MONDOPOINT PRIVACY POLICY
Last modified: February 4, 2019
This is the privacy policy (“Privacy Policy”) that governs how Mondopoint and our affiliated companies (“Mondopoint”, “we”, “our” or “us”), use Personal Information (defined below) that we process in connection with your use of our website: www.mondopoint.com (“Website”), our portal https://portal.mondopoint.com/ (“Portal”) and all related tools, software, and web services that we provide (collectively, our “Services”). Mondopoint makes its Portal available to allow efficient contract management and monitoring between healthcare providers and suppliers (our “Partner(s)”).
Please note that if you are accessing our Portal on behalf of one of our Partners and you disclose Personal Information relating to other people, you represent you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy. The Portal is not intended to serve as a vehicle for providing medical advice or health care services. Please consult a physician regarding specific diagnosis, treatment, or other health-related questions.
(1) Introduction
We are committed to respecting privacy and recognize the need for appropriate protection and management of any Personal Information that is shared with us as part of using our Services. As used in this Privacy Policy, “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual. We may collect Personal Information from you directly through our Services, or where authorized by you, we may access the Personal Information that you have provided third party services through the use of an application program interface.
You may choose whether or not to provide or disclose Personal Information in connection with your use of our Services. If you choose not to provide the Personal Information we request, you may still visit and use parts of our Services, but may be unable to access or use certain features, options, programs, products, and services.
Our Services may contain links to third-party websites, products, services, and advertisements that are not owned or controlled by Mondopoint. We are not responsible for the privacy practices or the content of those third party websites, products, services, and advertisements, and you visit them at your own risk.
(2) Categories of Personal Information Collected
We and our service providers may collect the categories of Personal Information set forth below in order to provide our Services to you, our Partners, or because we are legally required to do so:
- Name;
- Address;
- Username;
- Password;
- Email address;
- Title (your position or role);
- Employer; and
- Communications you send to us.
In addition, Mondopoint may receive, process, or transmit information which constitutes “Protected Health Information” on behalf of a Partner who is a “Covered Entity” (as such terms are defined by the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”)) in our role as a “Business Associate.” In such an event, we will protect this information and treat it confidentially in accordance with HIPAA and the Business Associate Agreement we have in place with the Partner.
(3) WHEN Personal Information is Collected
Mondopoint may collect certain information that may constitute Personal Information when our Partners access our Portal to fulfill their contract management needs. For example, we may collect username and password in combination with other categories of Personal Information listed in Section 2 (Categories of Personal Information Collected) to enable secure Portal login and to appropriately control access to role-based content. We process this Personal Information only as necessary to provide you services on our Portal under our Terms of Use and to further our legitimate interests in protecting our Portal and content.
In various areas of our Website and in printed materials, we provide you the opportunity to submit a form with basic contact information, such as your name, email, or mailing address. With your permission, Mondopoint uses such information to inform you of new products, technical information and services. If you no longer wish to receive these emails, the opt-out process is described in Section 7 (Your Choices) of this Privacy Policy.
Please note that we use certain third party service providers on our Services to enhance your experience or deliver certain services. These providers may collect Personal Information about you in performing their services and/or functions on our Services.
(4) Information Collected Automatically
We may automatically collect certain information when you use the Services (“Usage Data”). Usage Data includes the information that your web browser automatically sends to our servers whenever you visit. The Usage Data collected in our server logs may include information such as your web request, Internet Protocol address, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser. We send the cookies to your browser when you visit the Services. We may use Adobe Flash technology which remembers settings, preferences and usage in a manner similar to browser cookies, but which is managed through a different interface than the one provided by your web browser. You can reset your web browser and Adobe Flash Player to refuse all cookies. However, some features of the Services may not function properly if the ability to accept cookies is disabled.
We may use third party analytic software (for example, Google Analytics) to collect further Usage Data regarding the online usage patterns of our users. We may combine Usage Data with Personal Information in a manner that enables us to trace Usage Data to an individual user. For more information on Google Analytics’ processing of Personal Information, please see http://www.google.com/policies/privacy/partners/. By using a browser plugin http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.
(5) The Purposes For Which We Use Personal Information
We may use Personal Information and Usage Data to operate, maintain, and provide to you the features and functionality of the Services and for related business purposes. In particular, we may use your information to: (a) improve the quality and design of the Services and to create new features, functionality, and services by storing, tracking, and analyzing user preferences and trends; (b) remember information so that you will not have to re-enter it during your visit or the next time you visit the Services; (c) provide custom, personalized content and information; (d) monitor aggregate metrics such as total number of visitors, pages viewed, etc.; (e) track your uses of the Services; and (f) for our other legitimate legal, business, and commercial reasons.
(6) Information That Mondopoint May Disclose
We do not sell, lease, rent or otherwise disclose the Personal Information collected from our Services to third parties unless otherwise stated below or with your consent.
We may share Personal Information you submit (either personally or on behalf of a third party individual) through the Services and Usage Data with our Partners, affiliates or other third party service providers to perform tasks on our behalf and to provide our Services. We use commercially reasonable efforts to only engage or interact with third party service providers that post a privacy policy governing their processing of Personal Information. Notwithstanding the foregoing, we will comply with applicable laws regarding Personal Information transfers as well as any transfer restriction that is specified in an agreement between Mondopoint and a Partner.
To better serve our Partners, and to improve our Services, we may conduct research on user demographics, interests and behavior based on the Personal Information and other information provided to Mondopoint. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregated information with our affiliates, agents and business partners. This aggregate information does not identify a user personally. We may also disclose aggregated information in order to describe our Services to current and prospective business partners and to other third parties for other lawful purposes.
We may release any Personal Information: (a) if required to do so by law, or in the good-faith belief that such action is in compliance with state and federal laws (including, without limitation, copyright laws) or in response to a court order, subpoena, legal process or search warrant, (b) if we believe, in good faith, such action is appropriate or necessary to enforce our Terms of Use, exercise our legal rights, take precautions against liability, to investigate and defend ourselves against any claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Services, and to protect the rights, property, or personal safety of Mondopoint, our users or others, (c) to any current or future acquirer, parent company, affiliated entity, joint venture, or other entity controlled by, controlling, or under common control with us (in which case we will require such entities to honor this Privacy Policy); or (iv) or as described herein.
(7) Your Choices
You may update or correct your Personal Information and email preferences at any time by visiting your account’s profile page. You may choose not to receive future promotional or advertising emails from us by selecting an unsubscribe link at the bottom of each email that you receive from us, or by responding to the emails directly and requesting removal if such a link is not available. Additionally, you may send a request specifying your communications preferences using the contact information in Section 15 below. You cannot opt out of receiving transactional emails related to your account with us or our Services. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative, maintenance and operational emails (for example, in connection with a password reset request).
(8) Data Security
The security of Personal Information is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security.
(9) Retention of Personal Information
We reserve the right to retain any Personal Information as long as the Personal Information are needed to: (a) fulfill the purposes that are described in Section 5 (The Purposes For Which We Use Personal Information), and (b) comply with applicable law.
(10) Children’s Policy
Mondopoint does not knowingly collect or maintain Personal Information on or through the Services from persons under 13 years of age, and no part of the Services is directed to persons under 13. If you are under 13 years of age, then please do not use or access the Services at any time or in any manner. If we learn that Personal Information of persons under 13 years of age has been collected on the Services, then we will take the appropriate steps to delete this information from our systems. If you are a parent or guardian and discover that your child under 13 years of age has provided Personal Information to us, then you may alert us at privacy@mondopoint.com and request that we delete your child’s Personal Information from our systems.
(11) Special Note to International Users
The Services are hosted in the United States and are intended for and directed to users in the United States. If you are accessing the Services from the European Union, Asia, or any other region with laws or regulations governing Personal Information collection, use, and disclosure, that differ from United States laws, please be advised that your continued use of the Services will be governed by United States law, this Privacy Policy, and our Terms of Use. Information about you that we collect or that you submit may be transferred to, processed in, and held in countries other than the one in which you reside, including countries such as the United States, which the European Union has deemed do not provide “adequate” protection for personal information.
(12) Changes and Updates to this Privacy Policy
We reserve the right, at our discretion, to change the terms of this Privacy Policy at any time. You can see when this Privacy Policy was last updated by reviewing the “Last Modified” legend on the top of this page. We may provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY POLICY WILL APPLY IMMEDIATELY UPON POSTING TO OUR SERVICES.
(13) How We Respond to Do Not Track Signals
Mondopoint does not track Services users over time and across third party websites to provide targeted advertising. Accordingly, we do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Information about an individual consumer’s online activities over time and across third-party websites or online services.
(14) Your California Privacy Rights
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of Personal Information about you by Mondopoint to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to privacy@mondopoint.com or write to us at the address below.
(15) Contact Information
Please contact us with any questions, comments, or concerns as follows:
Mondopoint, LLC
ATTN: Privacy Agent
222 Merchandise Mart Plz, Ste 1230
Chicago, IL 60654
email: privacy@mondopoint.com