically express interest in a jointly offered product or service.
In certain situations, Lifelink Systems may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose Your personal information as required by law, such as to comply with a subpoena or other legal demand, when We believe in good faith that disclosure is necessary to protect Our rights, protect Your safety or the safety of others, investigate fraud, or respond to a government request.
If Lifelink Systems were to be involved in a merger, acquisition, or sale of all or a portion of its assets, You will be notified via email and/or by way a prominent notice on the Lifelink Systems Site of any change in ownership, uses of Your personal information, and choices You may have regarding Your personal information. We may also disclose Your personal information to any other third party with Your prior consent.
Your Rights and Choices
You may opt-out of receiving promotional communications, remove Your information from Our database, remove Your information from blogs, forums or testimonials, unsubscribe from communications related to the Lifelink Systems Software or Services, or cancel Your account by contacting us at firstname.lastname@example.org. In some cases, We may not be able to remove Your personal information, in which case We will explain that We are unable to do so and why.
Correcting, Updating and Accessing
Where We are unable to provide access to certain personal information that You request and are required to refuse, we will notify You in writing, document the reasons and outline further steps which are available to You.
We will retain Your personal information for as long as needed to provide the applicable service, and as needed to comply with Our legal obligations, resolve disputes, and enforce Our agreements. We may also retain data from which You cannot directly be identified.
Third Party Web Site Links
A Lifelink Systems Site may contain links to other websites. Lifelink Systems is not responsible for the privacy practices or the content of such third party websites. Inclusion of such websites on the Lifelink Systems Site does not indicate Lifelink Systems' endorsement of such third parties or confirm that Lifelink Systems has reviewed or approved the third party websites. Lifelink Systems recommends contacting the operators of those websites directly for information regarding their privacy policies.
The following disclosures apply only to individuals who reside in California. The California Consumer Privacy Act (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing Personal Information to provide notice of rights California residents have and can exercise.
California Notice of Collection. Lifelink Systems collects information corresponding to the following categories of information identified in the CCPA.
For more information on what We collect, please review the sections above regarding personal information collection. We collect and use these categories of Personal Information for the business purposes described in the section on “How We Use Personal Information We Collect From You”, including to provide and manage the services related to Our Lifelink Systems Platform.
Lifelink Systems does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities, We will comply with applicable law as to such activity.
Lifelink Systems discloses the following categories of information for commercial purposes:
We use and partner with different types of entities to assist with daily operations and manage the Lifelink Systems Site, Software and Service.
Right to Know and Delete. If You are a California resident, You have the right to know certain information about Our data practices in the 12 months preceding any such request. In particular, You have the right to request the following from Us:
You also have the right to have the Personal Information that Lifelink Systems has collected from You deleted. This is, however, not an absolute right and Lifelink Systems may have legal grounds for keeping such data.
Exercising Your Rights. To exercise any of these rights, please submit a request to email@example.com. Your request should specify which right You are seeking to exercise and the scope of the request. We will strive to confirm receipt of Your request within 10 days. We may require specific information from You to help us verify Your identity and process Your request. If We are unable to verify Your identity, We may deny Your requests to know or delete.
Authorized Agent. You can designate an authorized third party to submit requests on Your behalf. However, We will require written proof of the agent’s permission to do so and verify Your identity directly.
Right to Non-Discrimination. You have the right to not be discriminated against by Us as a result of Your exercising any of Your rights.
Information Retention. We will keep personal information used to make a decision affecting You for at least one year after using it to make the decision. We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for a legal or business purpose. We will take due care when destroying personal information so as to prevent unauthorized access to the information.
European Union (EU), United Kingdom (UK), and Switzerland
Data-processor: Under the General Data Protection Regulation of the EU (GDPR) and United Kingdom General Data Protection Regulation (UK GDPR), if you are a Lifelink Systems customer or partner, We and/or Our third party agents act as Your data sub-processors. Lifelink Systems primarily processes and stores Your data, including personal information, on servers located and operated within the U.S. If You reside or are located outside of the U.S., We may send to and store Your personal information in the U.S. in order to provide and operate the Lifelink Systems Site, Software and Services.
If your personal information (as defined by GDPR and UK GDPR as “personal data”) that is being processed by Lifelink Systems is subject to GDPR, We undertake to ensure an adequate level of protection of the personal data transferred outside the European Economic Area or UK, either by us, Our affiliates, and/or third party agents, in accordance with applicable legislation, in particular via the signature of the standard contractual clauses approved by the European Commission, UK Information Commissioner's Office, or the Privacy Shield certification.
Data Controller: In limited circumstances, where Lifelink Systems processes Your personal information as a data controller, You are entitled to certain privacy rights under certain circumstances:
VeraSafe has been appointed as Lifelink Systems' representative in the EU and UK for data protection matters, pursuant to Article 27 of the GDPR and UK GDPR respectively. If you are in the European Economic Area or UK, VeraSafe can be contacted only on matters related to the processing of personal data.
To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at:
EU +420 228 881 031.
UK +44 (20) 4532 2003
Alternatively, VeraSafe can be contacted at:
EU: VeraSafe Netherlands BV
Keizersgracht 391 A
1016 EJ Amsterdam
UK: VeraSafe United Kingdom Ltd.
37 Albert Embankment
London SE1 7TL
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Lifelink Systems is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Lifelink Systems complies with the Privacy Shield Principles for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions.
In compliance with the Privacy Shield Principles, Lifelink Systems commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Lifelink Systems at firstname.lastname@example.org.
Lifelink Systems has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.
User Protected Health Information
To the extent that User's Personal Identification Information and/or Medical Information constitutes protected health information, as defined in 45 CFR ' 160.103 ('Protected Health Information'), Lifelink Systems shall use and disclose such Protected Health information only in accordance with HIPAA. Users' rights regarding such Protected Health Information include:
_ Right to access User's Protected Health Information. User has the right to review or obtain copies of User's Protected Health Information records. User's request to review and/or obtain a copy of Protected Health Information records must be made in writing. Lifelink Systems may charge a fee for the costs of producing, copying, and mailing the requested information. Lifelink Systems will inform the User of the cost in advance.
_ Right to amend User's Protected Health Information. If User feels that User's Protected Health Information maintained by Lifelink Systems is incorrect or incomplete, User may request that Lifelink Systems amend the information. User's request must be made in writing and must include the reason User is seeking a change. Lifelink Systems may deny User's request if, for example, User asks us to amend information that was not created by Lifelink Systems, or User asks to amend a record that is already accurate and complete. If Lifelink Systems denies User's request to amend, Lifelink Systems will notify User in writing. User then has a right to submit to Lifelink Systems a written statement of disagreement with Lifelink Systems' decision, and Lifelink Systems will have the right to rebut that statement. (Please note that any amendment of records prepared by a healthcare provider, which User has forwarded to us, is the responsibility of the original provider. In such an instance, User should direct User's request to that provider.)
_ Right to an accounting of disclosures. User has the right to request an accounting of disclosures Lifelink Systems has made of User's Protected Health Information. The list will not include Lifelink Systems' disclosures related to User's treatment, Lifelink Systems' payment or health care operations, or disclosures made to User with authorization. The list may also exclude certain other disclosures, such as for national security purposes.
_ Right to request restrictions on the use and disclosure of User's Protected Health information. User has the right to request that Lifelink Systems restrict or limit how Lifelink Systems uses or discloses User's Protected Health Information for treatment, payment or health care operations.
_ Right to receive confidential communications. By using the Software and Services, User has consented to receive any confidential communications from Lifelink Systems as electronic communications that shall be made and may be accessed through the Software and Services or in any other less secure form to which User consents, including but not limited to email, SMS, or other messaging services.
_ Right to receive notification of a breach of Protected Health Information. In the event of a breach of User's Protected Health Information, User has the right to receive notification of such breach. User has consented to receive such notification through an electronic communication through the Software and Services.
Compliance Officer (Data Privacy Officer for GDPR Purposes)
Lifelink Systems, Inc.
548 Market Street
San Francisco, California 94104-5401 US