PRIVACY POLICY

The NewCrop™ Electronic Prescribing System. NewCrop’s proprietary electronic prescription offering integrates advanced communication and software technologies into the interactive storage and retrieval of information essential to providing optimal health care services. NewCrop accepts and transmits such information in the understanding that its policies and practices affect the privacy of patients and their health care providers, as well as other organizations and entities involved in such patients’ health care. Enrollment of subscribers and their authorized users takes place upon the acceptance and agreement by the appropriate authorized individuals of NewCrop’s Subscription and License Agreement, which contains terms and conditions affecting the use and protection of information concerning such individuals and their patients, including Individually Identifiable Health Information and Personally Identifiable Information (defined below).

Use of Information Generally. As provided in the Subscription and License Agreement, NewCrop may monitor, retrieve, store, modify, transmit and otherwise use any data and information submitted, stored or received by subscribers and/or their authorized users, including but not limited to Personally Identifiable Information and Individually Identifiable Health Information (defined below), as reasonably necessary or appropriate in the course of operating and making available the NewCrop™ Electronic Prescribing system and related features, functionality or other content.

Protected Health Information: any information, oral or recorded, that is created or received by a health care provider, public health authority, insurer, school, university, health care clearinghouse, etc., and the information relates to 1) a past, present, or future physical or mental health or condition of an individual; 2) providing health care to an individual; 3) to the past, present or future payment for the providing of health care to an individual.

Personally Identifiable Information: any data that could potentially identify a specific individual. Any information that can be used to distinguish one person from another and can be used for de-anonymizing anonymous data can be considered PII.

NewCrop may also disclose such data and information as necessary to comply with applicable law or legal directives. All such uses should be consistent with NewCrop’s applicable legal obligations, including those pertaining to the Health Insurance Portability and Accountability Act of 1996, Pub. L. No. 104–191, as amended, and any and all applicable regulations promulgated thereunder (collectively, “HIPAA”). Subject to the foregoing, NewCrop’s policy and legal responsibility is to use commercially reasonable efforts to protect the confidentiality of, and to assist subscribers and/or their authorized users as necessary in their efforts to comply with requirements of applicable law in regards to the use, disclosure, modification, deletion or other disposition of, such information.

Examples of Uses of Protected Health Information/Personally Identifiable Information (PHI/PII). Protected Health Information/Personally Identifiable Information (PHI/PII) may be disclosed or transmitted to third parties as necessary to implement a prescription or related transaction (such as transmitting a prescription to a pharmacy, either directly or indirectly through an intermediary, or communicating with a prescription benefit manager or health plan regarding related claims) Any Protected Health Information/Personally Identifiable Information (PHI/PII) provided to a third party for other purposes would be “de-identified” and “aggregated”, meaning that it would modified and combined with other similar information in such a way as to render it not susceptible to identification of particular individual patients or their particular health-related information.

Examples of Uses of Other Information. Personally Identifiable Information and other information not consisting of Individually Identifiable Health Information may be used, for example, to process and verify applications for authorization and enrollment, or to communicate with any professional licensing authority at any time for the purposes of confirming professional designations, credentials and license status of each authorized user, or to otherwise verify user credentials and identity both prior to enrollment and on each attempt to gain access to this website. Such data and information may also be used to contact subscribers and/or their authorized users regarding subscription renewals, account status, website usage, enrollment or other benefits and responsibilities under the terms of their enrollment and, except to the extent that subscriber or such authorized user has opted out of receiving such notices, to alert them to new developments and opportunities to receive additional products, services or other benefits from NewCrop or third parties with whom NewCrop maintains a marketing relationship. NewCrop reserves the right to develop for its internal use, and to provide its advertisers and sponsors with, de-identified aggregate information about website users and visitors, including usage patterns, user preferences and demographics, so as to facilitate the more accurate placement of advertising and other content and to develop useful new features, functionality and other content, the ownership of which de-identified aggregate information vests entirely in NewCrop upon its creation.

Correcting or Updating User Information. The NewCrop™ Electronic Prescribing system enables each subscriber’s account manager(s) and individuals designated by them to maintain directly Personally Identifiable Information, Individually Identifiable Health Information and other data and information stored by them in NewCrop’s system from time to time. NewCrop does not undertake to maintain or modify this information as stored by users, except insofar as it may modify its format or otherwise incorporate it into transmissions in the course of providing electronic prescription-related services.

Use of “Cookies”. When an individual user logs in to and is authenticated for access to the secure area of NewCrop’s website, and as the user accesses different levels of features, functionality or other content in NewCrop’s website, small scripts or “cookies” may be stored in the user’s computer to enable the user to maintain his or her access to the website and its content for the duration of the session. Such “cookies” would under normal circumstances be deleted upon conclusion of the session, although it might be possible for the user or others having access to the computer to use certain data retrieval technologies to recover such “deleted” information. In any case, NewCrop does not systematically monitor or log other “cookies” that may have been placed in the user’s computer by other websites, and NewCrop generally does not seek to retrieve or store information about other websites visited by the user, except that the identity of a website from which the user linked to NewCrop’s website may be registered as part of the session log. No cookies would be stored if the user visits the website solely to browse, view a demonstration or obtain more information about NewCrop and/or its products and services, without logging on as an enrolled subscriber or authorized user. While it is technically possible for users to disable the “cookies” feature of their web browsers, users should note that disabling “cookies” may prevent access to certain features and services in NewCrop’s website, or disable the user’s access altogether.

IP Addresses. “IP”, or internet protocol, addresses for website visitors may be recorded for purposes of technical support and connectivity requirements, but NewCrop would not generally disclose or provide such addresses to third parties other than its own consultants and service providers in connection with such support and connectivity.

Opting Out of E-Mail Communications. If a user wishes not to receive email communications from NewCrop or its licensors and suppliers related to the NewCrop™ Electronic Prescribing system, the user may submit an email to security@newcroprx.com with the word “Remove” in the subject line, whereupon NewCrop will remove that user from its email contact list as quickly as practicable.

Security and Privacy. If you suspect that NewCrop has suffered a security breach, that there has been a HIPAA violation, that PHI/PII has been improperly used, or if you have another privacy or security concern to discuss with NewCrop, please contact NewCrop at security@newcroprx.com.

Modifications to this Privacy Policy. As circumstances and needs change NewCrop reserves the right to modify its privacy and security policies and practices from time to time. Such changes may be reflected in updates to this Privacy Policy at any time, and users are encouraged to review this page frequently so as to remain informed about NewCrop’s policy as in effect from time to time.