Exceptional Healthcare’s Corporate

Privacy Policy

Summary

This Privacy Policy serves as notification to consumers, patients, third-party vendors, employees, and contractors on what personal data and protected health information (collectively referred to as ‘personal information’) we collect, how, why, and who has access to it and for what purpose.

This Privacy Policy applies to all information collected by Exceptional Healthcare and its third­ party service providers (collectively referred to as ‘Exceptional Healthcare,’ ‘us,’ or ‘ours’), that includes but is not limited to websites and applications that post a link to this Privacy Policy. The intention is for this Policy to constitute a statement of the principles and practices adhered to by the Company, its employees, and business partners.

For information on Exceptional Healthcare’s Health Insurance Portability and Accountability Act (HIPAA) Notice of Privacy Practices, you may find the link to this document HERE .

Our Commitment

Exceptional Healthcare, a premier leader in developing and operating community-based hospitals, is committed to securely safeguarding and maintaining the privacy of personal information we collect and process. In order for Exceptional Healthcare to provide our services, it is necessary for us to collect and use (aka ‘process’) the personal information of consumers, patients, website visitors, potential and existing employees, contractors, and business partners.

It is the policy of our practice that all physicians and staff and third parties preserve the integrity and the confidentiality of protected health information (PHI) pertaining to our patients. The purpose of this policy is to ensure that our community of hospitals, their physicians and staff have the necessary medical information, personal data, and PHI to provide the highest quality, medical care possible while protecting the confidentiality of our patients information to the highest degree possible for purposes of treatment, payment, and healthcare operations.

Privacy Practices

This Privacy Policy describes our practices regarding the collection and processing of personal information through various forums in which we operate such as within our hospitals, online website visitors, job application processes and employment management, billing and payment processing, and third-party contracts and business agreements. For purposes of clarity, "processing" as used in this policy includes the collection, use, storage, sharing, transmission, disclosure, and destruction of personal information. Personal information means any information, including sensitive data, which is linked or linkable to an identified or identifiable individual. The term includes pseudonymous data when the data is used in conjunction with additional information that can link the data to an identified or identifiable individual. The term does not include deidentified data or publicly available information.

By using Exceptional Healthcare’s websites, users consent to the collection and use of their personal information. By continuing to use our services and interact with Exceptional Healthcare physicians, hospital staff, and personnel within our business operations and by providing us your personal information, you are accepting the terms of this Privacy Policy.

Personal Information Collected Directly from You

Websites

When you visit Exceptional Healthcare’s website (our home page or one of our community hospital location webpages), you may choose to submit personal information to us such as by entering your name, phone number, email address, and potentially additional personal information, a message, or a question for purposes of us fulfilling your request for our information or services and communicating information that may be of interest to you.

Bill Payment

Our local community hospitals each provide patients the ability to pay a bill onsite or to process bill payment online using the applicable community hospital webpage. Exceptional Health uses third-party vendors by way of a link on its websites for the convenience of paying online when accessing a patient portal. Linked sites are not necessarily reviewed, controlled, or examined by Exceptional Healthcare. Each linked site may have its own terms of use and privacy notice. Users are asked to familiarize themselves with the privacy policy of these sites and comply with all terms when using linked sites. We are not responsible for the policies and practices of any linked site, or any additional links contained in them. We encourage users to read these linked sites’ terms and notices prior to using them.

Career Website and Employment

When you apply for employment with Exceptional Healthcare using our online Career website page, you may choose to submit your interest to us by way of our third-party vendor. Your personal information that you directly provide us at that time may include your first and last name, email address, phone number, postal mailing address, and a copy your resume attached or a pasting of your employment history. We may provide links to third parties' websites (“linked sites”) from our websites such as when applying to a job in which your personal information is shared with one or more of our vendors with whom Exceptional Healthcare engages. This data is shared to assist in the collection, processing, sharing, storage, and management of employment applications and candidate information received on our behalf.

As part of Exceptional Healthcare’s internal operations for recruiting and employee and contractor management, we may collect and process personal information to comply with legitimate business interests for meeting our employer and contract obligations. Categories of personal data received and collected may include, but are not limited to: name and aliases; mailing address; email address; phone numbers; employment history; salary requests and salary (or hourly wage) history; education, certification, and academic history; social security numbers; driver’s license number; and banking information for payroll processing or background checks.

We may also engage third-party vendors to support our internal operations with services that may include, but are not limited to:

• Human Resource (HR) services
• Payroll services
• Onboarding and training activities
• Time and attendance management
• Benefits management
• Technology deployment and management

Community Hospital Services

When you seek healthcare services from one of our hospital locations, your personal information and medical data is collected. We use and share your information for treatment, payment, and healthcare operation purposes. This means we use and share your health information:

• with other healthcare providers who are treating you
• with a pharmacy that is filling your prescription
• with your insurance plan to collect payment for healthcare services or to get pre-approval for your treatment; and
• to manage hospital operations, improve your care, educate our professionals, and evaluate provider performance.

Sometimes we may share your information with our business associates, such as a billing service, who help us with our business operations. All of our business associates must protect the privacy and security of your health information just as we do. We may also use or share your information to contact you about health-related benefits or services or about your upcoming appointments.

Information We Collect About You

Cookies and Technology

Our website uses cookies and similar technologies to improve user experience. Cookies are text files that are stored in the internet browser or by the internet browser on the user’s computer system. When a user visits a website, cookies can be placed locally on the user’s device. This cookie contains a character string, which is a unique identification code of the browser that will be recognized each time a user visits the website. Some elements of our internet site require that the accessing browser can still be identified after having left our page.

Our website also uses cookies that allow for an analysis of the user’s navigation and use of the website.

The following data can be collected by or transferred to our websites:

• webpage views
• use of website functions such as an informational website form submitted,
• information on the browser type and version used,
• the user’s operating system,
• the user’s internet service provider,
• the user’s IP address,
• the date and time of the access to our websites
• websites from which the user was referred to our webpages
• websites accessed by the user’s system via our website such third parties for bill payment
• the duration of the user’s visit
• the user’s preferred language
• browsing history (e.g., the time of the user’s first visit and most recent visit)

The following are tools we may utilize on our website to collect information about you:

Google Analytics:

We may use Google Analytics on our website to collect information about your online activity on our websites, such as the web pages you visit, the links you click, and the searches you conduct on our websites. We may use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website, where visitors have come to the site from and the pages they visited.

The information generated by those cookies and your current IP address will be transmitted by your browser to, and will be stored by Google on, servers in the United States and other countries. Google will use this information on our behalf for the purpose of evaluating your use of our website as described above. The IP address collected through Google Analytics will not be associated with any other data held by Google and is not otherwise stored on Exceptional Healthcare databases.

Exceptional Healthcare retains the privilege to access IP addresses gathered for Google Analytics functions to address breaches. However, this access is limited to the Exceptional Healthcare Azure console and is permissible only within a 3-month timeframe following the IP address collection. Once this period elapses, the IP address is erased, and Exceptional Healthcare loses visibility of the IP address.

For more information about the information gathered using Google Analytics please visit  https://marketingplatform.google.com/about/. You can prevent these cookies by selecting the appropriate settings on your browser. If you do this, you may not be able to use the full functionality of our websites. You may download and install the Google Analytics Opt-out Browser Add-on available here:  https://tools.google.com/dlpage/gaoptout.

Marketing and Selling of Your Personal Information

Exceptional Healthcare does not sell your personal data or protected health information to any third party or individual for any purpose.

Purpose Use Limitation

We limit the use and sharing of your personal information to the minimum necessary in order to provide healthcare services, treatment, and bill payment processing, to enhance users’ website experiences, for the improvement of our web management practices, to respond to inquiries, and for the consideration of employment with our community of hospitals and business operations, and to engage in employee and contractor communications.

As part of our commitment to delivering the highest quality of care and treatment to our patients, at times we may seek feedback from our patients by way of surveys to learn how we may enhance their experience with our hospitals, physicians, and staff. Our mission also seeks to improve the health and well-being of people living in communities with limited healthcare resources and therefore, we engage third parties as part of our outreach campaigns to showcase our patient-centered emergency care and inpatient hospitalization services. In doing so, Exceptional Healthcare does not market directly to individuals. Rather, we partner with third-party digital resources to raise awareness through advertising campaigns through which you may decide to click-through to obtain more information about us. In those instances, our third-party business partners may attach a tracking code or apply pixels so that when visitors come to our website, we are informed when it is the result of our advertising campaigns.

Text Messages

We may send you text messages that you have consented to receive for reasons that may include but are not limited to obtaining updates, reminders, or other conveniences for which you subscribed to receive. These communications are coming directly from one of our third-party vendors and are not managed by Exceptional Healthcare. You can cancel text messages at any time by texting "STOP". After you send "STOP", we may send you an additional text message to confirm that you have been unsubscribed. You will no longer receive text messages from that short code or number, as applicable, but you may receive text messages if you are subscribed to other text lists. Please note that canceling text messages may impact the quality or delivery expectations of services you initially requested or agreed to receiving. If at any time you have questions about the text messages, text "HELP". After you send "HELP" we will respond with instructions on how to use our service as well as how to unsubscribe. Message and data rates may apply.

Your Privacy Rights

Individuals whose personal data or PHI is collected and/or processed by Exceptional Healthcare is often referred to in privacy laws and regulations as a ‘data subject.’ Under applicable privacy laws and data protection regulations, data subjects are empowered to submit inquiries, raise concerns, file complaints, or make requests about the collection and use of their personal information known as exercising their privacy rights. To the extent of applicable law, a data subject may exercise the following rights without constraint, at reasonable intervals, and without excessive delay or expense:

• Right to access your personal data or receive an accounting of disclosure of your PHI
• Right to request erasure of your data, where permitted by law
• Right to rectify or update your inaccurate or out-of-date data
• Right to restrict or object to processing, where applicable by law, your data
• Right to restrict or object to automated decision-making
• Right of relatives or authorized agent to make requests about data on behalf of individuals
• Right to data portability
• Right to know all data collected about you
• Right to say no to the sale or sharing (as permitted by law) of your data (opt-out)
• Right to be informed of what categories of data will be collected about you prior to its collection 
• Right to know categories of third parties (e.g., types of vendors) with whom your data is shared
• Right to know the purpose of collecting your information
• Right to be informed of any changes in the processing purpose and method

Upon submission of a privacy rights request, we will authenticate your identity first by requesting information such as your name, email address, or other contact details, along with the Exceptional Healthcare hospital or office in which you established a relationship.

In accordance with the applicable federal and state privacy laws in which the relationship was established, you may have the right to designate an authorized agent or another person to submit a request on your behalf. To designate an authorized agent or another person to exercise your rights and preferences, please provide your authorized agent with a signed, written permission confirming that they have been authorized by you. To submit a request to exercise any of these privacy rights, please contact Exceptional Healthcare’s Privacy Manager:

By email:

    info@ehc24.com

    Please type in the Subject line of your email “Privacy Request” so that we may properly address your questions, concerns, or request.

Or in writing: 

    c/o Privacy Request

    Exceptional Healthcare Corporate Office

    3514 Cedar Springs Rd

    Dallas, TX 75219

We will respond to your requests within the timeframe stipulated by the applicable federal or state privacy regulation under which you established a relationship with Exceptional Healthcare. For example, as a patient providing PHI to of one of Exceptional Healthcare’s hospital, the Health Insurance Portability and Accountability Act (HIPAA) of 1996 (42 U.S.C. Section 1320d et seq.) would apply. As a visitor submitting personal data to one of Exceptional Healthcare’s websites requesting information, the relevant state law in which the location resides would apply. If more time is required than the initial timeline the relevant law allows to complete your request, we will notify you of the delay, reasons for the delay, and actions you can take as a result of the delay.

If your request is denied, you may appeal our decision by using one of the specified contact methods stated above. Please enclose a copy of (or otherwise specifically reference) the decision you want to appeal. We will respond to your appeal in accordance with applicable law.

Disclosure of Your Personal Information

Records Management and Data Retention 

We will retain your personal data and PHI for as long as necessary to achieve the purpose for which it was collected, usually for the duration of any treatment services, employment, and contractual relationship, and for any period thereafter as legally required or permitted by applicable law. If we wish to process your data beyond that point of time, we will ask for your consent for such activity.

Children Online Privacy

Our websites are not directed at children 15 years of age or younger, and we do not use them to knowingly solicit personal information from or market to children. If we learn that a child has provided personal information through one of our websites, we will remove that data from our systems.

Transparency and Notice

We maintain and provide notices to individuals and patients about why and how we collect and process their personal data and PHI. These notices include transparent and clear information on the use of personal information, including the purposes for which it is processed. Consistent with applicable legal requirements, notices will also include any other details about our activities to ensure that processing is fair such as the use of third parties, any other recipients of such data, and the rights and practical means for individuals to contact us or exercise their rights. In accordance with applicable laws, if the method or purpose of processing the personal data is changed, a notice will be provided to the data subject, along with a request and/or option to re-obtain consent, opt-out of processing, or restrict the processing of the changed data.

For purposes of responding to an individual’s data subject rights request, if applicable law requires, a notification shall be made to the individual making the request that communicates the status of their completed data subject rights request. (Details on Data Subject Rights are outlined in the section Your Privacy Rights). If we do not provide notice at the time of collection, transfer, or change, we will do so as soon as possible thereafter, except if there is an exemption under applicable law that applies. 

Cooperation with Federal and State Authorities

Exceptional Healthcare will only use personal data and PHI in accordance with applicable privacy regulations. This includes laws that may relate to the processing of personal data. If such applicable law requires greater protection of personal data than is set forth in this Policy, Exceptional Healthcare will adhere to the requirements of such law.

We will cooperate with the relevant privacy regulatory authorities and will respond to requests and questions about compliance with, or audits performed related to, data privacy laws and this Policy. We will also comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, local, or other governmental authorities as required by law.

Securing and Safeguarding Your Personal Information

Information Security

Exceptional Healthcare maintains a comprehensive information security program that is proportionate to the risks associated with its data processing activities. We implement the appropriate administrative, technical, physical, and organizational safeguards to reduce the risk of accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal data and PHI. Our technical measures include encryption, firewalls, regular software updates, intrusion detection/prevention systems, restricted access to authorized users on a need-to-know basis, and multi-factor authentication.

Physically, we ensure security through surveillance systems and restricted access to data centers and server rooms. Organizationally, we prioritize data security through employee training on privacy best practices, handling of personal data, incident response plans, and third-party security practices. The program is continuously adapted to mitigate operational risks and protect personal data.

Data Breach Response

In the event of a data breach or incident of unauthorized access, collection, processing, or similar unjustified disclosure of personal data, we are committed to promptly implementing reasonable risk mitigation measures. We will notify affected individuals and patients of the breach and, if necessary, inform the relevant authorities, as required under applicable laws.

Questions or Concerns About Your Privacy

How To Contact Us 

For purposes of compliance with this Privacy Policy and applicable privacy regulations Exceptional Healthcare is required by law to comply with, we have established two (2) mechanisms by which individuals may contact us with questions or with requests to exercise their privacy rights. If you would like to communicate with us regarding privacy issues or have questions, comments, or complaints, please contact our Privacy Manager as follows:

By email:

    info@ehc24.com

    To properly address your questions, concerns, or request, please type in the Subject line of your email “Privacy Request.”

Or in writing: 

    c/o Privacy Request

    Exceptional Healthcare Corporate Office

    3514 Cedar Springs Rd

    Dallas, TX 75219

Modifications to our Privacy Policy 

We reserve the right to change, modify, and update this Privacy Policy at any time. Please check periodically to ensure that you have reviewed the most current notice.

This Corporate Privacy Policy was last updated September 27, 2024. HERE