Website Privacy Policy

Last updated: January 24, 2024

This Privacy Policy applies to information collected by Primary Health Network and PHN Charitable Foundation (collectively, “we,” “our,” or “us”) in connection with your access or use of our website (primary-health.net) and our mobile application (collectively, our “online services”).  Our online services are designed to provide the community with information about our services, locations, and hours, as well as details about our organization and our partners.  Our online services are part of our outreach strategy and are designed to serve as resource tools.

This Privacy Policy describes the information we collect, how we use it, and how we protect it. When used in this policy, the term “personal information” means information about an individual that identifies or describes a natural person.  Any personal information that meets the definition of protected health information (“PHI”) under the Health Insurance Portability and Accountability Act (“HIPAA”) is governed by and will be used and disclosed solely as described in Primary Health Network’s Notice of Privacy Practices, not by this Privacy Policy.

By accessing or using our online services, you consent to the use of cookies and tracking technologies as described in this Privacy Policy.  Please read this policy carefully.

1 | What Information Do We Collect About You?

You may access and use our online services without providing your personal information.  There are several ways we may collect information about you:

A. Information You Provide to Us

You may access and use our online services without providing your personal information.  Our online services do not request, require or collect your personal information or your protected health information.

Our online services, specifically our website, contain links and integrations to third-party sites and services.  The third-party sites and services may request, require, or collect your personal information or your protected health information.  Any information collected by the third-party sites and services will be subject to their privacy policies which are available when you click on their links on our website.  We have also included their privacy policies below:

Name of Third Party	Type of Service Provided	Third-Party Privacy Policy
Intelichart	Appointment Scheduling	Intelichart Privacy Policy
Irecruit	Recruitment Portal	Irecuit Privacy Policy
Phreesia	Appointment Scheduling	Phreesia Privacy Policy

B. Information We Collect Automatically

We automatically collect certain device and use information when you access or use our online services, including:

• Device information: Our online services collect information about the devices used to access or use our website, including the hardware model, operating system and version, unique device identifiers such as Internet Protocol (“IP”) addresses, mobile network information, browser type and language and referring URLs.  With your device settings permitting, our online services may also collect information about the precise location of your device.
• Use information: We collect information about your use of our online services, including the date and time you visit the website; use or click through to any of the links; the information, content, or advertisements you view, hover over, or click on; the amount of time you spend viewing or using the website and mobile application; the number of times you return; other click-stream or site usage data; and emails or social media posts that you open, forward or click-through to our website and mobile application.

To collect such information, our online services use tracking technologies, including:

• Cookies (or browser cookies): A cookie is a small file or piece of data sent from a website and is stored on the hard drive of your computer or mobile device.  You may refuse to accept browser cookies by activating the appropriate setting on your browser, and similar capabilities may be available on your mobile device in the preferences for your operating system or browser.  Please note, however, that if you select this setting, you may be unable to access or use certain parts of our website.  Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website or use our app.

• Web beacons or tracking pixels: A tiny graphic image placed on a webpage that allows the website owner or a third party to collect information regarding the use of the webpage that contains the web beacon or pixel.

We use tracking technology vendors to help collect and analyze the information collected.  The companies may also combine information they collect from your interaction with our website with information they collect from other sources.  We may not have access to information these companies collect using cookies or other tracking technologies.  We use tracking technology vendors, including:

• Google Analytics: We use Google Analytics, a web analytics service provided by Alphabet Inc. (“Google”), to collect and analyze certain information relating to your use of our online services.  You can find out more about how Google uses data by visiting “How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners/).  For more information regarding Google Analytics, please visit Google’s website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
• LinkedIn: We use LinkedIn advertising services provided by LinkedIn to advertise open positions within our organization and track what users do after they see or click on our advertisement. This is to better provide relevant content and advertisements to our target audiences.  For more information regarding LinkedIn’s use of cookies, please visit their Cookie Policy and LinkedIn Cookie Table.
• Facebook Pixel: We use Facebook Pixel, a web analytics and advertising service provided by Meta Inc. (“Facebook”), to track what users do after they see or click on a Facebook advertisement for Primary Health Network and PHN Charitable Foundation, to track users who access our website or advertisements from different devices, and to better provide advertisements to our target audiences.  The data from Facebook Pixel is also saved and processed by Facebook.  Under Facebook’s Data Policy, it can connect this data with your Facebook or Instagram account and use it for its own and others’ advertising purposes.  If you would like to withdraw your consent for the use of your data with Facebook Pixel, please visit: https://www.facebook.com/settings/?tab=ads.

2 | How Do We Use Information About You?

We may use the information collected to:

• Improve Our Online Services: We may use your information to improve our website and mobile application, to help diagnose problems with our online services and servers; analyze trends; track users’ web page, and mobile application movements/activities.
• Personalize or Contextualize Our Services: We may use your information to help personalize and contextualize our website and provide relevant content based on how you interact with our website.
• Business Operations: We may use your information to understand your use of our online services in order to consider improving them, including to provide, change, market, or optimize our services to perform analytics and to create new services and products.  We also may use your information to determine whether applicable policies and terms are being violated.
• Security and Auditing: We may use your information to detect security incidents, protect against fraud or other malicious activity, and identify and repair errors that may arise.
• Complying with Laws: We may use your information to comply with applicable laws, including as required by judicial or administrative proceedings.

We may also use your information for other purposes as disclosed at the time you provide your information or otherwise with your authorization.

3 | How Do We Share Your Information with Others?

We may share your information with companies that we work with or provide services to us in the ways described below.

A. Affiliates and Subsidiaries

We may share information with our subsidiaries and affiliated companies for business and operational purposes.

B. Service Providers and Third Parties

We may share your information with service providers and third parties to perform services on our behalf, including:

• Data analytic, data connectivity and customer data providers and platforms
• Customer engagement or relationship management platforms
• Cloud computing providers
• Software development tools
• Data providers and analytics software
• Text delivery and analytics platform

C. For Corporate Transactions

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control.  If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity.  In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties.  Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use information provided through the Services in a manner that is consistent with this Privacy Policy.

D. For Legal Obligations/Safety

We may be required by law to comply with a valid legal process, such as a subpoena, court order, or search warrant, or where there is a lawful request, to disclose your information without your consent or notice.  We may also be required to disclose your information to a third party or governmental entity in response to a court order.  We may disclose your information to protect the security of our website, servers, network systems, and databases.

E. To Enforce Legal Rights

We may also share your information to protect our patients, employees, or property; in emergency situations; to investigate, prevent, or take other action regarding suspected illegal activity, fraud, or other wrongdoing; and to enforce our rights under our terms of service and policies, in court or elsewhere.

4 | What Choices Do You Have?

A. Cookies and Do Not Track

To control what cookies are collected when you are on our website, please click on the “Cookie Preferences” link at the bottom of the applicable webpage.

You may adjust your device or Internet browser settings to limit certain tracking or to decline cookies, but by doing so, the performance of your device or browser may prevent you from being automatically recognized upon revisiting and you may not be able to use certain features of the website.  Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable your device or browser from receiving cookies or controlling your tracking preferences.

B. Your Privacy Rights

• We do not sell your personal information.

• We do not conduct profiling in the furtherance of decisions that produce legal or similarly significant effects, however, Primary Health Network and PHN Charitable Foundation does not conduct such profiling.

5 | European Union Visitors

Please do not use our website if you are not a resident of the United States.  Our website is intended for use only by residents of the United States.  Use by visitors from the European Economic Area (or EEA) or the United Kingdom is prohibited.

6 | Children’s Privacy

We are committed to protecting the privacy of children.  Our website is intended for adults and minors age 13 and over.  It is not intended for or designed to attract persons under the age of 13. We do not permit registration by, nor do we knowingly collect personal information from individuals under the age of 13.  

7 | Third-Party Services and Websites

When you access or engage with a third-party service, application, or website, even when doing so through our website, equipment or applications, you are entering that service, application, or website and governed by its policies.  Many third parties have their own privacy policies that differ from ours.  This Privacy Policy only covers our website and does not cover any other third parties.  We may collect usage information related to those third-party products, services, applications, or websites if they are accessed through our websites or applications.

8 | How Do We Protect Your Information?

We take information security seriously.  We use commercially reasonable efforts to prevent unauthorized third-party access to your personal information.  However, we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclosure of your personal information.  Please note that we cannot ensure or warrant the security of any information you transmit to us over the internet or other electronic means (such as text messages).  You use our website at your own risk, and we accept no liability for unintentional disclosure.

9 | What About Changes to This Notice?

We may modify this Privacy Policy at any time.  When we do so, we will post the revised Privacy Policy on our website.  Please check the revision date at the top of this page to determine if the policy has been modified since you last reviewed it.  By continuing to use our website after any changes to this policy, you acknowledge and agree to the revised policy.

10 | Who Can You Contact with Questions or Concerns?

Please address comments or questions to us about this Privacy Policy via phone by calling
1-866-276-7018.  We are available Monday-Friday (excluding holidays), from 8:30 AM to 5:00 PM (EST).  You may also contact in writing at:

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