This Privacy Policy (this “Privacy Policy”) explains how The StayWell Company, LLC, and its affiliates, Krames LLC, and Mercury Healthcare Inc., dba WebMD Ignite (collectively referred to herein as “WebMD Ignite”, “us”, “our” or “we”) collect, use, share, and protect information concerning you, when you or your physicians or health care providers use our Krames on FHIR product (“KOF”), including the Patient Portal Integration for KOF. Protecting your privacy is important, and we’re committed to clearly explaining how we treat your Personal Information. Please read this Privacy -Policy carefully and be aware that by accessing and using content prescribed to you via KOF, you agree that you have read this Privacy Policy and that you accept and consent to the privacy practices described. If you have questions or concerns about this Privacy Policy, please e-mail us at privacy@webmd.com and include “Krames on FHIR” in the subject line. 

The Information We Collect and How We Collect It 

We do not collect any of your Personal Information except as set forth in this Privacy Policy. 

Information We Collect through Your Physician’s use of the KOF Product 

When you are provided educational content through our KOF product, we collect information that is provided by your healthcare provider, including (1) information that is required from a technical perspective for the system to function, such as user identifiers and account identifiers, as well as unique identifiers that are generated to track the encounter, (2) certain medical information, such as your medical record number, date of birth, name, email address, gender, condition and diagnosis list, medications list, procedures list, and your preferred language, and (3) certain information about your healthcare provider, which may include their name, user ID, and account ID. To the extent that the information we collect through your use of the KOF product is considered “protected health information” under HIPAA, or is otherwise excluded from the definition of Personal Information hereunder, we still treat it confidentially and provide it with the appropriate protections as required by law.

How We Use Your Information 

The information collected from your usage of the KOF product falls under the definition of “protected health information” under HIPAA and is therefore generally excluded from the definition of “Personal Information” in state-specific privacy laws. However, we believe it is important for you to understand how we use such information. The information that we collect from your usage of our KOF product is used to (1) provide services or products to you that have been contracted for by your healthcare provider as our client and (2) provide aggregate reporting to your healthcare provider when such reporting is a requirement under our contracted with such healthcare provider. Additionally, we may de-identify your personal information so that it no longer identifies you, and use such de-identified information for any lawful purpose, including for our own internal analysis, as well as product improvement or product development. 

Third Party Service Providers 

We may employ other companies and individuals to perform functions on our behalf, such as but not limited to, as applicable, fulfilling orders, delivering packages, sending postal mail and e-mail, serving ads on our behalf, providing search results and links, processing credit card payments and other services to support our business. These third-party service providers may have access to your information needed to perform their functions, but they may not use it for any other purpose. 

Your Rights under the Applicable Data Privacy Laws 

Applicable Data Privacy Laws provide you with specific rights regarding your information. This section describes your consumer rights and explains how to exercise those rights: 

• Your rights to view, correct, or change your personal information that are set forth in your healthcare provider’s Notice of Privacy Practices may apply to some or all of the information that we collect. Please read that notice so you know your rights and how to act on them.
• If you want to write to us to have your account deleted, or to make changes to your information, send it to the address listed in the “How to Contact Us” section below.

Location of Data Storage 

We and our technical infrastructure are located in the United States. Any information that we have about you is stored on servers located in the United States. If you are located in another jurisdiction, you should be aware that in order to provide the KOF service to you, we must transfer your personal information to the United States where it will be stored and processed in accordance with this Privacy Policy. We may transfer your information outside the United States to service providers with operations in other countries. We will take reasonable steps to protect your personal information. Note that the United States and other jurisdictions may not afford the same level of data protection as considered adequate in your own country and your personal information may be available to the United States government or its agencies under legal process made in the United States. 

Changes to this Privacy Policy 

From time to time, we may change this Privacy Policy and our privacy practices because of changes in legal or regulatory requirements, in our business practices, in our attempts to better meet your needs, or for any other reason. We reserve the right to revise this Privacy Policy in our sole discretion. When we do, we will post a revised privacy policy on this site. Any changes will be effective immediately upon posting. You are responsible for checking the privacy policy for these changes. 

How to Contact Us 

Should you have questions or concerns about this Privacy Policy or any other matter pertaining to our privacy practices, please contact us at: privacy@webmd.com and include “Krames on FHIR” in the subject line 

or 

The StayWell Company, LLC 
800 Township Line Rd, Suite 100 
Yardley, PA 19067 
Attn: Legal Department 

Copyright © 2022-2023. The StayWell Company, LLC. StayWell is a registered trademark of The StayWell Company, LLC or its affiliates. 

Changes to this Privacy Policy 

The date of any change, along with a brief description of the change, will be posted at the bottom of the Privacy Policy. 

Revised November 22, 2023 

11/22/2023: Incorporated edits to include Mercury Healthcare, Inc. dba WebMD Ignite; language inapplicable to Krames on FHIR was deleted 

11/30/2022: Added revision history; minor edits; updated data collection, data retention, and state privacy rights. Updated GDPR DPO designation to Dentons Europe.