You agree to this Policy by displaying, using or accessing the THC Website or any service or feature provided by THC, by providing personal or user information to the THC Website, by submitting or posting any information or other material to the THC Website, or by allowing or authorizing any person to do any of the same on your behalf or for your benefit. If you do not agree with this Policy, please do not use, or authorize another on your behalf to use, the THC Website or any such services or features. Questions and concerns regarding this Policy should be directed by e-mail to email@example.com.
This policy explains:
“Clinic Team”. The Clinic Team is made up of the clinicians who directly provide or support your care at the Clinic and may also include administrative colleagues.
“personal data”. Personal data is any information relating to a living individual who can be identified from the information.
“special personal data” or “special category data”, this is data that is deemed to be more sensitive than the above personal data. It includes for example data about your health (including mental health), genetic data and biometric data where processed to uniquely identify an individual; your gender and ethnicity.
Personal information we collect
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number. We refer to this information as “Order Information”.
How do we use your personal information?
We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
- Communicate with you;
- Screen our orders for potential risk or fraud; and
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
Sharing you personal Information
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
THC respects your privacy. Any information you give us is held with care and security, and will only be used as described in this Policy or otherwise with your consent. Furthermore, any information you provide us through the THC Website which constitutes “Protected Health Information” under and as described in the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, together with the regulations promulgated thereunder by the U.S. Department of Health and Human Services (collectively, “HIPAA”) shall be stored and treated in accordance with HIPAA requirements, subject to and as further described in this Policy.
However, we want to be upfront about the fact that part of the THC business includes providing you with access to materials, information, features and services in exchange for the right to use, on an opt-in or out basis (as described below) certain marketing, purchase preference, demographic, and other information which you may provide, or which we may collect based on your usage of the THC Website, and which we may leverage for the various commercial purposes described below or on the web pages where we collect such information. We will always use reasonable efforts to inform you as to the purposes for which we will use information, either through this Policy or as we collect it from you.
During registration (and possibly thereafter) you may be asked to give your name, a contact telephone number, a PIN or password, your date of birth, your postal address, e-mail address, and other contact or pertinent information. THC may also ask for other information required to provide particular services, such as your business name, information pertaining to your medical condition(s), practice specialties (if you are a physician or clinic), and other relevant information. Information may also be collected by your presence on the THC Website, even if you have not registered or subscribed.
Generally, this information falls into one of five categories:
(1) “Personal Identifying Information,” such as your name and e-mail address, which can be used to personally identify or contact you (or to confirm your identity in the case of user IDs and passwords),
(2) Protected Health Information (“PHI”), such as any medical conditions you may have, your medical history, your treatment history, and like information,
(3) “Billing Information,” such as your credit card information and billing address, which is a subset of Personal Identifying Information and which we may use to bill you for a service or feature which you have knowingly purchased,
(4) “Usage Information” such as your IP address, public postings, opinions or other matter you have either posted or reviewed, your click patterns on the THC Website, and other information indicative of your use of the service or features on the THC Website, and
(5) “Anonymous Information” which is an aggregate of the other information categories decoupled from any method of identifying the source of that information, which we use to determine the demographics, habits, preferences, or statistical characteristics of the THC Website users or subgroups thereof, but which cannot be used to identify you or your specific usage history. Anonymous Information may include portions of Personal Identifying Information, PHI, and Usage Information which have been decoupled from any identifying information and aggregated with that of other THC Website users.
How Each Type of Information Is Used
THC will use your Personal Identifying Information as follows:
(1) to regulate access to the THC Website and its features and services, as well as to your account (such as requiring passwords to access certain services or post content);
(2) to personalize and enhance your experience when visiting the THC Website;
(3) to promote to you (including contacting you by e-mail) THC or THC endorsed products or services, or other products or services in which we believe you may be interested, but only when you opt-in to receive our promotions and newsletters, and you may later opt-out from promotional emails through various mechanisms we provide (your PHI may also be used in a similar fashion as described below); and
(4) for other internal or administrative purposes consistent with our mission of providing our users with the highest quality experience, including contacting you about administrative issues pertaining to your account, or critical updates to the THC Website or the services you use or purchase. THC does not share, sell, rent, or trade Personal Identifying Information with third parties for their promotional purposes, except as you may expressly consent when such information is collected or may later expressly consent.
If you are registered as a “patient” (or similar designation) with the THC Website, THC will use your PHI, as coupled with Personal Identifying Information, only as you specifically direct or as otherwise may be permitted under HIPAA. For example, if you request us to assist you in scheduling a consultation with a doctor or clinic pertaining to a health condition you specify, we will request certain PHI (such as your health condition, medical history, treatment history, your history of use of medical marijuana, and other information) and provide that information to the doctor or clinic in conjunction with the appointment request unless you direct us not to disclose such information. In addition, if a doctor recommends to you treatments using medical marijuana, and that information is provided to the THC Website by the doctor or clinic, we will store and disclose that information (which may include PHI related to your condition and recommended treatments) as part of the THC medical marijuana recommendation certification service (see https://www.marijuanadoctors.com/tools/patient-verification, the “Certification Service”) unless you opt-out of the Certification Service.
This information will be accessible to clinics and other THC Website users who have your driver’s license and the physician/clinic recommendation number.
We may also use PHI, without disclosing it to others, to personalize and enhance your experience when visiting the THC Website and to promote to you (including contacting you by e-mail) THC or THC endorsed products or services, or other products or services in which we believe you may be interested based upon such PHI, but only when you opt-in to receive our promotions and newsletters, and you may later opt-out from promotional emails through various mechanisms we provide. In addition, we will decouple certain PHI from Personal Identifying Information and use this to create Anonymous Information which we will use as described in this Policy: for example, while we would not disclose your specific health conditions except as described in this Policy, we may create aggregate information from your PHI as combined with others’ PHI, such as the percentage of THC Website users registered as patients who seek treatment based on specific health conditions and use this as Anonymous Information.
We will use your Billing and Usage Information, as applicable, to bill you for the services which you knowingly purchase and to provide you with technical and billing support.
We will use Anonymous Information to optimize our marketing and product development efforts (such as keyword advertising purchases and search engine optimization), to determine the success of our marketing campaigns, to provide anonymous demographic information to sponsors, advertisers and partners, and other relevant commercial purposes which do not identify you individually. We may also provide Anonymous Information to our sponsors, advertisers and partners so that they may track the success of their advertising and promotional efforts, for example, to determine the demographic attributes and use preferences of visitors to pages in the THC
Website that feature their products or services.
THC may use third party providers and subcontractors for the features and services offered on the THC Website and also for internal, administrative, and tracking purposes. Service through these providers may necessarily include providing them with some or all of your Personal Information, PHI, Billing Information (for credit card processing, collections, and related matters), and your Usage Information (for subcontracted services and features), but we will use diligent efforts to restrict use of this Information by these third parties to the purpose of providing the specific THC feature, function, service or purpose for which the third party has been engaged, and, to the extent such parties are provided PHI, only to the extent they agree to abide by HIPAA obligations imposed on such parties based on their role and relationship to THC. Additionally, THC may share your Information with parents and affiliates under its control or common control, subject to the same restrictions described in this Policy.
In addition, THC specifically reserves the right, to the maximum extent permitted by law, to use or disclose any Information:
(a) for the purposes of enforcing our user agreements, use policies and the like or
(b) when requested by law enforcement agencies (whether or not under subpoena), if we reasonably suspect a violation of our user agreements or use policies or any applicable law.
How to Correct, Update or Delete Your Personal Identifying Information
If your Personally Identifiable Information changes, or if you no longer desire our service, you may update, correct, or delete such information by logging in to your account at the THC Website and then going to your profile page, or by contacting us at the contact information provided below. You may then correct or update the information presented.
Security: How Information is Stored
THC has appropriate technical and organizational security measures in place to reasonably protect against the loss, misuse and alteration of user data under our control. For example, we use appropriate encryption for payment card transactions, and we impose strict rules on THC employees who have access either to the databases that store member or user information or to the servers that host our services. We train our staff to understand applicable HIPAA and PCI requirements so as to avoid any violations of applicable standards. We also use reasonable efforts to assure that any subcontractor, provider, or other party that has access to any PHI has agreed to comply with appropriate HIPAA requirements. While we cannot guarantee that loss, misuse or alteration of data will not occur, we make diligent efforts to prevent such unfortunate occurrences.
Billing Information may also be stored by our payment card processors and be subject only to our limited control. If you are concerned about storage and use of your Billing Information by payment card processors, please e-mail us at firstname.lastname@example.org we will provide you with information on the privacy practices of our current payment card processors and related vendors.
Please note that information or data (including Usage Information), other than PHI and Billing Information, may not be stored in a manner which is PCI or HIPAA compliant. Accordingly, other than the PHI and Billing Information which we specifically request and/or state will be protected in accordance with the relevant standard, we do not recommend that you post, upload, provide, or use the THC Website or any related feature to collect or store any sensitive financial, payment, or personal information, and we cannot be responsible in any manner if you do so.
Additionally, we strongly recommend that you keep all of your user information, such as account IDs, passwords, and other sensitive information secret and not disclose such information to anyone else. We cannot be responsible for any use of this information should you disclose it to anyone else, or for the use or distribution of any of your information or data stored with the THC Website if it is obtained via use of your account ID or password. Please note that THC will never email you to “phish” for (attempt to convince you to disclose) your username or password.
Use of “Cookies,” Web Beacons, and Log Files
Similarly, THC, its advertisers, subcontractors, and other partners may also use “web beacons” (small image files which are used to track presence on web pages and surfing patterns) in a similar fashion to cookies, except that web beacons do not store any personal information on your computer. We may also use web beacons or similar technology to track clicks from our newsletters and the like.
Doctor, Clinic and Dispensary Inquiries
Patients may transmit requests for consultations, appointments, and other information to doctors or clinics via features available on the THC Website or other methods we may make available. If you send such an inquiry, a subset of your pertinent Personal Information and PHI, including your email address and any other information you supply at such time, may be visible and available to the applicable doctor, clinic, or dispensary, so that they may respond to your request or inquiry. We do not control whether such doctor, clinic, or dispensary adds you to its mailing lists or otherwise uses the information you choose to supply during said process.
We strongly recommend that you do not provide, during the inquiry process, any information that you do not wish doctors, clinics, or dispensaries to have. We also strongly recommend that you NEVER send any credit card, bank account, or other payment or financial information, nor any other confidential information, through such methods (and NEVER by email at all!).
Your inquiries are forwarded to the individual doctor, clinic, or dispensary you selected and also retained by us as Usage Information, from which we may create Anonymous Information.
Posted Information and Content; Use of Listing and Community Features
Although it is probably obvious, to the extent you submit or post any statement, opinion, testimonial, review, or listing to the THC Website (or any material which by its nature appears to be intended to be published or posted) or participate in any forum, chat, opinion feature, message board, blog, or any other interactive or community service or feature on the THC Website, all of the information contained in your submission or communications will likely become public information on the THC Website and possibly published by our affiliates or partners, and THC will not have any control over the use of such information by users and third parties with access to that information. THC reserves the right to use all of such information at its discretion without restriction.
Accordingly, if there is any matter in any such material which you do not intend or wish to be publicly available, published, distributed and otherwise used in a public fashion, please do not include it or submit it. We cannot honor any special request from you in that regard. We strongly discourage the submission or posting of any PHI in any such public forum or feature unless you wish such information to be publicly available.
Similarly, information posted or provided by doctors, clinics, dispensaries, and others about their specialties, practices, office hours, and similar matters, will be, subject to THC discretion, made publicly available to patients and other users to assist patients in identifying, choosing, locating, and communicating with them. Accordingly, we recommend that doctors, clinics, and dispensaries only provide information about themselves that they wish to be displayed publicly.
Additional privacy policies and other terms may apply to use of any community or interactive feature or service available through the THC Website or otherwise provided by THC. Please check the pages containing those features and services for more information.
Patients, clinics, doctors, dispensaries, and other THC Website users may receive one or several of our various newsletters. You may cancel your newsletter subscription at any time upon written notice to email@example.com.
Please note that all information and material collected or provided, in any manner and of whatever nature, may be transferred or assigned by THC in conjunction with a merger or the sale of all or a portion of the THC business (or similar event).
This Policy does not apply to business ideas, concepts or inventions that you send as suggestions or proposals to THC. If you want to keep content or business information, ideas, concepts or inventions private or proprietary, do not send them to THC without reaching an agreement with us as to its treatment, as we otherwise reserve the right to use them in our discretion. This Policy also does not apply to any information you submit to THC by e-mail unless expressly so stated herein.
Links to Other Websites
The THC Website contains links to third party websites and advertisements leading to promotions of third party products and services outside of our control. THC is not responsible for the privacy practices of such other websites or promotions. We encourage our users to be aware when they leave our website and to read the privacy statements of each website that collects personally identifiable information. This Policy applies solely to information collected by the THC Website and other websites operated or controlled by THC, and not any third party website.
The THC Website and the functions and features we offer are not intended for use by children or minors, although parents or guardians of minors who need to seek doctors or clinics may use the THC Website on such minors’ behalf. We ask that children and minors not use the THC Website directly, whether or not supervised by parents or guardians.
Modifications; Cancellation; Refund Policy
THC reserves the right to reasonably modify this Policy at any time. Minor changes will be posted on the THC Website, and you will be notified of material changes to this Policy by either:
(a) e-mail (to the e-mail account you registered with) or;
(b) a prominently posted notice, either here or on the THC Website home page, of pending material changes at least 30 calendar days prior to the effectiveness of such change.
If you do not agree with any such changes, or if you no longer wish to be subject to this Policy, you may contact THC (see above and also the terms tocancel your account, and upon complete payment of any amounts due and owing for any paid THC service you have knowingly purchased (if applicable), THC will use diligent efforts to delete your Personal Identifying and Billing Information.
The terms contained in this Policy are subordinate to any contrary terms contained in any express user or membership agreement between a user, doctor, clinic, or dispensary and THC or to any express written agreement containing the signatures of authorized representatives of both parties.
THC’s liability from or arising out of this Policy or any breach thereof is subject to the general limits of liability stated in the terms.
If you are located in a state (or other jurisdiction) where the THC Website is operated by an Affiliate, your relationship is solely with such Affiliate and not with THC, and any claims you may have arising out of or relating to this Policy or the THC Website shall be made solely against such Affiliate, and not THC.
You May Contact Us Here:
Transformative Health Center
13013 Justice Ave.
Baton Rouge, La 70809
Effective Revision Date: 10/24/19
Copyright © 2019 Transformative Health Center, Inc.
HIPAA is a federal law that protects the privacy of identifiable patient information, requires electronic and physical security standards related to the storage and use of PHI, and establishes standard transactions and code sets to simplify billing and other electronic transactions. HIPAA standards were updated in 2009 by the implementation of the HITECH Act and again in 2013 by the HIPAA Omnibus Rule. In accordance with HIPAA standards, MarijuanaDoctors.com is HITECH and BAA certified, and has put in place measures to protect the confidentiality of health information in any form, whether written, oral, or electronic.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at firstname.lastname@example.org
Transformative Health Center
[Re: Privacy Compliance Officer]