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PRIVACY POLICY

Simplify Compliance and its comprising brands (BLR, HCI, M. Lee Smith,
Bluepoint, and CCMI) is committed to protecting your privacy and hold our
relationship with users in the highest regard.In the first part of this Privacy
Policy, we outline how Simplify Compliance collects information online through
SimplifyCompliance.com or other Simplify Compliance websites which link to this
Policy (collectively known as “Simplify Compliance Sites”).

The second part of this Privacy Policy pertains to Personal Information that we
collected outside of Simplify Compliance Sites. “Personal Information” is
defined by any information that allows us to identify you by an identifier such
as your name, identification number, or location data.

‍By using a Simplify Compliance site and/or submitting your Personal Information
to Simplify Compliance or its brands (outlined below), you consent to the use,
storage, processing and transfer of that information in accordance with this
Privacy Policy.

‍For the purposes of the EU General Data Protection Regulation 2016/679 (the
“GDPR”), the data controller is Simplify Compliance with an office at 101
Creekside Crossing, Suite 1700-735, in Brentwood, TN 37027. Simplify Compliance
is based in and operates out of the United States. BLR, HealthLeaders, M. Lee
Smith, CCMI, and Bluepoint Leadership Development are all brands of Simplify
Compliance and have also adopted this Privacy Policy. Where your data is being
collected and used by one of the brands, all references to Simplify Compliance
herein will also apply to the respective brand.

QUESTIONS
‍If you have any questions or complaints regarding this Privacy Policy or
Simplify Compliance Sites, please contact us at Service@SimplifyCompliance.com
or by phone at 800-727-5257 or send a letter to:

Simplify Compliance
PO Box 5094
Brentwood, TN 37024

CHANGES TO THIS PRIVACY STATEMENT
‍This Privacy Policy may be modified from time to time. If there is a material
change in our privacy practices, we will post those changes to this privacy
statement. If there is a significant change, we will indicate on our sites that
our privacy practices have changed and provide a link to the new privacy
statement.

PART I – SIMPLIFY COMPLIANCE SITES PRIVACY POLICY
‍Our primary goal in collecting personal information is to provide you with the
best and most useful content and services. In addition, we may use the
information collected from you to contact you regarding our products and/or
services.

In order to use certain areas of Simplify Compliance Sites, a user may need to
complete a registration form. During registration, a user may be required to
give contact information (such as name and email address). We use this
information to contact the user about services on our site for which he/she has
expressed interest. Some information is optional while other information may be
required. In some cases a unique identifier (such as, username and password) may
be required in order to obtain further benefits from our Sites.

Forms on the Simplify Compliance sites that request financial information do so
in order to bill you for products or services ordered.

‍1. What information do we collect?
‍Simplify Compliance sites collect the following Personal Information about site
visitors:
‍
‍a) Site Use Information
‍Simplify Compliance collects technical information relating to each time a
visitor comes to a Simplify Compliance Site, including IP address, browser type
and version, time zone settings, browser plug-in types and versions, operating
system and platform type.

We may also collect information about your visit, including pages you searched
for and viewed and for how long, page response times, download errors, page
interaction, and any phone number used to call our customer service number. This
information can be collected without registration. This technical information
allows us to assess support needs and the popularity of content across Simplify
Compliance sites.

We may use this information for Remarketing, Google Display Network Impression
Reporting, or Google Analytics Advertising Reporting Features. Basic and
third-party vendors, including Google, use first-party cookies and third-party
cookies together to inform, optimize and serve ads based on someone’s past
visits to Simplify Compliance Sites (see item 2 in this Policy). Some Simplify
Compliance Sites use Bombora to aggregate anonymized data about customer
interests.

Some websites use Crazy Egg web analytics service. These services may record
mouse clicks, mouse movements, scrolling activity, as well as text you type in
the website. Crazy Egg is not using the information to collect any personally
identifiable information entered into the website. Crazy Egg does not track your
browsing habits across websites that are not using these services. Information
collected by Crazy Egg is used on an aggregate basis to improve site usability.
You can opt out from these services by visiting their site:
https://www.crazyegg.com/opt-out.

‍b) Information Provided to Simplify Compliance
‍You may provide Personal Information to us which may include your name,
personal and/or work email address, postal address, phone number, company name,
job title, certification designation, etc. If you are making a purchase, you
might also provide your credit card information. This information is optional to
benefit from certain Simplify Compliance products and services.

Surveys: When you participate in a Simplify Compliance survey, we may ask for
your Personal Information, such as name, e-mail address, employer, and any other
informa

 * Simplify Compliance collects Personal Information in the following ways:
   Membership Applications: You are sharing Personal Information with us when
   you join or renew your membership to any Simplify Compliance associations,
   including the Association of Clinical Documentation Integrity Specialists
   (ACDIS), the National Association of Healthcare Revenue Integrity (NAHRI),
   and the Association of Home Care Coding & Compliance (AHCC). Your membership
   log-in credentials will allow you to take advantage of exclusive, locked
   content on Simplify Compliance Sites.
 * Other Registration: When registering for complimentary online programs, we
   may ask for the same type of Personal Information.
 * Online Purchases: When you make a purchase through any of Simplify
   Compliance’s e-commerce sites, or when you subscribe to one of our
   publications through any Simplify Compliance site, you may be asked for the
   same type of Personal Information.
 * Other Subscription: When you subscribe to an e-mail newsletter, you may be
   asked for the same type of Personal Information. In many cases, your e-mail
   address will be required for fulfillment of the subscription.
 * Content: When you download complimentary content, including whitepapers and
   reports, from a Simplify Compliance Site, you may be asked for the same type
   of Personal Information in order to access.
 * Employment Applications: When you apply for employment with Simplify
   Compliance, we may ask for your Personal Information, including copies of
   your Resume, and any other information required to verify your
   qualifications.
   
 * Surveys: When you participate in a Simplify Compliance survey, we may ask for
   your Personal Information, such as name, e-mail address, employer, and any
   other information. Sometimes, the survey will be anonymous, in which case
   Personal Information is not required to provide input.

2. How does Simplify Compliance use “cookies”?
‍A cookie is a small text file containing a unique identification number that a
website will transfer to the hard drive of your computer. This unique number
identifies your web browser whenever you visit a Simplify Compliance
site.Simplify Compliance Sites use cookies to store usernames, passwords, and
other user preferences so that users don’t have to re-enter this information
each time they use a particular site. You should be aware that advertisers
serving ads on the Simplify Compliance Sites may use their own cookies.We, or a
data provider we have engaged, may place or recognize a unique cookie on your
browser to enable you to receive customized ads, content or services. No
personally identifiable information is placed into these cookies. The cookies
may reflect de-identified demographic or other data linked to data you
voluntarily have submitted to us, e.g., your email address, in hashed, non-human
readable form.The use of cookies is an industry standard, and cookies are
currently used on most major websites. Most web browsers are initially set up to
accept cookies. If you prefer, you can reset your browser to notify you when you
have received a cookie or set your browser to refuse to accept cookies
altogether. Some features of Simplify Compliance Sites may not work correctly if
you disable cookies entirely. To learn more please go to
http://www.networkadvertising.org/managing/opt_out.asp.


3. Does Simplify Compliance share information with third parties?
‍Occasionally, we make our customer list available to other reputable
organizations so you may receive offers you might find interesting. We permit
carefully selected organizations to advertise in our e-mail publications or let
them sponsor products. To stop receiving such e-mails, follow the unsubscribe
instructions in the e-mail or send an e-mail to Service@SimplifyCompliance.com
at any time.We may share Personal Information in the following ways:

‍a) Information You Give Us
‍1. Personal Information provided when you register for services or products.
When you provide Personal Information about you on a Simplify Compliance Site to
make a purchase or access an asset, we may share such Personal Information as
necessary to the complete the transaction requested by you. Simplify Compliance
also reserves the right to sell or otherwise provide mailing and information
lists to selected third parties. These third parties may contact you directly
regarding their products and services.

‍If you wish to opt out of the sale/distribution of such lists to third parties
at any time, you may do so by opting out. We will not share Personal Information
relating to individuals based in the EU or the United Kingdom unless you have
provided your opt in consent.

‍2. Sensitive Personal Information. Simplify Compliance does not share sensitive
Personal Information such as passcodes, credit card numbers, or health
information except as necessary to complete your requested transactions, to
process employment applications, or to comply with legal obligations. In such
cases, this is done under strict confidentiality and security protections.

Simplify Compliance may use third party companies and persons to perform certain
functions for us. These functions might include processing credit card payments,
providing customer service, and sending e-mail. These other companies and
persons may have access to customer information (such as Personal Information)
that is needed to perform their functions, but they are under contractual
confidentiality obligations and are not authorized to use the information for
any other purposes.

3. In the course of our business, Simplify Compliance might buy or sell sites or
assets. In these kinds of transactions, customer information (such as Personal
Information) is usually one of the transferred business assets. In the event
that Simplify Compliance, its subsidiaries, or affiliates is acquired, merged,
or otherwise combined with another party, customer information will be one of
the transferred assets.

‍b) Site Use Information
‍We may provide third-party sponsors/advertisers with front-end statistics
(i.e., impressions and click-throughs) on the performance of their
advertisements. In addition, we may share website statistics with other third
parties.

4. How do we use the information we collect?
‍We use your Personal Information according to the terms of our Privacy Policy
as it is written at the time of our use. We will only process your Personal
Information, including sharing it with third parties, where (1) you have
provided your consent, which can be withdrawn at any time (your electronic
approval will qualify as your consent), (2) the processing is necessary for the
execution of a transaction or contract to which you are a party, (3) we are
required by law, or (5) processing is necessary for the purposes of our
legitimate commercial interests, provided those interests do not override your
fundamental rights.

 1.  to carry out our obligations arising from any agreement entered into
     between you and Simplify Compliance, or between your employer and Simplify
     Compliance
     
 2.  to update and renew a membership
 3.  to provide you with the information, products and services you request from
     us
 4.  to arrange and deliver events and other programs relevant to your job and
     interest areas
 5.  to respond to your questions and provide related customer service
 6.  to improve Simplify Compliance Sites
 7.  to send you Simplify Compliance publications, special offers, and
     information we believe is useful to our customers and prospects, where you
     have not opted out of receiving such information at the email address at
     which you are receiving it. We may automatically process your information
     to determine which products and services may be of most use to you. You may
     opt out of such processing by emailing Service@SimplifyCompliance.com.
 8.  to send you third party information that Simplify Compliance believes is
     relevant to you
 9.  to notify you about changes to your products or services or to ask for your
     feedback in improving said products and services
 10. to allow you to participate in a contest, competition, or survey Surveys &
     Contests
 11. should you apply to work at Simplify Compliance, to process your employment
     application, including background checks and education and employment
     verification
 12. to comply with all applicable laws or legal processes, or provide
     information to protect the rights, property, or safety of Simplify
     Compliance or our customers, attendees, or prospects.

b) Information Collected Around Site Use

‍Simplify Compliance uses anonymous data collected on our Sites to let our
sponsors/advertisers see the front-end performance of their advertisements,
including impressions and clicks.

We also use this anonymous data to analyze the behavior of visitors our sites to
measure interest and determine areas to optimize that will better serve our
visitors.

‍c) Information Collected Around Certification

‍If you register for certification or recertification through any of Simplify
Compliance’s associations, we may use any Personal Information you provide doing
so in the same manner as we do with purchase and registration information. We
may use or disclose Personal Information, certification exam performance
information, and/or related assessment information to outline certification
participation, send notifications about the status of certification, or schedule
and administer exams. We will not share Personal Information about exam
performance or any reasonable accommodation request with the general public.

‍5. How can you review and modify your Personal Information?

‍You have the following options for modifying or deleting Personal Information
or demographic information provided by you to Simplify Compliance or its brands.

Email Service@SimplifyCompliance.com.

Send mail to the following postal address:
Simplify Compliance, PO Box 5094
Brentwood, TN 37024

Call 800-727-5257

‍6. What is the opt-out policy for Simplify Compliance sites?

‍Simplify Compliance provides all prospects and customers with the opportunity
to opt-out of receiving communications from our brands, individually or
holistically, and our partners. If you no longer wish to receive specific
communications or services, you have the following options:

BLR

Visit https://preferencecenter.blr.com/blr/emailsubscriptions
‍
‍Email Service@SimplifyCompliance.com
‍
‍Send mailed request to:
Simplify Compliance, PO Box 5094
Brentwood, TN 37024

Call 800-727-5257

HealthLeaders

Visit https://preferencecenter.hcpro.com/hlm/emailsubscriptions

‍Email Service@SimplifyCompliance.com

‍Send a mailed request to:
Simplify Compliance, PO Box 5094
Brentwood, TN 37024

Call 800-727-5257

CCMI

Visit https://preferencecenter.hcpro.com/ccmi/emailsubscriptions

‍Email Service@SimplifyCompliance.com

‍Send a mailed request to:
Simplify Compliance, PO Box 5094
Brentwood, TN 37024

Call 800-727-5257

You will find instructions for opting out of any e-mail you receive included at
the bottom of each email.

‍7. Your California Privacy Rights

For California Residents Only. If you are a current resident of California, you
have certain rights under the California Consumer Privacy Act.

Do not sell my Personal Information. Simplify Compliance may disclose your
Personal Information to third-party partners who may use that information to
market directly to you. As a California resident, it is your right to opt-out of
having your Personal Information licensed to third parties. We will not share
your information after we have received your notification that you are opting
out.

Request to know about your Personal Information. You have the right to request
disclosure of any Personal Information we have about you, along with categories
of information we hold about you, categories of recipients with whom we’ve
shared Personal Information, categories of information we share with others, and
categories of sources of the information. You may make a request once per
calendar year.

Request removal of your Personal Information. You have the right to request that
we delete any Personal Information we have about you.

Non-discrimination. Simplify Compliance does not discriminate against you if you
choose to take any action under the California Consumer Privacy Act.

If you wish to opt-out or take other actions available under California law, you
have the following options:

Send an e-mail to Service@SimplifyCompliance.com

Send a mailed request to:
Simplify Compliance, PO Box 5094
Brentwood, TN 37024

Call 800-727-5257

In your request, please attest that you are a current California resident and
provide a current California address for our response. As a security precaution
we may also require additional information to allow us to confirm your identity.

‍8. Your European Privacy Rights

For European or United Kingdom Residents Only. If you are based in the EU or the
UK, you may have rights under the General Data Protection Regulation (GDPR) in
relation to your Personal Information.


 * Request access to your Personal Information. You may have the right to
   request disclosure of any Personal Information we have about you, including
   recipients or types of recipients with whom we’ve shared Personal
   Information, the period for which Personal Information will be stored, the
   source of Personal Information, and any automated decision-making taking
   place around Personal Information.
   
 * Request correction of your Personal Information. You may have the right to
   rectify any inaccurate Personal Information we have about you.
 * Request removal of your Personal Information. You may have the right to
   request that we delete any Personal Information we have about you.
 * Request restriction of processing of your Personal Information. You may have
   the right to prevent or restrict us from processing your Personal
   Information.
 * Request transfer of your Personal Information. You may have the right to
   request, where technically possible, the transfer of Personal Information
   directly to a third party.

Where you believe that we have not complied with our obligations under this
Privacy Policy, or under European or UK data protection laws, you have the right
to make a complaint to an EU or UK Data Protection Authority, such as the UK
Information Commissioner’s Office.

If you wish to exercise your European or UK data subject rights, you have the
following options:

Send an e-mail to Service@SimplifyCompliance.com

Send a mailed request to:
Simplify Compliance, PO Box 5094
Brentwood, TN 37024

Call 800-727-5257

9. What kinds of processes and procedures are in place to protect against the
loss, misuse or alteration of your information?

‍Simplify Compliance Sites have security measures, such as firewalls, in place
to protect your Personal Information. While we cannot guarantee that loss,
misuse or alteration to data will not occur, we take precautions within our
control to prevent these occurrences. Certain sensitive information collected
for transactional purposes, such as your credit card number, is encrypted prior
to transmission.

You are ultimately responsible for the security of your Simplify Compliance
login credentials. You may not share your login credentials with others who have
not purchased or subscribed to restricted content on Simplify Compliance Sites.
You should log out of Simplify Compliance systems on your browser at the end of
each computer session to ensure that others cannot access your Personal
Information.

‍PART II – SIMPLIFY COMPLIANCE PRIVACY POLICY FOR INFORMATION COLLECTED OTHER
THAN THROUGH SIMPLIFY COMPLIANCE SITES

‍If you submit Personal Information to Simplify Compliance through any channel
other than our Sites, the same privacy rules set forth at Part I above for
Simplify Sites will be applied to the use and processing of your Personal
Information, apart from the following:


 1. The “cookies” and other tracking devices used by Simplify Compliance Sites
    do not apply to Personal Information gathered through other channels.
    
 2. When Simplify Compliance collects Personal Information through channels
    other than our Sites, it may apply a different privacy policy, which will be
    disclosed to you.

101 Creekside Crossing
Suite 1700-735
Brentwood, Tennessee 37027
800-727-5257

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