Privacy Policy

Thank you for visiting the City Care Partners Privacy Policy (the “Policy”). City Care Partners helps primary care providers improve the health of their patients and communities by participating in value-based care arrangements called Accountable Care Organizations or ACOs, specifically through the CMS LEAD Model.

This Policy applies to the personal information we collect through our website (the “Website”), through our care management and population health platforms (the “Platforms”), and our care coordination services (collectively, the “Services”) and describes:

• The Personal Information We Collect
• How We Collect Personal Information
• How We Use Personal Information
• Who We Disclose Personal Information To
• Choices and Access
• Contacting Us

1. Scope of this Policy

Personal information. We use “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked – directly or indirectly – with a particular individual or household. For this Policy, “personal information” does not include (a) aggregated or deidentified information that is not capable of being associated with or reasonably linked to an individual, (b) public information lawfully available from governmental records, or (c) protected health information or “PHI” that we process in our capacity as a business associate or participating entity under the Health Insurance Portability and Accountability Act or “HIPAA”.

Patients. If you are a Medicare beneficiary or a patient of a practice that participates in our ACO, you can find out more about your practice’s specific privacy practices by contacting them directly. For information specifically about how Medicare shares your claims data with our ACO, please review our Data Sharing & Privacy page.

Personnel. This Policy does not apply to our processing of personal information about job applicants, employees, or contractors.

Third-Party Links. For convenience, our Services may link to third-party sites that we do not control. This Policy does not apply to third-party sites, including how they define personal information or how they use it. We encourage you to read any third-party’s privacy policy and know your privacy rights before interacting with them.

International Users. Our Services are hosted in the United States and are intended for access and use by individuals located in the United States only. We may store and process your personal information in any country where we have facilities or in which we engage service providers. By using the Services, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

2. Changes and Updates to this Policy

We may change this Policy at our sole and absolute discretion and will post any changes on this page and update the date at the top, so be sure to check back periodically. All changes are effective when we publish them unless otherwise noted.

3. Personal Information We Collect

This section describes the categories of personal information we and our service providers collect. The types of personal information listed in each category are examples only and are not exhaustive.

• Personal identifiers and contact information, such as name, title, date of birth, postal and email address, telephone and fax number, National Provider Identifier (NPI) number, group practice number, state medical license number, tax identification number, and other unique identifiers.
• Web log and Cookie information, such as device identifiers, user ID, IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data, cookie identifier, browsing and search history.
• Health care practice-related information, such as information about the practices that participate in our ACOs and their patients.
• Demographic information, such as gender, military service, citizenship status and other protected class information that you may choose to provide us to the extent permitted by law.
• Commercial and financial information, such as accounts payable information relating to our service providers, vendors, and contractors.
• Educational, professional, or employment-related information, such as information about where you work and your company’s name, your position, what certifications or degrees you have obtained, or your educational, professional and employment history, and resume information.
• Audio and visual information, such as the sound of your voice, or your image, if you attended and spoke at a webinar that we hosted or attended an event with us or left us a voicemail.
• Location data, as it can be derived from your IP address and practice-location information provided to us by Platform users when setting up an account.
• Inferences drawn from any of the information identified above to create a profile reflecting your preferences regarding our Services.
• Other information you or others provide us. You or others may provide us with other personal information when communicating or otherwise interacting with us, such as information about your family and associations.

4. How We Collect Personal Information

We collect personal information from the following sources:

• You, including information you (a) provide to us directly when communicating with us or using our Services, including the interactive features of our Services; (b) submit through the Website or when registering for and using our Platforms; (c) register for a webinar or events; or (d) provide through your interactions with us.
• Web logs, Website analytic services, and Cookies, including information that is collected automatically from your device and stored in log files. For more information on website analytics and cookies, please see the Information Collected Automatically section below.
• Third parties, including:
  • Practices that participate in our ACOs;
  • Business contacts such as those that refer you to us;
  • Service providers, including technology/website hosting providers, analytics providers, and systems administrators; and
  • Data collection and aggregation services that, in turn, obtain this data from publicly available sources. We also obtain information from proprietary databases.

If you disclose any personal information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy.

5. How We Use Personal Information

We collect each of the categories of personal information above for a variety of purposes, including:

• To contact you, including to respond to your inquiries and questions, to contact you with information about our Services and promotional or other information that may be of interest to you, or to consider you for certain partnerships or collaborative opportunities.
• To operate our business and offer or provide Services, including client services, events, information, fulfilling our contractual obligations, and to alert Platform users to new projects, features, and services.
• To identify individuals, practices, or groups that might work with us, and pay you for, or communicate with you about, products or services you provide to us.
• To identify potential practices that may want to participate in one of our ACOs.
• To facilitate the management of care for patients and health care operations consistent with the CMS LEAD Model requirements and other applicable terms of use.
• To offer, maintain, and improve the Services that we provide or make available, including troubleshooting, and to give us insights on how you and other users utilize our Services.
• To protect and secure our Services, assets, network, and business operations, and to detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.
• To facilitate social sharing functionality on our Services that you choose to use.
• To facilitate marketing or re-marketing of our Services to you, including to track and associate Internet search and browsing behavior with our advertisements, and to help us understand what information and Services you may be interested in, so that we can personalize our interactions with you. However, we do not use the mobile phone number you provide us to make marketing calls or send marketing text messages.
• For aggregating and/or anonymizing personal information, so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
• For our business purposes, such as data analytics, audits, developing new products, conducting research regarding our Services for the purposes of enhancing, maintaining, improving, or modifying our Services, increasing business efficiencies, addressing legal, regulatory, or contractual requirements (including CMS reporting), tailoring, measuring, and improving our promotional campaigns, and planning, operating, managing, and expanding our business activities.
• As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and governmental authorities; (d) to protect our rights, privacy, safety, or property, and that of our ACOs, you, or others; (e) to enforce our terms and conditions; and (f) to allow us to pursue available remedies or limit the damages that we may sustain.
• In connection with certain business transactions, to facilitate any proposed or actual reorganization, bankruptcy, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our assets or stock.

6. How We Disclose Personal Information

The categories of third parties to whom we disclose personal information include:

• Service providers, including third-party providers of services such as Website and Platform hosting, data analysis, fraud prevention, information technology and related infrastructure provision, customer service, email delivery, auditing, and care management technology services.
• Practices that participate in our ACOs and other business contacts. As a reminder, this Policy does not apply to the collection, use, or disclosure of personal information by practices participating in our ACOs, though we may share information about inquiries we receive from individuals directly with the applicable practices. Please contact your practice with questions about their privacy practices.
• Advertising and analytics partners. We allow our third-party advertising and analytics partners to use cookies, scripts, pixels, beacons and other online data collection technologies (collectively, “Cookies”) to collect information about the use of our Services over time and the activities of users across unaffiliated sites and services. For more information, please see the Information Collected Automatically section below.
• Law enforcement, governmental authorities (including CMS), or other third parties to protect our rights and the rights of others, such as to respond to legal requests and legal process; to comply with applicable law or ACO program requirements; to cooperate with law enforcement; or to protect the health and safety of us, our ACOs, or any person.
• Third parties in connection with any proposed or actual reorganization, bankruptcy, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our assets or stock.
• As otherwise described to you when collecting the personal information.

7. Information Collected Automatically

We and our third-party partners collect information automatically in a variety of ways, including:

Your browser or device

Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.

Your use of the Platforms

When you use the Platforms, we and our service providers may track and collect usage data, such as the date and time the Platform on your device accesses our servers and what information and files you have downloaded.

Cookies

Cookies allow us to collect such information as browser type, time spent on the Services, pages visited, language preferences, unique identifiers, content you view, click on, or share, screen gestures or actions, and other traffic data. We and our service providers use the information for security purposes, to power the interactive features of our Services, to facilitate navigation, to display information more effectively, to personalize your experience, and to develop and improve the performance, functionality, and design of the Services.

If you do not want information collected through the use of Cookies, you can use the banner on our Website to decline non-essential Cookies. In addition, most browsers allow you to automatically decline Cookies or be given the choice of declining or accepting particular Cookies. If, however, you do not accept Cookies, you may experience some inconvenience in your use of the Services.

Analytics

We use third-party analytics services, including Google Analytics, which use Cookies to collect and analyze information about use of the Services and report on activities and trends. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on.

Google Analytics and Google Ads

We use tools like Google Analytics and Google Ads to help us understand how visitors engage with our Website and to measure the effectiveness of our advertising campaigns. Your choices on our consent banner directly control how these tools operate.

• If You Accept: When you accept advertising and analytics cookies, Google tags will be fully activated. We will collect and share information with Google to measure performance, personalize your experience, and for remarketing purposes, as detailed in this Policy.
• If You Decline: If you decline consent for Marketing or Performance cookies, your privacy choice is respected. We use Google's Advanced Consent Mode, which means we will not store or read any related cookies on your device for these purposes. Your personal data will not be used for ad personalization or shared with Google for remarketing lists. However, to help us understand the overall performance of our campaigns and website, our website will send non-personal, aggregated signals to Google. This "cookieless ping" does not contain any personally identifiable information. The data sent is limited to things like: (1) the type of browser you are using, (2) a generalized timestamp of your visit, (3) the country you are visiting from, or (4) an indication of the conversion action. This aggregated information allows us to model conversions and helps us make better decisions about our website and marketing efforts without compromising your individual privacy.

8. Choices and Access

You have additional choices regarding how we use your personal information, including the following:

Controlling promotional email communications preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in the email. You can also email us at info@citycarepartners.com and ask to be unsubscribed from our promotional emails. Please note that if you opt out of receiving promotional email communications from us, we may still send you Service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Website and Platforms, technical and security notices), from which you cannot opt out.

9. Children under 18

Our Services are not designed for, directed to, or intended for use by children under the age of 18. If you are under the age of 18, please do not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 18 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our system. If we know that a child under the age of 18 is using our Services, we will take steps to delete such information as soon as possible.

10. Retention of Personal Information

We retain personal information for as long as is needed or permitted to fulfil the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise;
• Whether there is a legal obligation to which we are subject, for example, certain laws and CMS program requirements require us to keep records of your transactions for a certain period of time before we can delete them; or
• Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations.

11. Third-Party Services

This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

12. Security

We seek to use reasonable organizational, technical, and administrative measures to protect personal information within our organization, including adhering to HIPAA security standards where applicable. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

13. Region-Specific Disclosures

Additional or different disclosures relating to the processing of personal information may apply to residents of certain states.

California. If you are a resident of the State of California, you have certain rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, use, and disclose; the right to delete your personal information; the right to correct inaccurate personal information; and the right to opt-out of the sale or sharing of personal information. City Care Partners does not sell personal information. To submit a request regarding these rights, please contact us at info@citycarepartners.com.

Nevada. If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits you to opt out of potential future sales of certain covered information. City Care Partners does not sell personal information. To submit a related request, please contact us at info@citycarepartners.com.

14. Contacting Us

Questions. If you have questions about this Policy or the processing of your personal information, please contact us at:

City Care Partners
Attn: Privacy Officer
575 8th Ave Floor 10, New York, NY 10018, United States

Phone: +1 347-534-2516
Email: info@citycarepartners.com