Privacy Policy

AXUALL, INC. PRIVACY POLICY FOR CREDENTIAL HOLDERS

 

AXUALL SERVICES ARE INTENDED FOR USE SOLELY BY AND ON BEHALF OF INDIVIDUALS LOCATED IN THE UNITED STATES.  IF YOU ARE CURRENTLY LOCATED IN THE EUROPEAN UNION, PLEASE OMIT.  

 

Effective Date: November 20, 2019

 

By using any Axuall Services, You consent to our collection, use, and disclosure of Your Information, as described in this Privacy Policy. Your use of the website is also subject to Axuall’s Terms of Use.  Any disputes related to this Privacy Policy will be governed by the applicable provisions of the Terms of Use, which are incorporated into this Privacy Policy by reference.

 

The “Axuall Services” means this website, the “digital wallet” that contains your credentials, and any other services provided by Axuall as may be selected by you or automatically delivered to you.  “You” and “your” means the person or entity using the Axuall Services and providing data in connection with the Axuall Services, as a “Credential Holder.”  “Axuall” “we”, “us” and “our” means Axuall, Inc., its subsidiaries and affiliates.  “Subscribers” are hospitals, health plans and other organizations that contract with Axuall to obtain your credentials, such as in connection with an application for employment or medical staff privileges.

 

The privacy of Your Information (defined below) is very important to Axuall.  This Privacy Policy explains the information we collect, how we use and store it, and with whom we share it.  This Privacy Policy explains your options and rights and we encourage you to read it carefully and to check back often to review any changes.  We may update this Privacy Policy occasionally, and we encourage you to check the effective date of this Privacy Policy whenever you use the Axuall Services to see if there have been any changes since your last visit.  Your continued use of the Axuall Services is your agreement to any of those changes.

 

1. THE INFORMATION WE COLLECT AND CREATE ABOUT YOU

 

We collect information in order to provide you with the Axuall Services and to provide you with information or notices related to your account.  Any information we collect from you or about you is considered “Your Information” under this Privacy Policy, except as explained below.   

 

Information Collected from You. We collect information such as your name, gender, age, NPI, SSN, birthday, employment history, email, state id/passport number, citizenship/residency status, and other contact information. We may also collect from you information such as your medical specialty, school(s), year(s) of graduation, state licensure information, and industry association membership in organizations like AOA or AMA.  This information is called “Credential Holder Information” and is part of Your Information under this Privacy Policy.

 

Information Collected from Credential Issuers. We will also collect information about you from the organizations that issue information about your credentials (“Credential Issuers”).  In order to collect information about you from Credential Issuers, we send Credential Issuers information about you, such as your name, NPI, last four digits of your social security number and similar information customarily required or requested by Credential Issuers in order to permit them to generate credentials.  

 

 

The Credential Issuers will send us information such as any applicable government credentials, National Practitioner Data Bank data, peer references, licensure status, medical references (such as medical school graduation, hospital dates of membership and references) and other information that is relevant to your credentials as a health care provider. We call this information “Credential Issuer Information” and it is part of “Your Information” under this Privacy Policy. 

 

You will be able to view the Credential Issuer Information provided about you, unless the Credential Issuer Information is marked as confidential; for example, references from your peer reviewers may be marked confidential and will not be open to you.  However, as the Credential Holder, you will have the ability to exclude any credential from your digital wallet and provide a note to the Credential Issuer explaining why you are rejecting the credential.  Your note will be part of Your Information when held by Axuall, but may be subject to different privacy policies of the Credential Issuer(s) to whom the note is sent.  A Credential Holder cannot modify or edit any credentials or other information provided by a Credential Issuer. 

 

Some credentials in your digital wallet are updated regularly by the Credential Issuer, such as National Practitioner Data Bank information. When you accept credentials into your digital wallet, you agree that we may collect updated information from the Credential Issuer and update your digital wallet. 

 

Information Collected about Your Use of Services:  We also automatically collect information from you related to your use and navigation of the Axuall Services, including this website.  This information may be collected by us or our third party service providers using website analytics tools or other technologies, like cookies, in order to collect information about your visit to and use of Axuall Services, including the Axuall website pages you visit, links you click and other actions you take while using Axuall Services.  We may also collect information that your browser automatically sends to the websites you visit, such as your IP address, browser type/language, and other information.  All of this navigation and usage information (together, “Usage Information”) help us to improve your experience in using Axuall Services.  Usage Information is not considered Your Information under this Privacy Policy.

 

Information Collected from Mobile Apps or Devices:  If you choose to use a mobile device to access Axuall Services, when made available by Axuall, we may collect information from your device, such as your geolocation data, which will enable some functions in accordance with your device settings (“Mobile Device Information”).  Mobile Device Information that does not identify you is not considered Your Information for the purposes of this Privacy Policy. 

 

Aggregated Information: We may also create aggregated, anonymized information that may include or be based on Your Information, Usage Information and Mobile Device Information, along with the similar information of other users (“Aggregated Information”).  Aggregated Information does not identify you, and is not considered Your Information under this Privacy Policy.

2. HOW WE STORE YOUR INFORMATION

We store Your Information in individual encrypted containers, called digital wallets, which are stored in Axuall’s cloud, located in the United States.  The security of Your Information is important to us.  We have established administrative, physical and technical safeguards in compliance with applicable law and general industry standards to safeguard and secure Your Information from unauthorized access or disclosure.  However, we cannot guarantee that Your Information is 100% secure.  You understand that no storage, processing or transfer of any information can be guaranteed to be completely secure.

 

3. HOW WE USE AND DISCLOSE YOUR INFORMATION

We may use and share Your Information in the following ways:

  • We use Your Information in order to provide you with access to and use of the Axuall Services. We also use it to service your account and to provide you with general information about Axuall and the Axuall Services. We use Your Information to answer your questions, to provide you with information you request, or to provide you with information about your account, registration or use of Axuall Services.

  • We may use or share Your Information to diagnose technical problems or to detect or prevent security issues.

  • We may use or share Your Information for our own internal business purposes including statistical, design or operational purposes, such as to measure traffic patterns and understand demographic trends among our users.

  • We may share Your Information with third parties that perform services on our behalf.  We will require them to comply with this Privacy Policy.

  • We may share Your Information with our related companies, such as affiliates, subsidiaries, joint ventures, or other companies under common control with us.  We will require them to honor this Privacy Policy.

  • We may use or share Your Information in connection with a merger, sale of all or some of our assets, debt financing, or other corporate event, including for due diligence for such transaction (collectively, a “Corporate Change”).  In the event of a Corporate Change, we may transfer Your Information, in whole or in part, to the relevant third part(ies) and, if such Corporate Change actually occurs, Your Information will then be subject to the privacy policies of such third part(ies).

  • We may use and share Your Information as required by law, when we believe it is appropriate to comply with law enforcement requests, to enforce this Privacy Policy or any other agreement with you, or to protect our and our users’ rights, property or safety.

  • While we do not currently use your email address to send you any periodic email or newsletter communications on topics generally relevant to our users, we reserve the right to do so in the future.  In that event, we will provide you with an opportunity to opt-out and/or unsubscribe to such communications.

  • The Axuall Services allow you to share Your Information in your digital wallet with Subscribers.   We intend that Subscribers will use Your Information solely for purposes of quality assurance, peer review and credentialing in connection with your application for membership in or employment by such Subscribers.  However, you understand that Subscribers are third parties that may have their own policies and procedures with respect to the maintenance and use of members’ and/or applicants’ information that they obtain from various sources, including Axuall.

  • We do not sell Your Information to third parties. 

  • Any sharing of Your Information that is not expressly permitted by this Privacy Policy, or future revisions to this policy, may occur only with your consent and applicable law.

  • We may use, share and/or sell information that does not identify you for any purpose, including providing it to third parties for their own business or marketing purposes.

 

4. COOKIES AND OTHER TECHNOLOGIES

We may use the following technologies to collect Usage Information:

 

  • “Cookies” are small text files inserted and stored by your web browser on your computer’s hard drive. They help us determine what parts of the website you visited, and also help us analyze and improve the design and technology of Axuall Services.  Your browser may permit you to disable cookies; please refer to your browser settings for further information.  However, if you disable cookies, you may not be able to use all of the features and functions of Axuall Services, and any settings or preferences you previously set that are controlled by the cookies may no longer be available.

  • We use navigational technology, including audit logs, which provides us with information on how you are using the website and other Axuall Services, similar to “cookies.”  We may use widgets and plugins so that you can use the Axuall Services more efficiently.   If these interactive mini-programs are made available to you on Axuall Services, you understand that they run on the website and collect your IP address, which page you are visiting on the website, and set a cookie to enable the widget to function properly.  Your interactions with these widgets are governed by the privacy policy of the company providing them, and not by this Privacy Policy.

 

This description of technologies used is not comprehensive, as we will continually update our systems to provide you with the best possible online experience.

 

5. RIGHTS UNDER STATE LAW

You may have additional rights under the law of the state where you reside, including if you are a California resident. In addition to all your rights under other parts of this Privacy Policy, your state law may provide you with the right to:

 

  • Request that we provide you with information about whether and to whom we have disclosed or sold* Your Information;

  • Request to have a copy of the specific information collected about you during the twelve months before your request;

  • Have Your Information deleted (with some exceptions);

  • Request that Your Information not be sold* to third parties; and

  • Not be discriminated against because you have exercised any of these rights.

 

*We do not sell Your Information.

 

You may make any of the above requests by contacting us with your request through one of the following two methods: support@axuall.com and (877) 298-1110. You may make such requests no more than twice in any twelve month period.  You understand that we may need to collect information from you to verify your identity in order to respond to your requests; we will respond within 45 days. 

 

6. UPDATING YOUR INFORMATION

Some of Your Information may be updated directly on the website.  You may also update Your Information by emailing us at support@axuall.com. We will use reasonable efforts to update Your Information as soon as possible. If you request that we delete Your Information, you understand that it may not be possible to delete information from our backup systems.  We will delete records in accordance with our general record retention policies and do not have any obligation or liability to you regarding Your Information that is deleted.

 

 

7. CONSENT TO TRANSFER

The website and Your Information is maintained in the United States, and Your Information will be processed and shared in the United States, where the laws and protections regarding data and information may be different from those of other countries.  If you (or anybody authorized by you to use your account, or the person(s) for whom you are using Axuall Services) are located in a country other than the United States, please be aware that Your Information will be transferred to the United States and, by providing such information, you consent to such transfer. 

 

8. LINKS TO THIRD PARTIES

This website and the Axuall Services may contain links to other websites and information solely for your convenience.  Please note that such other websites may have privacy policies different from ours and any use of such other websites and/or any information you provide to or through such other websites will be subject to the terms or use and privacy policies of those other websites and not this Privacy Policy.  We recommend that you review any third party privacy policies carefully before using those websites and/or providing any information to them.

 

9. CHILDREN

You must not use this website if you are under 18 years of age. We do not knowingly collect or solicit any information from minor children under the age of 18 or knowingly allow such minor children to create a user account. If we learn we collected or received information from a minor child under 18 without parental consent, or without verifiable reasons to believe the person under 18 is legally allowed to provide his or her own consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at support@axuall.com.

 

10. DO NOT TRACK DISCLOSURES 

Some web browsers provide “do not track” signals or other similar mechanisms that provide users the ability to exercise choice regarding the collection of personally identifiable information about an individual’s online activities over time and across third-party websites or online services.  Currently, we do not take any action in response to web browser “do not track” signals or similar mechanisms.  Although we use Google Analytics and other third party tracking tools for the website, we are not aware if third parties collect personally identifiable information about an individual’s online activities when such individual uses the website.

 

11. QUESTIONS AND CONCERNS

If you have any questions about this Privacy Policy, please contact us at policies@axuall.com.

 

12. CHANGES IN THIS PRIVACY POLICY

We may modify this Privacy Policy from time-to-time and will post such modifications prominently on the website. Please review this Privacy Policy each time you visit the website.  If you do not agree with a modification, your sole remedy is to stop providing information to us after the effective date of such modification and to stop using Axuall Services.

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