Privacy Policy

Management Performance Associates

PRIVACY POLICY

 

Introduction:

Our mission at Management Performance Associates is to provide compliance solutions and management consulting services to healthcare organizations.   

 

To assist us in carrying out our mission, we collect and process certain information you provide us. We work hard to be good stewards of your information. This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information.

 

This Privacy Policy applies to information we collect on the MPA website located at http://www.healthcareperformance.com and our Compliance Store located at https://mpa-compliance-store.myshopify.com/

What do we collect and how:

Anonymous and Aggregated Web Traffic Information.

General traffic, site usage, browser information, length-of-stay information, and location data, is collected and stored in log files. This type of information is collected and shared on an anonymous, aggregated basis meaning that we do not connect this information to your name or other personal information.

 

Personal Information (non-financial).

We collect all or some of the following personal information: first and last name and email address, in the following contexts:

 

Blog Subscriptions: To subscribe to the Management Performance Associates blog, we collect your email address. 

 

Blog Comments: If you submit a comment to a post on the Management Performance Associates blog, we collect your name, email address and website along with the comment you wish to post. If we decide to post your comment to our blog, we may include your name with your comment.

 

Requests: We collect information volunteered by users, including from requests via the Contact Form on our websites.  This includes your name, organization, position, phone number, email address, location, and service interests.  We also may collect email addresses of those who communicate with us via email.

 

Online Products/Programs: We may collect some contact information you’re explicitly asked to provide in connection with certain products or programs. For example, when you download our free resources such as MPA's Free Compliance Starter Kit, we ask for your name and email address.

 

Financial Information – Compliance Store.

When you chose to purchase a compliance product or service from Management Performance Associates using our online Compliance Store administered by Shopify, we collect your email address, name, company, billing address, shipping address, phone number and payment information.   

 

Protected Health Information.

Management Performance Associates does not collect "protected health information" as defined by the regulations issued under the Health Insurance Portability and Accountability Act (HIPAA) of 1996 via the website.

 

Analytics.

We use Google Analytics to help us understand how customers use our websites.  You can read more about how Google uses your Personal Information here:  https://www.google.com/intl/en/policies/privacy/ 

You can opt-out of Google Analytics here:  https://tools.google.com/dlpage/gaoptout  

 

Social Networking.

Our websites permit you to use a third party social networking platform such as LinkedIn and Twitter.  This may include use of social media plugins such as Tweet.  When you use these social networking platforms and plugins, your username and password for the available service or collected from you on these services may be shared with us.  When you use social networking platforms and plugins, you share your information with them and their privacy policy applies to disclosure of such information.  In addition, they may be able to collect information about you, including your activity or may notify your connections on the social networking platform about your use of the website.  Such services may allow your activity to be monitored across multiple websites for purposes of delivering more targeted advertising.  Please note that their own privacy polices apply and we encourage you to read them.  We may add new social networking plugins and buttons to our websites from time to time.

 

What we do with the info we collect:

We use anonymous and aggregated information to operate, develop and improve our services.

 

We process your personal information for the legitimate interest of providing compliance solutions and management consulting services to health care organizations.

 

We use your financial information for the purpose of providing you with the product or service you order.  We use Shopify to power our Compliance Store.  You can read more about how Shopify uses your personal information here:  https://www.shopify.com/legal/privacy

 

We use HubSpot for inbound marketing and to tailor our communications with you.  You can read more about how HubSpot uses your personal information here:  https://legal.hubspot.com/privacy-policy

 

Processing your information for the purposes described is necessary for us to do what we do and it’s in both of our interests.  When we use your information based on our legitimate interests, we conduct a balancing test based on the legitimate interest, necessity of processing your information, and how such processing impacts you.

 

We may also use or disclose your information where we conclude that we are required by law or have a good faith belief that access, preservation or disclosure of such information is reasonably necessary to protect the rights, property or safety of Management Performance Associates, its users or the public.

 

If you have any questions or concerns with us processing your information for this legitimate interest, please email us at privacy@healthcareperformance.com.   

 

We’ll ask for your consent before using your information for a purpose that extends beyond what you may reasonably expect from healthcare compliance service provider and that has a more significant privacy impact.

 

Management Performance Associates works with or may in the future work with trusted vendors in the following categories to help fulfill our mission and process your information for the purposes described: packaging, delivering or mailing, answering customer questions about products or services, sending postal mail, and storing data. We will only provide those companies the information they need to deliver the service, and they are contractually prohibited from using that information for any other purpose.

 

As we continue to develop our business, we may buy or sell businesses or assets.  In such transactions, confidential customer information generally is one of the transferred business assets.  In the event of a transaction involving the sale of some or all of Management Performance Associates’ businesses, customer and site visitor information may be one of the transferred assets and may be disclosed in connection with negotiations relating to a proposed transaction.  In such case, the transferred information may become subject to a different privacy policy.

 

What are Cookies and how do we use them:

As part of offering and providing customizable and personalized services, we use cookies and other online tracking technologies to store and sometimes track information about you to:

·         Provide you with personalized content based on your use of our websites

·         Enable you to more easily use our websites by remembering and using contact information and registration information

·         Evaluate, monitor and analyze the use of our websites and their traffic patterns to help improve our websites and services

 

The types of technologies we use include:

 

 

Cookies.
A cookie is a small amount of data that is sent to your browser from a Web server and stored on your computer’s hard drive.  Cookies enable us to identify your browser as a unique user.  Cookies may involve the transmission of information from us to you and from you to us.  Cookies may also be used by another party on our behalf to transfer information to us in accordance with their privacy policy.  Some cookies are "persistent cookies."  They are used by us each time you access our website.  Other cookies are called "session cookies."  Session cookies are used only during a specific browsing session.  We may use a session cookie, for example, to remember that you have already navigated through a particular menu.  We may also use "analytics cookies" that allow web analytics services to recognize your browser or device and, for example, identify whether you have visited our website before, what you have previously viewed or clicked on, and how you found us.  This information is provided anonymously for statistical analysis only.  Analytics cookies are usually persistent cookies.

 

You may disable browser cookies in your browser or set your browser to warn you when a cookie is being sent.  You may lose some features or functionality when you disable cookies.  Remember, also, that disabling cookies is browser specific.  If you log on using Microsoft Edge, you must also disable cookies in Safari if you use that browser at a different time. 

 

Log Files.
"Log files" track actions occurring on our websites and collect data including your IP address, browser type, internet service provider, referring/exit pages and date/time stamps.

 

Web Beacons.
"Web beacons," "tags," and "pixels" are electronic files used to record information about how you browse the site.  You cannot disable web beacons or pixel tags and they are not visible when browsing.

 

The above information is also collected and used by HubSpot to process sales.

 

Choices you have about your info:

You have the right to have your personal information corrected and/or erased.  You may send us an email at privacy@healthcareperformance.com to request access to, correct, or delete any personal information that you have provided to us. Please note, we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. 

 

You may have heard about “Do Not Track” (DNT), which is a privacy preference that users can set in their web browsers.  Our website does not support DNT codes. 

How we protect your information:

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those employees and contracted consultants who have a genuine business need to know it to provide you and your organization with our services. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

  • Our online Compliance Store uses encryption technology for credit card numbers, bank account numbers, passwords and registration information.
  • All client data is stored by our third party marketing and sales service providers, currently HubSpot and Shopify.  

 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How long we keep your information:

We keep your information only so long as we need it to provide the service you’ve requested of us and fulfill the purposes described in this policy. Because people who purchase or download resources from MPA are often interested in other solutions and resources, we keep your information on file to enable you to receive such resources.  If you subscribe to our blog or a mailing list, we keep your contact information on file until you instruct us to remove it.  If you unsubscribe from an email list or opt-out of email communications, we keep your email address on our opt-out list.    

Our policy on children’s information:

If you are under 18 years of age, you may not purchase products or services from, and you should not provide information to the website. We do not knowingly solicit personal information online from, or market online to, children under the age of 13.

For our friends in the EU:

This Privacy Policy includes information applicable to European Union (“EU”) residents or users accessing the website in the EU. If you are an EU resident, this Privacy Policy provides you with information regarding your rights under the EU General Data Protection Regulation (“GDPR”).  We do not market our services to persons or companies located in the EU.

 

Transfer of Personal Data.

Management Performance Associates and our websites are based in the United States and, regardless of where you access the website, the information collected as part of that use will be transferred to and maintained on servers located in the United States. The European Commission has determined that the US lacks an adequate level of protection for personal information of EU data subjects. Management Performance Associates is not currently certified under the Privacy Shield. By providing us with your information, you are consenting to the transfer of your personal data to the U.S.

 

Although there is risk in transmitting your information to a country that does not have adequate protection, Management Performance Associates does take steps to secure your personal data.

 

Your Choices.

The GDPR provides you with certain privacy rights.  If you wish to access or update your personal information, contact us at the address or number below.  You may also request to have your information deleted, although we may retain information for backups, prevention of fraud and abuse, satisfaction of legal obligations or other ongoing legitimate interests.  You may decline to share certain personal data, in which case we may not be able to provide you with some features and benefits.

 

Right to Object.

If you are located in the EU, you have the right to object to our processing that is based on legitimate interests by contacting us at the address or number below. 

 

Right to Lodge a Complaint.

If you are located in the EU and you believe that Company has infringed your rights under the GDPR, please contact us by sending an email to privacy@healthcareperformance.com or calling us at 314.394.2222.

 

You have the right to lodge a complaint with a supervisory authority, in particular in your applicable Member State.

For our friends in CA:

California Civil Code Section 1798.83 permits our website visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@healthcareperformance.com. Please make sure to state that you are a California Resident.

How we make changes to this policy:

We may change this policy from time to time and if we do, we’ll post any changes on this page. If you continue to use our website after those changes are in effect, you agree to the new policy. If the changes are significant, we may provide a more prominent notice or get your consent, as required by law.

Contact us:

If you have any questions about this policy or need to contact the Company to exercise your rights as a data subject under the GDPR, please contact MPA’s Privacy Officer at: privacy@healthcareperformance.com by calling us at 314.394.2222, or by mail to Management Performance Associates, 2705 Dougherty Ferry Road, Suite 202, St. Louis, MO 63122.

 

Last Updated: September 24, 2018