Privacy and Security Practices

Effective as of September 10, 2010

What are the kinds of ways that MCL protects your privacy?

MedClaims Liaison (MCL) is committed to protecting the privacy and security of our members. The information in our Privacy and Security Policy applies to MedClaims Liaison with respect to our company, our services, and our website. These practices govern data collection and usage of both personal data and healthcare data.

At MCL, we are passionate about your medical claims and delivering superior service to our members. In order to do that, we must collect many kinds of personal information about members and their dependents. To understand how we work to protect you, first consider the kinds of information we collect and the kinds of things we do with that information.

What kind of information does MCL collect?

Personal Health Information

With your authorization, MCL contacts your physicians, hospitals, other providers and payors on your behalf. We review your medical records, health care insurance company records, insurance policies, and insurance information to handle your medical reimbursements for you. In order to do this, MCL might access different websites, portals, member services departments, customer representatives and other sources to gather information.

As a member of a MCL, with your authorization we collect some of the following kinds of personal and healthcare information about you including your name, address, telephone number, email address, member identification numbers, medical records, billing records, claims information, information on your medical conditions, prescribed medications, health risk status, and other health and wellness-related information (“Personal Health Information”). Your employer or insurance broker may provide information to us on your behalf including certain financial information like your premium history. Member information that we collect includes information on registration forms, whether it was entered into our website, faxed or given to an MCL Service Team via phone. MCL also collects anonymous demographic information, which is not unique to you, such as your age, zip code, gender, preferences and interests.

Electronic Data

Like most commercial websites, we collect certain information that does not identify you personally, but provides MCL with "usage data," such as the number or frequency of visitors to the site or its pages. We analyze this data to improve our services, My MedClaims and our website. This electronic data includes information about your computer hardware and software, including: your IP address, browser type, domain names, access times and referring website addresses. We use this data to provide and improve upon the quality of our services. We also use this data for general statistics regarding the use of our website. For example, the MCL website may use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize your My MedClaims pages, or register with our website or for our services, a cookie helps us to recall your specific information on subsequent visits. This simplifies the process of recording your personal information. When you return to our website, the information you previously provided can be retrieved, so you can easily use the features that you customized. MCL cannot read or access any of your private online communications, other than those sent specifically to us.

General Correspondence

At MCL we keep track of many aspects of our correspondence in order to provide the best possible service to you. For example, each conversation, recipient, participant, email and phone call is logged and tracked so that we can proactively resolve reimbursement issues for our Members.

What do we do with your information?

Provide Services

As an authorized representative, we obtain and utilize your personal information to perform our scope of services. Members designate us to be their personal representative, authorizing MCL to communicate with their physicians, hospitals, health providers, insurance companies, third party payors, third party administrators, benefits administrators, government agencies or government programs, and sometimes employers, on their behalf. Your personal information is maintained and made available to MCL employees so that we can provide these services. From time to time, we may request or use personal information in order to deliver requested materials to you, respond to your questions, or deliver a product or service. Except to provide Our Services and as provided above, MCL will disclose your personal information only if required to do so by law or in the good faith belief that such action is necessary: (a) to conform to the edicts of the law or comply with legal process pursuant to a subpoena or summons; (b) to protect and defend the rights or property of MedClaims Liaison; (c) to act under exigent circumstances to protect the personal safety of users of MedClaims Liaison, or the public; (d) as permitted by law with our attorneys, accountants and auditors, your authorized representatives, if any, healthcare providers, third-party administrators, disease management companies, insurance companies, or insurance agents and brokers.

From time to time MCL may share your personal health information with carefully selected strategic partners. Some of these partners may help us perform statistical analysis, communicate with you or provide services to our members. All such third parties are prohibited from using your personal information except to provide these services, and they are required to maintain the confidentiality of your personal information. MCL may disclose information to consultants, lawyers, and other professionals so that they may lend expertise.

Statistical Analysis

MCL collects and uses Personal Health Information in order to develop statistical and other analyses using the data on a de-identified and aggregate basis. The development of analytical approaches is intended to make us more effective in providing its services and to increase the value of our services. We may share data with trusted strategic partners, including MedClaims Analytics, a related statistical analytics organization. Most strategic partners, consultants, lawyers and other professionals will only receive de-identified aggregate data, however, to the extent that they receive personal health information, they will have agreed to use the same methods as described in these practices, as well as comply with all applicable laws regarding the privacy, security and confidentiality of personal health information. MCL may share or sell de-identified personal health information or aggregate data with/to third parties. In no event is your name or other personally identifying information disclosed in any analytical report. MCL does not sell, rent or lease its customer lists to third parties.

Member Responsiveness

While MedClaims Liaison is not a HIPAA covered entity, as a member you can: (i) request certain restrictions on the use of your Personal Health Information; (ii) complain to the MedClaims Liaison Privacy Officer about any use or disclosure of your Personal Health Information at 855-MCL-4YOU (855-625-4968); and/or (iii) revoke your authorization to MedClaims Liaison to be your personal representative and to access, use and disclose your Personal Health Information.

Links to Third Party Resources

MCL has links on our website to potentially relevant information from other sources and other websites. These links do not constitute an endorsement of another company’s products or services. MCL cannot and does not take responsibility for the privacy and security practices or the accuracy or reliability of content of the organizations with links on our website. We encourages you to review the privacy statements of websites you choose to link to from our website so that you can understand how those websites collect, use and share your information.

Security of your Personal Information

MCL has adopted and adheres to stringent security standards designed to protect your personal information against accidental or unauthorized access or disclosure. Among the safeguards that MCL has developed for this site are administrative, physical and technical barriers that together form a protective firewall around the information entered into, stored or retrieved from our site. MCL secures your Personal Health Information on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information is transmitted to other websites or domains, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

E-Mail

Your e-mail, like most, if not all, non-encrypted Internet e-mail communications, may be accessed and viewed by other Internet users, without your knowledge and permission, while in transit to us. Because of this, please use the method of communication provided on the Contact Us page of our site under Help & Resources to get in touch with us in a secure format. To view this page, please click here. We will share your comments and questions with our MCL Service Team or those employees most capable of addressing them.

Passwords

We use many techniques to protect your passwords. You will be locked out of the website after three failed attempts to enter your password, at which time we recommend that you reset it. We require a new password be created after three failed attempts to enter it. MCL Members create security questions that may remind them of their password, however, an MCL Member’s password will not be disclosed, even to the MCL Member. Instead, we require that MCL Member’s create a new one. Do not share your User Name and Password with anyone. These passwords are stored on our servers in an encrypted format using hashing techniques such that portions of the characters are stored as hash marks (ie. ##). We require that your password must contain at least 6 characters and at least one character must be a non-alpha-numeric character (ie. !@#$%^&*).

Signing-Out

Please always sign-out at the end of each session on our website. Please be careful about using third-party computers or computers that you are not familiar with such as those in Internet cafés and be careful to ensure you have fully logged out.

Credit Card Information

Most of the information collected in the registration process will be used to process your membership order. During the order process, you will have to provide financial information such as your credit card number, expiration date, and security code. This information is used for billing purposes. If we have trouble processing an order, we will use this contact information to get in touch with you. In order to most efficiently serve you, credit card transactions and order fulfillment are handled by established third party banking and processing agents. They receive the information needed to verify and authorize your credit card or other payment information and to process your payment to MCL. This process is protected by an enhanced security system. We do not share your personal and financial information with any third parties. Within MedClaimsLiaison.com, your information is kept on password protected, limited access servers. Wherever possible and applicable, MedClaimsLiaison.com servers reside behind a corporate firewall that maintains controls on access to the system from both our internal network and the Internet.

Changes to Privacy and Security

MedClaims Liaison will periodically update this Privacy Statement to reflect changes in technology, law, our services, as well as the Company and customer feedback. We encourage you to periodically review the Privacy and Security Practices to be informed about how we are protecting your information.

Contact Information

We welcome your comments regarding Privacy and Security. If you believe that MedClaims Liaison has not adhered to the Privacy and Security Practices, please contact us via telephone at 855-MCL-4YOU (855-625-4968) or via email at privacy@medclaimsliaison.com. We will use commercially reasonable efforts to promptly determine and remedy your concern.