Privacy and Security Policy
Effective as of March 16, 2018
Refine Acne Clinics’, Commitment to Protecting Your Information and Your Privacy.
Refine Acne Clinics, PLLC understands that your health information is very personal, and is dedicated to maintaining the privacy of your personally identifiable information, including your Protected Health Information (collectively, “PHI“). PHI includes information about you that may be used to identify you (such as your name, date of birth, or address), and that relates to (a) your past, present or future physical or mental health or condition, (b) the provision of health care to you, or (c) your past, present or future payment for the provision of health care. In operating the Website, Refine Acne Clinics, PLLC may receive information and create records containing your PHI. Refine Acne Clinics, PLLC is required by law to maintain the privacy of your PHI and to provide you with notice of its legal duties and privacy practices with respect to your PHI.
Health Insurance Portability and Accountability Act.
Refine Acne Clinics, PLLC is subject to all data privacy standards and laws set forth by the Health Insurance Portability and Accountability Act. Any information submitted through a Consult is considered Protected Health Information under federal law.
If you have a question or concern regarding Refine Acne Clinics, PLLC’s HIPAA policies, or would like to request a written copy of the HIPAA policy, you may contact Refine Acne Clinics, PLLC’s HIPAA Compliance Officer, Sam LaBine at sam(a)refineacneclinics.com.
If you feel Refine Acne Clinics, PLLC has violated any part of HIPAA, please file a complaint with the United States Department of Health and Human Services here.
Collection, Use and Disclosure of Non-Personally Identifiable Information.
Refine Acne Clinics, PLLC may collect information about your use of the Website that does not contain any PHI, or may aggregate or create de-identified information that does not contain any PHI by removing information that personally identifies you from other information collected (collectively, “Anonymous Information“). Refine Acne Clinics, PLLC reserves the right to use or disclose Anonymous Information without restriction, subject to applicable law.
Collection, Use and Disclosure of Personally Identifiable Information.
Refine Acne Clinics, PLLC does not collect your PHI without your authorization, though the use of certain features of the Website or Services will require you to provide certain information to us. Any information you provide to us when you visit or use the Website and/or when you register or use your Account is voluntary. This information may include the following PHI:
- Contact information, including, without limitation, name, email address, mailing address, and phone number; and
- Health or medical information, including, without limitation, medical records, age, gender, health background, health status, prescribed and over-the-counter medications, medical ID number, driver’s license number, laboratory testing results, and photos).
Subject to the restrictions on the use and disclosure of your PHI under applicable law, Refine Acne Clinics, PLLC may use and disclose your PHI (including to third parties) to:
- Provide for the dermatological diagnosis and treatment of acne and skin aging.
- Provide, operate, analyze usage of and improve the Website and Products.
- Communicate with you about the Website and Products, and to deliver any administrative notices or alerts and communications relevant to your use of the Website or Products.
- Tailor the features, performance and support of the Website and Products to you and your preferences.
- Troubleshoot problems with the Website and provide you with customer support.
- Market our services and those of third parties we believe may be of interest to you when you have given us express authorization to do so.
- Investigate, deter, prevent, defend against or take other action regarding violations of Refine Acne Clinics, PLLC’s Terms of Service, illegal activities, suspected fraud or situations involving potential threats to the legal rights or physical safety of any person or the security of Refine Acne Clinics, PLLC’s network, Website or Products.
- Respond to subpoenas, court orders or legal processes.
- Facilitate the negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another person or entity.
- Protect the personal safety of Refine Acne Clinics, PLLC, its customers, or any other person in an emergency.
- Fulfill any other obligation of Refine Acne Clinics, PLLC as required by law.
In the event that we are legally compelled to disclose your PHI to a third party, we will make every reasonable effort to notify you, unless doing so would violate the applicable law, court order or other legal requirement.
Additionally, when you visit the Website or complete a Consult, Refine Acne Clinics, PLLC may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited and average time spent on the Website. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve web design and functionality.
Disclosure of Personally Identifiable Information to Third Parties.
The Website may contain links to third party sites whose information, privacy and security practices may be different than ours. Before using these third party sites or providing them with your PHI, you should carefully review and evaluate the privacy notices for such sites, as Refine Acne Clinics, PLLC has no control over information that is submitted to, or collected by, these third parties.
Protection of Personally Identifiable Information.
Refine Acne Clinics, PLLC employs reasonable physical, electronic and managerial security measures, and follows generally accepted industry standards to safeguard your PHI.
Refine Acne Clinics, PLLC utilizes firewall barriers, high-grade SSL encryption techniques, and authentication procedures, among others, to maintain the security of your online sessions and to protect Accounts and systems from unauthorized access. Refine Acne Clinics, PLLC software and patient health records are stored on medically-secure servers and backed up daily. All data is encrypted during storage and transmission.
Refine Acne Clinics, PLLC strictly limits access to your PHI. Refine Acne Clinics, PLLC’s employees and agents are trained in our confidentiality and HIPAA privacy policies, and only those employees and authorized agents of Refine Acne Clinics, PLLC who need such information to provide you with the Products have access to your PHI, and only under strictly controlled conditions. Refine Acne Clinics, PLLC and its employees and agents will use PHI only as necessary to provide the products and services through its website and online consultation.
Please be aware that no method of data transmission over the Internet or method of electronic storage can be guaranteed to be perfectly secure. As a result, while Refine Acne Clinics, PLLC takes extensive measures to protect your PHI, it cannot ensure or guarantee the security of any information you transmit to Refine Acne Clinics, PLLC or through the Website. Refine Acne Clinics, PLLC DOES NOT COVENANT, REPRESENT, OR WARRANT THAT THE TRANSMISSION OF YOUR PHI ONLINE WILL BE SECURE, AND YOU DO SO AT YOUR OWN RISK.
Your cooperation is imperative in safeguarding your PHI. If you are prompted to create a password, please choose the password carefully, as anyone with access to your password will be able to assume your online identity and view your medical information, change your PHI, and communicate with your Refine Acne Clinics, PLLC’s health care providers. It is your responsibility to prevent disclosure of your password to others, and to change your password if you feel that its security has been compromised. You may change your password from your Patient Portal profile page after logging in. Additionally, you will periodically receive correspondence from Refine Acne Clinics, PLLC at the email address you register with your Consult or on in the subscription box. While these emails will never contain your photos or payment information, they will sometimes include information relating to the details of your acne or skin aging treatment (as applicable). Accordingly, it is critical that you safeguard your designated email address and restrict access thereto. The registration of an email address with your Consult indicates your consent for Refine Acne Clinics, PLLC to transmit your PHI to such address.
Opting Out Of Future Communications
You can stop receiving marketing emails from Refine Acne Clinics, PLLC by clicking the unsubscribe link included at the bottom of a Refine Acne Clinics, PLLC marketing email. You cannot opt out of certain emails we need to send you relating to normal business operations (for example, direct messages from the Refine Acne Clinics, PLLC staff). To opt out of all emails from Refine Acne Clinics, PLLC, you may email email@example.com and terminate your relationship with Refine Acne Clinics, PLLC and all products and services the company offers.
Deleting Your Personal Health Information.
You may access and update certain information, or deactivate your Patient Portal Account from your dashboard page after logging into your Patient Portal. Additionally, you may at any time make a request to access, correct or update the PHI that Refine Acne Clinics, PLLC has collected about you by contacting us at firstname.lastname@example.org including requests to:
- View your medical records that have been provided to Refine Acne Clinics, PLLC.
- Inspect and copy your PHI.
- Amend your PHI if you believe your file is incomplete, incorrect or obsolete.
- Receive an accounting of all disclosures Refine Acne Clinics, PLLC has made of your PHI.
Refine Acne Clinics, PLLC will make reasonable efforts to respond promptly to all such requests. Refine Acne Clinics, PLLC may impose a fee for the costs associated with your request, including the costs of labor, materials and/or shipping. In certain circumstances, Refine Acne Clinics, PLLC may deny your request. In the event of a denial, we will inform you of the reason for such denial and you will have the opportunity to request a review of the denial and submit a statement of disagreement for inclusion in your records. Refine Acne Clinics, PLLC will not verify, modify or otherwise alter any of your PHI without your request or consent, provided that Refine Acne Clinics, PLLC may correct any errors or modify any immaterial information at any time.
You may at any time make a request for Refine Acne Clinics, PLLC to delete your PHI. Refine Acne Clinics, PLLC will promptly comply with all such requests, but only to the extent such requests are not in conflict with any requirements to retain such information pursuant to applicable law or otherwise. When we delete your PHI, it will be deleted from the active database, but may remain in our archives; we may also retain and continue to use your Anonymous Information. Due to HIPAA regulations, a copy of all medical data must be retained for seven years. Refine Acne Clinics, PLLC complies with this regulation by archiving that information on a secure, off-site, third-party server. Further, to the extent your PHI has been disclosed to third parties; Refine Acne Clinics, PLLC may not be able to access such PHI or cause the deletion or modification of such PHI by the relevant third parties.
As you browse Refine Acne Clinics, PLLC, advertising cookies will be placed on your computer so that we can understand what you are interested in. The techniques our partners employ do not collect personal information such as your name, email address, postal address or telephone number.
Persons under the Age of 18.
Persons under thirteen (13) years of age are not eligible to use the features, services and other aspects of the Website or the Products. Further, Refine Acne Clinics, PLLC does not knowingly collect PHI from anyone between the ages of thirteen (13) and eighteen (18) unless Refine Acne Clinics, PLLC has authorization from the parent or legal guardian of such individual. A parent or guardian of a person under the age of eighteen (18) may review and request deletion of such individual’s PHI as well as prohibit our use thereof. If you are a parent or guardian of an individual under the age of eighteen (18) and believe your child has disclosed PHI to Refine Acne Clinics, PLLC without your consent or authorization, please contact us at email@example.com.