Aledade Privacy Policy

Thank you for visiting the Aledade Privacy Policy (“Policy”). Aledade, Inc. and its subsidiary companies (collectively “Aledade,” “we,” “our,” “us”) help primary care providers improve the health of their patients and communities by participating in value-based care arrangements called Accountable Care Organizations or ACOs.

This Policy applies to the personal information we collect through our website (“Website”), through the Aledade Population Health Management Platform (the “App”), our Aledade Plus advanced care planning services (“A+”), and our other products and services (collectively, the “Services”) and describes:

• The Personal Information We Collect
• How We Collect Personal information
• How We May Use Personal information
• Who We Share Personal Information With
• How You Can Control Your Privacy Preferences
• How to Contact Us

1. Scope of this Policy.

Personal information. We use “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked – directly or indirectly – with a particular individual or household. For this Policy, “personal information” does not include (a) aggregated or deidentified information that is not capable of being associated with or reasonably linked to an individual, (b) public information lawfully available from governmental records, or (c) protected health information or “PHI” that we process in our capacity as a business associate under the Health Insurance Portability and Accountability Act or “HIPAA”.

Patients. If you are a patient of a practice that participates in one of our ACOs, you can find out more about your practice’s privacy practices by contacting them directly.

Personnel. This Policy does not apply to our processing of personal information about job applicants, employees, or contractors.

Third-Party Links. For convenience, our Services may link to third-party sites that we do not control. This Policy does not apply to third-party sites, including how they define personal information or how they use it. We encourage you to read any third-party’s privacy policy and know your privacy rights before interacting with them.

International Users. Our Services are hosted in the United States and are intended for access and use by individuals located in the United States only. By using our Services, you consent to the transfer of your personal information to the United States as described in this Policy. Please do not use our Services if you do not agree to the transfer and processing of your personal information in the United States or if it is illegal to do so in your home country.

2. Changes and Updates to this Policy.

We may change this Policy at our sole and absolute discretion and will post any changes on this page and update the date at the top, so be sure to check back periodically. All changes are effective when we publish them unless otherwise noted. By continuing to use our Services after we’ve posted changes to this Policy, you accept any changes.

3. Personal Information We Collect.

This section describes the categories of personal information we may collect about you. The types of personal information listed in each category are examples only and are not exhaustive.

• Personal identifiers and contact information, such as name, title, date of birth, postal and email address, telephone and fax number, National Provider Identifier (NPI) number, group practice number, state medical license number, tax identification number, and other unique identifiers.
• Web log and cookie information, such as device identifiers, user ID, IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data, cookie identifier, browsing and search history.
• Health care practice-related information, such as information about the practices that participate in our ACOs and their patients.
• Demographic information, such as gender, military service, citizenship status and other protected class information that you may choose to provide us to the extent permitted by law.
• Commercial and financial information, such as accounts payable information relating to our service providers, vendors, and contractors.
• Educational, professional, or employment-related information, such as information about where you work and your company’s name, your position, what certifications or degrees you have obtained, or your educational, professional and employment history, and resume information.
• Audio and visual information, such as the sound of your voice, or your image, if you attended and spoke at a webinar that we hosted or attended an event with us or left us a voicemail.
• Location data, as it can be derived from your IP address and practice-location information provided to us by App users when setting up an account.
• Inferences drawn from any of the information identified above to create a profile reflecting your preferences regarding the App.
• Advanced care planning information through A+, such as information for living wills, powers of attorney, advanced care directives, medical and medication directions, as well as personalized health care objectives.
• Other information you or others provide us. You or others may provide us with other personal information when communicating or otherwise interacting with us, such as information about your family and associations.

4. How We Collect Personal Information.

We collect personal information from the following sources:

• You, including information you (a) provide to us directly when communicating with us or using our Services; (b) submit through the Website or when registering for and using the App; (c) registering for a webinar or events, or (d) through your interactions with us such as during a collaborative research project.
• Web logs, Website analytic services, and Cookies, including information that is collected automatically from your device and stored in log files. For more information on website analytics and cookies, please see the Advertising and Analytics section below.
• Third parties, including:
  • practices that participate in our ACOs;
  • business contacts such as those that refer you;
  • services providers, including technology/website hosting providers, analytics providers, and systems administrators; and
  • data collection and aggregation services that, in turn, obtain this data from publicly available sources. We also obtain information from proprietary databases.

5. How We May Use Personal Information.

We collect each of the categories of personal information above for a variety of purposes.

• • To contact you, including to respond to your inquiries and questions, to contact you with information about our Services and promotional or other information that may be of interest to you, or to consider you for certain partnerships or collaborative opportunities).
  • To operate our business and offer or provide Services, including client services, events, information, fulfilling our contractual obligations, and to alert App users to new projects, features, and services.
  • To identify individuals, practices, or groups that might work with us, and pay you for, or communicate with you about, products or services you provide to us.
  • To identify potential practices that may want to participate in one of our ACOs.
  • To facilitate the management of care for patients and health care operations consistent with the App Terms of Use or other applicable set of Service terms.
  • To offer, maintain, and improve the Services that we provide or make available, including troubleshooting, and to give us insights on how you and other users utilize our Services.
  • To protect and secure our Services, assets, network, and business operations, and to detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.
  • To facilitate marketing or re-marketing of our Services to you, including to track and associate Internet search and browsing behavior with our advertisements, and to help us understand what information and Services you may be interested in. However, this excludes any mobile phone number you provide us.

• For our business purposes, such as data analytics, audits, developing new products, conducting research regarding our Services for the purposes of enhancing, improving, or modifying our Services, increasing business efficiencies, and planning, operating, managing, and expanding our business activities.

• As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and governmental authorities; (d) to protect our rights, privacy, safety, or property, and that of our ACOs, you, or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain.

6. Who We Share Personal Information With.

We may have disclosed each of the categories of personal information above to third parties for a business purpose and may continue to do so. The categories of third parties with which we share personal information include:

• Service providers, such as information technology providers, marketing and other contractors operating on our behalf that support the operation of our business and our Services.
• Practices that participate in our ACOs and other business contacts. As a reminder, this Policy does not apply to the collection, use, or disclosure of personal information by practices participating in our ACOs, though we may share information about inquiries we receive from individuals directly with the applicable practices. Please contact your practice with questions about their privacy practices.
• Advertising and analytics partners. We may allow our third-party advertising and analytics partners to use cookies, scripts, pixels, beacons and other online data collection technologies (collectively, “Cookies”) to collect information about the use of our Services over time and the activities of users across unaffiliated sites and services. We and our partners may use the data collected from our Services to make personalized offers relating to our Services on third-party sites that you visit (e.g., Facebook, Twitter, and LinkedIn). For more information, please see the Advertising and Analytics section below.
• Law enforcement, governmental authorities, or other third parties to protect our rights and the rights of others, such as to respond to legal requests and legal process; in connection with the establishment, exercise, or defense of legal claims; to protect our rights and interests, including to enforce our agreements, policies, and terms of use; to detect, suppress, or prevent fraud; or to protect the health and safety of us, our ACOs, or any person.
• Third parties who may acquire all or part of our business or assets or act as successors in interest to our business or to whom we transfer any of our rights or obligations, in which case your personal information may continue to be used by that third party in a manner consistent with this Policy.
• As otherwise described to you when collecting the personal information.
• As otherwise directed by you, such as sharing advanced care planning information collected through A+ Services.

7. Advertising and Analytics.

We and our third-party partners collect information about your use of our Services through Cookies for the purposes of analytics and interest-based advertising based on your browsing history. We permit third-party online advertising networks, social media companies and other third-party services, to collect information about your use of our Services over time so that they may play or display ads about our Services on other websites, services, or devices you may use.

To summarize, we may engage in the following:

• Analytics. We permit our analytics partners to collect information about users of our Services through Cookies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site(s), advertising ID, IP address and other information about your device. We may share a common account identifier (such as a hashed email address or user ID) with our analytics partners to help identify you across devices. This data is used to identify and remedy issues with our Services, to give us insights on how you and other users utilize the Services, to develop new services, and to conduct research regarding our Services for the purposes of enhancing, improving, or modifying them.
• Advertising. We permit third-party online advertising networks, social media companies and other third-party services, to collect information about your use of our Services over time so that they may play or display ads about our Services on other websites, services, or devices you may use. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. To learn more about online behavioral advertising, and your ability to opt out of this type of advertising (sometimes called interest-based advertising) visit one of the advertising industry-developed opt-out pages, such as https://youradchoices.com/ or https://www.aboutads.info/.

We support the self-regulatory principles of the Digital Advertising Alliance (“DAA”). We work with advertisers, advertising networks, advertising servers, and analytics companies (“Ad Partners”) that use data collection technologies to understand how our Services are being used and to analyze your browsing history to deliver advertising relevant to your interests, as well as to provide advertising-related insights. These advertisements may appear on other websites or services, including through social media networks. These Ad Partners may be able to associate devices across third-party websites or services over time and link various devices used by the same individual.

• Social media platforms. We may display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, Snapchat, and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier – like a user ID or hashed email address – with these platform providers or they may collect information from our website visitors through a first-party pixel, to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
• Third-party advertising and analytics partners. We work with a variety of third-party partners to provide advertising services. For example:

• Google Analytics. We use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. Google Analytics also allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. We share a unique identifier – like a user ID or hashed email address – with Google to facilitate the service. Google Analytics’ data practices are governed by the Google Analytics Terms of Service and the Google Privacy Policy, as they may be amended from time to time. For more information about Google Analytics and the information it collects, you can visit Google Analytics’ policies here. You can view the Google Analytics’ Opt-Out Browser Add-On here. We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available here, or by visiting NAI’s online resources here.

• Pardot. We use Pardot to learn more about how you use the Website. Pardot sets a cookie on your browser to remember your preferences when you return to our site; these cookies store a unique identifier. To learn more about the cookies that Pardot sets, you can visit Pardot’s website here.

• Pendo.io, Inc. We use Pendio.io, Inc. cookies help us maintain and troubleshoot the App, improve the App and our services, and for other purposes described above. To learn more about Pendo’s privacy practices, please review Pendo’s Privacy Policy here. We may also use Pendo.io’s session replay to improve the App. Session replay allows us to watch playbacks of your interactions with the App (masking any sensitive data, such as PHI), and provides our internal teams with insights into your use of the App.
• AdRoll. We also deploy a pixel from AdRoll to track your behavior on the Website and facilitate re-marketing of our Services on other third-party sites that you visit later. For a list of third-party sites where we may re-market our Services to you via the AdRoll pixel, please click here. For information about AdRoll’s California Consumer Privacy Act (“CCPA”) disclosures, please click here.

For more information about how Ad Partners use the information collected by these technologies and your options for restricting Cookies placed by some of these Ad Partners, please visit the DAA’s opt-out page. The DAA’s opt-outs are device- and browser-specific and may not work on all devices. If you choose to opt-out through the DAA’s tools it does not mean you will cease to see advertising. Rather, the ads you see will be based on the website or application you are visiting and not your interests.

8. Privacy Preferences.

You have some choices regarding how we use your personal information, including the following:

• • Controlling promotional email communications preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in the email. You can also email us at privacy@aledade.com and ask to be unsubscribed from our marketing emails. You may still receive Service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Website and App, technical and security notices).

• Modifying your device settings. You can restrict our Website and App from accessing certain device information, such as advertising IDs, or permitting the use of Cookies by changing your permissions in your mobile device’s settings menu. Please note that the withdrawal of permission to access some device information may result in an inability to take full advantage of our Services.

• Controlling data collected by Cookies.  You can control the data collected by Cookies using a variety of tools. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies. For additional options for restricting Cookies placed by Ad Partners, please visit the DAA’s opt-out page. The DAA’s opt-outs are device- and browser-specific and may not work on all devices. If you choose to opt-out through the DAA’s tools it does not mean you will cease to see advertising. Rather, the ads you see will be based on the website or application you are visiting and not your interests. Certain features of our Services may not be available if cookies are disabled.

9. Children under 18. 

Our Services are not designed for, directed to, or intended for use by children under the age of 18. If you are under the age of 18, please do not use our Services or otherwise provide us with any person data either directly or by other means. If a child under the age of 18 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that remove the personal information from our system. If we know that a child under the age of 18 is using our Services, we will take steps to delete such data as soon as possible.

10. Retention of Personal Information.

We retain personal information only for as long as is reasonably necessary to fulfil the purpose for which it was collected. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

Therefore, we retain personal information for as long as you continue to use our Services for the purposes explained in the How We May Use Personal Information section above. When you stop using our Services, we will retain your personal information for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices you have made, such as to receive marketing communications. We will also retain personal information supplied when signing up for our Services, including complaints, claims and any other personal information supplied during the contract period until the statutory limitation periods have expired, when this is necessary for the establishment, exercise or defense of legal claims.

11. Region-Specific Disclosures.

Additional or different disclosures relating to the processing of personal information apply to residents of the following states:

• California & Colorado. If you are a resident of the States of California or Colorado, please click here for additional state-specific privacy disclosures.

• Nevada. If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits you to opt out of potential future sales of certain covered information that a website operator has collected or will collect about you. To submit such a request, please contact us at privacy@aledade.com.

12. Contacting Us.

Questions. If you have questions on the processing of your personal information or are unhappy with how we’ve handled your personal information, please contact us at:

Mail: Aledade, Inc.
Attn: Privacy Officer
4550 Montgomery Avenue, Suite #950N
Bethesda, MD 20814

Email: privacy@aledade.com

Accessibility. We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests, please contact us toll free at 866-252- 0873 or send an email to disabilityaccess@aledade.com.

App support. If you need App support, please contact our App Support Team at aas@aledade.com.