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PRACTICE FUSION PRIVACY POLICY



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Effective Date: December 31, 2019

Introduction

Our mission is to drive better and more affordable healthcare through innovative
software and information solutions for providers throughout the care continuum,
their patients, and health researchers. Our solutions include our electronic
health record, practice management and patient health record software, our care
coordination and clinical data transmission services, and our health outcomes
research solutions.

This Privacy Policy (this "Policy") applies to the software and information
services we offer through our website located at www.practicefusion.com, our
cloud-based electronic health record and practice management solutions, and
web-enabled emails sent as part of, in connection with, or relating to such
software and information services (collectively, our "Services"). This Policy
does not apply to any other services. Maintaining your trust is important to us,
and we strongly encourage you to read this Policy in full.

The purpose of this Policy is to describe how we and our partners collect, use,
and share information about you. This Policy may incidentally describe how our
Services gather and use information about other individuals or information about
you that may be submitted by another user. This Privacy Policy, however, only
applies to how we and our partners collect, use, and share information about you
with respect to the Services covered by our Practice Fusion Terms of Use or our
Healthcare Provider User Agreement ("User Agreement"), and not to any other
service we may offer to any other individual or customer.

Some of our users - such as healthcare providers - are subject to laws and
regulations governing the use and disclosure of health information they create
or receive, including the Health Insurance Portability and Accountability Act of
1996, as amended from time to time, together with the regulations adopted
thereunder ("HIPAA"). When we store, process or transmit "individually
identifiable health information" (as defined by HIPAA) on behalf of a healthcare
provider who has entered into a Healthcare Provider User Agreement, we do so as
its "business associate" (as also defined by HIPAA). Under this agreement, we
cannot use or disclose individually identifiable health information in a way
that the provider itself may not. We are also required to, among other things,
apply reasonable and appropriate measures to safeguard the confidentiality,
integrity, and availability of the individually identifiable health information
we store and process on behalf of such providers. For the purpose of this
Policy, the term "healthcare provider" means any user who is a "health care
provider" (as defined by HIPAA) or any user who is a member of such health care
provider's "workforce" (as also defined by HIPAA). For additional information
regarding our business associate obligations, please see Sections 4.1.8 and 9 of
our Healthcare Provider User Agreement.

Information Collected by Our Services

Information You Submit or We Collect on Your Behalf:
We collect information from you when you:

 * Enter information on our Services, such as when you register for our
   Services, use our Services to send a message to someone else, or complete a
   form;

 * Upload a document, image, or other data file on our Services;

 * Contact us; or

 * Make a customer service request or attend one of our individual or group
   training sessions.

We also collect information on your behalf when you authorize us to retrieve and
import information from another user or other third party within our Service or
as set forth in the User Agreement.

Information we collect about you may include your name, address, telephone
number, email address, or the information you enter on or upload to our
Services.

Payment Information: Depending on the Services you use, we may also collect your
billing information, including credit or debit card account information, or
other forms of payment ("Payment Card Information"). By submitting your Payment
Card Information, you expressly consent to the sharing of your information with
third-party payment processers and other third-party services (including but not
limited to vendors who provide fraud detection services to us and other third
parties). These third parties may store your Payment Card Information for future
use in our Services. We do not store your Payment Card Information, nor do we
have direct control or responsibility for your Payment Card Information. The
third party services that we utilize are contractually obligated to keep your
Payment Card Information secure and confidential.

Automatically Collected Information:
We and our partners automatically gather information whenever you visit, log in,
or otherwise interact with our Services, including when you receive emails
delivered via our Services. We and our partners use the technologies described
below and similar technologies that may not be expressly described (which we
collectively call "Engagement Tools") to gather this information to enhance and
operate our Services in a number of ways, such as to:

 * Save user preferences and information;

 * Preserve session settings and activity;

 * Authenticate users;

 * Enable support and security features;

 * Tailor the delivery of informational messages, media, advertising and other
   content; and

 * Analyze the performance and use of our Services and its various features and
   content.

Even if you do not register with us or submit any information on our Services,
our Engagement Tools will automatically receive information about, and the
software running on, the computer, mobile phone, or tablet (each, a "Device")
you use to interact with our Services.

Device Information: When you interact with our Services, we collect information
about your Device such as the URL of services your Device is requesting and the
referring web pages, your IP address, Device type, operating system, browser
type, application identifier, and, under certain circumstances, the location
information your Device sends to us.

Cookies & Similar Technologies: We and our partners collect information about
you and your Devices through cookies, web beacons, and similar technologies. A
"cookie" is a small data file sent from a website and stored on your Device to
identify your Device in the future and allow for an enhanced personalized user
experience based on your previous activity on the website. A "session cookie"
disappears after you close your web browser, or may expire after a fixed period
of time. A "persistent cookie" remains after you close your web browser and may
be accessed every time you use our Services. We and our partners may use both
session and persistent cookies on our Services. You should consult your web
browser to modify your cookie settings. Please note that if you delete or choose
not to accept cookies from us, you may not be able to use certain features of
our Services.

Some of our partners deploy these technologies directly on our Services. These
third parties may collect information over time about your use of our Services,
as well as your online activities across other websites or online services. Some
third parties may allow you to opt-out of targeted advertising based on this
information. You can find more information about these opt-outs from the Network
Advertising Initiative (NAI) and the Digital Advertising Alliance (DAA).

Information from Other Sources:
We may receive or proactively gather information about you from other sources
and add it to information we otherwise have about you for any purpose described
in this Policy. This may include situations where a third party seeks to
communicate with you through the Services or establish an "Integration" (as more
fully describe below under the heading, Third Party Integrations).

How We Use Information

We may use the information we collect for the following purposes:

 * Operating our Services and developing new functionality and features;

 * Responding to questions and communications, or obtaining your feedback about
   our Services;

 * Administering and logging your participation in educational and informational
   programs, including webinars and other classes, and any product or support
   matters that may arise from such programs;

 * Preparing and delivering announcements about features, functionality, terms
   of use, or other aspects of our Services or your interests and informing you
   about offers for services or products we believe may be of interest to you,
   including from third party sponsors;

 * Providing you with more relevant content, including clinical support tools,
   assessments or medical-related information or services, patient support
   programs, advertising, or other programs appearing on our Services or
   third-party services;

 * Analyzing usage trends and patterns and measuring the effectiveness of
   content, programs, advertising or the features or functionality of the
   Services, including emails that may be sent by us to you;

 * Preparing reports for any of the purposes described in this Policy, including
   for current or future sponsors, advertisers or other partners to show
   utilization or trends about the use of our Services. Such reports may include
   demographic or other general user information, but will not include
   personally identifiable information unless the recipient has agreed to
   confidentiality obligations;

 * Safeguarding and protecting our Services, the information we collect, and the
   rights of us, our users or third parties, and in response to legal process;

 * We may use your Payment Card Information as stated in the "Payment
   Information" Section above;

 * Any other purpose described in this Policy or your User Agreement; or

 * When we otherwise have your permission.

How our Services Allow Users to Share Information:

One-on-One Communications:
Our Services can be used to facilitate one-on-one communications between users
and other persons. Examples include:

 * Sending an appointment confirmation or other notification to another user;

 * Making a referral to another healthcare provider;

 * Sending a prescription to a pharmacy;

 * Sending a test requisition to a clinical laboratory; or

 * Sending a message to a patient.

In any one-on-one communication, users are sending information to one another or
to an individual or entity who may not be a user of the Services. Depending on
the message, this could include the sharing of contact and other personally
identifiable information.

Directories:
If you are a healthcare provider who has entered into a Healthcare Provider User
Agreement, you will have the ability to have your contact and directory
information listed in one or more of our professional directories of healthcare
providers on our Services that users and/or the general public may be able to
view. These directories include profile information (e.g., contact, specialty
and other information) and other features that allow users and/or the general
public to locate and contact those listed in the directory.

If you visit our Services seeking to contact or schedule an appointment with a
provider listed in one of our directories, you may need to submit personally
identifiable and other information.

Public Forums:
Our Services include public forums that allow users to communicate with groups
of users or the general public. Information a user posts in one of our
communities may be available to a wide range of individuals, and should be
presumed public. We strongly advise users to exercise care in selecting what
information they share with our communities or public forums, and strongly
recommend against sharing any personally identifiable, health, or other
sensitive information that could directly or indirectly be traced to any
individual, including themselves.

Surveys, Feedback, Informational Programs:
From time to time you may receive survey requests through emails or displays
within our Services that request feedback on a variety of topics. These programs
may be sponsored or funded by third parties, and may include branded or
unbranded content about medical conditions, treatments and products, or safety
and regulatory information resources. If you choose to engage with or use one of
these requests, you may be asked to provide information that may be used to
supplement information that you submitted to our Services. This information may
be shared with the sponsor of the program.

Records:
Our Services allow users to store personally identifiable and health information
("Records"), including Records that identify other individuals, including other
users. Certain of our Services permit users to share all or portions of these
Records at their discretion.

You should be aware that this Policy covers only the information you submit
through our Services. If you contact or exchange information with another user
in person or through a means other than our Services, such activity is not
covered by this Policy. Because our Services enable users to share information
you share with them, you should take care in selecting with whom you share your
Records and other information. Although our Services process such transmissions,
we are not responsible for the actions of persons with whom you share your
Records and other information.

Emails and Other Communications:
Our Services allow users to communicate with others through our in-product
instant messaging services, Service-branded emails, and other electronic
communication channels. Communications that are sent by or on behalf of a user
are indicated as being "From" that user, such as when our Services send an
appointment notification from, and on behalf of, a healthcare provider to his or
her patient. Additionally, we may communicate administrative or Service-related
announcements through email or other communications within our Services. These
communications may be "real time" communications or communications triggered
automatically upon the occurrence of certain events or dates - such as a
repeated sign-in failure or an appointment notification. Please note that you
may not be able to opt out of receiving certain messages from us.

Emails and other communications from individuals who are not users of our
Services, or that we send in connection with business agreements or subject
matter other than the User Agreements, are not covered by this Policy. If, for
example, you contact us regarding a job opening, that communication to us is not
covered by this Policy even though that job opening may have been posted on our
Services.

Third Party Integrations

Our Services may allow you to connect your account on our Services with third
parties, such as when a healthcare provider seeks to integrate our electronic
prescribing module into our partner's national electronic prescribing network,
or when a healthcare provider approves us integrating or linking his or her
account with a third parties' billing software (any such integration, an
"Integration"). Integrations can also be initiated by third parties seeking to
establish Integrations with you, such as when a clinical laboratory desires to
transmit lab results directly into a healthcare provider's electronic health
record account rather than transmitting the result by fax or other means. Your
use of these Integrations is entirely optional. Should you choose to utilize
these Integrations, you may be prompted to give us permission to perform certain
actions in your account, such as creating, updating or deleting certain
information. Please note that if you choose to utilize any Integration, any
information you elect to provide to third parties will be subject to whatever
agreement you have with them, including, if applicable, their terms of use or
privacy policy, and not this Policy. To disable an Integration, you can contact
us through one of the methods described at https://help.practicefusion.com/s/.

Sharing of Information

We may share information you submit to us with third parties under the following
circumstances:

 * When you choose to share such information through our Services, such as
   "one-on-one" communications between a provider and a patient or another
   healthcare provider;

 * When your account has been issued by an account administrator with
   administrative rights over your account, your account administrator will have
   access to your account information;

 * With third party service providers that have agreed to confidentiality
   obligations, which may include, as applicable, business associate contract
   obligations;

 * If you are a healthcare provider who has entered into a Healthcare Provider
   User Agreement, we may share information with the third parties who are
   subject to confidentiality obligations that you have elected to establish
   Integrations with, or who seek to establish Integrations with you, and to
   facilitate, maintain and monitor the utilization of such Integrations;

 * If you are a healthcare provider who has entered into a Healthcare Provider
   User Agreement, we may also share information with third parties who are
   subject to confidentiality obligations who are funding or administering
   certain branded or unbranded content about medical conditions, treatments and
   products, or safety and regulatory information resources, such as clinical
   decision support tools, patient savings offers, co-pay offset or discount
   programs, medication adherence programs, and other similar programs, and with
   sponsors of advertising appearing within our Services. The purposes of such
   sharing may include administration, recordkeeping or compliance obligations,
   and assessing the effectiveness or utilization of any such program;

 * If you receive any honoraria or payment in connection with a survey or
   request for feedback, your information may be shared with the funding source
   or sponsor of such survey or program;

 * When we share your Payment Card Information as described in the "Payment
   Information" Section above;

 * To protect our Services, the information we collect, and the rights of us,
   our users, and any third parties, including to verify your identity;

 * To detect, prevent, investigate, or address fraud, illegal activity, or
   violations of our terms and agreements;

 * In response to legal process, such as a search warrant, court order, or
   subpoena, or when we have a good faith belief that the law requires us to do
   so;

 * With our current and future subsidiaries or corporate affiliates or actual or
   potential investors;

 * In connection with a potential or actual sale, merger, transfer, exchange,
   reorganization or other disposition (whether of assets, stock, or otherwise)
   of all or a portion of the business conducted by our Services. If such a
   transaction occurs, the acquiring company's use of your information will
   remain subject to this Policy, as may be subsequently amended;

 * Any other purposes described in this Policy or your User Agreement; or

 * When we otherwise have your permission.

Security

To help prevent unauthorized access, maintain data accuracy, and protect against
the inappropriate use of the information we collect, store, and transmit, we
deploy a range of technical, physical and administrative safeguards. Under our
Healthcare Provider User Agreement and applicable law, we are required to apply
reasonable and appropriate measures to safeguard the confidentiality, integrity,
and availability of individually identifiable health information residing on,
and processed by, those elements of our Services that we operate as a business
associate on behalf of healthcare providers. It is important to remember,
however, that no system can guarantee 100% security at all times. Accordingly,
we cannot guarantee the security of information stored on or transmitted to or
from our Services.

Third Party Services

This Policy applies only to our Services. It does not apply to services offered
by third parties, including websites and other online services that our Services
may display links to or to advertisements appearing within the Services. When
you click on such links or advertisements, you will be visiting websites or
interactive services operated by third parties, who have their own information
collection practices and may also collect information through the use of
Engagement Tools. We do not have control over how any third party collects or
uses information, so you should review their privacy policies to learn of their
practices.

Changes to this Policy

We believe in continuous innovation, which, along with changes in our business,
may require that we amend this Policy from time to time. We will post a revised
Policy along with its effective date on this page. Because this Policy can
change at any time, we encourage you to reread it periodically to see if there
have been any changes, amendments, or updates. If you object to the changes or
any terms within this Policy or the User Agreements, you should discontinue
using our Services. Your continued use of our Services following the effective
date means that you have consented to the Policy, as amended, changed, or
updated.

Viewing and Updating Your Information

Our Services aim to provide you with access to the information you submit and
the means to update it within our Services consistent with applicable law. This
can be accomplished by logging into our Services and updating that information,
or contacting a customer support representative, although please be advised of
the important limitations described below. Under certain circumstances, we may
ask you to verify your identity before your request is processed.

Please note that, unless you have administrative rights over another user's
account pursuant to our Healthcare Provider User Agreement, you are not entitled
to access, update, or delete the content of another user's account.

If you have used our Services to share information with another user or a third
party, you will not be able to access, update, or delete that shared
information. Further, if another user of our Services submits information that
identifies you, you will not be able to access, update, or delete that
information.

Certain users - such as healthcare providers - may be required under applicable
laws or regulations to retain information about you for extended periods of time
or indefinitely. Additionally, we may have independent obligations under
applicable laws or regulations to retain such information indefinitely. Finally,
for disaster recovery and business continuity purposes we retain copies of data
stored by our Services for indefinite periods of time.

HIPAA grants patients certain rights to access and amend certain health
information that their healthcare providers retain about them. Patients should
submit requests to access or amend their health information directly to their
healthcare providers.

If you are a California resident, you may be afforded certain additional rights
under the California Consumer Privacy Act of 2018 regarding our use of your
personal information. To learn more about your California privacy rights, visit
our CALIFORNIA PRIVACY NOTICE.

Contact Us

If you have questions regarding this Policy, please contact us at:

Practice Fusion, Inc.
Legal Department
731 Market Street, Suite 400
San Francisco, CA 94103


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