Website Privacy Policy

Privacy Policy

Introduction

Our Privacy Notice covers types of information Wooster Community Hospital (“we,” “our,” or “us”) may collect from you or that you may provide when you visit our Website and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using our Website, you agree to our Privacy Notice. This policy may change from time to time (see Changes to Our Privacy Notice). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on our Website or through any of its features or provide any information about yourself to us, including your name, address, telephone number, email address, or any other information by which you might be identified. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacyrequest@wchosp.org.

Information We Collect

We collect and use different types of information from and about you including:

  • Information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual (“Personal Information”).
  • Non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Website feature.
  • Technical information, including the Internet protocol (“IP”) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, or operating system and platform. In some jurisdictions, an IP address is considered Personal Information.
  • Non-personal details about your Website interactions, including the full Uniform Resource Locators (“URLs”), clickstream information to, through, and from our Website (including date and time), products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.

Personal Information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated information.

If we combine or connect non-personal, demographic, or technical data with Personal Information so that it directly or indirectly identifies an individual, we treat the combined information as Personal Information.

How We Collect Your Personal Information

Direct Collection of Personal Information

The information we collect on or through our Website or directly from you through other means may include:

  • Information that you provide by filling in forms on our Website.
  • Records and copies of your correspondence (including email address) if you contact us.
  • Your search queries on the Website.
  • Information submitted when you report a problem with our Website.
  • Information submitted when you request further services.
  • Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before engaging in certain transactions through our Website.
  • Information provided while using any other interactive features of our Website.

Automated Technologies or Interactions

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, logs, location data, other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Recognize you when you return to our Website.
  • Speed up your searches.
  • Estimate our audience size and usage patterns.

We may use the following automatic data collection technologies on the Website:

  • Cookies. We may collect information automatically using cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. For further information, visit https://allaboutcookies.org.

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons, location, or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the provider responsible for that advertisement or other targeted content directly.

Data Collected from SMS/RCS Consent

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, excluding aggregators and providers of the Text Message services.

Purpose for Collection and Use of Your Personal Information

We use information that we collect about you or that you provide to us, including any Personal Information:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • In order to process any orders for products or services, we may send your data to, and also use the resulting information from, credit reporting agencies to prevent fraudulent purchases.
  • To fulfill any other purpose for which you provide it.
  • To notify you about changes to our Website or any products or services we offer or provide through it.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users or consumers is among the assets transferred.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your Personal Information.
  • To allow you to participate in interactive features on our Website.
  • For any other purpose with your consent.

We may also use your information to contact you about our goods and services that may be of interest to you. If you have agreed to receive marketing, you may always opt out at a later date. If you no longer wish to be contacted for marketing purposes, please contact us at 1761 Beall Ave. Wooster, OH 44691 Attn: Health Information Management.

Who We Share Your Personal Information With

We may share your Personal Information by disclosing it to a third party for a business purpose. We do not sell your Personal Information to third parties. For more information regarding your rights to opt-out of sales of your Personal Information to third parties if you live in certain jurisdiction, see the appropriate section for the jurisdiction where you reside in this notice).

We may also share your Personal Information:

  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users or consumers is among the assets transferred.
  • To enforce or apply our terms of use found at https://www.woosterhospital.org/terms-of-use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Wooster Community Hospital, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We may share non-personal information without restriction.

Restrictions on Future Collection and Use

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

SMS Messaging

If you provide us with a phone number capable of receiving SMS/RCS messages, we will send you SMS/RCS messages only with your consent. We will only utilize an automatic telephone dialing system (“ATDS”) as defined in the Telephone Consumer Protection Act (“TCPA”) with your express prior written consent, as provided in TCPA. We securely store your phone information and will not share your SMS/RCS consent, or any third party.

Covered Entity/Business Associate Privacy Notice

In almost all situations, we are considered a Covered Entity under HIPAA and our privacy practices as a Covered Entity are provided at HIPAA Notice of Privacy Practices.

In the event we obtain Protected Health Information as a Business Associate, subject to the terms of any service agreements or Business Associate Agreements with third parties, the following applies:

Definitions

“HIPAA” means the Health Insurance Portability and Accountability Act of 1996, as amended, including without limitation the Health Information Technology for Economic and Clinical Health Act of 2009

“Covered Entity” means a health plan, healthcare provider, healthcare clearinghouse, or any authorized entity representative that must comply with the HIPAA Privacy or Security Rules.

“Business Associate” means a person or entity who performs functions or activities for, or provides services on behalf of, a Covered Entity that involves the use or disclosure of PHI.

“Business Associate Agreement” means a formal written agreement between us and our Covered Entity customers, and/or between us and our Business Associate subcontractors, which requires us and our Business Associate subcontractors to comply with specific protections afforded to the security and privacy of PHI under HIPAA.

“Protected Health Information” or “PHI” means all individually identifiable health information that is transmitted or maintained in any form or medium by a covered entity. Individually identifiable information is any information that can be used to identify an individual that was created, used, or disclosed in the course of providing a healthcare service such as diagnosis or treatment, or in relation payment for the provision of healthcare services.

Use and Disclosure of PHI

We may use or disclose PHI on behalf of, or to provide services to, Covered Entities for purposes of performing our obligations under our service agreements, provided that such use or disclosure is permitted or required by the applicable service agreement and Business Associate Agreement, and would not violate the HIPAA privacy or security rules as applicable to Business Associates.

We may use PHI internally for our own internal management, administration, data aggregation and legal obligations but only to the extent such use of PHI is permitted or required by the applicable Business Associate Agreement and would not violate HIPAA as applicable to Business Associates.

We may disclose PHI to downstream subcontractors or agents that provide supporting services to us. If the performances of our services to a Covered Entity requires the release of PHI to a downstream subcontractor or agent, all such subcontractors and agents will be required to enter into a Business Associate Agreement with us and to comply with the same terms and conditions that apply to use and disclosure of PHI under service agreements and Business Associate Agreements with our customers including the implementation and maintenance of required HIPAA privacy and security safeguards.

We may disclose PHI for law enforcement purposes, or in response to subpoenas as required by law, and for other national priority purposes when an authorization or opportunity to object is not required by HIPAA.

Safeguards

We have established and maintain appropriate safeguards to prevent the use or disclosure of PHI other than as provided for by our services agreements, our Business Associate Agreements and HIPAA. These safeguards include administrative, physical and technical safeguards that reasonably and appropriately protect the confidentiality, integrity and availability of the PHI that we access, receive, process, maintain and/or transmit on behalf of our Covered Entity customers.

Examples of such safeguards include but are not limited to:

  • maintaining appropriate clearance procedures and providing supervision to assure that our workforce follows appropriate security procedures;
  • providing appropriate training to our staff to ensure that our staff complies with our privacy and security policies;
  • making appropriate use of encryption when transmitting PHI over the internet;
  • utilizing appropriate storage, backup, disposal and reuse procedures to protect PHI;
  • utilizing appropriate authentication and access controls to safeguard PHI;
  • utilizing appropriate security incident procedures and providing training to our staff sufficient to detect and analyze security incidents; and
  • maintaining a current contingency plan and emergency access plan in case of emergency to assure that the PHI we hold on behalf of a Covered Entity is available when needed.

Mitigation of Harm

In the event of a use or disclosure of PHI that is in violation of the requirements of a Business Associate Agreement, we will mitigate, to the extent practicable, any known, harmful effect resulting from the violation.

Such mitigation will include:

  • reporting any use or disclosure of PHI not provided for by the Business Associate Agreement, and any security incident that we become aware of, to the Covered Entity; and
  • documenting such disclosures of PHI and information related to such disclosures as would be required for a Covered Entity to respond to a request for an accounting of disclosures of PHI in accordance with HIPAA.

Access to PHI

We will make available to our Covered Entity customers that information necessary for the Covered Entity to provide individuals with their rights of access, amendment, and accounting of disclosures in accordance with HIPAA. Upon request from such Covered Entity, we will make our internal practices, books and records including policies and procedures relating to the use and disclosure of PHI received from, created by, or received by a Business Associate on behalf of the Covered Entity available to the Covered Entity or the Secretary of the U.S. Department of Health and Human Services for the purposes of determining compliance with the terms of the Business Associate Agreement and HIPAA regulations.

Conflict with Other Provisions of Our Privacy Notice

To the extent that any of the above HIPAA provisions of our Privacy Notice conflict with the remainder of this Privacy Notice, the HIPAA provisions prevail with respect to our Covered Entity customers and our downstream Business Associate subcontractors.

Your Personal Information Rights

Your Personal Information Use Choices

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising

You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. If you disable or refuse cookies or similar tracking files, some features of our Website may be inaccessible or not function properly. Some browsers include a “Do Not Track” (“DNT”) setting that can send a signal to the online services you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Website may not respond to all browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described in this policy.

Promotional Offers

If you do not wish to have your contact information used to promote our products or services, you can opt-out by sending us an email stating your request to privacyrequest@wchosp.org. If we have sent you a promotional email, you may reply to it with a request to be excluded from future email distributions. This opt-out does not apply to information provided to us as a result of registration, account management, services provided, or other transactions.

Targeted Advertising by the Company

If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target audience preferences, you can opt out by sending us an email stating your request to privacyrequest@wchosp.org.

Accessing and Correcting Your Personal Information

You may send us an email at privacyrequest@wchosp.org to request access to, correct, or delete Personal Information that you have provided to us. We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. If we cannot delete your Personal Information except by also deleting your user account, we will delete your user account upon request to delete your Personal Information.

Residents of Other States

Certain states provide (now or in the future) their residents with rights to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information.
  • Correct inaccuracies in their personal information, taking into account the information’s nature and processing purpose.
  • Data portability.
  • Opt-out of personal data processing for:
    • targeted advertising;
    • sales; or
    • profiling in furtherance of decisions that produce legal or similarly significant effects.
  • Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights please email us at privacyrequest@wchosp.org. To appeal a decision regarding a consumer rights request, please email us at privacyrequest@wchosp.org with a description of the initial request and the reason why you believe our determination regarding the request was incorrect.

Nevada Residents

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request by emailing us at privacyrequest@wchosp.org.

How We Protect Your Personal Information

We employ physical, procedural, and technological security measures designed to meet the requirements of the HIPAA Security Rule and to help protect your information from unauthorized access or disclosure. We may use encryption, passwords, and physical security measures to help protect your information against unauthorized access and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Retention Period

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you and, where applicable, PHI may be de-identified in accordance with HIPAA. We reserve the right to use such anonymous and de-identified data, including HIPAA de-identified information, for any legitimate business purpose without further notice to you or your consent.

Governing Law

Our Website is controlled and operated by Wooster Community Hospital. We provide our Website for use only by persons located in the United States. We make no claims that the Website or any of its content is accessible or appropriate outside of the United States. Access to the Website may not be legal by certain persons or in certain countries. If you access the Website from outside the United States, you do so on your own initiative and are responsible for compliance with local laws. If you are accessing our Website from any location with regulations or laws governing personal data collection, use or disclosure that differ from United States laws or regulations, please note that through your continued use of our Website, you are transferring personal information to the United States. Also, we may transfer your data from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Website. By providing any information, including personal information, on or to our Website, you consent to such transfer, storage and processing. By choosing to visit our Website or provide your personal information to us, you agree that any dispute over privacy or the terms contained in our Privacy Notice will be governed in accordance with the governing dispute resolution and arbitration provisions in our terms of use found at Terms of Use.

Text Messaging (SMS and RCS)

Text messaging opt-in data and consent will not be shared with third parties, excluding aggregators and service providers. Text messaging opt-in data and consent will not be sold or rented to third parties for marketing or promotional purposes.

Changes to Our Privacy Notice

We reserve the right to amend our Privacy Notice at our discretion and at any time. It is our policy to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you through a notice on the Website home page. The date the Privacy Notice was last revised is identified at the top of the page. When we make changes to our Privacy Notice, we will post the updated notice on the Website and update the notice’s effective date. You are responsible for periodically visiting our Website and our Privacy Notice to check for any changes. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Wooster Community Hospital collects and uses your information described here and in the Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us by:

  • Emailing us at privacyrequest@wchosp.org
  • Mailing us at Wooster Community Hospital, 1761 Beall Ave. Wooster, OH 44691 Attn: Health Information Management
  • Calling us toll free at 330-263-8615