Digital privacy policy

PLEASE READ THIS PRIVACY POLICY BEFORE USING ANY ATLANTIC HEALTH SYSTEM DIGITIAL PROPERTIES

At Atlantic Health System (“AHS”), we take your privacy seriously and we are committed to maintaining your trust. This Digital Privacy Policy (this “Policy”) explains how we collect, use, protect and share information about you when you engage with our digital properties, including Atlantichealth.org and its subdomains, the Atlantic Health MyChart patient portal, the “Atlantic Health App,” the “Atlantic Health Take Me There App,” and Atlantic Health email communications (“AHS Digital Properties”).

We encourage you to read this Policy carefully in its entirety to understand our methods and practices regarding your information and how we treat it. If you have any questions or concerns, please contact us using the “Contact Us” section below. By accessing and/or using AHS Digital Properties, you acknowledge that you have read, understand, and agree to be bound by this Policy. If you do not agree with any term of this Policy, please do not access or use AHS Digital Properties.

This Policy applies only to information that we collect through your engagement with AHS Digital Properties and does not apply to any offline data collection mechanisms. This Policy also does not apply to information collected outside of AHS Digital Properties through your engagement with affiliated or third-party web pages, mobile applications, social media sites, discussion boards or email lists. AHS Digital Properties may contain links to affiliated or third-party websites or mobile applications that are not owned, operated, licensed, or controlled by AHS. AHS is not responsible for the privacy practices or content of such other websites or mobile applications. AHS affiliated websites and third-party websites and mobile applications may be governed by their own separate privacy policies. We encourage you to read any applicable privacy statements before accessing or using affiliated or third-party websites or mobile applications.

PLEASE NOTE: AHS maintains a separate policy in connection with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) that explains how AHS uses and discloses medical information about you, which can be viewed here: <AHS Notice of Privacy Practices>  <Aviso Sobre Practicas De Privacidad > You may also request a paper copy from the AHS Privacy Officer using the “Contact Us” section below.

Types of Information We Collect

Information You Choose to Provide to Us:

Users of AHS Digital Properties (“Users”) may choose to provide personally identifiable information when engaging with AHS Digital Properties, including, but not limited to, name, email address, home address, phone number, date of birth or login credentials. Users may choose to provide this personally identifiable information on AHS Digital Properties to submit surveys, complete health risk assessments, request information about a particular service or procedure, sign up to receive emails, apply for a job, register for an event, create or activate an account, or take other optional actions. We do not share the personally identifiable information you provide on AHS Digital Properties with third-parties, unless permitted by law and as described in this Policy.

Information We Collect Automatically:

AHS may use tracking technologies to collect and analyze information about how Users interact with AHS Digital Properties. These tracking technologies may collect personally identifiable information automatically, which may be used in multiple ways, including but not limited to, analyzing and improving the utility and functionality of AHS Digital Properties to create better online experiences and for interest-based advertising purposes.

AHS Digital Properties may collect, store and share the following personally identifiable information:

  • IP address
  • User IDs and client IDs
  • Browser, operating system, and device data
  • Location data
  • Advertising click ID
  • Referring URL
  • Other unique identifiers
  • Information we receive from our third-party vendors collected on our behalf
  • Information we receive from other sources as permitted by applicable laws, rules and regulations

We do not share the personally identifiable information collected automatically on AHS Digital Properties with third-parties, unless permitted by law and as described in this Policy.

AHS Digital Properties may also collect, store and share usage data, including browsing data (e.g., web pages viewed in a browser or mobile application), click actions (e.g., buttons clicked on web pages or emails), session ID, session duration, scroll data, video plays, emails opened, and other activity that occurs on AHS Digital Properties. Additionally, AHS Digital Properties may collect, store and share data on the sources that drive traffic to AHS Digital Properties, including referral sources (e.g., links that Users click to arrive on AHS Digital Properties) and advertising engagement data (e.g., ads that Users click to arrive on AHS Digital Properties). AHS Digital Properties use third-party products and services that help AHS track and analyze visitor activity on the AHS Digital Properties, measure the effectiveness of our advertising campaigns, and support the optimization of our advertising efforts.  Usage data, referral source data and advertising engagement data that include personally identifiable information paired with health information are not shared with third-parties unless permitted by law and as described in this Policy.

Protected Health Information:

AHS Digital Properties do not use tracking technologies to share Protected Health Information (as defined by HIPAA) with third-parties that relates to the individual’s past, present, or future physical or mental health condition, their receipt of healthcare, and/or their payment for healthcare, unless permitted by law.

How Information Is Used

We do not sell or rent any data collected on AHS Digital Properties. We may disclose personally identifiable information, health information and/or Protected Health Information (as defined by HIPAA) when required by law or in the good-faith belief that such disclosure is necessary:

(1) to comply with a legal process, applicable laws, regulations and/or government requests;

(2) to enforce this Policy;

(3) to respond to claims that any material, document, image, graphic, logo, design, audio, video or other information provided by you violates the rights of a third-party;

(4) in connection with a merger, acquisition, reorganization or sale of our assets;

(5) to protect the rights, property, or personal safety of AHS, its Users or the public; and/or

(6) to detect, prevent, or otherwise address fraud, security or technical issues relating to AHS Digital Properties.

AHS may use information as follows:

  • Browser data, operating system data and device data: We may use this information to gather aggregate information about the ways Users access AHS Digital Properties to analyze and improve utility, accessibility, design, functionality and the overall digital experience of Users.
  • IP Address and location data: AHS Digital Properties may convert a User’s IP address into the longitude and latitude of the User’s location and may convert the longitude and latitude coordinates into a zip code. We may also collect location data when Users search for health care providers, facilities or services by city, state or zip code or interact with maps on AHS Digital Properties. For instance, “The Atlantic Health App” and “The Atlantic Health Take Me There App” may interact with the host device’s location-based services. We may use location information in a variety of ways, including but not limited to:

o   Calculate the volume of digital traffic that comes from various regions so that we can better understand Users’ needs and interests in different parts of our serviceable area; and/or

o   Deliver a more relevant, personalized experience by customizing content on our website, mobile applications or emails to display nearby healthcare providers, hospitals, or other facilities, use location information to provide directions, customize map views, or provide Users with information on nearby events, services or other offerings.

  • Usage data: We may use data on how Users engage with AHS Digital Properties (e.g., web pages viewed, emails opened, buttons clicked, videos played, session duration, session ID) in a variety of ways, including but not limited to:

o   Estimate the volume of digital traffic to various pages and sections of AHS Digital Properties;

o   Better understand the needs and interests of Users by analyzing which content is most frequently viewed and the actions that are most frequently taken;

o   Monitor how Users use AHS Digital Properties to improve digital experiences;

o   Identify bugs, broken links or other poor experiences; and/or

o   Collect and store information about User preferences, behaviors and areas of interest.

  • Advertising/campaign source and inbound traffic data: We may use data about the sources of traffic to AHS Digital Properties, including advertising click IDs and referral URLs, to identify sources, ad platforms, ad assets, campaigns and search activity that drive the most volume to AHS Digital Properties and the activities Users perform upon arriving at AHS Digital Properties.
  • Marketing communications: We may reach out to Users with information, updates, and details about our services, including sending marketing communications and requesting feedback on our services, when permitted by law.  In crafting certain marketing messages, we may utilize the personal data we've gathered about Users to tailor the content to Users’ needs and interests.
  • Employment opportunity information: For individuals interested in job opportunities, AHS Digital Properties may allow Users to submit job application information. We may collect information from job applicants for human resources recruitment purposes, which may be used by AHS and our affiliates.

Technologies Used to Collect Information

AHS Digital Properties use multiple tracking technologies to collect information.

  • Google Tag Manager: AHS Digital Properties use Google Tag Manager to store Google Analytics tags and other tracking technologies as described below. Data collected by tracking technologies is configured to decouple personally identifiable information from health information before sharing with third-parties, in accordance with applicable law.
  • Google Analytics: AHS Digital Properties use Google Analytics to collect aggregated statistics about User volume and usage of our web and mobile application pages. This enables us to learn about Users as a group.  Personally identifiable information is stored in a CDP (customer data platform) and decoupled from health information before sharing with Google Analytics.
  • Tracking Pixels: A tracking pixel is a snippet of code embedded on a page of a website or mobile application that collects information about Users, the sources that drove them to the digital property, and/or the way they engage with AHS Digital Properties. AHS Digital Properties do not use the Meta pixel.
  • Cookies: A cookie is a snippet of code stored in a User’s web browser that may be fired by a tracking pixel. AHS Digital Properties may use first-party cookies to store information about previous visits or engagements Users have had with AHS Digital Properties and may “recognize” or “remember” Users across multiple sessions. For example, cookies may enable us to remember your preferences, search activity, or location data to provide a better, more relevant User experience based on your previous activity. Most web browsers give Users the ability to control whether or not they accept cookies by editing the browser’s privacy settings. Please note that choosing to disable cookies may adversely impact some features and functionality on AHS Digital Properties. Additionally, some browsers have an optional setting called “Do Not Track”, which sends a signal to websites, requesting that a User’s browsing data not be tracked. AHS Digital Properties are not presently set up to respond to browser Do Not Track signals.

Data Retention & Electronic Communications

We may retain information from AHS Digital Properties for an indefinite period of time. You may request to access, update or delete your information by using the “Contact Us” section below. We will review your request in accordance with applicable law. Please note that in certain circumstances, we may not be able to completely remove your data from our systems. For example, we may retain your personal information for legitimate business purposes, compliance with healthcare provider requirements, fraud prevention, account recovery, legal obligations, or if it is stored in our data backup systems, cached, or archived pages.

You may choose to stop receiving marketing emails from AHS by using the “Unsubscribe” link at the bottom of any marketing email. Please note that certain communications are necessary for the proper functioning and use of AHS Digital Properties and you may not have the ability to opt out of those communications.

Digital Security

We have security measures in place to protect the data that we collect and retain. AHS Digital Properties are protected through various security controls and platforms and the use of modern encryption methods. Network firewalls and modern remote access and authentication methods are enabled to prevent unauthorized access to AHS systems and digital services. The environment is monitored for anomalous activities and events are escalated as appropriate to mitigate the risk of security breaches.  

While we take measures to protect User data, please note that no digital property can be absolutely protected against intentional or malicious intrusion attempts. Furthermore, AHS does not control the devices or the Internet over which you may choose to send personally identifiable information and cannot, therefore, prevent such interceptions or compromises to your information while in transit to AHS. We cannot and do not guarantee the absolute security of electronic communications or transmissions since any transmission made over the Internet by any organization or individual runs the risk of interception.

Further, we cannot guarantee the effectiveness of third-party privacy policies or security measures.

AHS Digital Properties are hosted in the United States and are governed by United States law. If you are using any AHS Digital Property from outside the United States, please be aware that your data shall be transferred and stored in the United States where our servers are located.

A Note to Parents and Legal Guardians

AHS Digital Properties are not intended for children under the age of 13, except as otherwise set forth herein. We will not knowingly collect information from Users in this age group. We take children’s privacy and safety very seriously.

We encourage parents and guardians to get involved with their children’s online usage and to provide guidance and be aware of personal information their children may be providing online.  Our patient portal is available for use by children ages 12-17. We encourage all parents and guardians to instruct their children in the safe and responsible use and disclosure of their personal information while using the Internet.

If you are under the age of 13, please ask your parent or guardian to help you use those parts of AHS Digital Properties that ask for personally identifiable information and ask your parent or guardian for permission before you send any information about yourself (e.g., your name, address, email address).

Changes to This Policy

We may update this Policy from time to time. Following any amendment of this Policy, your continued use of AHS Digital Properties, including but not limited to your disclosure of any information to us through AHS Digital Properties, will signify your consent to and acceptance of its revised terms for all previously collected information and information collected from you in the future.

Contact Us

Please contact us using the information below if you have any questions about this Policy or how your information is used, if you would like to request that we delete your information, if you believe that your personal information has been misused, or if you believe that we have not complied with this Policy or applicable privacy laws. We will respond to your questions and requests, investigate any concerns, and take appropriate steps to address any issues that are identified.

Privacy Officer
Atlantic Health System, Inc.
465 South Street, Suite 203
Morristown, NJ 07962
Phone: 973-660-3143

Last updated:  July 15, 2024