Effective: December 14, 2018
Integrated Healthcare Association, (“IHA”, “we,” “us,” “our”) owns and operates the Symphony Provider Directory (“Symphony”). Symphony is a centralized, statewide, cloud-based technology platform for providers and health plans that serves as a single source for provider directory data such as demographics, services, products and networks (“Service”).
We are committed to letting you know what kinds of information we may gather about you, how we will collect, use, and share that information, and how you can contact us or otherwise manage that information.
Information We Collect About You
We collect, process, and retain information from you and any devices you may use when you use or interact with our Site and Service, and in other ways described below.
Types of Information We Collect: We collect two basic types of information from you: (1) personally identifiable information (“PII”) and (2) non-personally identifiable information (“non-PII”). PII is any information that you supply to us that can individually identify you. PII includes, among other things, your name, contact information (e.g., email address, postal address, telephone number, place of work) and identification numbers (e.g., National Provider Identifier or Federal Employer Identification Number (FEIN). Non-PII includes information that does not personally identify you. Non-PII includes, among other things, gender, information about your use of the Site such as your general location information, your search terms and search results and other information regarding your use of the Service.
Personally Identifiable Information: As a general matter, you can browse the Site without submitting your PII to us. However, there are a number of circumstances in which you may supply us with your PII. The following lists the most common ways in which we may collect your PII:
- Registration for an account or creating a profile
- Accessing the Service
- Automatically as you navigate through the site. Information collected automatically may include IP addresses and information collected through “cookies” and other tracking technologies.
- Signing up to receive e-mail offers, newsletters, or alerts
- Participation in surveys, panels, or market research
- Any other place on the Site where you knowingly volunteer information
Information You Give Us: We receive and store information you enter on our Site, information contained in any separate customer agreement you have with us, information you give us in accordance with such an agreement, and information that you give us in any other way.
Information We Automatically Collect: We collect information about your use of our Site, such as the pages you view and other interactions you have. We receive and store certain types of information whenever you interact with our Site. Our Site uses “cookies,” tagging, and other tracking technologies to help enable your use of the Site and enable us to enhance or personalize your experience. This information includes computer and connection information such as statistics on your page views, traffic to and from our Site, referral URL, your IP address, and device identifiers. This information also may include your browsing history, transaction history, and your web log information.
Location Information: When you visit our Site, we may receive information about your location and your mobile device, including a unique identifier for your device. Location information allows us to provide location-based services, such as search results, and other personalized content. We will only collect precise geo-location information with your consent; however some services or features may not function properly without this information. See How to Limit the Use of Your Information for more information.
Information from Other Sources: We may supplement the personal information we collect with information from third parties, including the health plans that are participating in the SYMPHONY PROVIDER DIRECTORY, or from our offline interactions with you to, among other things, enable us to verify and/or update information contained in our records and better serve our users.
How We Use Your Information
We may use and disclose information we gather about you, including your PII, to operate the Site; provide the Service; to improve, correct, and maintain the Site and Service, including fulfilling your requests for information; analyzing and compiling trends and statistics, and communicating with you.
We also may use your information to:
- Verify your identity and account information;
- Provide customer support;
- Track and evaluate the use of the Site;
- Send you information about features and enhancements on or to our Site;
- Send you newsletters or other materials;
- Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal; and
- Perform statistical, demographic, and marketing analyses of users of the Site and their usage patterns.
Combination of Your Personally Identifiable Information: We may use the information from one portion of the Site on other portions of the Site, and we may combine information gathered from multiple portions of the Site into a single record. We also may use or combine information that we collect offline or we collect or receive from third-party sources for many reasons, including to enhance, expand, and check the accuracy of our records. Additionally, information collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected.
How We Share Your Information With Others
We share your personal information with third parties as described below. In addition, we may share information that does not specifically and personally identify you, such as aggregate information, device identifiers or other unique identifiers publicly with our partners, agents, or vendors. For example, we may share information publicly to show trends about the quality of provider information over time through the use of our Services.
Information collected from Healthcare Providers
We use and distribute PII provided by healthcare providers that have registered for the Services (“Providers”) to health insurers and health care service plans (“Health Plans”) that are participating in the SYMPHONY PROVIDER DIRECTORY (“Participating Plans”), and with which the Provider has a current contractual obligation or obligation under state of federal laws to provide such PII, including any changes and updates. Our distribution of PII to such health plans will be tracked in an audit log which Provider will be able to view through its account on the Site.
Information collected from Health Plans
We use and share information provided by Participating Plans about the Providers with which they have a contractual relationship, including any changes and updates to such information, with other Participating Plans. We do not share information related to Providers with Participating Plans if the information is not specifically authorized by the Provider, or is not required by the Health Plan to comply with state and federal regulations related to provider directory maintenance.
The Site enables Providers and/or Participating Plans to enter into Private Data Sharing Agreements under which additional data elements can be shared between the contracting parties. Our distribution of extended data elements under a Private Data Sharing Agreement will be tracked in an audit log which the Providers will be able to view through their accounts on the Site.
Third-Party Service Providers
We may engage third-party service providers to perform functions on our behalf such as hosting and analytics including, but not limited to: hosting, technical integration, analytics, maintenance, customer services and fraud protection. These entities may have access to PII if needed to perform their functions, which we will share as needed.
We may also provide your PII to third parties to whom you ask us to send such information.
Business Partners: We may share information that personally identifies you with business partners who provide products and services that we think you may be interested in.
Law Enforcement, Legal Process, and Emergency Situations: We may also use or disclose your personal information if required to do so by law or on the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or our Site; (b) protect and defend our rights or property, the Site or our users, or (c) act to protect the personal safety of us, users of the Site or the public.
Use of Non-Personally Identifiable Information: We may disclose your non-PII in any other manner that we deem appropriate. Among other things, we will disclose non-PII to third parties to help us determine how people use parts of the Site and how we can improve our Site. We will also disclose non-PII to our service providers and other third parties about how our users collectively use the Site.
How to Access and Modify Your Information
You can update your account information through your account.
If you would like to request access, modification, correction, or deletion of personal information that you have provided to us or that you believe we may have collected about you, please contact us at email@example.com. We may not be able to delete your personal information without also deleting your user account. You will not be permitted to examine the personal information of any other person or entity.
In order to verify your identity, you may be required to provide us with personal information prior to accessing any records containing information about you. We may not accommodate a request to change or delete personal information if we believe doing so would violate any law or legal requirement, or cause the information to be incorrect.
When we delete PII, it will be removed from the active database, but may remain in our archives as allowed or required by applicable law, and we may retain de-identified information about your use of Service. Once we disclose your PII to third parties, we may not be able to access that PII any longer and we cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.
We will honor any legal right that you have to access, modify or erase your personal information. To request access and to find out whether any fees may apply, if permitted by applicable state, federal, or national law (outside of the United States), please contact firstname.lastname@example.org.
How to Limit the Use of Your Information
You have choices about the information you provide and how we use your information. These choices, and any related consequences, are described in detail below.
Marketing Emails: When you create an account through our Site you are required to provide us with an accurate e-mail address through which we may contact you. Such registration or requests through our Site constitutes your express acknowledgment that we may use your e-mail address to communicate with you about product offerings from us, our selected vendors, and partners. While you cannot opt-out of receiving notifications and other communications regarding your account, you can opt-out of receiving promotional and other marketing emails from us by using the “unsubscribe” feature in our marketing e-mails. You can also opt-out of having your PII shared with business partners and third parties for their own marketing purposes by contacting us at email@example.com and stating your request.
Location Tracking: Most mobile devices allow you to control or disable the use of precise location services by any application on your mobile device through the device’s settings’ menu.
Cookies and Tracking Technology
Like many websites, we use tracking technologies such as cookies, web beacons and similar technologies to record your preferences, and track the use of our Site. We may also use these technologies to monitor traffic, improve the Site, and make them easier to use and more relevant. Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Site may not work or may not work as designed.
Some content or applications on the Site may be served by unaffiliated third parties. We do not control these third parties’ tracking technologies or how they may be used. We are not responsible for the content or privacy practices on any website not operated by us to which our Site link or that link to our Site.
Online Tracking Choices: You also have choices to limit some tracking mechanisms that collect information when you use the Site. Many web browsers automatically accept cookies, but you can usually modify your browser’s setting to decline cookies if you prefer. If you choose to decline cookies, certain features of our Site, including the Site themselves, may not function properly or remain accessible to you. In addition, you may also render some web beacons unusable by rejecting or removing their associated cookies. Note that if you choose to remove cookies, you may remove opt-out cookies that affect your advertising preferences.
How We Secure Your Information
We take reasonable security measures to help protect the personal information collected through the Site and Services. Please understand, however, that while we try our best to safeguard your personal information (including PII) once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.
You can help protect the privacy of your own information by using encryption and other techniques to prevent unauthorized interception of your personal information. You are responsible for the security of your information that you transmit to us or view, download, or otherwise access when using unencrypted, public or otherwise unsecured networks.
Other Important Information
Users Outside of the United States: If you use any of our Site outside of the United States, you understand and consent to the transfer of your personal information to, and the collection, processing, and storage of your personal information in, the United States and elsewhere. The laws in the U.S. and these countries regarding personal information may be different than the laws of your state or country.
Your California Privacy Rights: If you are a California resident, California law permits you to request certain information regarding the disclosure of your personal information by us and to third parties for the third parties’ direct marketing purposes. To make such a request, please send your request, by mail or email, to:
Attn: Symphony Provider Directory Legal Department
500 12th Street Suite 310
Oakland, California 94607
For Questions or to Report a Problem
P: (510) 208-1740
Attn: Symphony Provider Directory
500 12th Street Suite 310
Oakland, California 94607