Last Updated on 1/11/2019

At Collaborate Healthcare P.C. (“Collaborate”) we value privacy and data protection. We are devoting a lot of effort and making significant investments in order to comply with all relevant Legislations, including Regulation (EU) 2016/679 of the General Data Protection Regulation (also known as «GDPR»), which came into force on May 25, 2018 and affects the protection of all personal data we have in our possession.

This Personal Data Protection Policy (“Privacy Policy”) is an integral part of the Terms of Use. The Privacy Policy covers “Personal Information” collected by Collaborate from visitors, users, third parties at the direction of users, and user systems as well as through the operation of websites, mobile applications, and software by Collaborate and its affiliates (“Collaborate,” “we,” and “us”), including the Collaborate Health Cloud platform (collectively “CHC”). The Privacy Policy describes how Collaborate collects, uses, and discloses "Personal Information."

"Personal Information" means information that alone or when in combination with other information may be used to readily identify, contact, or locate an individual, such as: name, address, email address, phone number, social security number, and insurance-issued ID numbers. “Personal Information” also includes identifiable health information collected about an individual. We do not consider Personal Information to include information that has been anonymized so that it does not allow a third party to easily identify a specific individual.

About Collaborate

Collaborate provides patients and health service providers with the CHC to manage appointments, personal health records, communications, and other related activities. Other than information gathered through our website at, Collaborate acts as a service provider for health service providers and does not own or control the information that is submitted to us through the CHC. The information that is submitted through the CHC will be held subject to the requirements specified by our health service provider clients and applicable law, such as the General Data Protection Legislation (GDPR).

This Privacy Policy does not reflect the privacy practices of Collaborate’s health service provider clients and Collaborate is not responsible for our clients’ privacy policies or practices. Collaborate does not review, comment upon, or monitor our health service provider clients’ privacy policies or their compliance with their respective privacy policies, nor does Collaborate review our client’s instructions to determine whether they are in compliance or conflict with the terms of a client’s published privacy policy or applicable law.

Collection of personal information

We may collect information, including Personal Information, about you in the following instances:

The Collaborate Website. You may visit the websites of Collaborate without revealing any Personal Information. However, in some instances, Collaborate may require certain Personal Information, such as contact information, so we can respond to your inquiries or provide you with requested information.

The Collaborate Health Cloud platform (CHC). The CHC may collect information, including Personal Information and health information, about you in three ways: (1) from you directly, (2) from your health service provider, or (3) from a third party as directed by you or a health service provider (i.e. a Collaborator, a Caregiver or a Family Member).

Directly from Users. There are several ways you can submit data to the CHC. For example, you can:

  • Type information into the CHC (examples: registering, updating your profile, sending a message to your physician, scheduling an appointment).
  • Upload an image, a document, or any other data or
  • When you provide feedback to help Collaborate improve its operations. You should exercise care in selecting the information that you share in a survey or feedback communication. We strongly recommend against providing Collaborate any personal health or other sensitive information that could be traced to you or any other individual.

Making Payments. When you make payments through the CHC, you may need to provide financial account information, such as your credit card number, to our third-party service providers.

Customer Support. We may collect Personal Information through your communications with our customer-support team.

Cookies, Automatic Data Collection, and Related Technologies. Collaborate and our third-party partners, such as analytics service providers, may automatically receive and record certain non-Personal Information from users using cookies, web beacons, server logs and other similar tools. For example, Collaborate may collect information about how you visit and navigate through the CHC, when you click on a link or open a web page, use certain elements of the CHC, or open an email sent by Collaborate. Collaborate may use this information to provide certain functionality, improve the tools and services, and monitor the use of the tools and services. For example, we use these tools to save user preferences, preserve session settings and activity, help authenticate users, allow users to auto-fill sign-in pages of websites they frequently visit, and debug and evaluate the performance of the CHC. Our partners also may collect such information about your online activities over time and on other websites or apps. You may be able to change browser settings to block and delete cookies when you access the CHC through a web browser. However, if you do that, the CHC may not work properly.

If you give us inaccurate, incomplete or false information, we may permanently delete or suspend your account at CHC.

Use of personal information

We use Personal Information to facilitate and improve our services,as permitted by our agreements with health service providers and applicable law; and communicate with you. We may also use anonymized and aggregate information for business purpose.

Internal and Service-Related Usage. We use information, including Personal Information, for internal and service-related purposes and may provide it to third parties to allow us to facilitate the CHC. We may use and retain any data we collect to provide and improve our services.

For example, we may use Personal Information for the following purposes:

  • Maintaining and operating the CHC (this may include registering you, processing payments, or providing you with customer support).
  • Making announcements about features, terms, policies, or other aspects of the CHC.
  • Responding to questions and communications, which we retain in the ordinary course of business and
  • Protecting the CHC, the information it protects, the rights of third parties and in response to legal process (more fully discussed below).

Consents and Authorizations. Collaborate may request your consent or authorization in connection with the use or sharing of Personal Information about you. In some instances, this will be because this Privacy Policy or applicable law or regulations require us to obtain such consent. In other instances, such consent will be for informational purposes. Any request to obtain your consent does not narrow the scope of this Privacy Policy. By using the CHC, you accept and agree to Collaborate’s information handling practices in the manner described.

Surveys and Ratings. The content of feedback you provide to Collaborate is presumed public. Collaborate will let you know in advance how it will use survey or rating feedback in any such request for such information.

Protect the CHC and data it stores. We may send email or SMS to the contact details you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance. We may also send you marketing emails if you request more information about our products and services. Emails and/or SMS are often transactional or relationship messages, such as appointment requests, reminders and cancellations and other notifications. Collaborate may not offer you the option of opting out of receiving some of these messages although Collaborate may allow you to modify how often you receive such messages. If you opt-in to receiving marketing announcements from Collaborate, we will allow you to opt-out of receiving those announcements.If you wish to opt-out from all email communications then you will have to end this Agreement and delete your account at the CHC.

Anonymized and Aggregate Data. We may anonymize and aggregate any data collected through the CHC, and use it for business purposes. For example, we may use such data for evaluating and profiling the performance of the CHC, including analyzing usage trends and patterns and measuring the effectiveness of content, features, or services.

Information sharing and disclosure

Access to your personal data is only available to those who need access, with the sole purpose of serving you.

We may share your information:

  • With our third-party vendors and service providers.
  • With your health service provider.
  • With collaborator’s at the direction of your health service provider, with others at your direction.
  • To comply with legal obligations.
  • To protect and defend our rights and property and
  • With your permission.

We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of the CHC. When protected health information is shared, such vendors and service providers will be bound by appropriate confidentiality and security obligations which include business associate contract obligations as required by the GDPR.

Displaying or Disclosing your personal information, including your personal health information, to Health Service Providers and Others. The content you provide to the CHC may be displayed on the CHC or disclosed to others at yours or your health service provider’s direction. Your health service provider (including his or her staff) will have access to your account information, including your Personal Information. However, your health service provider will not have access to any payment information, such as your credit card number, through the CHC. Your provider may: (i) receive and store your account information; (ii) restrict your ability to submit, delete or edit information; (iii) suspend or terminate your account access or (iv) access or retain any information you provide or otherwise store as part of your account for any purposes required or permitted under applicable law. When you contact or schedule an appointment with a health service provider, the provider will need your name, contact information, as well as other information. You may also be permitted to share the content of your health records with others (Family Member). We are not responsible for the privacy practices of the others who will view and use the information you disclose to others. Collaborate does not control your physician’s use of the health information contained in the CHC. Your physician should provide you with his or her policy regarding their use of information in the CHC. You and your physician control access to health information in the CHC. You and your physician may access your health information in the CHC through use of passwords on this Site. You should be careful on who you allow to use your password, as anyone with access to your password may access your health information. You should safeguard your password, and change your password frequently. Collaborate does not control the distribution of your password. If you believe that someone has usurped your password, please contact us at

Your physician is able to provide access to your health information in the CHC to other physicians or persons with whom he or she would like to obtain or share information for purposes of treating you (Collaborators). In such cases, to the degree that is feasible, Collaborate will make efforts to anonymize your information so that it does not allow the Collaborator to easily identify your identity. If you would like to restrict the persons with whom your physician communicates about you, you should communicate your concerns to your physician directly.

Collaborate makes no guarantees regarding the currency, accuracy or completeness of your health information in the CHC, and is not responsible for typographical errors therein, or inaccuracies or other errors and/or omissions contained in it.

For purposes of running and operating this portal, Collaborate may log the number of times you or others access your health information in the CHC, and may retain such information for diagnostic and analytical purposes, and for as long as we desire.

Marketing. We do not rent, sell, or share Personal Information about you with other people or companies for their direct marketing purposes, unless we have your permission. We may allow third parties to advertise their products and services on the CHC.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose collected information, if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; or protect your, our, or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.

With Your Permission. We may also disclose your Personal Information with your permission.

Information retention

Collaborate’s collection, use, and disclosure of information are generally governed by service agreements with our health service provider clients. Information maintained to provide these services to our business clients is retained only for as long as we have a valid business purpose and in accordance with applicable law. Collaborate may retain archived information for a period of five years (or longer if required by law) as necessary to comply with legal obligations, resolve disputes and enforce our agreements and other authorized uses under this Privacy Policy.

Account Deactivation. If you desire to deactivate your account please have your provider contact us. Upon receiving such a request, Collaborate will deactivate your account and archive or delete your Personal Information in accordance with this Privacy Policy, including any health information.

Limits to Your Requests for Access, Amendment, or Deletion. You may not be able to access, update, or delete information that you share with another user or other party through the CHC. Others may also submit personal information that identifies you (for example, when submitting medical family history). You will also not be able to access, update, or delete that information. Certain users, such as health service providers, may be required under applicable laws to retain information about patients for extended periods of time. Collaborate will continue to retain such information on their behalf.
Collaborate indefinitely stores non-personal information, as well as any feedback you provide us.

Access / Correction
In most cases, Collaborate obtains Personal Information on behalf of a health service provider. To request access to, correction, amendment, or deletion of this Personal Information, a patient or user should make the change using the CHC or contact the health service provider to which the data was provided. For other inquiries, please contact us at


The security of your data is extremely important to us. We use technical and organizational measures such as encryption and anonymization to ensure that the security of your personal data meets the highest standards. Nevertheless, no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we take steps to ensure security on our systems. Please note this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such safeguards.

Collaborate provides its services to health service providers, and when we process personal health information on behalf of such health service providers, we are acting as a “business associate” to them. Therefore, Collaborate must adopt and maintain appropriate physical, technical, administrative, and organizational procedures to safeguard and secure the protected health information we process. We also may not access, use, or disclose the protected health information except as permitted by health service provider clients, you, and/or applicable law. Collaborate strives to protect the privacy of the Personal Information it processes, and to avoid inadvertent disclosure.

If Collaborate learns of a security system’s breach, Collaborate maintains an incident response policy that includes notifications consistent with applicable law.

By using the CHC or providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the CHC.


The CHC is intended for use in the European Union only. By using the CHC, you will transfer data to the European Union. Access to the CHC is administered in the European Union and is intended solely for users within the European Union.

If you are visiting from the United States or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the European Union and processing globally. By providing your information you consent to any transfer and processing in accordance with this Privacy Policy.

Persons under the age of 18

The CHC is not intended for or designed to attract persons under the age of 18. Collaborate does not knowingly collect personal information directly from minors or children. If your child has provided us with personal information without your consent, please contact Collaborate immediately.

Without limiting the above, the CHC does allow persons above the age of 18 years—such as health service providers, parents and caregivers - to provide, share and store personal information about others, including minors and children. Any user providing, storing or submitting information on behalf of a child assumes full responsibility over the submission, use, and transmission of such information.

Changes and updates to the Privacy Policy

We may revise this Privacy Policy, so review it periodically.

Posting of Revised Privacy Policy. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted. If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

New Uses of Personal Information. From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

What are your rights in relation to your personal data?

  • You have the right to information and access, to know which data we process, why and by whom.
  • The right of rectification if for some reason your data is not valid or incorrect.
  • The right to restrict processing, as the case may be, to specify what data you want to be processed and which ones you want to restrict.
  • The right of deletion, that is the right to erasure from our database in some cases, especially if there is no need for us to have your data.
  • The right of portability, to give you the data we have processed to transfer it to another partner or other company.
  • The right of objection. If applicable, you are entitled to oppose the processing of your data. However, since some of these data are necessary for your health care provider to provide you with health care related services, the objection may lead to the termination of your relationship with us or your health care provider.
  • The right to automated individual decision-making, since you have the right not to be subject to decisions taken solely on the basis of automated processing, including profiling.
  • The right to withdraw the consent you have given us for the use of your data for commercial purposes.

In order to exercise any of your above mentioned rights, you must send us your request by email at We will evaluate your request within thirty (30) days. If there are objective reasons that do not allow us to meet your request, we will inform you. You can exercise these rights at no cost. If they are often reiterated, we have the right to ask you to pay a management fee of up to €25. In order to verify your identity and process your request we may ask for identification documents .

How can you complain about how your personal data is processed?

If you disagree with the way we have processed your personal data, you can email the Data Protection Officer at Alternatively, contact us through our contact details available at www.collaborate247/contact.

You can also contact the Personal Data Protection Authority, which is available at .

Contacting Collaborate

If you have any questions, comments, or concerns about Collaborate or this Privacy Policy, please email us at

You can also contact the Personal Data Protection Authority, which is available at .

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