This Privacy Notice describes how personal information is collected, used and stored through use of the practice management platform by Sage Practice, Inc. (“Sage Practice” or “we” or “us” or “our”) and through use of our websites and web-based resources. We refer to our platform, websites and web-based resources as the “Services”.

In this Notice, we use the word “Subscriber” to refer to anyone who has subscribed to and paid for use of our practice management platform (for example, a wellness practice or health practitioner), and also includes their individual sub-users. We use the word “you” and “your” to refer to any individual user of our Services, such as a practitioner, staff member or client of a Subscriber, or an individual browsing or using our websites and web-based resources. We use the word “Client” to refer to any individual that interacts with Sage Practice’s practice management platform to book or use the services of a Subscriber.

Notice to Clients

If you are a Client at any of our Subscriber practices or practitioners, your practice or practitioner controls your client information, including your contact information, billing details and client records. Please contact your practice or practitioner for any questions about your client information or contact Sage Practice for any questions about management of your Sage Practice authentication information. See the section titled Client Data below for further information.

Why Sage Practice Collects Personal Information

Sage Practice collects personal information in order to provide our Services to our Subscribers and their users, for our own business purposes (such as managing your subscription and payments), to learn about use of our Services (for improvement, accessibility and relevant content), and to provide you with information about our Services, including features and promotions. We collect only the minimum amount of personal information needed for these purposes. We do not sell or trade personal information, and we will only share your personal information with third parties in the ways that are described in this Privacy Notice.

Information Sage Practice Collects from You

Contact Information. We collect your contact information, such as your name, email address and organization, when you fill out our online forms or set up your user account for our Services. We use your contact information to activate your user account, give you access to the Services, and to send you notices about your user account. We may also use your contact information for marketing purposes, such as promotional emails, direct mail and sales contacts. You can opt-out of our marketing communications at any time by unsubscribing or contacting us at support@sagepractice.com. Please note that other than email addresses used in authentication credentials, Sage Practice does not collect or manage the contact information of clients, or any marketing or other communications between a Subscriber and its clients.

Client Authentication Information. We collect your authentication credentials (email and password) (“Client Authentication Information”) when you create an account to link, book and obtain services from one or more Subscriber practices as a Client.

Billing Information. When a Subscriber subscribes to our Services, we also ask them to provide credit card information to process payments. We do not keep your credit card information. Credit card information is provided directly to our payment processor who is PCI-compliant. We receive a ‘token’ from the payment processor that replaces sensitive information and acts as a non-sensitive identifier which can be used by the payment processor to reference your credit card information when future payments need to be processed.

Log and Device Information. When you access and browse our Services, we collect information about how you are accessing our Services, such as your internet or mobile network connection, your browser or the type of mobile device you are using (if applicable). We use this log and device information to identify how our Services are being accessed and used so we can optimize them for the types of connections, browsers and devices being used. This information is not used to market or send promotions at an individual user level.

Cookies and Tracking Information. Our website uses cookies. Cookies are small data files that are downloaded to your computer or device by a website. Your web browser lets you manage cookies through its “settings” or “options” menus. You can change your browser settings to display a warning before accepting a cookie or to refuse all cookies other than essential cookies required for the functioning of the Services. You can also delete cookies at any time; however, please note that certain cookies must remain in order to use certain portions of the Services. We also use web beacons, which are tiny graphic objects embedded in a web page or an email which allows us to determine if a user has viewed the web page or email.

We use cookies and web beacons:

• To learn about use of our websites, such as user traffic patterns and the effectiveness of our navigational structure

• To identify email open rates in order to gauge the effectiveness of certain communications or marketing campaigns to practices

• To allow you to login to secure areas of our Services

• To store your login credentials for easy access to our Services

• For more information about cookies, see our Cookie Policy.

Client Data

Client Data. Subscribers use our practice management platform to collect personal information from their clients and create client records. These records may include a client’s name, address, health insurance and billing information, medical charts, appointment history and other client data (“Client Data”). This information is sometimes referred to as “personal health information”, “protected health information”, “data concerning health” or “sensitive data” depending on the location of the Subscribers and the privacy laws applicable to them. If you are a Client, Client Data is collected from you when you visit your Subscriber practice or practitioner and when you create a profile or book appointments with the Subscriber practice through our online booking Service.

Subscriber’s Role. Subscribers retain sole control over Client Data and may be referred to as a “health information custodian”, a “covered entity” or a “controller” depending on their location and the privacy laws applicable to them. Subscribers determine:

• What Client Data to collect;

• How the Subscriber will use the Client Data;

• Who has access to Client Data;

• How long the Subscriber will store Client Data; and

• On what basis the Subscriber may delete Client Data.

• Subscribers are responsible for complying with laws and regulations governing the use of Client Data, and for determining the legal basis for such use.

Sage Practice’s Role. Sage Practice is a service provider to Subscribers and may be referred to as an “agent”, “business associate” or “processor” of the Subscriber. Sage Practice stores Client Data in its secure data centers and makes it available to Subscribers and their users through our practice management platform. Therefore, except in relation to Client Authentication Information, Sage Practice otherwise has no control over Client Data. Sage Practice will only access Client Data on the instructions of the Subscriber or its representatives or, in rare cases, where needed in order to prevent or address technical problems, your requests for support, or if required by law or court order. Please note that in order for Sage Practice to verify that we have true consent to access your account and its data, that we may verify the person requesting that we access. We may store and access non-identifiable usage data in connection with managing your subscription and licenses.

Client Authentication Data. In the interest of facilitating a more convenient and comprehensive experience to Clients, Sage Practice allows Clients to use their Client Authentication Information to link, book and obtain services from Subscribers; the email, phone number and password for these unified accounts used by Clients are referred to as Client Authentication Data. Sage Practice shall be considered a “personal information custodian” or a “controller” of Client Authentication Data for the purpose of administration of authentication and access to the practice management platform and to each of the Subscriber accounts that the Client is linked to. Client Authentication Data shall not be considered Subscriber Data. Furthermore, for the purpose of Client Authentication Data, Sage Practice does not qualify as a “covered entity” because Client Authentication Data is not deemed to be personal health information. Sage Practice assumes responsibility for the safeguarding of Client Authentication Data and will not disclose Client Authentication Data to any Subscriber without the prior consent of the Client. Sage Practice shall be responsible to ensure that only Clients who have successfully authenticated and are linked to a specific Subscriber account are allowed to access such Subscriber account.

Storage Location. Client Data is stored in a data center located in the United States. Please note that we use US-based service providers for appointment reminders sent by SMS and, therefore, Client Data contained in appointment reminders will go through and may be stored temporarily in the United States. We require all our data centers and service providers to maintain a high level of security and to comply with applicable privacy laws.

Client Rights. Clients have certain rights with respect to their Client Data, which may include knowing what information your Subscriber practice has about you, correcting any inaccurate Client Data, obtaining a record of your Client Data and, in certain circumstances, deleting or removing your Client Data. Please note that Subscribers have strict legal and regulatory obligations around Client Data and may not always be permitted to delete or remove Client Data.

Questions about Client Data. If you have any questions about your Client Data or wish to exercise any or your client rights, please contact your Subscriber practice or practitioner. If your Subscriber practice or practitioner has any questions about the management of Client Data in the Services, they may contact us and we will support them as needed to respond to your request. Please note that, in order to maintain strict security of your Client Data, we can only access Client Data upon instruction from the Account Owner of the Subscriber. If your questions are about your Client Authentication Data, you may contact us directly and we will respond to your request.

Sharing Your Information

We do not sell or distribute personal information to third parties for their own commercial or marketing purposes. We will only share personal information we collect in the following circumstances:

Suppliers and Service Providers. In order to operate our business and provide the Services to our Subscribers and their users, we may need to share a limited amount of personal information, including Client Data, with our third-party suppliers and service providers. Before sharing personal information, we ensure that the third parties receiving the personal information have provided appropriate safeguards, and that privacy rights are protected and preserved. Some of the areas where we use third-party suppliers and service providers include:

• Our data centers where all platform data is stored

• Customer support services to help us collect feedback and manage our support services

• Communication services to send out email and SMS notices or reminders

• Payment processors

Corporate Transactions. We may share personal information in connection with negotiating or carrying out a financing or acquisition of our business, a merger or amalgamation with another business, or a sale of all or part of our company assets. Before sharing personal information, we will ensure that appropriate confidentiality and non-disclosure undertakings are in place. We will not share Client Data in these circumstances.

Compliance with Laws. We may disclose personal information to governmental or judicial authorities (to respond to a request, subpoenas, registrations, or legal processes) or other third parties (as required by law, to comply with our legal and regulatory obligations, or to protect and secure our interests, rights, and our assets), to enforce security requirements, or to respond to an emergency which we believe, in good faith, requires us to disclose personal information. . We may also be required to disclose personal information to enforce our legal rights, to enforce security requirements, or to respond to an emergency which we believe, in good faith, requires us to disclose personal information. In such instances, we carefully review a request to make sure it complies with applicable law; if we consider the request to be too broad, we may try to narrow it to minimize the scope of the request, and, if permissible, we will make every reasonable effort to give you as much notice and detail as we can regarding the disclosure of your personal information, what information was disclosed and why. We will not disclose Client Data unless legally required to do so.

Client Authentication Data. Sage Practice shall not share your Client Authentication Data with any of the Subscribers that you, as a client, elect to link your account to.

Anonymized / Aggregated Data. Sage Practice may use computer-generated algorithms to gather anonymous and aggregated information from Subscriber Data in order to assist in our continued development and improvement of the Services, and for the purpose of analysis or compiling statistical data. We will ensure that such anonymized individualized information is not shared outside of Sage Practice without the consent of the Subscriber, but we are permitted to share aggregated analysis about the use of the Services.

Security

We take reasonable measures, including firewall barriers, SSL/TLS encryption techniques, and authentication procedures, to help protect personal information from accidental loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. In addition, we limit access to Subscriber Data to those employees, agents, contractors and other third parties who have a business need to know. We protect your personal information, including Client Data stored in our platform, by:

• Using industry standard security controls such as encryption and an SSL (Secured Sockets Layers) certificate to ensure information is transmitted over a secured connection between your browser and our web server.

• Using state-of-the-art data centers with appropriate security and compliance certifications, such as ISO-27001, SOC 2, etc.

• Having our personnel sign strict confidentiality agreements in addition to completing periodic training to ensure they understand the confidential nature of the data we process, and only accessing your account when you request assistance from us.

• Requiring password protection of your user account with a password set by you. We cannot access or identify your password. The only way to recover a password is for you to initiate a reset via the email address or mobile phone number you use for the Services.

• While we employ industry standard measures to protect your information, no electronic communication can ever be completely secure. You share responsibility for protection of your personal information by setting a strong password and by keeping your username and password confidential, along with utilizing the security features available to you and according to your needs.
  
  

Storage Period

We retain personal information only for as long as necessary to achieve our stated purposes, or as required by applicable law. For example, Contact and Billing information is kept for as long as a Subscriber account is active and for a reasonable period after it has been deactivated in the event you or your Subscriber wish to re-activate the account as well as for Sage Practice to meet legal requirements and internal record retention policies. User account information may also be retained as necessary to comply with our legal obligations, resolve disputes or maintain our relationship with a Subscriber.

If you are a client of one of our Subscriber practices, please contact your practice or practitioner for information regarding the storage period for your Client Data.

Your Rights

Individuals have certain rights with respect to their personal information. These rights are set out below. If you are a client of one of our Subscriber practices, please contact your practice or practitioner to exercise any of these rights with respect to your Client Data. To exercise your rights over your Client Authentication Data, please Contact Us.

Correction and Deletion. We will make reasonable efforts to ensure that the personal information we collect from you is accurate and complete. You may update, correct or delete your account information at any time by logging into your user account and modifying your personal information, including your preferences to receive messages from us. You may also update, correct or delete your personal information by contacting us as noted below.

Withdrawing Consent. Where we have relied on your consent to use your personal information, you have the right to withdraw that consent at any time by contacting us as noted below, which we will give effect to promptly. In addition, all our marketing email messages contain the ability to automatically “opt-out” or unsubscribe from our mailing lists and marketing messages.

Access and Portability. You have the right to request a record of the personal information that we have collected about you and to ask that the information be provided in a structured, used electronic format (where applicable and technically feasible). There may be some cases where we cannot provide you with certain information about you if it would mean disclosure of personal information of another person or other confidential information, or if it would compromise our security systems. If you require access to your personal information, please Contact Us. We will respond to you within thirty (30) days of receiving your request. We may charge a fee where permitted by applicable law.

Restriction and Objection. In certain limited circumstances, individuals in the EU, Switzerland or the UK may request that we restrict our use of their personal information and, where we rely on legitimate interests as the legal basis for using your personal information, you have the right to object to such use. In these cases, we can be required to no longer use your personal information; however, this may mean that certain components of our Services cannot be made available to you. If you wish to exercise your right to restrict or object, please Contact Us.

Complaints. You have the right to lodge a complaint with a supervisory authority (i.e., the independent public authority responsible for monitoring data protection laws in your country).

Contact Us

If you have any questions or concerns about our Privacy Notice and our privacy practices, please contact us at:

Sage Practice, Inc. 

Email: support@sagepractice.com

Attention: Privacy Officer - Alec Rodgers, Founder

support@sagepractice.com