Privacy Policy
This Privacy Policy governs your use of our online interfaces and properties (e.g., websites and mobile applications) owned and controlled by Script Partner LLC and its affiliates (collectively, “Script Partner,” “we,” “us,” and “our”), including the www.scriptpartner.health website and any Script Partner mobile application (the “Site”), as well as the services (“Services”) and products (“Products”) available to users through the Site.
Script Partner is a technology and services platform. Script Partner is not a health care provider and does not practice medicine. Clinical care made available through the Site is provided by an independent, clinician-owned professional entity (the “Medical Group”) and its licensed providers (the “Providers”). Script Partner’s platform supports (i) telehealth care delivered to patients by the Medical Group and its Providers, which Script Partner supports on the Medical Group’s behalf (the “Telehealth Services”); and (ii) administrative and technology support that Script Partner provides to prescribing physicians and their practices to help their patients access prescribed medications (the “Provider Support Services”). This Privacy Policy is directed to you as a patient, prospective patient, or visitor to the Site, and it explains how Script Partner handles your information and how its role, and the legal framework that applies to your information, differs across these settings. If you are a health care provider or practice, the information you and your personnel exchange with Script Partner in connection with the Provider Support Services is governed by your separate written agreement with Script Partner, as described under “Information Relating to Health Care Providers” below.
If you are looking for state-specific privacy information, please review our Additional State-Specific Privacy Disclosures and, where applicable, our Consumer Health Data Privacy Policy, each of which is incorporated into this Privacy Policy. We are committed to maintaining the privacy and security of your personal information, and we appreciate that health information may be particularly sensitive. Script Partner respects the privacy of health care providers (“Providers”), patients and users of the Services (“Members”), and website visitors (“Visitors”).
HOW HIPAA APPLIES TO SCRIPT PARTNER
Script Partner is not a HIPAA covered entity. The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) applies to Script Partner because it acts as a business associate. Its role depends on which Service is involved:
Telehealth Services — Business Associate of the Medical Group. The Medical Group and its Providers are the HIPAA covered entities responsible for your telehealth care, and the protected health information (“PHI”) created or received in connection with that care is governed by the Medical Group’s Notice of Privacy Practices and by HIPAA. Script Partner supports the Telehealth Services as a business associate of the Medical Group and handles PHI only as permitted by its Business Associate Agreement with the Medical Group and by HIPAA.
Provider Support Services — Business Associate of the Practice. When Script Partner provides medication access support to a prescribing physician or practice, Script Partner acts as a business associate of that provider or practice. PHI handled in that role is governed by the business associate agreement that forms part of the provider’s separate written agreement with Script Partner, and Script Partner uses and discloses that PHI only as permitted by that agreement and HIPAA. Providers should refer to “Information Relating to Health Care Providers” below.
Where information you provide is not PHI governed by HIPAA — for example, certain information collected from Visitors to the Site, or information you provide to Script Partner directly before any provider-patient relationship is formed — this Privacy Policy, and where applicable our Consumer Health Data Privacy Policy, describe how we handle it. Even where Script Partner is not acting as a covered entity, it maintains the privacy and security of health information consistent with the standards of the HIPAA Security Rule.
ACCEPTANCE OF PRIVACY POLICY
By using the Site or Services, you agree to the terms of this Privacy Policy. If you do not agree, you may not use the Services or the Site. Your continued use of the Services following the posting of changes to these terms will mean that you accept those changes.
PERSONAL INFORMATION PROVIDED BY YOU
Script Partner collects your personally identifiable information (“PII”), including health information, through the Services when you choose to provide it — for example, when registering as a Member, completing a medical intake or questionnaire, communicating with a Provider, or making a purchase. PII can include your name, prescription and over-the-counter medications, health conditions, medical history, address, telephone number, email address, date of birth, credit or debit card number, health care coverage, pharmacy, and physician. In connection with the Telehealth Services, we also collect the clinical information necessary to deliver care, which may include information you report about your health, measurements and vital signs, laboratory results, and information about your response to treatment. Script Partner may also collect certain information you indirectly provide when you use the Site, such as your activity on the Site or when you interact with our communications.
SCRIPT PARTNER’S COLLECTION OF YOUR PUBLICLY AVAILABLE INFORMATION
In order to better provide the Services and to help manage your care, Script Partner may request publicly available personal information about you that is maintained by consumer data companies such as Acxiom and/or LexisNexis or other similar services. This information may be used to verify your identity in online transactions and to help tailor the Services to your needs.
By agreeing to Script Partner’s Terms of Use, and subject to any separate consent or authorization you provide, you authorize and consent that your medical information may be retrieved from Healthcare Entities and from health records systems and data sources in order to provide and support the Services. Script Partner obtains this information as a business associate of, and under the authority of, the treating provider or practice. Please read the “Consent to Records Retrieval and Care Coordination” section of the Terms of Use carefully to understand how your medical information may be collected and exchanged.
SCRIPT PARTNER’S USE OF PERSONAL INFORMATION
Providing the Services. Script Partner may use your PII to address your requests and to provide and support the Services, including to (i) support the Medical Group and its Providers in delivering care to you; (ii) obtain your medication and other relevant health information from your physicians, pharmacies, health care coverage providers, pharmacy benefit managers, and health information networks involved in your care; (iii) support treating providers with information and analysis relevant to your care and medications; (iv) process and fulfill your orders and payments; (v) support your access to prescribed medications, including identifying options that may reduce your costs where available; and (vi) support other services directed by a Provider or requested by you.
Assisting You in Managing Your Care. Script Partner may use your PII to assist you in managing your care and medications. To do so, Script Partner may contact you by phone, email, or text to, among other things, schedule or remind you of telehealth visits, confirm your current medications, remind you about refills, coordinate care with your other providers, and provide other health care services.
Marketing by Script Partner. Script Partner may use your PII to deliver advertisements and marketing communications that we believe may be of interest, and these communications will be delivered solely by Script Partner. We will not use PHI for marketing in a manner that requires your authorization without first obtaining that authorization. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.
SMS Program. Script Partner may send SMS short-code messages as part of our messaging program. When you receive texts from a short code, you may respond — for example, with keywords to stop receiving texts or to request help — and we may log your responses to administer the program. Personal data collected through and for the purposes of user-requested alerts and service notifications, including short-code text messages, will not be shared, sold, or rented to any affiliated or unaffiliated third parties for marketing purposes.
OUR COMMITMENTS REGARDING SENSITIVE HEALTH DATA
We know that information about your medications and health conditions is sensitive. Script Partner does not sell your PHI, and does not sell consumer health data, without your express authorization. Script Partner does not use third-party advertising trackers, pixels, or similar technologies to disclose your health conditions, the medications you are prescribed, or the fact that you have sought care for a particular condition to advertising platforms or data brokers for those parties’ own advertising purposes. Any use or disclosure of PHI is made in accordance with HIPAA and the governing Business Associate Agreement and, as applicable, the Medical Group’s Notice of Privacy Practices.
DISCLOSURE OF PERSONAL INFORMATION
Script Partner does not receive monetary payment from any external party in exchange for the ability to buy, rent, or license your PII. Neither Script Partner nor the Medical Group sells PHI without your express authorization. For more information about your rights under HIPAA, including your right to revoke an authorization in writing at any time, please refer to the Medical Group’s Notice of Privacy Practices.
Disclosures Related to Providing the Services. Based on your authorization and consent under the Terms of Use, and acting as a business associate of the treating provider or practice (and, where applicable, as the provider’s delegate or authorized participant), Script Partner may obtain your PHI from your Healthcare Entities and from health information exchanges and networks for treatment, payment, and health care operations purposes. You acknowledge that information you provide may be disclosed to Healthcare Entities, including a treating or referring provider and dispensing pharmacies, in order to provide the Services. Where Script Partner supports a treating provider through the Provider Support Services, Script Partner discloses the resulting medication history and safety-review information to the requesting provider or practice. Script Partner is not responsible for protecting the privacy of your information once it is in the possession of a Healthcare Entity acting in its own right.
Disclosures to Third Parties Assisting in Our Operations. Script Partner may share your PII with other companies that work with or on behalf of Script Partner to provide the Products and Services, such as technology, payment-processing, laboratory, pharmacy, and network-connectivity providers. These companies may use your PII only to assist Script Partner in its operations, and those that handle PHI do so under written agreements consistent with HIPAA.
Disclosures Under Special Circumstances. We may provide information about you to respond to subpoenas, court orders, legal process, or governmental regulations, or to establish or exercise our legal rights or defend against legal claims. We may also share information where necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to physical safety, or as otherwise required by law.
Business Transfers. We may share your PII with another business entity in connection with the sale, assignment, merger, or other transfer of all or a portion of Script Partner’s business. We will require any such successor entity to honor the terms of this Privacy Policy.
AUTOMATICALLY COLLECTED INFORMATION AND ANONYMOUS INFORMATION
Aggregated Data. Script Partner collects aggregate queries for internal reporting and tracks and aggregates Visitor activity into our analysis of general traffic flow. We may remove personal identifiers from PII and maintain it in aggregate form to generate anonymous, aggregated statistical information, which may be shared on an aggregated basis with our affiliates, business partners, and service providers.
Web Server Logs and IP Addresses. An Internet Protocol (“IP”) address is a number that automatically identifies the computer or device you use to access the Internet. Script Partner may use IP addresses to conduct analyses and performance reviews and to administer the Services.
Cookies and Web Beacons. Cookies are pieces of information that a website transfers to a user’s computer to store information about a user’s preferences. Script Partner uses cookies to improve your online experience. You can set your browser to refuse cookies, but some portions of the Services may not work properly if you do. Some of our web pages may use web beacons in conjunction with cookies to compile aggregate statistics about Site usage. As described above, we do not use these technologies to disclose your health conditions or prescribed medications to advertising platforms for their own advertising purposes.
REFERRALS / LINKS
The Services contain links to third-party websites that may offer information of interest. This Privacy Policy does not apply to those websites, and Script Partner recommends reviewing their privacy policies individually.
SECURITY
Script Partner stores PII and other data using industry-standard physical, technical, and administrative safeguards designed to secure data against foreseeable risks, such as unauthorized use, access, disclosure, destruction, or modification, consistent with the standards of the HIPAA Security Rule. Please note, however, that while Script Partner endeavors to maintain a secure and reliable environment, the confidentiality of any communication or material transmitted to or from the Services or via email cannot be guaranteed.
YOUR ROLE IN PROTECTING YOUR PRIVACY
You are responsible for maintaining the confidentiality of your Script Partner account password. Never share your password with anyone you do not want accessing your account. You agree that any user of your password is bound by the terms set forth in this Privacy Policy and the Terms of Use, and it is your sole responsibility to inform Script Partner of any need to deactivate a password.
RESPONSE TO “DO NOT TRACK” SIGNALS
Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not yet been adopted, Script Partner does not currently process or respond to “Do Not Track” signals, except where required by applicable law.
CHILDREN’S PRIVACY PROTECTION
The Services, including the Site and any mobile application, are not designed for use by, or intentionally targeted at, children under 18 years of age, and the Telehealth Services are available only to patients who are at least 18. If you are under 18, you may only use the Site with the involvement of a parent or guardian. Script Partner does not knowingly collect or maintain information about anyone under the age of 13 without the consent of the child’s parent or guardian, and no one under the age of 13 should submit any PII to Script Partner or the Site.
YOUR CHOICES AND HOW TO CONTACT US
At certain locations on the Site where information about you may be requested, you are offered the opportunity to opt out of receiving marketing communications from Script Partner. You may also review and request changes to your PII that Script Partner has collected, including requesting removal of your PII from Script Partner’s databases in order to prevent future communications or to stop receiving the Services, subject to our legal and clinical record-retention obligations. You may exercise these choices by:
- Emailing your request to support@scriptpartner.com; or
- Mailing your request to: Script Partner LLC, Attention: Privacy Officer, 1407 Broadway, Suite 1910, New York, NY 10018.
Please note that if information constitutes PHI or part of a medical record, your rights to access, amend, or restrict that information, and the ability to delete it, are governed by HIPAA and applicable state medical-records law and are described in the Medical Group’s Notice of Privacy Practices. For PHI held by Script Partner as a business associate, Script Partner will forward or assist with your request as directed by the applicable covered entity.
ADDITIONAL STATE-SPECIFIC PRIVACY DISCLOSURES
Notice related to state-specific privacy laws for residents of states including California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia is available in our Additional State-Specific Privacy Disclosures. Many of these laws exempt PHI and information governed by HIPAA; the disclosures explain how they apply to information that is not so governed.
CONSUMER HEALTH DATA (WASHINGTON, NEVADA, CONNECTICUT, AND SIMILAR LAWS)
Certain states, including Washington (My Health My Data Act), Nevada, and Connecticut, regulate “consumer health data” that is not otherwise governed by HIPAA. To the extent Script Partner collects consumer health data subject to these laws, we maintain a separate, standalone Consumer Health Data Privacy Policy that describes the categories of consumer health data we collect, the purposes for which we collect and use it, the categories of sources, the categories of third parties and the specific affiliates with which it may be shared, and how you may exercise your rights to access, delete, and withdraw consent. That policy is available through a distinct link on our homepage. Where these laws require it, we obtain your affirmative, opt-in consent before collecting consumer health data that is not necessary to provide a Service you have requested, obtain separate consent before sharing such data, and obtain a valid written authorization before any sale of such data. We do not use geofencing to identify or track consumers seeking health care services, to collect consumer health data, or to send health-related messages based on a consumer’s proximity to a health care facility.
INFORMATION RELATING TO HEALTH CARE PROVIDERS
This section applies if you are a health care provider, practice, or a member of a provider’s staff who uses the Provider Support Services. Information that a provider or practice and its personnel exchange with Script Partner in connection with the Provider Support Services — including PHI submitted or accessed to perform medication access support — is governed by the provider’s separate written agreement with Script Partner, including any business associate agreement and agency agreement, and not by this Privacy Policy. In the event of any conflict, that agreement controls as to that information. This includes situations where Script Partner contacts a patient directly on the provider’s behalf to support the Provider Support Services (for example, to confirm a medication list or insurance details): those contacts are made in Script Partner’s capacity as the provider’s business associate and are governed by the provider’s agreement, not this Privacy Policy. This Privacy Policy governs Script Partner’s handling of information about patients and Site visitors where a patient engages Script Partner directly through the Site or the Telehealth Services.
POLICY UPDATES
This Privacy Policy may be revised from time to time as we add new features and Services, as laws change, and as privacy and security best practices evolve. We display an effective date at the top of this Privacy Policy so that it is easier for you to know when a change has been made. If we make material changes regarding the use or disclosure of PII, we will provide notice on the Site, via email, or through the applicable app store. Small changes that do not significantly affect individual privacy interests may be made at any time and without prior notice.
QUESTIONS?
If you have any questions about this Privacy Policy or about Script Partner’s handling of your information, please contact support@scriptpartner.com or 1-844-507-7910, or write to Script Partner LLC, Attention: Privacy Officer, 1407 Broadway, Suite 1910, New York, NY 10018.
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