Website and mobile application Privacy Statement

Revised: 05/01/2020

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Introduction

Home OT Daily provides a website, a mobile-enabled website, and a mobile app:

• "homeotdaily.com," or "wellshareprogram.org" (the Websites)

• “HOTD Mobile Application” (the App), for both iPhone and Android

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The Websites and the App allow our members and other users to view health-related information, communicate with our practitioners and staff, arrange for clinical and health plan services, and access additional services.

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This Privacy Statement applies to the Websites and the App, which are owned and operated by Wellshare Program Inc (“Home OT Daily”, “HOTD”). This Privacy Statement describes how Home OT Daily collects and uses the personal information you provide on, and other information that is collected from your use of the Websites and the App. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

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Personal information means information that is individually identifiable. Information that has been de-identified by Home OT Daily or others is no longer personal information and is not covered by the terms of this Privacy Statement.

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All of your protected health information maintained by Home OT Daily, including information you provide on the Websites and the App, is also subject to the Notices of Privacy Practices issued by HOTD under the Health Insurance Portability and Accountability Act (“HIPAA”). The Notices of Privacy Practices may contain additional provisions relating to the use and disclosure of your information that go beyond the terms of this Privacy Statement.

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Home OT Daily is committed to protecting the privacy of the users of the Websites and the App. We will use and disclose your personal information as stated in this Privacy Statement.

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Website and mobile application Privacy Statement

Use and disclosure of health information includes using the information to provide treatment to the individual, to make payments for such treatment, and to conduct ongoing quality improvement activities. Our use and disclosure of an individual's personal information (including health information) is limited as required by state and federal law. We do not sell or rent personal information about visitors to the Websites or the App.

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Security

The Websites and the App have security measures in place that are intended to help protect against the loss, misuse, unauthorized access or alteration of information under our control both during transmission and once the information is received. These measures include encryption of data using the Secure Socket Layer (SSL) system, and using a secured messaging service when we send your personal information electronically to the Websites or the App. Despite these measures, the confidentiality of any communication or material transmitted to or from us via the Websites or the App by Internet, text message or email cannot be guaranteed. At your discretion, you may contact us at the mailing address or telephone number listed in the "Questions, complaints, and contacts" section at the end of this Privacy Statement.

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Revisions to the Privacy Statement

We may revise this Privacy Statement from time to time as we add new features or modify the way in which we manage information, or as laws change that may affect our services. If we make material changes to our Privacy Statement, we will post notice of this on our Websites and the APP prior to the changes becoming effective. Any revised Privacy Statement will apply both to information we already have about you at the time of the change, and any personal information created or received after the change takes effect. We include a version number on this Privacy Statement consisting of the date (year, month, and day) it was last revised. We encourage you to periodically reread this Privacy Statement, to see if there have been any changes to our policies that may affect you.

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Website and mobile application visitor data

In addition to web logs, described below, Home OT Daily routinely gathers data on website and mobile application activity, such as how many people visit the site or mobile applications, the web pages or mobile screens they visit, where they come from, how long they stay, etc. The data is collected on an aggregate basis, which means that no personally identifiable information is associated with the data. This data helps us improve our content and overall usage. The information is not shared with other organizations for their independent use.

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The Websites and the App do not honor a browser’s signal or header request not to track the user's activity.

 

Data caching by mobile applications

In order to ensure a good user experience, certain data may be temporarily or permanently cached by the Mobile Applications on users’ mobile devices. Any data that is personally identifiable will be encrypted and will not be viewable by anyone without access to the user’s User ID and Password.

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Collecting and using and disclosing personal information

Except as disclosed in this Privacy Statement, we do not collect any personally identifiable information about visitors to the Websites or the App. The policies, sources, uses and disclosures of information are outlined in Sections 1 through 19 that follow:

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1. Information Collection Use

We collect the following personal information from you:

• contact information such as name, email address, mailing address, and phone number

• age or date of birth

• unique identifiers such as user name, account number, and password

• preferences information such as preferred first name and the types of emails you’d like to receive from us

• health or medical information

• credit card information

• medical record number or health record number

• if you apply for Home OT Daily coverage online, personal health and demographic information about you and those dependents for whom you wish to receive coverage

• your location, if you ask for directions to a facility from your mobile device

• de-identify the information in accordance with HIPAA and/or other applicable law

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We use and disclose this information to:

• communicate your health information, or the health information of someone you are caring for, to health care providers treating you or the other person

• communicate to you the health information of others you are authorized to act on behalf of on the Websites or the App

• pay for prescription refills or medical bills

• apply for Home OT Daily coverage

• send you requested product or service information

• respond to customer service requests

• administer your account

• send you newsletters, text messages or email communications

• respond to your questions and concerns

• improve our website, app, and marketing efforts

• conduct internal quality improvement or business analysis

• display driving directions on your mobile device
  
  When you provide us with personal information about dependents and family members, we will only use this information for the specific reason for which it is provided.

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2. Web logs

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As is true of most websites, we gather certain information automatically. We maintain standard Web logs that record data about all visitors and customers who use the Websites or the App and we store this information for no longer than reasonably useful to carry out its legitimate business purpose, or as legally required. These logs may contain the Internet domain from which you access the site (such as aol.com, abc.org, etc.); the IP address which is automatically assigned to your computer when you get on the Internet (a static IP address may be identifiable as being connected to you, while a dynamic address is usually not identifiable); the type of browser and operating system you use; the date and time you visited; the pages or mobile screens you viewed; and the address of the website you linked from, if any. If you sign on to the Websites or the App to use secured features, our Web logs will also contain an individual identifier and show the services you have accessed.

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All Web logs are stored securely, and may only be accessed by Home OT Daily employees or designees on a need-to-know basis for a specific purpose. Home OT Daily uses Web log information to help us design our Websites and the App, to identify popular features, to resolve user, hardware, and software problems, to make the Websites and the App more useful to visitors and for security purposes.

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3. Internet cookies

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We and our partners may place Internet "cookies" or similar technologies on the computer hard drives of visitors to the Websites or the App. Information we obtain helps us to tailor our site and the App to be more helpful and efficient for our visitors. The cookie consists of a unique identifier that does not contain information about your health history. We use two types of cookies, "session" cookies and "persistent" cookies, along with other similar technologies.

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A session cookie is temporary, and expires after you end a session and close your web or app browser. We use session cookies to help customize your experience on our site, maintain your signed-on status as you navigate through our features, and to track your "click path" through our Web pages or mobile screens.

Persistent cookies remain on your hard drive after you've exited from our website, and we use them for several reasons. For instance, if you've given us permission to email you with information about your Home OT Daily benefits, or for other reasons, we may place a persistent cookie on your hard drive that will let us know when you come back to visit our site. We sometimes use this type of persistent cookie with a "Web beacon" (see below). Persistent cookies will not contain any personal health information about you such as a Home OT Daily Health/Medical Record number.

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You may have software on your computer that will allow you to decline or deactivate Internet cookies, but if you do so, some features of the Websites or the App may not work properly for you. For instructions on how to remove cookies from your hard drive, go to your browser's website for detailed instructions. In addition, further information regarding cookies may be available on other websites or from your Internet service provider. Safari, Chrome, Firefox, Internet Explorer and iOS browsers are commonly used browsers.

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4. Web beacons

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We may also occasionally use "Web beacons" (also known as "clear gifs," "Web bugs," "1-pixel gifs," etc.) that allow us to collect non-personal information about your response to our email communications, and for other purposes. Web beacons are tiny images, placed on a Web page or email, that can tell us if you've gone to a particular area on our website. For example, if you've given us permission to send you emails, we may send you an email urging you to use a certain feature on our website. If you do respond to that email and use that feature, the Web beacon will tell us that our email communication with you has been successful. We do not collect any personal health information with a Web beacon, and do not link Web beacons with any other personal health information you've given us.

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Since Web beacons are used in conjunction with persistent cookies (described above), if you set your browser to decline or deactivate cookies, Web beacons cannot function.

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5. Re-targeting

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We partner with a third party ad network to manage our advertising on other sites. Our ad network partner uses cookies, Web beacons, and other tracking technologies to collect information about your activities on this and other Websites and to then provide you with HOTD advertising on other websites. We may also place a persistent third-party cookie (provided by Google) on your hard drive if you sign on to HOTD.org. This cookie will prevent HOTD.org members from seeing advertising that is targeted towards people who are not members of Home OT Daily’s health plan, when searching on Google.

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If you wish to not have this information used for the purpose of serving you targeted ads, you may opt out. Please note this does not opt you out of being served advertising. You may continue to receive generic non-targeted ads.

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6. Emails and SMS text messaging

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Home OT Daily uses a third-party vendor to help us manage some of our email and text messaging communications with you. While we do supply these vendors with email addresses or mobile telephone numbers of those we wish them to contact, your email address or mobile telephone number is never used for any purpose other than to communicate with you on our behalf. When you click on a link in an email, you may temporarily be redirected through one of the vendor's servers (although this process will be invisible to you) which will register that you've clicked on that link, and have visited our Websites or HOTD Mobile Application. Home OT Daily never shares any information, other than your email address or telephone number, with our third-party email and text messaging vendors, which may only share this information with its authorized subcontractors.

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Even if you have given us permission to send emails or text messages to you, you may revoke that permission at any time by following the "unsubscribe" information at the bottom of the email or by replying “Stop” to any text message you receive from us.

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7. Evaluation and quality improvement

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We will periodically ask users to complete surveys asking about their experiences with features of the Websites or the App. Our surveys ask visitors for demographic information such as age, gender, and education, but will not request that users provide specific information about any medical condition. We use survey information for evaluation and quality improvement purposes, including helping Home OT Daily to improve information and services offered through the Websites and the App. In addition, users giving feedback may be individually contacted for follow-up due to concerns raised during the course of such evaluation. Demographic information and Web log data may be stored for future evaluation and quality improvement activities.

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8. Application for Home OT Daily membership

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If you apply for Home OT Daily membership through the Websites or the App, you will be asked during the application process to disclose certain personal information so that we can evaluate your eligibility, and you will be asked to verify the truthfulness of your answers.

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9. Messages and transactions

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Comments or questions sent to us using email or secure messaging forms will be shared with Home OT Daily staff and health care professionals who are most able to address your concerns. We will archive your messages once we have made our best effort to provide you with a complete and satisfactory response.

Some of our services such as our automated appointment selection and prescription refill services interact directly with other Home OT Daily data systems. Data about your transaction may be stored in these systems, and available to people who test and support these systems.

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When you use a service on the secure section of the Websites or the App to interact directly with Home OT Daily health care professionals, some information you provide may be documented in your medical record, and available for use to guide your treatment as a patient.

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10. Credit card transactions

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If you provide us with your credit card number for pharmacy prescriptions or other payments, we will treat your credit card number in a secure manner.

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11. Data integrity and correction

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Requests to view and correct personal information from the Websites or the App may be submitted using the contact information in the "Questions, complaints, and contacts" section below.

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If your personal information changes, or to update or request deletion of information collected on our Websites or the App, or if you believe a third party has provided us with your personal information and you would like to request that it be edited or removed from our database, please use the contact information in the “Questions, complaints, and contacts” section below. We will respond to all access requests within 30 days.

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12. Children

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We do not knowingly collect personally identifiable information from children under the age of 13. If Home OT Daily is made aware of collecting information from a child under 13 we will delete this information.

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13. Disclosures

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We may disclose personal information to any person performing audit, legal, operational, or other services for us. We will use information which does not identify the individual for these activities whenever reasonably possible. Information disclosed to vendors or contractors for operational purposes may not be re-disclosed to others by such a vendor or contractor, except as permitted by HOTD and applicable law.

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We may also disclose your personal information to third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us.  

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These services may include:

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• payment processing

• providing customer service

• sending marketing communications

• fulfilling subscription services

• conducting research and analysis

• providing cloud computing infrastructure

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We may also disclose your personal information:

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• as required by law, such as to comply with a subpoena, or similar legal process

• as described in our Notices of Privacy Practices for protected health information

• when we believe in good faith that disclosure is necessary to protect our rights, protect you or others from threats of imminent harm, investigate fraud or other activity in violation of the law, or respond to government requests (including to meet national security or law enforcement requirements)

• to protect the security and reliability of the Websites and the App

• if Home OT Daily is involved in a merger, acquisition, or sale of all or a portion of its assets. You will be notified via email and/or a prominent notice on our Websites and the App of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information

• to any other third party with your prior consent to do so

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14. Opt out

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If a user makes a request to receive information (for example, requesting a subscription to one of our online publications) in an ongoing manner through the Websites or the App by providing an email address or mobile phone number the user may request to discontinue future mailings or messages. Similarly, if you receive information about a Home OT Daily service through email or text message, you may make a request to discontinue receiving similar messages in the future. All such materials sent to you by email or text message will contain information about how to opt out. Please note, however, that you cannot opt out of certain messages, such as an email letting you know that a staff member has sent you a secure message, or our Together At Home newsletter.

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Also, if as a member you register to use protected features on our Websites or the App, you may be given an opportunity to receive emails about different types of Home OT Daily products, services, announcements, and updates. On our website, you may change your preferences by clicking "my profile" at the top right of each page, then choosing "communication preferences" on the left.

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15. Other requests to limit use and disclosure of your personal information

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State and federal laws may allow you to request that we limit our uses and disclosures of your personal information for treatment, payment, and health care operations purposes. We will consider all requests and, if we deny your request, we will notify you in writing. Federal law requires us to agree to your request to restrict disclosures to a health plan or insurer relating to specific health care services, if you have paid for those services in full. The law does not, however, require us to restrict any disclosures we think are important for treatment purposes.

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16. Data retention

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We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

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17. Social media

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Our Websites and the App include Social Media Features, such as the Facebook button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy statement of the company providing them.

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18. Links to third party websites

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Our Websites and the App include links to other websites whose privacy practices may differ from those of Home OT Daily. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.

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19. Geolocation

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If you are using the App to find our facilities and other locations, with your permission, we will use the geolocation feature of your mobile device to give you directions to that facility. When you download and use the App, we automatically collect information on the type of device you use, operating system version, and the device identifier (or “UDID). We do not share your location information with any third party and do not use it for any reason other than to give you directions. You may opt out of location based services by editing the setting at the device level. For additional information regarding how to do this, please contact us by sending a message to the Home OT Daily Web manager.

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Questions, complaints, and contacts

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If you have any questions about this Privacy Statement, our policies and practices concerning the Websites or the App, your rights under this statement, and your dealings with the Home OT Daily Websites or the App, you can contact Home OT Daily by telephone at 1-207-200-3167by sending a message to the Home OT Daily Web manager, or by U.S. mail at the address below:

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Home OT Daily Digital Experience Center

35 Bay Street

Portland, ME 04103

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HIPAA NOTICE OF PRIVACY PRACTICES

 

Notice of Privacy Practices

 

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.  PLEASE REVIEW IT CAREFULLY.

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In this notice we use the terms "we," "us," and "our" to describe Wellshare Program Inc and Home OT Daily. For more details, please refer to section IV of this notice.

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WHAT IS "PROTECTED HEALTH INFORMATION"?

Your protected health information (PHI) is individually identifiable health information, including demographic information, about your past, present or future physical or mental health or condition, health care services you receive, and past, present or future payment for your health care. Demographic information means information such as your name, social security number, address, and date of birth.

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PHI may be in oral, written, or electronic form. Examples of PHI include your medical record, claims record, enrollment or disenrollment information, and communications between you and your health care provider about your care.

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Your individually identifiable health information ceases to be PHI 50 years after your death.

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ABOUT OUR RESPONSIBILITY TO PROTECT YOUR PHI

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By law, we must

1. protect the privacy of your PHI;

2. tell you about your rights and our legal duties with respect to your PHI;

3. notify you if there is a breach of your unsecured PHI; and

4. tell you about our privacy practices and follow our notice currently in effect.

5. ​

We take these responsibilities seriously and have put in place administrative safeguards (such as security awareness training and policies and procedures), technical safeguards (such as encryption and passwords), and physical safeguards (such as locked areas and requiring badges) to protect your PHI. As in the past, we will continue to take appropriate steps to safeguard the privacy of your oral, written, and electronic PHI.

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YOUR RIGHTS REGARDING YOUR PHI

This section tells you about your rights regarding your PHI, and describes how you can exercise these rights.

 

Your right to access and amend your PHI

Subject to certain exceptions, you have the right to view or get a copy of your PHI that we maintain in records relating to your care or decisions about your care or payment for your care. Requests must be in writing.

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After we receive your written request, we will let you know when and how you can see or obtain a copy of your record. If you agree, we will give you a summary or explanation of your PHI instead of providing copies. We may charge you a fee for the copies, summary or explanation.

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If we don't have the record you asked for but we know who does, we will tell you who to contact to request it. In limited situations, we may deny some or all of your request to see or receive copies of your records, but if we do, we will tell you why in writing and explain your right, if any, to have our denial reviewed.

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If you believe there is a mistake in your PHI or that important information is missing, you may request that we correct or add to the record. Please write to us and tell us what you are asking for and why we should make the correction or addition. Please write to us as described above in the section entitled "Your right to see and receive copies of your PHI." We will respond in writing after receiving your request. If we approve your request, we will make the correction or addition to your PHI. If we deny your request, we will tell you why and explain your right to file a written statement of disagreement.

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Submit all written requests for access or amendments to us at:
Home OT Daily
Health Information Services
35 Bay St
Portland, ME 04103  

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Your right to choose how we send PHI to you or someone else

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You may ask us to send your PHI to you at a different address (for example, your work address) or by different means (for example, fax instead of regular mail).

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If your PHI is stored electronically, you may request a copy of the records in an electronic format offered by Home OT Daily. You may also make a specific written request to Home OT Daily to transmit the electronic copy to a designated third party.

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If the cost of meeting your request involves more than a reasonable additional amount, we are permitted to charge you our costs that exceed that amount.

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Your right to an accounting of disclosures of PHI

You may ask us for a list of our disclosures of your PHI.. You are entitled to one disclosure accounting in any 12-month period at no charge. If you request any additional accountings less than 12 months later, we may charge a fee.

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An accounting does not include certain disclosures, for example, disclosures

• to carry out treatment, payment and health care operations;

• for which Home OT Daily had a signed authorization;

• of your PHI to you;

• from a Home OT Daily facility directory;

• for notifications for disaster relief purposes;

• to persons involved in your care and persons acting on your behalf; or

• not covered by the right to an accounting.

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Your right to request limits on uses and disclosures of your PHI

You may request that we limit our uses and disclosures of your PHI for treatment, payment, and health care operations purposes. We will review and consider your request. We are not required to agree to your request, except to the extent that you request a restriction on disclosures to a health plan or insurer for payment or health care operations purposes and the items or services have been paid for out of pocket in full.  However, we can still disclose the information to a health plan or insurer for the purpose of treating you. For requests to restrict your PHI for payment or health care operations purposes, please request the restriction prior to receiving services from Home OT Daily.

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If the services are not paid for in full and out of pocket by you or by someone on your behalf, we do not have to agree to your request to restrict uses or disclosures of PHI for health care operations, payment or treatment purposes. We will consider all submitted requests and, if we deny your request, we will notify you in writing.

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Your right to receive a paper copy of this notice

You have a right to receive a paper copy of this notice upon request.

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Home OT Daily Staff SUBJECT TO THIS NOTICE

This notice applies to the entirety of the Home OT Daily service in the USA.

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Our health care delivery sites include Administration and Group Teams on the Home OT Daily website, Together At Home online forum and mobile applications.

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To provide you with the health care you expect, to treat you, to pay for your care and to conduct our operations, such as quality assurance, accreditation, licensing and compliance, these Home OT Daily sites and staff share your PHI with each other.

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Our personnel may have access to your PHI either as employees, professional staff members and others authorized to enter information in a HOTD medical record, volunteers, or persons working with us in other capacities. Our region may share your PHI with HOTD and Wellshare Program Inc, in connection with shared services and other national Home OT Daily activities for treatment, payment, or health care operations purposes. 

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HOW WE MAY USE AND DISCLOSE YOUR PHI

Your confidentiality is important to us. Our clinicians and employees are required to maintain the confidentiality of the PHI of our members and patients and we have policies and procedures and other safeguards to help protect your PHI from improper use and disclosure. Sometimes we are allowed by law to use and disclose certain PHI without your written permission. We briefly describe these uses and disclosures below and give you some examples.

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How much PHI is used or disclosed without your written permission will vary depending, for example, on the intended purpose of the use or disclosure. Sometimes we may only need to use or disclose a limited amount of PHI, such as to send you an appointment reminder or to confirm that you are a health plan member. At other times, we may need to use or disclose more PHI such as when we are providing medical treatment.

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• Treatment: This is the most important use and disclosure of your PHI. For example, our health care personnel, including trainees, involved in your care use may disclose your PHI to diagnose your condition and evaluate your health care needs. Our personnel will use and disclose your PHI in order to provide and coordinate the care and services you need: for example, prescriptions, X-rays, and lab work. If you need care from health care providers who are not part of Home OT Daily, such as community resources to assist with your health care needs at home, we may disclose your PHI to them.

• Payment: Your PHI may be needed to determine our responsibility to pay for, or to permit us to bill and collect payment for, treatment and health-related services that you receive. 

• Health care operations: We may use and disclose your PHI for certain health care operations, for example, quality assessment and improvement, training and evaluation of health care professionals, licensing, accreditation, and determining premiums and other costs of providing health care, and preventing criminal activity, fraud, or misrepresentation.

• Business associates: We may contract with business associates to perform certain functions or activities on our behalf, such as payment and health care operations. These business associates must agree to safeguard your PHI.

• Appointment reminders: We may use your PHI to contact you about appointments for treatment or other health care you may need.

• Identity verification: We may photograph you for identification purposes, storing the photo in your medical record. This is for your protection and safety, but you may opt out.

• Health Information Exchange: We may share your health information electronically with other organizations through a Health Information Exchange (HIE) network. These other organizations may include hospitals, laboratories, health care providers, public health departments, health plans, and other participants. Sharing information electronically is a faster way to get your health information to the health care providers treating you.  You can choose not to have your information shared through any of our HIE networks (that is, “opt out”) at any time.  You may do this by contacting Home OT Daily Member Services, 35 Bay St, Portland, ME 04103. If you opt out, the health care providers treating you could call Home OT Daily to ask that your health information be provided in another way, such as by fax, instead of accessing the information through the HIE network. 

• Specific types of PHI: There are stricter requirements for use and disclosure of some types of PHI, for example, drug and alcohol abuse patient information, HIV tests, and mental health information. However, there are still circumstances in which these types of information may be used or disclosed without your authorization. If you become a client in our substance use program, we will give you a separate written notice, as required by law, about your privacy rights for your substance use disorder program PHI.

• Underwriting: We may use and disclose your PHI, to the extent permitted under applicable law, for underwriting purposes, including the determination of benefit eligibility and costs of coverage and to perform other activities related to issuing a benefit policy. However, we are prohibited from using or disclosing your genetic information for underwriting purposes. Your genetic information includes information about your genetic tests, your family members’ genetic tests, and requests for or receipt of genetic services by you or any family members.

• Communications with family and others when you are present: Sometimes a family member or other person involved in your care will be present when we are discussing your PHI with you. If you object, please tell us and we won't discuss your PHI or we will ask the person to leave.

• Communications with family and others when you are not present: There may be times when it is necessary to disclose your PHI to a family member or other person involved in your care because there is an emergency, you are not present, or you lack the decision making capacity to agree or object. In those instances, we will use our professional judgment to determine if it's in your best interest to disclose your PHI. If so, we will limit the disclosure to the PHI that is directly relevant to the person's involvement with your health care. For example, we may allow someone to examine your progress notes.

• Disclosure in case of disaster relief: We may disclose your name, city of residence, age, gender, and general condition to a public or private disaster relief organization to assist disaster relief efforts, unless you object at the time.

• Program directory: When you are a patient in one of our facilities, we may create a directory that includes your name, geo-location and your general condition. This information may be disclosed to a person who asks for you by name. You may object to the use or disclosure of some or all of this information. If you do, we will not disclose it to visitors and any other members of the public.

• Research: Home OT Daily engages in extensive and important research. Some of our research may involve medical and neurological and some is limited to collection and analysis of health data. Research of all kinds may involve the use or disclosure of your PHI. Your PHI can generally be used or disclosed for research without your permission if an Institutional Review Board (IRB) approves such use or disclosure. An IRB is a committee that is responsible, under federal law, for reviewing and approving human subjects research, to protect the safety of the participants and the confidentiality of PHI.

• Public health activities: Public health activities cover many functions performed or authorized by government agencies to promote and protect the public's health and may require us to disclose your PHI.

  • For example, we may disclose your PHI as part of our obligation to report to public health authorities certain diseases, injuries, conditions, and vital events such as births. Sometimes we may disclose your PHI to someone you may have exposed to a communicable disease or who may otherwise be at risk of getting or spreading the disease.

  • The Food and Drug Administration (FDA) is responsible for tracking and monitoring certain medical products, such as pacemakers and hip replacements, to identify product problems and failures and injuries they may have caused. If you have received one of these products, we may use and disclose your PHI to the FDA or other authorized persons or organizations, such as the maker of the product.

  • We may use and disclose your PHI as necessary to comply with federal and state laws that govern workplace safety.

• Health oversight: As health care providers and health plans, we are subject to oversight conducted by federal and state agencies. These agencies may conduct audits of our operations and activities and in that process, they may review your PHI.

• Military activity and national security: We may sometimes use or disclose the PHI of armed forces personnel to the applicable military authorities when they believe it is necessary to properly carry out military missions. We may also disclose your PHI to authorized federal officials as necessary for national security and intelligence activities or for protection of the president and other government officials and dignitaries.

• Fundraising: We may use or disclose your demographic information and other limited PHI such as dates and where health care was provided, to certain organizations for the purpose of contacting you to raise funds for our organization. If we contact you for fundraising purposes, we will provide you with a clear opportunity to elect not to receive any further fundraising communications.

• Required by law: In some circumstances, federal or state law requires that we disclose your PHI to others. For example, the secretary of the Department of Health and Human Services or state regulatory agency may review our compliance efforts, which may include seeing your PHI.

• Lawsuits and other legal disputes: We may use and disclose PHI in responding to a court or administrative order, a subpoena, or a discovery request. We may also use and disclose PHI to the extent permitted by law without your authorization, for example, to defend a lawsuit or arbitration.

• Law enforcement: We may disclose PHI to authorized officials for law enforcement purposes, for example, to respond to a search warrant, report a crime on our premises, or help identify or locate someone.

• Serious threat to health or safety: We may use and disclose your PHI if we believe it is necessary to avoid a serious threat to your health or safety or to someone else's.

• Abuse or neglect: By law, we may disclose PHI to the appropriate authority to report suspected child abuse or neglect or to identify suspected victims of abuse, neglect, or domestic violence.

• Coroners and funeral directors: We may disclose PHI to a coroner or medical examiner to permit identification of a body, determine cause of death, or for other official duties. We may also disclose PHI to funeral directors.

• Inmates: Under the federal law that requires us to give you this notice, inmates do not have the same rights to control their PHI as other individuals. If you are an inmate of a correctional institution or in the custody of a law enforcement official, we may disclose your PHI to the correctional institution or the law enforcement official for certain purposes, for example, to protect your health or safety or someone else's.

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ALL OTHER USES AND DISCLOSURES OF YOUR PHI REQUIRE YOUR PRIOR WRITTEN AUTHORIZATION

Except for those uses and disclosures described above, we will not use or disclose your PHI without your written authorization. Some instances in which we may request your authorization for use or disclosure of PHI are:

• Marketing: We may ask for your authorization in order to provide information about products and services that you may be interested in purchasing or using.  Note that marketing communications do not include contacting you with information about treatment alternatives, prescription drugs you are taking or health-related products or services that we offer or that are available only to our health plan enrollees. Marketing also does not include any face-to-face discussions you may have with your providers about products or services.

• Sale of PHI: We may only sell your PHI if we received your prior written authorization to do so.

• Psychotherapy Notes:  On rare occasions, we may ask for your authorization to use and disclose “psychotherapy notes”.  Federal privacy law defines “psychotherapy notes” very specifically to mean notes made by a mental health professional recording conversations during private or group counseling sessions that are maintained separately from the rest of your medical record.  Generally, we do not maintain psychotherapy notes, as defined by federal privacy law.

When your authorization is required and you authorize us to use or disclose your PHI for some purpose, you may revoke that authorization by notifying us in writing at any time. Please note that the revocation will not apply to any authorized use or disclosure of your PHI that took place before we received your revocation. Also, if you gave your authorization to secure a policy of insurance, including health care coverage from us, you may not be permitted to revoke it until the insurer can no longer contest the policy issued to you or a claim under the policy.

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HOW TO CONTACT US ABOUT THIS NOTICE OR TO COMPLAIN ABOUT OUR PRIVACY PRACTICES

If you have any questions about this notice, or want to lodge a complaint about our privacy practices, please let us know by calling or writing to Home OT Daily Member Services, 35 Bay St, Portland, ME, 04103 (207)200-3167. You also may notify the secretary of the Department of Health and Human Services.

We will not take retaliatory action against you if you file a complaint about our privacy practices.

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CHANGES TO THIS NOTICE

We may change this notice and our privacy practices at any time, as long as the change is consistent with state and federal law. Any revised notice will apply both to the PHI we already have about you at the time of the change, and any PHI created or received after the change takes effect. If we make an important change to our privacy practices, we will promptly change this notice and make the new notice available on our member website at: www.homeotdaily.com/terms-privacy. Except for changes required by law, we will not implement an important change to our privacy practices before we revise this notice.

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EFFECTIVE DATE OF THIS NOTICE

This notice is effective on May 1st, 2020.