Privacy

ORIAH (Manage Addiction Lifeline Platform)
HIPPA COMPLIANCE
and
GENERAL PRIVACY POLICY

Your Information. Your Rights. Our Responsibilities.

Effective Date: June 1, 2018

This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

Dr. Tony Juneja Privacy Contact electronic mail info@managedaddiction.com Tel: 732-942-5056

We care about data privacy and security. By using the Site, you agree to be bound by our Privacy Policy posted on the Site, which is incorporated into these Terms of Use. Some of our Services store your personal information in accordance with this Privacy Policy. Even if you do not register with or provide any personal information to ORIAH or the Manage Addiction Lifeline Platform, we collect information about your use of the ORIAH Sites and Apps and the Services. We may also acquire information about our users from external sources. Please be advised the Site is hosted in the United States. If you access the Site from the European Union, Asia, or any other region of the world with laws or other requirements governing personal data collection, use, or disclosure that differ from applicable laws in the United States, then through your continued use of the Site, you are transferring your data to the United States, and you expressly consent to have your data transferred to and processed in the United States. Further, we do not knowingly accept, request, or solicit information from children or knowingly market to children. Therefore, in accordance with the U.S. Children’s Online Privacy Protection Act, if we receive actual knowledge that anyone under the age of 13 has provided personal information to us without the requisite and verifiable parental consent, we will delete that information from the Site as quickly as is reasonably practical.

Your Rights
You have the right to:
  • Get a copy of your paper or electronic medical record
  • Correct your paper or electronic medical record
  • Request confidential communication
  • Get a list of those with whom we’ve shared your information
  • Get a copy of this privacy notice
  • Choose someone to act for you
  • File a complaint if you believe your privacy rights have been violated
Your Choices
You have some choices in the way that we use and share information as we:
  • Tell family and friends about your condition
  • Provide disaster relief
  • Include you in a hospital directory
  • Provide mental health care
  • Market our services and sell your information
  • Raise funds
Our Uses and Disclosures
We may use and share your information as we:
  • Treat you
  • Run our organization
  • Bill for your services
  • Help with public health and safety issues
  • Do research
  • Comply with the law
  • Respond to organ and tissue donation requests
  • Respond to organ and tissue donation requests
  • Address workers’ compensation, law enforcement, and other government requests
  • Respond to lawsuits and legal actions
Your Rights

When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.
Get an electronic or paper copy of your medical record

  • You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you. Ask us how to do this.
  • We will provide a copy or a summary of your health information, usually within 30 days of your request. We may charge a reasonable, cost-based fee.
Ask us to correct your medical record
  • You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this.
  • We may say “no” to your request, but we’ll tell you why in writing within 60 days.
Request confidential communications
  • You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address.
  • We will say “yes” to all reasonable requests.
Ask us to limit what we use or share
  • You can ask us not to use or share certain health information for treatment, payment, or our operations. We are not required to agree to your request, and we may say “no” if it would affect your care.
  • If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurer. We will say “yes” unless a law requires us to share that information.
Get a list of those with whom we’ve shared information
  • You can ask for a list (accounting) of the times we’ve shared your health information for six years prior to the date you ask, who we shared it with, and why.
  • We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.
Get a copy of this privacy notice

You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.

Choose someone to act for you
  • If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information.
  • We will make sure the person has this authority and can act for you before we take any action.
File a complaint if you feel your rights are violated
  • You can complain if you feel we have violated your rights by contacting us using the information on page 1.
  • You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/
  • We will not retaliate against you for filing a complaint.
Your Choices

For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions.
In these cases, you have both the right and choice to tell us to:

  • Share information with your family, close friends, or others involved in your care
  • Share information in a disaster relief situation
  • Include your information in a hospital directory

If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.

In these cases we never share your information unless you give us written permission:

  • Marketing purposes
  • Sale of your information
  • Most sharing of psychotherapy notes

In the case of fundraising:

  • We may contact you for fundraising efforts, but you can tell us not to contact you again.
Our Uses and Disclosures

How do we typically use or share your health information?

We typically use or share your health information in the following ways.

Treat you

We can use your health information and share it with other professionals who are treating you.
Example: A doctor treating you for an injury asks another doctor about your overall health condition.

Run our organization

We can use and share your health information to run our practice, improve your care, and contact you when necessary.
Example: We use health information about you to manage your treatment and services.

Bill for your services

We can use and share your health information to bill and get payment from health plans or other entities.

Example: We give information about you to your health insurance plan so it will pay for your services.

How else can we use or share your health information?

We are allowed or required to share your information in other ways – usually in ways that contribute to the public good, such as public health and research. We have to meet many conditions in the law before we can share your information for these purposes. For more information see: http://www.hhs.gov/ocr/privacy/hipaa/ understanding/consumers/index.html.

Help with public health and safety issues

We can share health information about you for certain situations such as:

  • Preventing disease
  • Helping with product recalls
  • Reporting adverse reactions to medications
  • Reporting suspected abuse, neglect, or domestic violence
  • Preventing or reducing a serious threat to anyone’s health or safety

Do research

We can use or share your information for health research.

Comply with the law

We will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we’re complying with federal privacy law.

Respond to organ and tissue donation requests

We can share health information about you with organ procurement organizations.

Work with a medical examiner or funeral director

We can share health information with a coroner, medical examiner, or funeral director when an individual dies.

Address workers’ compensation, law enforcement, and other government requests

We can use or share health information about you:

  • For workers’ compensation claims
  • For law enforcement purposes or with a law enforcement official
  • With health oversight agencies for activities authorized by law
  • For special government functions such as military, national security, and presidential protective services

Respond to lawsuits and legal actions

We can share health information about you in response to a court or administrative order, or in response to a subpoena.

Our Responsibilities

  • We are required by law to maintain the privacy and security of your protected health information.
  • We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
  • We must follow the duties and privacy practices described in this notice and give you a copy of it.
  • We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.

For more information see:
www.hhs.gov/ocr/privacy/ hipaa/understanding/consumers/noticepp.html.

OTHER PRIVACY

USER DATA

We will maintain certain data that you transmit to the Site for the purpose of managing the performance of the Site, as well as data relating to your use of the Site. Although we perform regular routine backups of data, you are solely responsible for all data that you transmit or that relates to any activity you have undertaken using the Site. You agree that we shall have no liability to you for any loss or corruption of any such data, and you hereby waive any right of action against us arising from any such loss or corruption of such data.

ELECTRONIC COMMUNICATIONS, TRANSACTIONS, AND SIGNATURES

Visiting the Site, sending us emails, and completing online forms constitute electronic communications. You consent to receive electronic communications, and you agree that all agreements, notices, disclosures, and other communications we provide to you electronically, via email and on the Site, satisfy any legal requirement that such communication be in writing. YOU HEREBY AGREE TO THE USE OF ELECTRONIC SIGNATURES, CONTRACTS, ORDERS, AND OTHER RECORDS, AND TO ELECTRONIC DELIVERY OF NOTICES, POLICIES, AND RECORDS OF TRANSACTIONS INITIATED OR COMPLETED BY US OR VIA THE SITE. You hereby waive any rights or requirements under any statutes, regulations, rules, ordinances, or other laws in any jurisdiction which require an original signature or delivery or retention of non-electronic records, or to payments or the granting of credits by any means other than electronic means.

Registration

While some services may be used without registering, certain Services do require that you register with ORIAH for them to function properly. If you choose to register or update an existing account with ORIAH or access certain Services, you may be required to provide certain personal information, such as your name, address, telephone number, gender, email address and date of birth, and a username and password to access your ORIAH account. You are responsible for ensuring the accuracy of the personal information that you submit to ORIAH.

Email Newsletters

At registration and at various times as you use the ORIAH Site(s), you will be given the option of providing us with personal information in order to receive informational/promotional newsletters via email from ORIAH and/or directly from third parties. From time to time ORIAH may offer users of third party websites to the opportunity to subscribe to our newsletters through those websites. If you elect to subscribe to one of our newsletters on a third-party website, the operator of that website will provide us with the personal information you have provided in connection with the subscription request, which we may use in accordance with this Privacy Policy as though you had provided it directly to ORIAH. In ORIAH Message Boards, if you turn on the email notification for posts you have created or participated in, you will receive an email when there has been any activity on those posts. If you later decide you no longer want to receive email updates, you can turn it off by navigating to the Email Alerts section in your Message Board settings.

Market Research

From time to time, ORIAH may conduct online research surveys on behalf of itself and third parties through email invitations, pop-up surveys and online focus groups. When participating in a survey, we may require you to provide your location, age and if there’s a sweepstakes associated with the market research survey, your name and contact information for purposes of sweepstakes administration. The information you submit in a survey may be used by ORIAH for research and measurement purposes, as described below, including to measure the effectiveness of content, advertising or programs. The personal information you provide in connection with a sweepstakes entry will be used for the sole purpose of administering the sweepstakes and as required by applicable law. We will not knowingly invite individuals who are under the age of 13 to participate in market research surveys. Market research surveys conducted by or on behalf of ORIAH will contain a link to this Privacy Policy.

ORIAH Message Boards and Other Public Forums

ORIAH may feature several message board areas and other public forums where users with similar interests including with respect to certain medical conditions can share information and support one another or where users can post questions for experts to answer. We also offer online discussions moderated by healthcare experts. Our message boards are open to the public and should not be considered private.

Any information (including personal information) you share in any online message board or other forum is by design open to the public and is not private. You should think carefully before posting any personal information in any public forum. What you post can be seen, disclosed to or collected by third parties and may be used by others in ways we cannot control or predict, including to contact you for unauthorized purposes. As with any public forum on any site, the information you post may also show up in third-party search engines.

If you mistakenly post personal information in our message board areas and would like it removed, you can send us an email to request that we remove it by using the Contact Us link on every page of the ORIAH Sites. In some cases, we may not be able to remove the information.

Emails You Send to ORIAH

This Privacy Policy does not apply to information, content, business information, ideas, concepts or inventions that you send to ORIAH by email. If you want to keep content or business information, ideas, concepts or inventions private or proprietary, do not send them in an email to ORIAH.

Services and Device Information

When you access and use the Services, ORIAH automatically collects and stores in its server logs information from your browser or mobile device such as your IP address or unique device identifier, browser information (including referring URL), your preferences and settings, cookies and information about the content you have viewed, and actions taken (e.g., search queries, ad engagement, clicks and the associated dates and times). ORIAH may also collect device-specific information when you install and use an App including your device model, operating system information, advertising ID (which is a unique, user-resettable identification number for advertising associated with a mobile device) and App version and usage information. When enabled by you, we collect precise location information provided by your mobile device, which you may disable through the device settings.

Cookies and Other Tracking Technologies

We and our partners use cookies to collect information about your use of the Services. “Cookies” are small data files assigned to your browser when you visit an ORIAH Site which enable recognition of your browser and collect and store information about your use of the Services, as described above. In addition to cookies, we and our partners use other tracking technologies that collect information about your use of the Services, including mobile identifiers and “web beacons” which are small graphic files (sometimes called “clear GIFs” or “web pixels”) embedded in a web page or email typically used to monitor activity and send relevant information back to a home server (which can belong to the host site, a network advertiser or some other third party).

Our advertising service partners may use cookies and other tracking technologies to collect information about your use of the ORIAH Sites, including content you have viewed. These third parties may use this information to help ORIAH deliver advertising on the ORIAH Sites and on other third-party websites based on your browsing activity on the ORIAH Sites. ORIAH may further tailor the advertising on the ORIAH Sites and these other third-party websites based on additional information to the extent known by ORIAH or these third parties. Two of the third parties that ORIAH works with are Google and Facebook. In addition to using the information it collects performing services for ORIAH, Google may also use such information as described in its privacy policy. To see how Google may use information collected through our use of the Google services on the ORIAH Sites visit https://www.google.com/ policies/privacy/partners.

While Facebook does not provide any personal information to ORIAH, Facebook may use information that it has about you and that it collects performing services for ORIAH (which may be associated with personal information that Facebook has about you) as described in its privacy policy available at https://www.facebook.com/ about/privacy.

How Information Collected About You Is Used

Information about your use of the Services may be used for the following purposes:

  • to provide, improve and create new Services,
  • to respond to your inquiries and to send you administrative communications about the ORIAH Sites and Services,
  • to obtain your feedback about the ORIAH Sites and Services,
  • to send you secure electronic messages and personalized emails pertaining to your interests as inferred from your use of the Services, including news, announcements, reminders and opportunities from ORIAH,
  • to statistically analyze trends and user behavior and activity including how frequently areas of the ORIAH Sites are visited, how the Services are being used and how many emails are received and opened,
  • to provide you and people with similar demographic characteristics and interests with more relevant content including advertising both on and off the ORIAH Sites and Apps,
  • to offer lead generation services,
  • to detect and defend against fraud and other threats to the Services and our users,
  • to identify issues with the Services,
  • to conduct research and measurement activities, including those described below, and
  • to administer your account.

In addition, ORIAH may use personal information about you for other purposes that are disclosed to you at the time we collect the information and/or with your consent.

ORIAH may combine your personal information and other information collected about your use of the Services, and also supplement with information from external sources for the purposes described in this Privacy Policy. For example, information that ORIAH collects about you may be combined by ORIAH with other information available to ORIAH through third parties for research and measurement purposes, including measuring the effectiveness of content, advertising or programs. This information from other sources may include age, gender, demographic, geographic, personal interests, product purchase activity or other information. We may report aggregate information, which is not able to be identified back to an individual user of the ORIAH Sites, to our current or prospective advertisers and other business partners.

ORIAH will not sell your personal information to third parties for their use without your consent.

Compliance with Law, Regulation, and Law Enforcement Requests

To cooperate with government and law enforcement officials and private parties to enforce and comply with law, we may release personal information to third parties: (1) to comply with legal requirements such as a law, regulation, search warrant, subpoena or court order; (2) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; or (3) in special cases, such as in response to a physical threat to you or others, to protect property or defend or assert legal rights. In addition, we may disclose personal information as described below.

How Your Information is Secured and Retained

We take reasonable security measures to protect the security of your personal information. Despite ORIAH’s efforts to protect your personal information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted.

The security of your personal information is important to us. When you enter personal information (including personal health information in various Services), we encrypt the transmission of that information or use SSL connections (Secure Socket Layer) technology.

We will retain your personal information as long as your account is active or as needed to provide you Services. At any time you can remove your personal information or instruct us to remove it, but you should be aware that it is not technologically possible to remove each and every record of the information you have provided to ORIAH from our servers. We will also retain your personal information as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

Cookies

Most browser software can be set to reject Cookies. Most browsers offer instructions on how to reset the browser to reject Cookies in the “Help” or “Settings” or “Preferences” section of your browser’s toolbar. Refer to your particular bowser for additional information about turning off Cookies.

California Residents

FOR RESIDENTS OF CALIFORNIA ONLY. Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of your personal information with third parties. If you reside in California and have provided your personal information to us, you may request information about our disclosures of certain categories of personal information to third parties for direct marketing purposes in the preceding calendar year. You can submit such request by sending an email by using the “Contact Us” link at the bottom of every page of the ORIAH Site.

Children

We are committed to protecting the privacy of children. The ORIAH Sites are not designed or intended to attract children under the age of 13. The ORIAH Sites do not collect personal information from any person we actually know is under the age of 13. If a parent or guardian establishes a user account for a minor, the parent or guardian is solely responsible for providing supervision of the minor’s use of the ORIAH site. The parent or guardian assumes full responsibility for ensuring that the registration information is kept secure and that the information submitted is accurate. The parent or guardian also assumes full responsibility for the interpretation and use of any information or suggestions provided through the ORIAH site for the minor.

Note to Users Outside of the United States

ORIAH and our technical infrastructure are located in the United States. The personal information that you provide to us is stored on servers located in the United States. If you are located in another jurisdiction, you should be aware that in order to provide the Services to you, we must transfer your personal information to the United States where it will be stored and processed in accordance with this Privacy Policy. We may transfer your information outside the United States to service providers with operations in other countries. By using the Services, you consent to such collection, storage and processing in the United States and elsewhere, though the United States and other jurisdictions may not afford the same level of data protection as considered adequate in your own country. We will take reasonable steps to protect your personal information. Note that your personal information may be available to the United States government or its agencies under legal process made in the United States.

Additional Information for ORIAH Visitors from the European Economic Area (“EEA”)

When you use the Services, we may collect, store, use and otherwise process your personal information as described in this Privacy Policy. We rely on a number of legal bases to process your information, including where: (i) necessary for our legitimate interests in providing and improving the Services including offering you content and advertising that may be of interest to you; (ii) necessary for our legitimate interest in keeping the Services, Sites and Apps safe and secure; (iii) necessary for the legitimate interests of our service providers and partners; (iv) necessary to perform our contractual obligations in the ORIAH Terms of Use; (v) you have consented to the processing, which you can revoke at any time (however a revocation does not affect the lawfulness of processing of your personal data that occurred prior to the date of revocation); (vi) you have expressly made the information public, e.g., in a ORIAH message board or other public forums; (vii) necessary to comply with a legal obligation such as a law, regulation, search warrant, subpoena or court order or to exercise or defend legal claims; and (viii) necessary to protect your vital interests, or those of others.

If you are a ORIAH user in the EEA, you can: (i) access personal information we have about you (we will try to provide information within 30 days of your request); (ii) have your personal information corrected or deleted (in most cases you can correct personal information you have submitted to us by going back to the specific Service, logging-in and making the desired change); (iii) in certain circumstances, you can object to our processing of your personal information and we will discontinue such processing unless we have compelling legitimate grounds to continue; (iv) withdraw consent previously provided (however a withdrawal does not affect the lawfulness of processing of your personal data that occurred prior to the date of withdrawal); or (v) if you believe that we have not complied with applicable data protection laws, you may lodge a complaint with your local supervisory authority. If you wish to inquire as to whether we maintain any of your personal information and if so, whether you wish to exercise any of those rights that are available to you with respect to such personal information, you may contact us as described in the Contacting ORIAH About Your Personal Information or Privacy section below. We will respond to your request within a reasonable timeframe.

We will retain your personal information for as long as necessary to provide the Services to you and fulfill the purposes described in this Privacy Policy. This is also the case for third parties within whom we share your information to perform services on our behalf. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it. If you have registered with ORIAH and you no longer want us to use your registration information to provide the Services to you, you may close your account.

Contacting ORIAH About Your Personal Information or Privacy

Please send us an email by using the “Contact Us” link at the bottom of every page of the ORIAH Site if you have any questions about this Privacy Policy or the personal information we maintain about you.

You can also contact ORIAH, INC. at:

ORIAH INC.
1215 Route 70
Lakewood, NJ 08701
Phone: (732) 942 – 5056
Email: beawareinc@gmail.com

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us.

Changes to this Privacy Policy

We reserve the right to change or modify this Privacy Policy and any of our Services at any time and any changes will be effective upon being posted unless we advise otherwise. If we make any material changes to this Privacy Policy we will notify you by means of a notice on the ORIAH Sites and/or by email to our registered users (sent to the email address specified when you register) prior to the change becoming effective. By continuing to use the Services after changes are made to this Privacy Policy, you agree to such changes. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. If you do not accept the terms of this Privacy Policy, we ask that you do not register with us and that you do not use the ORIAH Site. Please exit the ORIAH Site immediately if you do not agree to the terms of this Privacy Policy.

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