Services means eCW products and services, illustrated by sites, records and portals
The policy defines Services as eCW’s products and services, illustrated by websites (Sites), electronic medical records systems, practice management systems, healthcare provider customer portals and patient portals, and software and mobile applications for those products. The list closes with "etc.," so it is illustrative rather than a closed set.
Supporting quotations
1.1.1. "Services" means eCW's products and services, such as our websites ("Sites"), electronic medical records systems, practice management systems, healthcare provider customer portals ("Provider Portals"), patient portals ("Patient Portals", collectively with Provider Portals, "Portals"), software and mobile applications for the foregoing, etc.
Qualifications & exceptions
Illustrative list; the definition is open-ended.
Not stated here
Whether a given eCW offering falls outside the illustrative list.
Use & Processing · Company practice
Collected information is used to personalize the experience and provide the Services
eCW says it uses information collected from Services users to personalize and improve the visit and experience, to provide the Services to the reader or its customers, and for the other purposes set out later in the policy. The purposes are stated at this level of generality and cross-referenced to the later purpose section.
Supporting quotations
eCW uses information collected from users of the Services to personalize and improve your visit and experience, to provide the Services to you or our customers, and for other purposes set out below.
Qualifications & exceptions
Improvement and personalization are stated without a description of the technique used.
Not stated here
What the later purpose section adds is not part of this section.
Use & Processing · Company commitment
eCW uses PHI as a business associate only on Provider instructions under HIPAA
The policy states that it supplements the Customer Documents and that eCW uses PHI only as a business associate of its Providers, who are covered entities, in accordance with instructions or restrictions the Provider gives it and in full compliance with the applicable HIPAA provisions. The commitment is bounded by the Provider’s instructions and by HIPAA rather than by the policy alone.
Supporting quotations
4.1.1. This Privacy Policy supplements the Customer Documents. eCW only uses such PHI as a "business associate" of its Providers, who are "covered entities," in accordance with any instructions or restrictions provided to eCW by the Provider and in full compliance with the applicable provisions of HIPAA.
Qualifications & exceptions
Use of PHI is limited to the Provider’s instructions or restrictions and to HIPAA compliance.
eCW describes itself as a business associate and its Provider customers as covered entities.
Not stated here
The instructions and any additional restrictions are in the Customer Documents, which are not supplied.
Use & Processing · Company practice
Personal Information is used to provide Services, improve experience and target offers
The use section says eCW uses collected Personal Information to provide Services to customers and their authorized users, to improve user experience with the Services and to communicate about requested information. It adds that eCW may use Personal Information to help target specific offers to customers and others and to develop and improve the Services, that it may disclose Personal Information as described in Section 7, and that the following list of uses applies.
Supporting quotations
5.1. eCW uses the Personal Information collected to provide Services to our customers and their authorized users to improve user experience with the Services, and to communicate with you about requested information. eCW may use Personal Information to help target specific offers to customers and others and to develop and improve its Services. Additionally, eCW may disclose your Personal Information as discussed below in Section 7, and use your Personal Information to:
Qualifications & exceptions
Targeted offers are described as a possible use (“may use”).
Disclosures are governed by a separate section that this text cross-references.
Not stated here
The policy does not describe how targeted offers are selected in this section.
Use & Processing · Company practice
Information is used to provide service to Provider customers, including for their patients
eCW lists providing service to its customers, which include Providers, as a use of information, and says that where the reader is a patient of a Provider it uses the reader’s information when providing the Services to that Provider.
Supporting quotations
Provide service to our customers, which include Providers. If you are a patient of a Provider, we use your information when providing the Services to the Provider.
Qualifications & exceptions
The stated use for patient data is tied to providing Services to the Provider.
Use & Processing · Company practice
Marketing use includes inferring interest and sending promotional materials
eCW says it may use information to communicate about its products, services and related issues, to try to identify whether a reader may be interested in the Services or its business partners’ products and services, and to send information and promotional materials when it thinks something may interest the reader. Marketing e-mails carry an unsubscribe link that the reader can use to stop receiving them.
Supporting quotations
Communicate with users about our products, services, and related issues. We may use your information to try to identify if you may be interested in any of the Services or our business partners' products and services. If we think something may interest you, we may send you information and promotional materials. You may unsubscribe from receiving marketing e-mails from us by using the unsubscribe link included in marketing e-mails.
Qualifications & exceptions
Interest assessment covers both eCW offerings and business partners’ offerings.
The stated opt-out covers marketing e-mails through the unsubscribe link.
Not stated here
Whether other marketing channels, such as calls or text messages, carry the same opt-out is not stated here.
Use & Processing · Company practice
Research and analysis, including advertising-impression auditing, uses information
eCW lists conducting research and analysis, including auditing related to advertising impressions, as a use, and says it may use information subject to the reader’s consent, or otherwise in de-identified or aggregate form, as part of research studies.
Supporting quotations
Conduct research and analysis, including auditing related to advertising impressions. We may use your information, subject to your consent, or otherwise in de-identified or aggregate form as part of research studies.
Qualifications & exceptions
Identifiable use for research is conditioned on consent; otherwise the stated basis is de-identified or aggregate data.
Not stated here
What counts as de-identified or aggregate data for this purpose is not defined in this section.
Use & Processing · Company practice
Quality verification, improvement and new-Service development are stated uses
eCW also lists verifying and maintaining the quality of the Services, improving the Services and developing new Services as uses of the collected information.
Supporting quotations
Verify and maintain the quality of our Services, improve the Services, or develop new Services.
Use & Processing · User right or choice
Marketing opt-out is available, but non-marketing messages continue
Readers may opt out of receiving marketing communications by following the instructions in a communication or by contacting eCW through the Contact Information section. If they opt out, eCW may still send non-marketing communications, such as those about the account or the ongoing business relationship.
Supporting quotations
8.1. You may opt-out of receiving marketing communications from us by following the instructions included in such a communication or by contacting us as provided in the Contact Information Section 17. If you opt out, we may still send you non-marketing communications, such as those about your account or our ongoing business relationship.
Qualifications & exceptions
The opt-out is limited to marketing communications; service messages continue.
Opt-out can be exercised through the message itself or by contacting eCW.
Not stated here
Whether opt-out covers marketing through channels other than e-mail is not stated here.
Use & Processing · User right or choice
Readers may review and request changes to their Personal Information on contact
eCW says a reader may review and request changes to the Personal Information it has collected about the reader by contacting it through the Contact Information section. The mechanism is a request to eCW rather than a self-service account tool.
Supporting quotations
8.2. You may review and request changes to the Personal Information we have collected about you by contacting us as provided in the Contact Information Section 17 below.
Qualifications & exceptions
The route given is contact with eCW under Section 17.
Not stated here
The policy does not state a response time or any limits on access in this section.
Use & Processing · Permission or license
Services are for the United States, and use is treated as authorizing US processing
The Services are said to be intended for use only in the United States of America. A reader using the Services or contacting eCW from outside the United States is advised that information provided or automatically collected will be transferred to the United States, and that by using the Services or submitting information the reader explicitly authorizes that transfer and subsequent processing in the United States in accordance with the policy.
Supporting quotations
The Services are intended for use only in the United States of America. If you use the Services or contact us from outside of the United States of America, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States of America; and (ii) by using the Services or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States of America in accordance with this Privacy Policy.
Qualifications & exceptions
Authorisation for transfer is inferred from using the Services or submitting information.
The paragraph addresses only transfer into the United States, not transfers out of it.
Not stated here
Whether other safeguards apply to the transfer is not stated here.
Use & Processing · Company practice
The California notice restates the improvement, service and targeting purposes
Before its list of statutory business purposes, the notice says eCW uses CCPA/CPRA Personal Information to improve the reader’s experience with the Services, to provide the Services and to communicate about requested information, and that it may use the information to help target specific offers and to develop and improve the Services. It then introduces a list of business or commercial purposes for which the information may be used.
Supporting quotations
eCW uses the CCPA/CPRA Personal Information collected in an effort to improve your experience with the Services, to provide the Services to you and to communicate with you about information that you request. eCW may also use CCPA/CPRA Personal Information to help target specific offers to you and to help eCW develop and improve its Services. Additionally, eCW may use Your CCPA/CPRA Personal Information for one or more of the following business or commercial purposes:
Qualifications & exceptions
Targeting offers is framed as a possible use (“may also use”).
Not stated here
The notice does not say whether the list that follows is exhaustive of its purposes.
Use & Processing · Company practice
Providing service to Provider customers is a listed California business purpose
Providing service to eCW’s customers, which include Providers, is one of the listed business or commercial purposes. The entry is stated without limiting language about patient data.
Supporting quotations
Provide service to our customers, which include Providers
Use & Processing · Company practice
Marketing products, services and events is a listed California business purpose
Marketing and communicating about eCW’s products, services, events and other offerings appears as a business or commercial purpose in the list.
Supporting quotations
Market and communicate about our products, services, events, and other offerings
Use & Processing · Company practice
Vendor and partner diligence and relationship administration are listed purposes
Conducting diligence regarding eCW’s vendors and partners and administering vendor and partner relationships is listed as a business or commercial purpose. The entry extends the stated uses to due-diligence activity about business counterparties.
Supporting quotations
Conduct diligence regarding our vendors and partners and administer vendor/partner relationships
Not stated here
The notice does not say what information about vendors or partners is used.
Use & Processing · Company practice
Research and analysis is a listed California business purpose without stated conditions
Conducting research and analysis is a listed business or commercial purpose. Unlike the general use section, which conditions identifiable research use on consent or uses of de-identified or aggregate data, this entry carries no stated condition.
Supporting quotations
Conduct research and analysis
Qualifications & exceptions
The entry is stated without the consent or de-identification conditions used in the general use section.
Not stated here
Whether the general section’s conditions still apply to this entry is not stated.
Use & Processing · Company practice
Personalizing and developing offerings and maintaining service quality are listed purposes
Two further entries cover providing, supporting, personalizing and developing eCW’s products, services, events and other offerings, and undertaking activities to verify or maintain the quality or safety of a service and to improve, upgrade or enhance it.
Supporting quotations
Provide, support, personalize, and develop our products, services, events, and other offerings
Undertake activities to verify or maintain the quality or safety of a service of the business and to improve, upgrade, or enhance such services
Use & Processing · Permission or license
Purposes also include those disclosed at collection or otherwise set out in the statute
The list ends with a residual entry covering uses as described to the reader when the CCPA/CPRA Personal Information was collected, or as otherwise set forth in the CCPA/CPRA. The residual entry leaves room for purposes stated at the point of collection.
Supporting quotations
As described to you when collecting your CCPA/CPRA Personal Information or as otherwise set forth in the CCPA/CPRA
Qualifications & exceptions
The entry is open-ended by reference to point-of-collection descriptions and the statute.
Not stated here
Which point-of-collection notices eCW uses is not shown in this section.