CarePilot Privacy & Security Policy

In order to provide our services, we will from time to time ask you to provide us with information about yourself &/or the patient(s) in your care. Because we realize that this information is in most cases intensely personal and confidential, we have created this Privacy and Security Policy ("Policy"). This Policy explains why we ask you for information, how we will - and will not - use the information you choose to provide us, and how we safeguard your Personal Information to ensure that it is only used for the purposes you intend.

Our site is based on three core principles:

1. We will not share your Personal Information with anyone without your prior permission.
2. We will never use your Personal Information for any purpose without your permission, and then we will use it only for that purpose.
3. We will keep your Personal Information private and secure.

We have been approved to display the Healthcare On the Net (HON) Foundation HonCode Seal to show objective validation of our privacy policy. HON is an independent, non-profit privacy organization that promotes the use of fair information practices and provides objective certification for Internet sites that maintain certain levels of privacy and security for Personal Information that they collect. To verify our compliance, click on the HON logo.

Changes to the Policy

We regularly review our Policy to ensure that it provides an appropriate level of protection for your Personal Information. From time to time, we may make changes to our Policy to keep it current with industry standards. We will post the date of the most recent revisions on this page. Please check back here from time to time to make sure that you are current and up-to-date on our Policy. Please keep in mind that your use of our Web site means that you accept our Privacy and Security Policy. For more information on this point, please read our Terms of Use.

Information Protected under this Policy

This Policy applies to what we call "Personally Identifiable Information". We define "Personally Identifiable Information" as any information that could identify you or could be used to contact or locate you. This includes information that may not identify you directly, but that could be used to identify you if used in conjunction with other information, for example, an email address in combination with a password.

Information Collected

At various locations on our site, we ask you for information. It may be optional or mandatory for you to provide the information based on the activity that you are performing.

The information we seek to collect, at different places on our site, allows us to provide you (whether you are a patient or caregiver) with information that is targeted specifically to you or the individual for whom you are seeking information. In the event that you would like to be contacted by a particular home health agency(s) (HHA), this information allows the HHA(s) to contact you regarding potential care.

Data Sharing and Transfer Practices

Advertisements

We will not give or sell your Personal Information to any advertiser. Therefore, no intermediaries such as advertisers, credit card companies, banks, distributors, etc., will be provided with your Personal Information.

Links

We do not provide your Personal Information to any third parties without your prior permission. However, from our site, you will be able to link to Third Party Web sites operated by companies that are not affiliated with CarePilot.

We provide information from a variety of reputable sources regarding home health agencies, and provide you with the ability to send a link to that content along with explanatory messages written by you to third parties (your friends, relatives, etc.) via email. We do not limit the information you may send in a message. We do caution you to minimize the confidential information you send in the text of a message, as there is no way we can prevent information delivered off of our site from being transmitted or used improperly by the recipient of your message.

CarePilot does not endorse and is not responsible for the privacy practices of the Third Party Web sites. If you choose to link to one of these Third Party Web sites, you should review their privacy policy to understand how that Third Party Web site collects and uses your Personally Identifiable Information.

Sale or Transfer of Corporate Assets

CarePilot expressly reserves the right to transfer its database of information in part or as a whole to another legal entity as part of a sale or merger of all or part of CarePilot, Inc. with a separate legal entity. Any entity acquiring any data assets of CarePilot will do so with the express, written commitment to use the data only for the purposes for which it was provided to CarePilot, and only after CarePilot is satisfied that the acquiring entity can and will provide at least the same level of protection to personal information as CarePilot does.

Initial User Registration

Some areas of our site are public, and can be viewed without registering as a member of our community. Many areas, however, contain information that is most effective when targeted to individual users. In order to tailor the user experience, and to provide users with a better understanding of our offerings, we ask users to register with us before entering these areas of the site. The registration process is meant to be as simple as possible, and seeks information necessary to contact you with appropriately customized information and/or care options.

We also provide periodic emails that will inform you of news & updates concerning CarePilot. In order to receive this service, you will be asked to check a box to tell us that you want us to provide you with this service.

Personally Identifiable Health Information

After you have registered as a member of CarePilot, you may choose to use certain CarePilot interactive content, tools and services that may ask you to voluntarily provide other types of information about yourself, &/or the patient(s) in your care, including Personally Identifiable Health Information. We retain your Personally Identifiable Health Information in accordance with the authorization you provide at the time you use the tool.

Personally Identifiable Health Information that you enter into "My Profile" &/or "My Care Recipients" is used to provide you personalized and clinically relevant information. CarePilot creates a personal page specifically for you where this information resides. You control and authorize who can gain access to this page.

Home Health Agency Registration

If you are an employee of an HHA registering his or her agency with CarePilot, we may ask you to provide us with your agency's contact information, ownership type, personnel detail, pricing structure, and services offered. Upon request, we will make this information available to users of our site who are seeking out home care service providers.

Contacting a Home Health Agency via CarePilot

If you agree to share your contact information & Care Recipient profile with an HHA for the purpose of learning more about potential homecare services, your name, contact information, & Care Recipient profile will be given to the HHA. The HHA will be under strict laws governing the release of your name or information to any other person or entity for purposes directly related to your homecare needs, and not for any marketing or other purpose. The HHAs, not CarePilot, are responsible for ensuring that they are in compliance with all laws governing the release of Personally Identifiable Health Information.

Email a Friend

When you use CarePilot's "Email a Friend" functionality, CarePilot emails the content you designate to your friend's email address and identifies your email address as the sender. CarePilot uses the friend's email address to send your friend the particular email you requested.

Statement of HIPAA Compliance and compliance with State privacy laws

The Health Insurance Portability and Accountability Act ("HIPAA") controls the collection, use, and distribution of individually identifiable health information by certain health care providers, called "covered entities" under the statute. All of CarePilot's services are HIPAA compliant and are also compliant with all other relevant Federal, state, and local laws and regulations.

CarePilot is not a covered entity as that term is defined under HIPAA. As a result, and because you (instead of a third party) have willingly and knowingly provided the information we collect, HIPAA does not apply to our services.

Cookies

We collect Non-Personal Information about your use of our Web site through the use of cookies. Every computer that accesses CarePilot's web site is assigned a different cookie. A cookie is a piece of data stored on your computer's hard drive containing information about you that helps your Web browser remember specific information that a Web server can later retrieve. For instance, by setting a cookie on our site, you would not have to log in a password more than once, thereby saving time while on our site. If your Web browser rejects cookies, you may still use our site. The only drawback to this is that you will be limited in some areas of our site. Cookies can also enable us to track and target your areas of interests to enhance your experience on our site.

Knowing where your browser has been on our website helps us enhance the areas that you find valuable and eliminate areas that you do not like. We also use cookies to gather broad (non-personal) demographic data, so that we can target our information to particular communities within our user base.

Log Files

The first time you register with CarePilot, we store your registration information along with a code that identifies your initial entry point into our site. This information is used solely for the benefit of those partners of CarePilot who refer users to us, so that we may tell them the number of their users who have accessed our site. We do not provide our partners with any other information about you without your express permission.

Rights of Other Organizations or Entities to View Data Entered on CarePilot's Web Site

Except as set forth in this Privacy Policy or as specifically agreed to by you, CarePilot will not disclose any Personally Identifiable or Personal Health Information it gathers from you on our website. We may only release Personally Identifiable or Personal Health Information to third parties: (1) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (2) in special cases, such as in response to a physical threat to you or others, to protect property or defend or assert legal rights. In the event that we are legally compelled to disclose your Personally Identifiable or Personal Health Information to a third party, we will attempt to notify you unless doing so would violate the law or court order.

Correcting Your Personal Information

After you have completed the registration process, we will send you an e-mail thanking you for your participation on our site. You will have the ability to remove your personal information from our contact list at any time you so desire, by filling out our contact form. Our customer service staff will remove your information from our contact list upon receiving your request.

Opting Out of the Database

You can make changes to any information you have given us at any time by clicking on the My Account link at the top of every page on the Web site and making the desired changes.

CarePilot Connections

As a service to our users, CarePilot features message boards and other public forums where users with similar interests or care challenges can share information and support one another or where users can post questions for experts to answer.

Any information shared (including Personally Identifiable and Personal Health Information) that you reveal in an email, message board, Ask Our Expert posting or online discussion such as CarePilot Connections is by design open to the public and is not a private, secure service. You should think carefully before disclosing any Personally Identifiable or Personal Health Information in any public forum. What you have written may be seen, disclosed to or collected by third parties and may be used by others in ways we are unable to control or predict, including to contact you for unauthorized purposes.

Children

We are committed to protecting the privacy of children. Neither CarePilot nor any of its services are designed or intended to attract children under the age of 13. We do not collect Personally Identifiable Information from any person we actually know is under the age of 13. A parent or guardian, however, may use CarePilot to establish a "My Care Recipient" profile for a minor. The parent or guardian is solely responsible for providing supervision of the minor's use of CarePilot. The parent or guardian assumes full responsibility for ensuring that the registration information is kept secure and that the information submitted is accurate. The parent or guardian also assumes full responsibility for the interpretation and use of any information or suggestions provided through CarePilot for the minor.

Security

We take every precaution to protect your Personal Information. When you provide us with Personal Information, it is protected both online and off-line.

Listed below are some of the security procedures that CarePilot uses to protect your privacy:

• Requires both a personal username and a password in order for users to access their Personally Identifiable Information or Personal Health Information.
• Firewalls to protect information held in our servers. Data contained on our servers is visible only to proprietary middleware applications. Sign-on passwords are required by internal staff and are changed on a periodic basis. All internal activity is logged.
• Utilizes Secure Socket Layer (SSL) encryption in transmitting Personally Identifiable Information to our servers. In order to take advantage of encryption technology, you must have an Internet browser which supports 128-bit encryption.
• Closely monitors the limited number of CarePilot employees who have potential access to your Personally Identifiable Information.
• Requires all CarePilot employees to abide by our Privacy Policy and to be subject to disciplinary action if they violate it.
• Backs-up our systems to protect the integrity of your Personally Identifiable and Personal Health Information.

Offline Protection

While we use SSL encryption to protect personal information online, we also work very hard to protect personal information off-line. Any information we receive, whether defined as personal information or not, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our database administrators) are granted access to your Personal Information. ALL of our employees are kept up-to-date on our security and privacy practices. Every quarter, as well as any time new policies are added, our employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure that our users' information is protected. We also protect and secure the physical environment in which data is stored. We store Personal Information on servers kept in a secure environment, within locked, environmentally controlled server rooms.

Despite CarePilot's efforts to protect your Personally Identifiable Information and Personal Health Information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted.