Last Updated: January 13, 2020
RCMtoGO’s Statement: People have the freedom to choose how their digital content is shared.
- Who we are, our Services and our Website
- Hosting and Cloud Services
- What information do we collect when you use or visit our website?
- Domain Registration Services
- How do we use the information we collect about you?
- Our legal basis for processing personal information
- With whom do we share your information?
- Your data protection rights
- Your Choices
- Security: how we keep your information secure?
- Processing in the United States
- Data retention and deletion
- Third-party websites
- Questions and complaints
If you have questions about our practices or any of your rights described below, you may contact us at firstname.lastname@example.org. This inbox is actively monitored and managed so that we can deliver an experience you can trust.
1. Who we are, our Services and our Website
1.1 RCMtoGO, LLC offers a variety of services to Clients (“you”) which range from practice management hosting and reporting services, revenue cycle management services, and server hosting solutions, among others.
1.2 The services offered by RCMtoGO are collectively referred to as the Services in this Notice.
1.3 We also have a website (the “Website”) where website visitors, prospective customers and potential job applicants can find out more about us and our Services.
2. Hosting and Cloud Services
This section explains our privacy practices in relation to the data we collect when we provide Hosting and Cloud Services to you.
In this section, “Client” refers to businesses to which we provide the Hosting and Cloud Services.
2.1 What information do we collect when we provide Hosting and Cloud Services?
2.1.1 When Clients use our Hosting and Cloud Services, they provide us with third party data. We only collect this data in accordance with our Client’s instructions. This means that our Clients are in control of the data they upload to our platforms.
2.1.2 We enter into agreements with our Clients that set out our legal obligations in relation to that data, and explain that we may only use such data to provide the Services to our Client (i.e. to provide Hosting Services, Cloud Services or the Domain Registration Services). In many legal jurisdictions, particularly those within the European Economic Area (“EEA”), RCMtoGO is a “data processor” in relation to such Client data. Each of our Clients would be a “data controller”. As a controller, each RCMtoGO Client is responsible for complying with the requirements for controllers under the General Data Protection Regulation (“GDPR”) which requires notice, disclosure and specific legal bases for transferring data to RCMtoGO and using the Hosting and Cloud Services. As a processor, RCMtoGO has some – but not all – of those responsibilities.
2.1.3 If you would like more information about the data collected by a particular Client and, in turn, transferred to RCMtoGO, please refer to that Client’s privacy notice which would typically be located on their website.
2.2 Information that you provide
2.2.1 The personal information we collect from you when we provide you with Services will depend on the type of service or support you require.
2.2.2 Some personal information is collected directly from you when you:
(a) create an account or purchase any of our Services (for example, billing information, contact information, credit card number and in certain circumstances, government identification);
(b) request assistance from our technical support team (for example, your phone number or email address);
(c) log in to your account, such as your log-in credentials (for example, your username and password);
(d) complete contact forms or request newsletters or other information from us (for example, your email address); or
(e) participate in surveys or contests or participate in activities we promote which might require information from you.
2.2.3 We will also collect and process other data that might be less obvious to you. For example, account-related information is collected in association with your use of the Services (like the types of services you have used, your payment history, the amount of your payments, your domain name, information about when products renew or expire, customer service requests, information requests, etc.).
2.2.4 Some of this data may be personal data. We may use this information to contact you from time to time about our products, promotions and other services that relate to your account. You can manage and choose the information you want to receive. Please see Section 11 for more information.
2.2.5 Most of the personal information that we collect is necessary to keep all of our Services functional and accessible by you. If we’re asking for personal information beyond this scope, we’ll make sure to clearly let you know why we need it (and what the effects of not providing it may be).
2.3 Information we collect automatically
2.3.1 When you use our Hosting Services, we may collect certain information automatically from your device. This may include information like your IP address, your device type, any unique device identification numbers, browser types, information about your broad geographic location (for example, country or city level location) and other technical information that may identify you.
2.3.2 By way of example, data about usage of services is automatically collected when you use and interact with our Services, including metadata, log files and cookie/device IDs. This information includes specific data about your interactions with the features, content and links (including those of third parties, such as social media plugins) contained within the Services as well as the information listed in the previous paragraph.
2.4 Information we collect from third party sources
2.4.1 In our capacity as a data controller, we may collect information from third parties. This may include information from partners in order to maintain functionality of your Services (such as domain name registrations and third-party email suites). We may combine this data with information we already have so that we can properly update, analyze, and expand our Services. This information will only be used for the specific reason for which it was provided to us.
3. What information do we collect when you use or visit our website?
3.1.1 Information you provide
RCMtoGO receives and stores information you provide to us though your use of the Website.
Additionally, we gather certain information automatically and store it in log files. This information may include IP addresses, browser type, internet service provider, referring / exit pages, operating system, date / time stamp and / or clickstream data.
We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics or site functionality.
Our Website contains social media features such as the Facebook button and other widgets that operate on our Website. These features may collect information such as your IP address and the pages you are visiting on our site and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Website. Your interactions with these features are governed by the privacy statement of the company providing the applicable feature.
We use the following types of cookies:
Persistent Cookies: We use persistent Cookies to improve your experience of using the site. This includes recording your “Accept Cookies” consent which first appears when you use the site.
Session Cookies: Session Cookies are temporary and deleted from your machine when your web browser closes. These Cookies help us to rack Domain Registration Services (Section 4).
Third Party Cookies: Third party cookies from YouTube, Google, and other similar services may be in use on the site, depending on whether videos are currently embedded in content, etc.
4. Domain Registration Services
4.1 We will share your information (such as WHOIS info) to the extent necessary to comply with ICANN or any other regulations and policies when you register a domain name with us.
General Data Processing Information in Connection with our Services and the Website
5. How do we use the information we collect about you?
5.1 To the extent that we are a data controller, we use the information collected through your use of our Services for the following purposes:
(a) to improve and optimize the operation and performance of our Services to you, and for the Website;
(b) to carry out obligations arising under agreements entered into between you and RCMtoGO;
(c) to diagnose problems and identify security risks, errors or needed enhancements to the Services;
(d) for research regarding the effectiveness of our Services, the Website and related marketing, advertising and sales efforts;
(e) to respond to your support requests, and to communicate with you though email, via the website and telephone calls or automated phone calls or text messages;
(f) to provide you with information about our products and services; and
(g) to investigate, prevent or act regarding illegal activities, suspected fraud or otherwise as required by law.
5.2 Often, much of the data is aggregated or statistical data about how people use our Services or Website and is not linked to any personal data. To the extent that this data is itself personal data, or is linked to personal data, we treat it accordingly.
6. Our legal basis for processing personal information
6.1 Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
6.2 If we ask you to provide personal information to comply with a legal requirement or to perform our contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information while relying on our legitimate interests (or those of a third party), we will make clear to you at the relevant time what those legitimate interests are.
7. With whom do we share your information?
7.1 With the exception of trusted business affiliates and/or associates who work on behalf of or in connection with us, we will not provide to or sell to any third party your personal information and will keep all such data confidential. For example, we share information with third parties where the functionality and maintenance of our Services depends on it (such as sharing data with domain registries in order to maintain your Services or domain registrations).
Third parties and trusted affiliates or associates
7.2 We may contract with third parties to assist us in optimizing our Services, including assistance related to the authorization and processing of payments, fulfilment of service requests, and requests for assistance.
7.3 We may utilize third-party platforms to provide web-based and email-based advertisements for our Services after you have visited and left our Website.
7.4 We also use web analytics services to improve the usability of our customer experience. These services may record anonymous data such as mouse clicks, movement, and scrolling activity, but we’ll never use them to collect personal data from you. We only use this data internally to help us understand and enhance your RCMtoGO experience.
7.5 RCMtoGO’s primary business operations are all located in Nevada in the United States and we are subject to the laws and regulations in that jurisdiction. We may be called upon by various law enforcement agencies to comply with ongoing investigations. Compliance may include the secure handover of Client data to a legally authorized government agency.
7.6 Outside the United States, RCMtoGO may also be required to disclose personal information to other law enforcement bodies, regulatory, government agency, court or other third party in compliance with applicable laws or regulation to which RCMtoGO may be subject.
7.7 We will only disclose this information where we believe disclosure is necessary (i) as a matter if applicable law or regulation (ii) to exercise or defend our legal rights or (iii) to protect your vital interests or those of any other person.
8. Your data protection rights
8.1 Depending on your jurisdiction of residence, you may have the data protection right to access, correct, update, or to request deletion of your personal information.
8.2 If you are a resident of the EEA you also have the following data protection rights:
- you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
- if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- you have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EU are available here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
RCMtoGO does not, and does not intend to, sell personal information as “selling” is defined under the California Consumer Protection Act (“CCPA”).
California residents who wish to submit requests for information pursuant to Sections 1798.110 and 1798.115 of the CCPA may do so by emailing email@example.com.
9. Your Choices
9.1 Contact information: RCMtoGO customers with established accounts may review and alter the contact information associated with their RCMtoGO account(s) by contacting their Account Manager.
9.2 Web-based advertisements: RCMtoGO and its advertising partners comply with “opt out” signals provided either by a user’s web browser automatically, by a user manually opting-out of web-based advertisements at http://www.networkadvertising.org/choices/.
9.3 Email marketing: To unsubscribe from promotional marketing emails you can click the unsubscribe link in a promotional email.
9.4 Cookies and other tracking technologies:
For information on how to manage cookie settings click on the links below:
10. Security: how we keep your information secure?
We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include reducing log retention where possible to the minimum level required to enable our systems administration and security staff to ensure services are running smoothly.
11. Processing in the United States
12. Data retention and deletion
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements, to enforce our agreements or comply with our legal obligations). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing, until deletion is possible.
13. Third-party websites
15. Questions and complaints