QTC Commercial Services, LLC. PRIVACY POLICY

Last Updated: 01/31/2024

This Privacy Notice explains how QTC Commercial Services, LLC. (“QTC Commercial Services, LLC.”, “we”, “us” or “our”) collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with our website and other websites we own and operate that link to this Privacy Notice (the “Sites”), and our services (collectively, the “Services”).

QTC Commercial Services, LLC. may provide services to companies such as insurance carriers, third-party administrators, employers, and public and federal entities (“QTC Commercial Services, LLC. Customers”). In the course of providing these services, we collect personal information about the individuals our customers refer to QTC Commercial Services, LLC.. We process any personal information received from our customers or created in the course of providing services to our customers in accordance with any restrictions set forth in our contracts with them. We recommend referring to the QTC Commercial Services, LLC. Customer’s privacy notice, including their Notice of Privacy Practices (as applicable), for information on how they engage service providers, like us, to collect and process Customer Data on their behalf.

I. WHAT IS PERSONAL INFORMATION?

When we use the term “personal information” in this Privacy Notice, we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or any other data or information that constitutes “personal data”, “personal information,” or “personally identifiable information” under applicable law.

II. OUR COLLECTION AND USE OF PERSONAL INFORMATION

We collect personal information in a variety of ways. For example, you may provide us your personal information when you apply to be and/or become a medical provider and use our Services, submit a referral, send us messages, subscribe to our mailing lists, newsletters, or other forms of marketing communications, or use some other feature of our Service.

We may link or combine your activities and information collected from you on our websites with information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below). This allows us to provide you with a personalized experience regardless of how you interact with us.

Personal Information Collected from You

We may collect the following categories of personal information in connection with providing the Services and operating our business:

  • Medical Provider Information. If you apply to join the QTC Commercial Services, LLC. network as a medical provider, we may collect your first and last name, phone number, state of licensure, medical license number, specialty, referral information, current practice setting, whether you are board certified, and information regarding how you learned about QTC Commercial Services, LLC.. We use this information to process your application, fulfill your request, to communicate with you directly, and to determine whether you are eligible to join our network. Once you join our medical provider network, we will also collect your provider portal username and password. As part of our medical provider network, we will collect information about the services you provide, the location of your offices, your specialty, and other information that is necessary to conducting a business relationship with you.
  • Inquiry and Communications Information, including information provided in custom messages sent through an online form, to one of our email addresses, or via phone. This also includes contact information provided on our Services. We use this information to investigate and respond to your inquiries, and to communicate with you.
  • Newsletter and Marketing Communications We use the contact information you provide to us to manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
  • Events and Programming If you fill out any forms or participate in QTC Commercial Services, LLC. events or programming, we may collect your contact information (such as your name, email, and phone number, postal code) and any other information requested as part of the event or programming, including photos/videos (each, as applicable). If you are part of our event or programming partner, we may also collect your personal information including your name, company email, and company address.
  • Business Representative Contact Information.If you are a business representative, we collect your information in connection with the performance of our services and business development efforts. This information may include your first name, last name, company contact information (e.g., email, phone, address), job title, and any other information related to the performance of the agreement with us.
  • Employment Application Information,including your contact and demographic information, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.

Personal Information Collected from You

We also obtain personal information from third parties, which we often combine with personal information we collect either automatically or directly from an individual.

We may receive the same categories of personal information as described above from the following third parties:

  • QTC Commercial Services, LLC. Entities: We may receive personal information from other companies and brands owned or controlled by QTC Commercial Services, LLC.., and other companies that own or are under common ownership as QTC Commercial Services, LLC..
  • Social Media: When an individual interacts with our Services through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Facebook, LinkedIn, Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
  • Service Providers:Our service providers that perform services solely on our behalf, including the medical providers who perform examinations on our behalf, collect personal information and often share some or all of this information with us. This information may include contact information, demographic information, health information, payment information, information about your communications and related activities, and information about your orders or referrals. We may use this information to administer and facilitate our services, your orders, and our marketing activities.
  • Customers: We may receive your information from our customers in connection with providing our services to them. This information may include health information and other necessary information to provide the requested services.
  • Other Sources: We may also collect Personal Information from publicly available sources, third-party data providers, and others, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

Additional Uses of Personal Information

We may use personal information we collect to:

  • Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations or to deliver the Services you have requested;
  • Verify your identity and entitlement to Services when you contact us or access our Services;
  • For marketing and advertising purposes, including to market to you or offer you information and updates on products or services we think that you may be interested in;
  • Communicate with individuals, including via mail, email, social media, and phone calls;
  • Administer, improve, and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services;
  • Facilitate customer support services;
  • Identify and analyze how individuals use our Services;
  • Test, enhance, update, and monitor the Services, or diagnose or fix technology problems;
  • Help maintain the safety, security and integrity of our property and Services, technology assets and business;
  • To enforce our Terms of Service , to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
  • Prevent, investigate, or provide notice of fraud or unlawful or criminal activity;
  • Comply with contractual and legal obligations and requirements; and
  • For any other lawful purpose, or other purpose that you consent to.

Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.

III. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES TO COLLECT INFORMATION

We, and our third-party partners, may automatically collect information you provide to us and information about how you access and use the Services when you visit our services, read our emails, or otherwise engage with us. We may collect this information through a variety of tracking technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, , location-identifying technologies and logging technologies (collectively, “tracking technologies”) and we may use third-party partners or technologies to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.

We, and our third-party partners, use tracking technologies to automatically collect usage and device information, such as:

  • Information the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an AdID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
  • Information about the way you access and use our services,
  • Information about how you use the Service, such as the pages you visit, the links you click, the ads you view and click on, videos you watch, and other similar actions.
  • Information about your location, such as general geographic location that we or our third-party providers may derive from your IP address.
  • Analytics information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the services and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its opt-out options at https://tools.google.com/dlpage/gaoptout

All the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Sites and Services, and to improve the effectiveness of our Services, offers, advertising, communications and customer service. We may also use this information, the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our services.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the services, as some features and services may not work properly. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

IV. OUR DISCLOSURE OF PERSONAL INFORMATION

We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:

  • QTC Commercial Services, LLC. Entities: We may share personal information with other companies owned or controlled by QTC Commercial Services, LLC., and other companies that own or have common ownership as QTC Commercial Services, LLC., which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any company that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
  • Marketing Providers: We may coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
  • Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, legal advisors, IT services, analytics services, employment application-related services, payment processing services, and administrative services.
  • Other Users of the Service: Through the Services, our customers have the ability to look up medical providers and see the medical provider’s name, location, and specialty.
  • Customers: We share personal data with our customers in connection with the provision of our Services. Our customers use your information for their own business and commercial purposes.
  • Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
  • Legal Obligations and Rights:We may disclose personal information to third parties, such as law enforcement:
    • in connection with the establishment, exercise, or defense of legal claims;
    • to comply with laws or to respond to lawful requests and legal process;
    • to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
    • to detect, suppress, or prevent fraud;
    • to protect the health and safety of us and others; or
    • as otherwise required by applicable law.
  • With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or service-related publications.

V. CONTROL OVER YOUR INFORMATION

You may control your information in the following ways:

  • Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
  • Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at referrals@1strehab.com. We may not be able to modify or delete your information in all circumstances.

VI. DATA RETENTION

We will usually store the personal information we collect about you for no longer than necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests, contractual obligations, and applicable law. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations

Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store the personal information and isolate it from further processing until deletion or deidentification is possible.

VII. CHILDREN’S PERSONAL INFORMATION

Our Sites are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16 through our Sites. If an individual is under the age of 16, they should not use our Sites or otherwise provide us with any personal information through our Sites. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect through our Sites has been provided by a child under the age of 16, we will promptly delete that personal information. Although our Services are not directed to children under the age of 16, it is possible that our customers may request that we perform an examination of a child under the age of 16. If we have performed an examination of your child at the direction of our customer, we encourage you to contact your insurance provider or employer to exercise your rights with respect to your child’s personal information.

VIII. LINKS TO THIRD-PARTY WEBSITES OR SERVICES

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

IX. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

X. CONTACT US

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to referrals@1strehab.com.

XI. ADDITIONAL CALIFONRIA PRIVACY DISCLOSURES

These Additional California Privacy Disclosures (“California Disclosures”) supplement the information contained in our Privacy Notice by providing additional information about our personal data processing practices relating to individual residents of California. For a detailed description of how we collect, use, disclose, and otherwise process personal data in connection with our services, please visit our Privacy Notice. Unless otherwise expressly stated, all terms defined in our Privacy Notice retain the same meaning in these California Disclosures.

For the purposes of these California Disclosures, personal information does not include publicly available information or deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you. Additionally, these California Disclosures do not describe our practices when we process Customer Data as a “service provider” in accordance with our contractual agreements with our customers.

Collection and Use of Personal Information

We collect personal information from and about consumers for a variety of purposes. We collect this information from a variety of sources, including directly from you, from your employer or organization, from our customers, from our service providers and affiliates, from your browser or device when you use our Services, or from third parties that you permit to share information with us. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to the Our Collection and Use of Personal Information sections of our Privacy Notice.

In the last 12 months, we have collected the following categories of personal information:

  • Identifiers, such as your name and email address;
  • California Customer Records (Cal. Civ. Code § 1798.80(e)), such as your phone number;
  • Commercial Information such as products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Internet/Network Information,
  • Geolocation Data, such as your approximate location based upon your IP address;
  • Call Recording Information, such as call recordings when you contact customer service (in accordance with applicable law);
  • Professional/Employment Information, such as licensure information;
  • Other Personal Information,including information you submit into the feedback forms and any communications between you and QTC Commercial Services, LLC.; and
  • Inferences, such as information generated from your use of the Services reflecting predictions about your interests and preferences

Disclosure of Personal Information

In the last 12 months, we may have disclosed all of the categories of information we collect with third parties for a business purpose, as described in the Our Disclosure of Personal Information section of the Privacy Notice. The categories of third parties to whom we sell or disclose your personal information for a business purpose include:

  • Service providers and advisors that perform services for us, on our behalf, which may include providing marketing and advertising services, providing mailing or email services, tax and accounting services, data enhancement services, fraud prevention, web hosting, or similar services;
  • Select strategic partners who use this information to perform analytics and conduct research, or for other purposes;
  • Analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our Service;
  • We may also disclose personal information to other third parties at your direction or upon your request, or to comply with legal process or contractual obligations, as described in our Privacy Notice.

Sales and Sharing for Targeted Advertising

Unless you have exercised your right to opt-out, we may disclose or “sell” your personal information to third parties for monetary or other valuable consideration, or “share” your personal information to third parties for cross-context behavioral advertising purposes. The third parties to whom we sell or share personal information may use such information for their own purposes in accordance with their own privacy policies.

We have sold or shared the following categories of personal data for the purposes described in our Privacy Notice, subject to your settings and preferences and your Right to Opt-Out: Contact Information, Commercial Information, and Network Activity.

The categories of third parties to whom we may sell or share the personal data include:

  • Business and Marketing Partners (if applicable)

We may also disclose personal data for the purposes described in the Our Disclosure of Personal Information section of our Privacy Notice.

Sensitive Information

The following personal data elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”):

  • User log in and password;
  • Personal data revealing racial or ethnic origin, mental or physical health diagnosis, sex life, or sexual orientation;

We use this sensitive information for the purposes set forth in the Our Collection and Use of Personal Information section of our Privacy Notice.

We do not sell sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising.

Your Privacy Choices

In accordance with applicable privacy law, and depending upon the jurisdiction in which you reside, you may have some or all of the following rights in respect of your personal information:

  • Right of access. You may have the right to obtain:
    • confirmation of whether, and how, we are processing your personal information;
    • information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
    • information about the categories of recipients with whom we may share your personal information; and
    • a copy of the personal information we hold about you.
  • Right to correction. You may have the right to obtain rectification or correction of any inaccurate or incomplete personal information we hold about you.
  • Right to deletion. You may have the right, in some circumstances, to require us to delete your personal information.
  • Right to opt-out. You may have the right to opt-out of certain processing activities. For example, you may have the right to opt-out of the use of your personal information for targeted advertising purposes, or to “sell” or “share” your personal information with third parties in certain contexts.
  • Right to appeal. In the event that we decline to take action on a request exercising one of your rights set forth above, you have the right to appeal our decision.
  • Right of no retaliation. You have a right against retaliatory treatment should you choose to exercise any of the above rights.

How to Exercise Your Privacy Rights

To submit a request to exercise one of the privacy rights identified above, please submit a request by:

  • Emailing referrals@1strehab.com with the subject line “Individual Rights Request Form,”
  • Completing our Individual Rights Request Form; or
  • Calling 1-888-914-9661. When prompted, you will need to enter the following PIN: 002876. Please leave a message with your name, relationship to QTC Commercial Services, LLC., the right you wish to exercise, and your email address and phone number.

We may need to verify your identity before processing your request, which may require us to request additional personal information from you. We will only use personal information provided in connection with a consumer rights request to review and comply with the request.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

If your request pertains to personal information we process as a service provider to our customers, we will direct you to submit your request to the customer on whose behalf we process your personal information.

Exercise Your Right to Opt-Out of Personal Information Sales or Sharing for Targeted Advertising

Unless you have exercised your right to opt-out, we may disclose or “sell” your personal information to third parties for monetary or other valuable consideration, or “share” your personal information to third parties for cross-context behavioral advertising purposes. The third parties to whom we sell or share personal information may use such information for their own purposes in accordance with their own privacy policies.

You do not need to create an account with us to exercise your right to opt-out. However, we may ask you to provide additional personal information so that we can properly identify you to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

To exercise the right to opt-out, you may submit a request by clicking the links below:

  • Cookies-based Opt-Out (Do Not Sell or Share My Personal Information). To exercise your right to opt-out as it relates to the use of cookies and other tracking technologies for analytics and targeted ads, please fill out our Individual Rights Request Form.
  • Opt-Out of “Selling” of Personal Information. In limited circumstances we may share your personal information (such as your name, e-mail address, postal address, and phone number) with third parties who may use such information for their own commercial or business purposes (including their own direct marketing purposes). To opt out of such sharing, please fill out our Individual Rights Request Form.