Privacy Policy

This Privacy Policy applies to the websites operated by My Best Practice, LLC (“My Best Practice,” “MBP,” “we,” “us,” or “our”), including www.mbpractice.com, practice.mbpractice.com, affiliated subdomains, mobile applications (“Mobile Apps”), and related services (collectively, the “Service”).

This Privacy Policy describes how MBP collects, uses, discloses, retains, and protects personal information associated with our public websites, account registration, communications, customer support, and non-PHI use of the Service.

This Privacy Policy does not govern Protected Health Information (“PHI”) that registered users or their organizations (“Members”) create, receive, maintain, or submit through the Service. PHI is governed by MBP’s Terms of Service, the applicable Business Associate Agreement (“BAA”), and applicable law. If there is a conflict concerning the treatment of PHI, the applicable BAA will control.

The descriptions in this Privacy Policy are subject to MBP’s actual information practices, vendor contracts, applicable BAAs, documented procedures, and applicable law.

1. Member-Controlled Data 

MBP generally has no direct relationship with individuals whose personal information or PHI MBP processes on behalf of Members. The applicable Member controls that information.

An individual who seeks access to, correction of, amendment of, or deletion of information processed on behalf of a Member should direct that request to the applicable Member. If a Member requests that MBP remove or modify information, MBP will process the request in accordance with the Member’s instructions, applicable agreements, documented procedures, and applicable law.

MBP may retain personal information processed on behalf of Members for as long as reasonably necessary to provide the Service and as permitted or required by applicable agreements and law. MBP may also retain information as reasonably necessary to:

·         comply with legal and regulatory obligations;

·         resolve disputes;

·         prevent fraud, abuse, or security incidents;

·         maintain the security, integrity, availability, and recovery of the Service;

·         enforce agreements; and

·         maintain backups, logs, archives, and other records in accordance with documented retention procedures.

Residual copies may remain in backups, logs, archives, or other systems for a limited period after deletion from active systems. Such information will remain subject to applicable confidentiality, security, and use restrictions while retained.

2. Information Collection and Use 

Depending on how you interact with MBP and the Service, we may collect the following categories of information.

Contact Information 

Name, email address, mailing address, telephone number, and other contact information you provide.

Billing and Financial Information 

Payment details, billing address, transaction information, tax identification information, and other information necessary to process payments or administer billing. Payment information may be collected or processed by third-party payment service providers on MBP’s behalf.

Account and Authentication Information 

Username, account identifiers, login credentials, authentication information, security questions or verification information, and account preferences and settings.

Business Information 

Business or practice name, professional or organizational information, license or registration information, and other information concerning your practice or organization that you provide to MBP.

Device, Network, Usage, and Diagnostic Information 

We may collect information concerning the device, browser, network, and use of the Service, including:

·         Internet Protocol (“IP”) address;

·         browser type;

·         operating system;

·         internet service provider;

·         referring and exit pages;

·         date and time stamps;

·         pages or features used;

·         device identifiers;

·         diagnostic information;

·         security events;

·         audit events;

·         error reports; and

·         other technical or usage information.

Information Relating to AI-Enabled Features 

For optional AI-enabled features, we may collect or process non-PHI information concerning the use and configuration of those features, including whether a feature is enabled, feature and model settings, account or user identifiers, timestamps, diagnostic information, usage information, and security and audit events.

The treatment of PHI and customer content submitted to an AI-enabled feature is governed by the Terms of Service, the applicable BAA, and applicable law.

Purposes of Use 

MBP may use information for the following purposes:

·         fulfill orders and provide requested products or services;

·         send order confirmations;

·         provide requested product or service information;

·         send product updates and account communications;

·         respond to customer-service requests;

·         administer and secure accounts;

·         process payments and manage billing;

·         send newsletters and marketing communications, subject to applicable law;

·         respond to questions and concerns;

·         provide, operate, maintain, secure, support, analyze, and troubleshoot the Service;

·         detect, investigate, and prevent fraud, abuse, security incidents, and technical problems;

·         monitor and improve Service performance and reliability;

·         comply with applicable law and legal process;

·         enforce our agreements and policies; and

·         protect the rights, safety, property, and security of MBP, our users, Members, and others.

De-Identified, Aggregated, and Synthetic Information 

MBP may use properly de-identified, aggregated, or synthetic information that cannot reasonably be used to identify an individual, Member, customer, or practice.

MBP may use such information, without attempting to re-identify it, to operate, secure, analyze, test, support, troubleshoot, measure, and improve the Service and its features.

MBP will not use this provision to authorize the use or disclosure of PHI in a manner prohibited by the applicable BAA or applicable law.

Location Information 

We do not request or collect precise location information from your mobile device. We and our service providers may infer approximate location from an IP address where reasonably necessary for security, fraud prevention, telecommunications, or delivery of the Service.

3. Information Sharing 

MBP does not sell personal information.

MBP may share personal information in the ways described in this Privacy Policy and as otherwise permitted by applicable agreements and law.

Service Providers and Subprocessors 

MBP may provide personal information to service providers and subprocessors that help MBP operate and deliver the Service. These providers may include providers of:

·         hosting;

·         data storage;

·         security;

·         communications;

·         email;

·         fax;

·         payment processing;

·         customer support;

·         recording;

·         transcription;

·         analytics;

·         artificial-intelligence functionality; and

·         other infrastructure or operational services.

These providers may process personal information only as necessary to provide services to MBP and are subject to applicable contractual confidentiality, security, use, and data-protection restrictions.

When a service provider creates, receives, maintains, or transmits PHI on MBP’s behalf, that processing is governed by the applicable BAA and applicable law.

MBP may update or replace service providers and subprocessors as reasonably necessary to operate and provide the Service. MBP is not required to provide advance notice of every provider or subprocessor change unless required by applicable law or a separate written agreement.

MBP maintains an internal inventory of relevant service providers and subprocessors as part of its vendor-management and data-governance practices. This Privacy Policy does not create an obligation to publish that inventory.

AI-Enabled Features 

MBP may use service providers and subprocessors to deliver optional AI-enabled features. Depending on the feature selected, these providers may process information that an authorized user selects, submits, or makes available to the feature.

Non-PHI personal information used to operate and support AI-enabled features is handled under this Privacy Policy. PHI is handled under the Terms of Service and applicable BAA.

MBP does not use PHI or other customer content to train general-purpose artificial-intelligence models unless the applicable Member expressly authorizes that use in writing. Our subprocessors are not permitted to use that information for their own independent purposes.

De-Identified, Aggregated, and Synthetic Information 

MBP may create and use information that has been properly de-identified, aggregated, or synthetically generated so that it cannot reasonably be used to identify a person, patient, client, Member, customer, or other individual.

MBP may use such information, without attempting to re-identify it, to:

·         operate the Service;

·         maintain security;

·         detect fraud and abuse;

·         analyze usage;

·         test and troubleshoot features;

·         support customers;

·         measure performance;

·         conduct quality assurance; and

·         improve the Service.

This provision does not authorize the use or disclosure of PHI in a manner prohibited by the applicable BAA or applicable law.

Business Transactions 

If MBP is involved in a merger, acquisition, reorganization, financing, bankruptcy, sale of assets, or similar transaction, personal information may be transferred or disclosed as reasonably necessary in connection with that transaction, subject to applicable confidentiality and legal requirements.

Legal Disclosures 

MBP may disclose personal information:

·         as required by law, subpoena, court order, or other legal process;

·         when MBP reasonably believes disclosure is necessary to protect MBP’s rights, property, or safety;

·         to protect the safety of users, Members, patients, or other individuals;

·         to investigate fraud, abuse, security incidents, or unlawful activity;

·         to respond to a government request;

·         to enforce MBP’s agreements, policies, or legal rights;

·         to service providers acting on MBP’s behalf; or

·         with your consent or as otherwise permitted by applicable law.

Requests involving PHI will be handled in accordance with the Terms of Service, the applicable BAA, and applicable law.

4. User Access and Choice 

If your personal information changes, you may be able to correct or update certain information by logging into your MBP account and using the available account settings.

You may also contact MBP to request assistance with access, correction, deletion, or other privacy-related requests. MBP will respond in accordance with applicable law, applicable agreements, and the rights and instructions of the applicable Member.

Privacy requests concerning information processed on behalf of a Member may need to be directed to that Member. MBP’s ability to respond to or fulfill a request may depend on the Member’s instructions, the nature of the information, applicable law, contractual obligations, security requirements, and legitimate retention needs.

MBP may retain personal information while an account is active or as reasonably necessary to:

·         provide the Service;

·         comply with legal obligations;

·         resolve disputes;

·         prevent fraud or abuse;

·         maintain security;

·         enforce agreements;

·         support business continuity and disaster recovery; and

·         maintain backups, logs, archives, and other records.

Marketing Communications 

When you create an MBP account, MBP may use your name and email address to communicate with you about your account, including account information, service alerts, product education, and other service-related matters.

MBP may also send marketing emails, including newsletters and promotional communications from MBP or its partners, subject to applicable law. You may opt out of marketing communications by using the unsubscribe link included in the applicable email.

Opting out of marketing communications will not prevent MBP from sending administrative, transactional, security, legal, or service-related communications.

5. Tracking Technologies and Cookies 

MBP uses cookies and similar technologies on its websites and within the Service.

These technologies may be necessary to:

·         authenticate users;

·         maintain sessions;

·         remember preferences;

·         provide security;

·         operate the Service;

·         analyze usage;

·         improve performance; and

·         support website and Service functionality.

If you reject or disable cookies, portions of the Website or Service may not function properly.

Information collected through cookies and similar technologies may be associated with an account or combined with other personal information where permitted by applicable law.

Some browsers provide a “Do Not Track” setting. Because there is no consistent industry standard for responding to these signals, MBP’s websites may not respond to all such signals. MBP will process legally recognized browser-based opt-out preference signals where required by applicable law.

Analytics and Log Files 

MBP automatically collects and stores certain information in log files. This information may include:

·         IP addresses;

·         browser type;

·         internet service provider;

·         referring and exit pages;

·         operating system;

·         date and time stamps;

·         clickstream data;

·         pages and features used;

·         diagnostic information;

·         security events; and

·         audit events.

MBP may use this information to:

·         operate, secure, administer, and troubleshoot the Website and Service;

·         analyze trends and usage;

·         investigate suspicious or unauthorized activity;

·         improve performance and user experience;

·         detect and prevent fraud and abuse; and

·         comply with legal and contractual obligations.

Log and usage information may identify or be reasonably linkable to an individual, device, account, Member, or user. Where applicable, MBP will treat such information as personal information.

MBP may collect statistics concerning the behavior of visitors, Members, and users. MBP may use service providers to analyze Website and Service usage on MBP’s behalf.

Third-Party Tracking 

MBP’s service providers may use cookies, scripts, pixels, software-development kits, or similar technologies on MBP’s behalf to provide website functionality, security, analytics, communications, and other services described in this Privacy Policy.

Those providers may collect device and usage information, including IP address, browser or device type, operating system, pages or features used, timestamps, and approximate location derived from an IP address.

Their use of personal information is limited by applicable contracts and law.

If MBP uses advertising or marketing cookies on public websites, MBP will provide notices, choices, or consent mechanisms required by applicable law.

MBP does not sell personal information.

MBP does not use tracking technologies within authenticated clinical areas for third-party targeted advertising.

6. Security 

MBP uses administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, disclosure, or destruction.

MBP uses encryption in transit to protect sensitive information transmitted between supported browsers, applications, and the Service.

MBP follows generally accepted security practices appropriate to the nature of the information and the Service. However, no method of transmission over the Internet or method of electronic storage is completely secure. MBP therefore cannot guarantee absolute security.

If you have questions about security practices, contact MBP at info@mbpractice.com.

PHI is subject to the security obligations in the Terms of Service, the applicable BAA, and applicable law.

7. Additional Information 

Social Media Widgets 

The Website may include social-media features, such as “Like” buttons, sharing tools, widgets, or interactive mini-programs.

These features may collect your IP address, identify the page you are visiting, and set a cookie or similar technology to enable the feature to operate.

Social-media features may be hosted by a third party or hosted directly on the Website. Your interactions with those features are governed by the privacy policy and terms of the provider offering the feature.

Links to Other Sites 

The Website or Service may contain links to websites, applications, services, or environments that are not owned or controlled by MBP.

MBP is not responsible for the privacy practices, content, security, or policies of third-party websites or services. When you leave the Website or Service, review the applicable third party’s privacy policy and terms.

This Privacy Policy applies only to information collected by MBP through the Website and Service.

8. Changes to This Policy 

MBP may update this Privacy Policy from time to time to reflect changes in the Service, information practices, legal requirements, security practices, or business operations.

If MBP makes material changes, MBP may provide notice by email, through the Service, by posting a notice on the Website, or by other legally permitted means. The updated Privacy Policy will become effective on the date stated in the updated policy.

MBP encourages you to review this Privacy Policy periodically.

9. Contact Us 

Questions regarding this Privacy Policy may be directed to:

My Best Practice, LLC
353 Lexington Avenue, Office #317
New York, NY 10016
Email: info@mbpractice.com

Counsel Review Notice 

This Privacy Policy is intended for review and operational use by My Best Practice, LLC. It should be reviewed and approved by licensed counsel before publication and periodically thereafter to confirm consistency with MBP’s Terms of Service, Business Associate Agreements, vendor arrangements, data practices, AI-enabled features, and applicable law.