Ondemand Visit Privacy Policy for the European Union’s General Data Protection Regulation
The privacy policy explains how we (Ondemand Visit) use any personal information we collect about you when you use this website and our services.  In this document, we use certain terms to cover certain matters required by the European Union’s General Data Protection Regulation (GDPR), which came into force in May 2018. The meaning of these terms are as follows:
1. Personal data
Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):
Names and contact information such as emails and telephone numbers
US Social Security or Foreign National Identification Numbers
Your Employer
Your Credit card number
Your address
2. Sensitive Personal Data
Sensitive personal data refers to the above but includes medical information and biometric data.  For example:
Medical conditions and history
Racial or ethnic origin
Biometric data (such as a photo as part of a physician-patient interaction)
3. Data Controller
For General Data Protection Regulation purposes, the “Data Controller” means the person or organization who decides the purposes for which and the way in which any personal data is processed.
The Data Controller is Ondemand Visit LLC.
The Data Protection Officer can be contacted at policy@ondemandvisit.com.
4. Data Processor
A “Data Processor” is a person or organization which processes personal data for the Data Controller.
5. Data Processing
Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organizing, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction of data.
What information do we collect about you and how?
Ondemand Visit, as a Data Controller, is bound by the requirements of the General Data Protection Regulations (GDPR).
You agree that we are entitled to obtain, use and process the information you provide to us to enable us to provide and discharge our Services and for other related purposes including;
Updating and enhancing our records about you
Analysis for management purposes
Legal and regulatory compliance
Providing information to insurance carriers, hospital systems, physicians and others
We collect information about you when you fill in any of the forms on our website for example, in sending an inquiry, filling in a survey, giving feedback etc. Website usage information is collected using cookies.
When submitting forms or using the applications we provide for mobile devices or using the website or using the physician/ patient portal on the website, we use a third-party software provider for automated data collection and processing purposes. They will not use your data for any purposes and will only hold the data in line with our policy on data retention and as part of the services we provide to you.
Cookies are text files put on your computer to collect standard internet log information and visitor behavior information.  This information is then used to track visitor use of the website and to create statistical reports on website activity.
You can set your browser not to accept cookies.  Please note in a few cases some of our website features may not function because of this.
Analytics – e.g. how visitors use our website
We use Google Analytics to store information about how visitors use our website so that we may make improvements and give visitors better user experience.
Google Analytics is a third-party information storage system that records information about the pages you visit, the length of time you were on specific pages and the website in general, how you arrived at the site and what you clicked on when you were there. These cookies do not store any personal information about you eg name, address etc. and we do not share the data.
IP addresses
An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet. Ondemand Visit does not have access to any personally identifiable information and we would never seek this information. Your IP address is logged when visiting our site, but our analytic software only uses this information to track how many visitors we have from particular regions.
Internet-Based Advertising
We use the Internet, LinkedIn, Facebook and Twitter and other services for the marketing of our services and products. As such there are tracking codes installed on our website so that we can manage the effectiveness of these marketing campaigns.  We do not store any personal data within this type of tracking.
How will we use the information about you and why?
We take your privacy seriously and will only use your personal information to provide the Services you have requested from us.  We will only use this information subject to your instructions, data protection law and our duty of confidentiality.
For Business to Consumer Clients and Contacts our lawful reason for processing your personal information will be “A contract with the individual” e.g. to supply goods and services you have requested through our website, applications and portal.  This also includes steps taken at your request before entering into a contract.
Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organizations for the purposes of completing tasks and providing the Services to you on our behalf.  However, when we use third-party service providers, we disclose only the personal information that is necessary to deliver the Services and we have contracts in place that require them to keep your information secure and not to use it for their own direct marketing purposes.
We collect information on our website to process your inquiry, give advice based on survey data and improve our services.  If you agree, we will also use this information to share updates with you about our services which we believe may be of interest to you.
We will not share your information for marketing purposes with companies so that they may offer you their products and services.
Transferring your information outside of Europe
As part of the services offered to you through this website, the information which you give to us may be held in or transferred to countries outside the European Union (“EU”), including the USA. For example, some of our third-party providers are and may be located outside of the EU.  Where this is the case, we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy.  By submitting your personal data, you’re agreeing to this transfer, storing or processing.  Where our third-party suppliers are in the USA we have ensured that their services fall under the “Privacy Shield” whereby participating companies are deemed to have adequate protection and therefore facilitate the transfer of information from the EU to the US.
If you use our services while you are outside the EU, your information may be transferred outside the EU to give you those services.
Security precautions in place about data collected
When you give us personal information, we take steps to make sure that it’s treated securely. Any sensitive information (such as credit or debit card details) is encrypted and protected.
Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We may analyze your personal information to create a profile of your history, conditions and other information so that we can contact you with information relevant to you. We may make use of extra information about you when it is available from external sources to help us do this effectively.
We would like to send you information about our services which may be of interest to you.  If you have consented to receive marketing, you may opt-out at any point as set out below.
You have a right at any time to stop us from contacting you for marketing purposes.  To opt-out please email: policy@ondemandvisit.com.
How long will we hold your data for?
Marketing: We will hold your data for a period of 6 years with a review every 3 years.  You will have the opportunity to opt-out or update or delete data at any point should you need to do so and details are set out in this policy as to how to do that.
Contracted Services: We will hold your data for 7 years in line with our regulatory requirements.
Access to your information, correction, portability and deletion
What is a Subject Access Request?
This is your right to request a copy of the information that we hold about you.  If you would like a copy of some or all your personal information, please email at policy@ondemandvisit.com. We will respond to your request within one month of receipt of the request.
We want to make sure your personal information is accurate and up to date.  You may ask us to correct or remove information you think is inaccurate by emailing policy@ondemandvisit.com or writing to the above address.
Objections to processing of personal data
It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” applies.  The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defense of a legal claims.
Data Portability
It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:
(a)    The processing is based on consent or on a contract, and
(b)    The processing is carried out by automated means.
Your Right to be Forgotten
Should you wish for us to completely delete all information that we hold about you for:
Email: policy@ondemadvisit.com
We may not be able to honor any such request in view of record keeping requirements and laws and ongoing medical professional and ethical obligations. We will notify you if this is the case, as part of our response to any such request.
Other websites
Our website contains links to other websites.  This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.
If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority.   The supervisory authority will then tell you of the progress and outcome of your complaint. It is your responsibility to identify correctly the supervisory authority in your country.
Changes to our Privacy Policy
We keep our privacy policy under regular review, and we will place any updates on this web page.  This privacy policy was last updated on October 1, 2018 and the Version number is 1. in line with the new GDPR guidelines.
How to contact us
Please contact us if you have any questions about our privacy policy or information, we hold about you:
By email: policy@ondemandvisit.com.
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