You agree to this Policy by displaying, using, or accessing the CMS Website or any service or feature provided by CMS, by providing personal or user information to the CMS Website, by submitting or posting any information or other material to the CMS Website, or by allowing or authorizing any person to do any of the same on your behalf or for your benefit. If you do not agree with this Policy, please do not use, or authorize another on your behalf to use, the CMS Website or any such services or features. Questions and concerns regarding this Policy should be directed by e-mail to info@GreenWayMichigan.com.
CMS respects your privacy. Any information you give us is held with care and security, and will only be used as described in this Policy or otherwise with your consent. Furthermore, any information you provide us through the CMS Website which constitutes “Protected Health Information” under and as described in the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, together with the regulations promulgated thereunder by the U.S. Department of Health and Human Services (collectively, “HIPAA”) shall be stored and treated in accordance with HIPAA requirements, subject to and as further described in this Policy.
However, we want to be upfront about the fact that part of the CMS business includes providing you with access to materials, information, features and services in exchange for the right to use, on an opt-in or out basis (as described below) certain marketing, purchase preference, demographic, and other information which you may provide, or which we may collect based on your usage of the CMS Website, and which we may leverage for the various commercial purposes described below or on the web pages where we collect such information. We will always use reasonable efforts to inform you as to the purposes for which we will use information, either through this Policy or as we collect it from you.
Registration and Membership; Information Collected
In order to access certain content, features or services on the CMS Website, or to create an account which allows you to store information, post materials, and utilize our tools for scheduling appointments and consultations, you may be required to first “join” or become an CMS Website member (or join in another specific capacity, such as a physician, clinic, dispensary, or patient) and complete one or several forms. During registration (and possibly thereafter) you may be asked to give your name, a contact telephone number, a PIN or password, your date of birth, your postal address, e-mail address, and other contact or pertinent information. CMS may also ask for other information required to provide particular services, such as your business name, information pertaining to your medical condition(s), practice specialties (if you are a physician or clinic), and other relevant information. Information may also be collected by your presence on the CMS Website, even if you have not registered or subscribed.
Generally, this information falls into one of five categories: (1) “Personal Identifying Information,” such as your name and e-mail address, which can be used to personally identify or contact you (or to confirm your identity in the case of user IDs and passwords), (2) Protected Health Information (“PHI”), such as any medical conditions you may have, your medical history, your treatment history, and like information, (3) “Billing Information,” such as your credit card information and billing address, which is a subset of Personal Identifying Information and which we may use to bill you for a service or feature which you have knowingly purchased, (4) “Usage Information,” such as your IP address, public postings, opinions or other matter you have either posted or reviewed, your click patterns on the CMS Website, and other information indicative of your use of the service or features on the CMS Website, and (5) “Anonymous Information,” which is an aggregate of the other information categories decoupled from any method of identifying the source of that information, which we use to determine the demographics, habits, preferences, or statistical characteristics of the CMS Website users or subgroups thereof, but which cannot be used to identify you or your specific usage history. Anonymous Information may include portions of Personal Identifying Information, PHI, and Usage Information which have been decoupled from any identifying information and aggregated with that of other CMS Website users.
How Each Type of Information Is Used
CMS will use your Personal Identifying Information as follows: (1) to regulate access to the CMS Website and its features and services, as well as to your account (such as requiring passwords to access certain services or post content); (2) to personalize and enhance your experience when visiting the CMS Website; (3) to promote to you (including contacting you by e-mail) CMS or CMS endorsed products or services, or other products or services in which we believe you may be interested, but only when you opt-in to receive our promotions and newsletters, and you may later opt-out from promotional emails through various mechanisms we provide (your PHI may also be used in a similar fashion as described below); and (4) for other internal or administrative purposes consistent with our mission of providing our users with the highest quality experience, including contacting you about administrative issues pertaining to your account or critical updates to the CMS Website or the services you use or purchase. CMS does not share, sell, rent, or trade Personal Identifying Information with third parties for their promotional purposes, except as you may expressly consent when such information is collected or may later expressly consent.
Additionally, if you are a physician, clinic, or other healthcare provider registered as a “doctor,” we may allow users registered as patients to contact you by email or other means made available through our systems, to set up an appointment or consultation or other relevant purposes. This is a necessary part of our service and no opt-out is available. If you wish to no longer receive such communications, you may deactivate your account by logging into your profile at the CMS Website.
If you are registered as a “patient” (or similar designation) with the CMS Website, CMS will use your PHI, as coupled with Personal Identifying Information, only as you specifically direct or as otherwise may be permitted under HIPAA. For example, if you request us to assist you in scheduling a consultation with a doctor or clinic pertaining to a health condition you specify, we will request certain PHI (such as your health condition, medical history, treatment history, your history of use of medical marijuana, and other information) and provide that information to the doctor or clinic in conjunction with the appointment request unless you direct us not to disclose such information. In addition if a doctor recommends to you treatments using medical marijuana, and that information is provided to the CMS Website by the doctor or clinic, we will store and disclose that information (which may include PHI related to your condition and recommended treatments) as part of the CMS medical marijuana recommendation certification service (see, the “Certification Service”) unless you opt-out of the Certification Service. This information will be accessible to clinics and other CMS Website users who have your driver’s license and the physician/clinic recommendation number.
We may also use PHI, without disclosing it to others, to personalize and enhance your experience when visiting the CMS Website and to promote to you (including contacting you by e-mail) CMS or CMS endorsed products or services, or other products or services in which we believe you may be interested based upon such PHI, but only when you opt-in to receive our promotions and newsletters, and you may later opt-out from promotional emails through various mechanisms we provide. In addition, we will decouple certain PHI from Personal Identifying Information and use this to create Anonymous Information which we will use as described in this Policy: for example, while we would not disclose your specific health conditions except as described in this Policy, we may create aggregate information from your PHI as combined with others’ PHI, such as the percentage of CMS Website users registered as patients who seek treatment based on specific health conditions and use this as Anonymous Information.
We will use your Billing and Usage Information, as applicable, to bill you for the services which you knowingly purchase and to provide you with technical and billing support.
We will use Anonymous Information to optimize our marketing and product development efforts (such as keyword advertising purchases and search engine optimization), to determine the success of our marketing campaigns, to provide anonymous demographic information to sponsors, advertisers and partners, and other relevant commercial purposes which do not identify you individually. We may also provide Anonymous Information to our sponsors, advertisers and partners so that they may track the success of their advertising and promotional efforts, for example, to determine the demographic attributes and use preferences of visitors to pages in the CMS Website that feature their products or services.
CMS may use third party providers and subcontractors for the features and services offered on the CMS Website and also for internal, administrative, and tracking purposes. Service through these providers may necessarily include providing them with some or all of your Personal Information, PHI, Billing Information (for credit card processing, collections, and related matters), and your Usage Information (for subcontracted services and features), but we will use diligent efforts to restrict use of this Information by these third parties to the purpose of providing the specific CMS feature, function, service or purpose for which the third party has been engaged, and, to the extent such parties are provided PHI, only to the extent they agree to abide by HIPAA obligations imposed on such parties based on their role and relationship to CMS. Additionally, CMS may share your Information with parents and affiliates under its control or common control, subject to the same restrictions described in this Policy.
In addition, CMS specifically reserves the right, to the maximum extent permitted by law, to use or disclose any Information (a) for the purposes of enforcing our user agreements, use policies and the like or (b) when requested by law enforcement agencies (whether or not under subpoena), if we reasonably suspect a violation of our user agreements or use policies or any applicable law.
Security: How Information is Stored
CMS has appropriate technical and organizational security measures in place to reasonably protect against the loss, misuse, and alteration of user data under our control. For example, we use appropriate encryption for payment card transactions, and we impose strict rules on CMS employees who have access either to the databases that store member or user information or to the servers that host our services. We train our staff to understand applicable HIPAA and PCI requirements so as to avoid any violations of applicable standards. We also use reasonable efforts to assure that any subcontractor, provider, or other party that has access to any PHI has agreed to comply with appropriate HIPAA requirements. While we cannot guarantee that loss, misuse, or alteration of data will not occur, we make diligent efforts to prevent such unfortunate occurrences.
Billing Information may also be stored by our payment card processors and be subject only to our limited control. If you are concerned about storage and use of your Billing Information by payment card processors, please e-mail us at info@GreenWayMichigan.com and we will provide you with information on the privacy practices of our current payment card processors and related vendors.
Please note that information or data (including Usage Information), other than PHI and Billing Information, may not be stored in a manner which is PCI or HIPAA compliant. Accordingly, other than the PHI and Billing Information which we specifically request and/or state will be protected in accordance with the relevant standard, we do not recommend that you post, upload, provide, or use the CMS Website or any related feature to collect or store any sensitive financial, payment, or personal information, and we cannot be responsible in any manner if you do so.
Additionally, we strongly recommend that you keep all of your user information, such as account IDs, passwords, and other sensitive information secret and not disclose such information to anyone else. We cannot be responsible for any use of this information should you disclose it to anyone else, or for the use or distribution of any of your information or data stored with the CMS Website if it is obtained via use of your account ID or password. Please note that CMS will never email you to “phish” for (attempt to convince you to disclose) your username or password.
Use of “Cookies,” Web Beacons, and Log Files
Similarly, CMS, its advertisers, subcontractors, and other partners may also use “web beacons” (small image files which are used to track presence on web pages and surfing patterns) in a similar fashion to cookies, except that web beacons do not store any personal information on your computer. We may also use web beacons or similar technology to track clicks from our newsletters and the like.
Finally, servers owned or controlled by CMS will log each website visitor’s IP address, browser type, operating system, referring and exiting URLs, and other statistical and technical information. Except for the purposes of enforcing this Policy or any user agreements, and assisting law enforcement agencies, CMS will treat this as Anonymous Information
Doctor, Clinic and Dispensary Inquiries
Patients may transmit requests for consultations, appointments, and other information to doctors or clinics via features available on the CMS Website or other methods we may make available. If you send such an inquiry, a subset of your pertinent Personal Information and PHI, including your email address and any other information you supply at such time, may be visible and available to the applicable doctor, clinic, or dispensary, so that they may respond to your request or inquiry. We do not control whether such doctor, clinic, or dispensary adds you to its mailing lists or otherwise uses the information you choose to supply during said process.
We strongly recommend that you do not provide, during the inquiry process, any information that you do not wish doctors, clinics, or dispensaries to have. We also strongly recommend that you NEVER send any credit card, bank account, or other payment or financial information, nor any other confidential information through such methods (and NEVER by email at all!).
Your inquiries are forwarded to the individual doctor, clinic, or dispensary you selected and also retained by us as Usage Information, from which we may create Anonymous Information.
Posted Information and Content; Use of Listing and Community Features
Although it is probably obvious, to the extent you submit or post any statement, opinion, testimonial, review, or listing to the CMS Website (or any material which by its nature appears to be intended to be published or posted) or participate in any forum, chat, opinion feature, message board, blog, or any other interactive or community service or feature on the CMS Website, all of the information contained in your submission or communications will likely become public information on the CMS Website and possibly published by our affiliates or partners, and CMS will not have any control over the use of such information by users and third parties with access to that information. CMS reserves the right to use all of such information at its discretion without restriction.
Accordingly, if there is any matter in any such material which you do not intend or wish to be publicly available, published, distributed, and otherwise used in a public fashion, please do not include it or submit it. We cannot honor any special request from you in that regard. We strongly discourage the submission or posting of any PHI in any such public forum or feature unless you wish such information to be publicly available.
Similarly, information posted or provided by doctors, clinics, dispensaries, and others about their specialties, practices, office hours, and similar matters, will be, subject to CMS discretion, made publicly available to patients and other users to assist patients in identifying, choosing, locating, and communicating with them. Accordingly, we recommend that doctors, clinics, and dispensaries only provide information about themselves that they wish to be displayed publicly.
Additional privacy policies and other terms may apply to use of any community or interactive feature or service available through the CMS Website or otherwise provided by CMS. Please check the pages containing those features and services for more information.
Please note that all information and material collected or provided, in any manner and of whatever nature, may be transferred or assigned by CMS in conjunction with a merger or the sale of all or a portion of the CMS business (or similar event).
This Policy does not apply to business ideas, concepts, or inventions that you send as suggestions or proposals to CMS. If you want to keep content or business information, ideas, concepts, or inventions private or proprietary, do not send them to CMS without reaching an agreement with us as to their treatment, as we otherwise reserve the right to use them at our discretion. This Policy also does not apply to any information you submit to CMS by e-mail unless expressly so stated herein.
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