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SKYGEN USA Credentialing Service Privacy Policy

Last Updated:  March 1, 2017.

SKYGENUSA Powering Healthcare for the Digital Age

PLEASE READ ALL OF THIS DOCUMENT.  PRINT THIS PAGE FOR YOUR RECORDS.

BY ACCESSING AND USING THE PLATFORM, YOU AGREE THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY POLICY AND AGREE TO BE BOUND BY IT. 

SKYGEN USA, LLC and its affiliates (collectively referred to as “SKYGEN USA,” “us,” “our,” or “we”), provide web-based access to information about healthcare professionals who apply for or participate in healthcare or dental plans or networks, with a goal of promoting efficiency and cost-savings for the initial data collection processes for credentialing of such healthcare professionals (“Service”).  SKYGEN USA is the owner and operator of  the website located at www.skygenusa.com/credentialing  (“SKYGEN USA Website”), of mobile applications (“SKYGEN USA App(s)”), and of other websites, online services, social media sites, and related documentation and help files related to the Service (collectively, the “Platform”).   We respect the privacy of visitors to the Platform. This Privacy Policy describes what information SKYGEN USA will collect from visitors and participants such as yourself, and how we will use that information once it is collected. It also describes how you can ask SKYGEN USA and its affiliates to remove any of your personal information that may have been collected or stored during this or previous visits to the Platform. 

Remember that your use of the Platform is at all times also subject to the SKYGEN USA Credentialing Terms of Use (“Platform Terms of Use”), and all applicable App agreements (collectively with this Privacy Policy, the “Agreement”). 

This Privacy Policy is the sole statement of our privacy policy with respect to the Platform, and no summary, modification, restatement or other version, or other privacy statement or policy, in any form, is valid unless we post a new or revised privacy policy.  SKYGEN USA MAY REVISE THIS POLICY AT ANY TIME, AND SUCH REVISIONS WILL BE EFFECTIVE IMMEDIATELY UPON THEIR POSTING TO THIS PAGE. YOU AGREE TO PERIODICALLY REVIEW THIS PRIVACY POLICY FOR SUCH CHANGES.  YOUR USE OF THE PLATFORM INDICATES YOUR ACCEPTANCE OF THIS PRIVACY POLICY — IF YOU DISAGREE WITH THE PRIVACY POLICY, DO NOT USE THE PLATFORM OR THE SERVICE.

This Privacy Policy does not apply to the practices of any third party, affiliates, business partners, or guests that SKYGEN USA does not own or control. It is your responsibility to become familiar with any privacy policy promulgated by such third parties, affiliates, business partners, or guests, if any. Likewise, this Privacy Policy does not apply to websites or mobile apps owned or operated by third parties, even if such websites or mobile aps are linked to the Platform.  We may integrate certain parts of our Platform with and allow you to log into your account on the Platform through social networking platforms like Facebook. As part of such integration, the social networking platform provides us with access to certain information that you have provided to that social networking platform. SKYGEN USA will collect, use, maintain and disclose such information in accordance with this Privacy Policy. However, please remember that the manner in which social networking platforms collect, use, maintain and disclose your information is governed by the policies of such social networking platforms. SKYGEN USA HAS AND SHALL HAVE NO LIABILITY OR RESPONSIBILITY FOR THE PRIVACY PRACTICES OR OTHER ACTIONS OF ANY SOCIAL NETWORKING PLATFORMS, WEBSITES, OR THIRD PARTIES THAT YOU USE IN CONNECTION WITH THE PLATFORM.

I.          YOUR PERSONAL INFORMATION

A. Collection, Storage and Removal of Personal Information.

Throughout the Platform there are several forms that request information and allow you to request information. These forms typically ask for contact information (such as name and email address) required to process your request. SKYGEN USA may also collect and store other personal information about you (such as your physical address, phone number, and any other identifier that permits us to contact you), if you provide it to us voluntarily. If you do not want us to have information about you, simply do not submit it to us. We may use Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of our Platform, and we may link this information to your information for our business purposes, such as personalizing your experience on our Platform and evaluating our Platform and Service.  We do not collect credit card information on our Platform.   We contract with a third party service provider to collect and process any credit card information.    Please be sure to read the privacy policy posted on the website that requests your credit card information before you pay for any services offered on our Platform. 

If you download a SKYGEN USA App, we may collect and store your mobile device state information, unique mobile device identifiers (“UDID”), device hardware and operating system information, information relating to how an application functions on your mobile device, and the physical location of your mobile device (“Mobile Device Information”).

If you are using the Platform as a Healthcare Professional (defined in the Platform Terms of Use), we may also collect from you any or all of the information about you described in the Credentialing Information List posted on the Platform, and from the public domain,  healthcare provider groups with whom you are associated (“Provider Groups”), Subscribers to the Service, and other third parties.  We may combine Credentialing Information about you that we collect with any personal information you choose to provide us, as long as we use the combined information as described in this Privacy Policy.

Any personally identifiable information, including without limitation the Credentialing Information that we store about you in our databases is referred to in this Privacy Policy as “Your Personal Information”.   

B.  Accessing, or Removing Your Personal Information.

You can request access to and correct, update, or remove Your Personal Information if it changes, or if you no longer want to receive information from SKYGEN USA beyond information related to the Service. This can be done by contacting us through your Platform account, or at W140 N8981 Lilly Road, Menomonee Falls, WI 53051 (address), 855-934-9825 (phone), or CredentialingService@skygenusa.com.

We may use Your Personal Information to send you important service announcements and updates regarding our Platform or, if you are a Subscriber, about your account status and the Service. You will not be able to unsubscribe from these service announcements and updates as they contain important information relevant to your use of the Platform and the Service.  In addition, we may not be able to completely remove Your Personal Information from our systems in certain circumstances. For example, we may retain Your Personal Information for legitimate business purposes, if it may be necessary to prevent fraud or future abuse, for account recovery purposes, if required by law, or as retained in our data backup systems or cached or archived pages. All of Your Personal Information that we keep will continue to be subject to the terms of the Privacy Policy to which you have agreed.

C. Use of Your Personal Information.

We may store Your Personal Information and use it for internal purposes.  For example, we may store, review and analyze Your Personal Information so that we can better understand your interests, and improve our services to better meet those interests. We may also use Your Personal Information to send you text messages and email you personalized news about the Service and other items of interest. BY PROVIDING YOUR EMAIL ADDRESS AND PHONE NUMBER, YOU ARE GIVING US YOUR PRIOR WRITTEN CONSENT TO RECEIVING EMAIL MESSAGES AND TEXT MESSAGES FROM US.  You can stop text messages at any time by texting STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to the number sending the text message, or you can tell us not to send you text messages by contacting us as described in this Privacy Policy.  We may also employ other companies and people to perform tasks on our behalf and we may need to share Your Personal Information with them to do so. Unless we tell you differently, they do not have any right to use Your Personal Information beyond what is necessary to assist us.

We may also use Your Personal Information for research regarding the effectiveness of the Platform and our business planning, marketing, advertising, and sales efforts. We may provide Your Personal Information to third parties for these purposes, including independent providers of services, potential or actual advertisers, providers of advertising services (including website tracking services), commercial affiliates, sponsors, licensees, researchers and other similar parties.

Except as otherwise stated in this Privacy Policy, SKYGEN USA will not sell or license personal information that you provide to us without first notifying you of our intended use of the information at the time that you provide such information.  However, we retain the right to release your personal information to proper authorities when required by law or when we in good faith believe that we must release the information: (a) to satisfy a legal order or comply with legal process; (b) to defend the rights of SKYGEN USA, or its subsidiaries, affiliates, related companies,  business partners, or other users of the Platform; (c) to protect the rights, property, personal safety or privacy of SKYGEN USA employees, agents, affiliates, business partners, customers or Platform users; (d) as part of our transfer of our business assets; or (e) to investigate or prevent a violation by you of any contractual or other relationship with us or your illegal or harmful activity.

D. Use of Credentialing Information.

If you are a Healthcare Professional that has entered into a subscription agreement to use the Service, we may also use Your Personal Information as necessary for our provision of the Service to you and other users of the Service.  You understand and agree that federal or state government agencies, managed care organizations, insurance carriers, healthcare networks, hospitals, employers, Provider Groups, and third party administrators (“Subscribers”), may access, download, and use Your Personal Information in deciding whether to allow, deny, or modify the terms of your participation in health care or dental plans or networks (“Networks”), and/or in deciding whether to approve your eligibility for credentialing, membership, clinical privileges, employment or contracting as a provider of health care services for one or more Subscriber(s) (“Participation”).  AS SUCH, TO THE EXTENT YOU HAVE PROVIDED US PERMISSION VIA THE PLATFORM FOR GENERAL ACCESS FOR SUBSCRIBERS, YOU HEREBY CONSENT TO SKYGEN USA AND ANY THIRD PARTY AUTHORIZED BY US TO COLLECT, USE, AND TRANSMIT YOUR PERSONAL INFORMATION, AND CONSENT TO SUBSCRIBERS ACCESSING, DOWNLOADING, AND USING YOUR PERSONAL INFORMATION FOR PURPOSES RELATING TO NETWORKS, OR TO YOUR PARTICIPATION.  In addition, you hereby agree to the terms of the Authorization, Attestation, and Release with respect to the use of Your Personal Information by Subscribers in the any credentialing application process relating to you, or otherwise relating to your Participation.  Access to Your Personal Information shall be available only to those Subscribers for whom you have provided to SKYGEN USA general approval for such access, and for whom have not withdrawn such approval by following the procedures on the portion of the Platform dedicated to Healthcare Professionals.

E. Your Mobile Device Information.

We may use Your Mobile Device Information to provide you with tailored information and features as you use the Apps. We may also use your Mobile Device Information to notify You of features and services that may be available on your mobile device, analyze trends, administer the Apps, and gather broad demographic data for aggregate use. Certain features may require our collection of the UDID or phone number of your mobile device. 

In addition, some mobile network providers (“Mobile Providers”) in the United States are required to use technology that tracks the physical location of mobile devices that use their service. Depending on your Mobile Provider and mobile device, we may automatically receive this information. If we begin to offer services that use this tracking (“pinpointing”) information, we will obtain your consent (an opt-in) before using the information. AFTER OBTAINING SUCH CONSENT, WE MAY USE AND STORE THIS INFORMATION TO PROVIDE LOCATION-BASED SERVICES, INCLUDING LOCATION-TARGETED ADVERTISING.   BY ACCESSING THE PLATFORM THROUGH YOUR MOBILE DEVICE, YOU ARE EXPRESSLY CONSENTING TO OUR COLLECTION OF SUCH INFORMATION, AND ARE PROVIDING US WITH YOUR PRIOR WRITTEN CONSENT TO RECEIVE TEXT MESSAGES AND ELECTRONIC EMAIL TO YOUR MOBILE DEVICE. WE MAY USE YOUR ELECTRONIC CONTACT INFORMATION TO SEND YOU COMMUNICATIONS.

Most mobile devices provide users with the ability to disable location services. These controls are usually located in the mobile device's settings menu. If You have questions about how to disable Your mobile device's location services, we recommend You contact your Mobile Provider or Your mobile device manufacturer.  However, note that if you disable location services, You may not be able to use some of the Platform functions and services.

F.  Advertisers.

We may use “web beacons”, i.e. “web bugs” or “single–pixel” or “clear” GIFs, on the Platform. Web beacons allow ad networks to provide anonymized, aggregated auditing, research, and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their website.

We also may allow advertisers to choose the users who will see their advertisements or promotional offers. You agree that we may provide any non-personal information we have collected from you to an advertiser, so that advertiser may select the appropriate audience for advertisements or offers. For example, we might use the fact you are located in Wisconsin to show you ads or offers for products and services in Wisconsin, but we will not tell such businesses who you are.

IN ADDITION, IF YOU HAVE NOT OPTED OUT OF OUR TARGETED ADVERTISING, YOU AGREE THAT WE MAY SHARE YOUR PERSONAL INFORMATION WITH ADVERTISERS IN ORDER TO DELIVER SPECIFIC TARGETED ADVERTISING OR OFFERS TO YOU (“Targeted Advertising”).  If we enable Targeted Advertising for our users by default, you will be able to opt out of Targeted Advertising at any time by changing the applicable settings on the SKYGEN USA Site or SKYGEN USA Apps.  You may see certain ads on other websites if we participate in advertising networks administered by third parties. These networks track your online activities over time by collecting information through automated means, including through the use of the automated technologies described above, and they use this information to show you advertisements that are tailored to your individual interests. The information they collect includes information about your visits to our Platform, such as the pages you have viewed. This collection may take place both on our Platform and on third-party websites that participate in the relevant ad network, such as websites that feature advertisements delivered by the ad network.

If you want to prevent third parties from delivering tailored advertising, VISIT THE NETWORK ADVERTISING INITIATIVE OR THE DIGITAL ADVERTISING ALLIANCE TO OPT OUT. YOU MAY REQUEST TO OPT-OUT OF GOOGLE’S USE OF COOKIES BY VISITING HTTPS://TOOLS.GOOGLE.COM/DLPAGE/GAOPTOUT . ALL APPLICABLE TERMS ON ADVERTISER WEBSITES WILL APPLY TO YOUR REQUEST TO OPT-OUT IN ADDITION TO THIS PRIVACY POLICY.

II.        PROTECTION OF YOUR PERSONAL INFORMATION

A.  Your Responsibility.

It is your responsibility to protect account login information, such as your username and password, from unauthorized access. You must not share your login information with any third party.  If you share your login information with anyone, that person will be able to access your personal information and send messages as if they were you. We recommend you log out after accessing your account, change your password on a periodic basis, and limit access to your computer or mobile device and their browsers.  Do not use the SKYGEN USA Site from computers or public libraries or Internet cafes because Your Personal Information may not be protected. 

B.  No Guarantee.

While we use commercially reasonable security measures to prevent unauthorized persons from accessing our files or tampering with the Platform, we cannot guarantee that these efforts will always be successful. WE DO NOT REPRESENT, WARRANT, OR GUARANTEE THAT OUR SAFEGUARDS WILL PROTECT THE TOTAL PRIVACY OF YOUR PERSONAL INFORMATION, OR THE SECURITY OF ANY INFORMATION YOU TRANSMIT THROUGH THE PLATFORM.

California law requires that we disclose how we respond to “do not track” signals.  The Platform does not recognize “do not track” signals from your web browser.

California law also permits users that are residents of California to request the following information regarding our disclosure of their personal information to third parties for those third parties’ direct marketing purposes (i) a list of certain categories of personal information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year; (ii) the identity of certain third parties that received personal information from us for their direct marketing purposes during that calendar year; and (iii) examples of the products or services marketed (if we have that information). If you are a California resident and would like to make such a request, please email us at CredentialingService@SKYGENUSA.com.

III.       NON-PERSONAL DATA

A. Automatic Collection of Technical, Non-Personal Data.

We may on occasion collect certain technical, non-personal data from Platform visitors, such as the operating system and browser your computer is using, or the website from which you linked to the Platform. Such data by itself does not allow us to identify you personally.

B. "Cookies" and Data Automatically Placed On Your Computer or Mobile Device.

SKYGEN USA may store data in the form of a "cookie" or similar file or tracking technology that is automatically downloaded to your computer or mobile device, and uniquely identifies your browser and may store information or settings on your computer or device.  We also may send instructions to your computer or device using JavaScript® or other computer languages to gather information about your interactions with the Platform.  These actions allow us to improve the functionality of our Platform and customize your Platform experience to match your interests, based at least in part on your past visits, and to facilitate login and security features. If applicable, our advertising providers may also transmit cookies to your browser, application, or device when you click on ads that appear on the Platform or third party websites. Clicking on a link to a third party website from our Platform may also allow that third party website to transmit cookies to you.

If you do not want to accept cookies from the Platform or allow SKYGEN USA to store information relating to such cookies, check your Internet browser's instructions and adjust your browser settings accordingly. Most browsers can be configured to notify you when cookies arrive and ask your approval to accept them, or to refuse cookies outright. Most browsers can also delete cookies you may have accepted in the past. SKYGEN USA cookies will not damage your system or files in any way. If you do decide to disable cookies, certain areas and features of our Platform may not perform as designed. By using our Platform, you consent to our use of cookies as described above.

C.  Use of Non-Personal Information.

We may use and share non-personal, de-identified information (i.e. information that cannot be used to identify you) for any lawful business purpose without any obligation or accounting to you. For example, we can use non-personal information for monitoring which aspects of and to what degree the Platform is utilized by visitors, developing products, services, and providing those offerings to other users and third parties. We may use Your Personal Information to generate non-personal information. When we do so, we will take reasonable measures to ensure that the non-personal information is no longer personally identifiable and cannot later be used to identify you. We may also disclose non-personal, aggregate, anonymous data in a de-identified format to investors and potential partners based on information collected from users.