Notice of Privacy Practices
Effective Jan 24, 2022
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
We* are required by law to protect the privacy of your health information. We are also required to provide you this notice, which explains how we may use information about you and when we can give out or “disclose” that information to others. You also have rights regarding your health information that are described in this notice. We are required by law to abide by the terms of this notice.
The terms “information” or “health information” in this notice include any information we maintain that reasonably can be used to identify you and that relates to your physical or mental health condition, the provision of health care to you, or the payment for such health care. We will comply with the requirements of applicable privacy laws related to notifying you in the event of a breach of your health information.
We have the right to change our privacy practices and the terms of this notice. If we make a material change to our privacy practices, and if we maintain a website, we will post a copy of the revised notice on our website www.firsthandcares.com. If we maintain a physical delivery site, we will also post a copy in our office. The notice will also be available upon request. We reserve the right to make any revised or changed notice effective for information we already have and for information that we receive in the future.
How We Use or Disclose Information
We must use and disclose your health information to provide that information:
To you or someone who has the legal right to act for you (your personal representative) in order to administer your rights as described in this notice; and
To the Secretary of the Department of Health and Human Services, if necessary, to make sure your privacy is protected.
We have the right to use and disclose health information for your treatment, to bill for your health care and to operate our business. For example, we may use or disclose your health information:
For Payment. We may use or disclose health information to obtain payment for health care services. For example, we may disclose your health information to your health plan in order to obtain payment for the medical services we provide to you.
For Treatment. We may use or disclose health information to aid in your treatment or the coordination of your care. For example, we may disclose information to your physicians or hospitals to help them provide medical care to you.
For Health Care Operations. We may use or disclose health information as necessary to operate and manage our business activities related to providing and managing your health care. For example, we might analyze data to determine how we can improve our services. We may also de-identify health information in accordance with applicable laws. After that information is de-identified, it is no longer subject to this notice and we may use it for any lawful purpose.
To Provide You Information on Health-Related Programs or Products such as alternative medical treatments and programs or about health-related products and services, subject to limits imposed by law.
For Reminders. We may use or disclose health information to send you reminders about your care, such as appointment reminders with providers who provide medical care to you or reminders related to medicines prescribed for you.
We may use or disclose your health information for the following purposes under limited circumstances:
As Required by Law. We may disclose information when required to do so by law.
To Persons Involved With Your Care. We may use or disclose your health information to a person involved in your care or who helps pay for your care, such as a family member, when you are incapacitated or in an emergency, or when you agree or fail to object when given the opportunity. If you are unavailable or unable to object, we will use our best judgment to decide if the disclosure is in your best interests. Special rules apply regarding when we may disclose health information to family members and others involved in a deceased individual’s care. We may disclose health information to any persons involved, prior to the death, in the care or payment for care of a deceased individual, unless we are aware that doing so would be inconsistent with a preference previously expressed by the deceased.
For Public Health Activities such as reporting or preventing disease outbreaks to a public health authority. We may also disclose your information to the Food and Drug Administration (FDA) or persons under the jurisdiction of the FDA for purposes related to safety or quality issues, adverse events or to facilitate drug recalls.
For Reporting Victims of Abuse, Neglect or Domestic Violence to government authorities that are authorized by law to receive such information, including a social service or protective service agency.
For Health Oversight Activities to a health oversight agency for activities authorized by law, such as licensure, governmental audits and fraud and abuse investigations.
For Judicial or Administrative Proceedings such as in response to a court order, search warrant or subpoena.
For Law Enforcement Purposes. We may disclose your health information to a law enforcement official for purposes such as providing limited information to locate a missing person or report a crime.
To Avoid a Serious Threat to Health or Safety to you, another person, or the public, by, for example, disclosing information to public health agencies or law enforcement authorities, or in the event of an emergency or natural disaster.
For Specialized Government Functions such as military and veteran activities, national security and intelligence activities, and the protective services for the President and others.
For Workers’ Compensation as authorized by, or to the extent necessary to comply with, state workers compensation laws that govern job-related injuries or illness.
For Research Purposes such as research related to the evaluation of certain treatments or the prevention of disease or disability, if the research study meets federal privacy law requirements.
To Provide Information Regarding Decedents. We may disclose information to a coroner or medical examiner to identify a deceased person, determine a cause of death, or as authorized by law. We may also disclose information to funeral directors as necessary to carry out their duties.
For Organ Procurement Purposes. We may use or disclose information to entities that handle procurement, banking or transplantation of organs, eyes or tissue to facilitate donation and transplantation.
To Correctional Institutions or Law Enforcement Officials if you are an inmate of a correctional institution or under the custody of a law enforcement official, but only if necessary (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.
To Business Associates that perform functions on our behalf or provide us with services if the information is necessary for such functions or services. Our business associates are required, under contract with us and pursuant to federal law, to protect the privacy of your information and are not allowed to use or disclose any information other than as specified in our contract and permitted by law.
Additional Restrictions on Use and Disclosure. Certain federal and state laws may require special privacy protections that restrict the use and disclosure of certain health information, including highly confidential information about you. Such laws may protect the following types of information:
Alcohol and Substance Abuse
Biometric Information
Child or Adult Abuse or Neglect, including Sexual Assault
Communicable Diseases;
Genetic Information
HIV/AIDS
Mental Health
Minors Information
Prescriptions
Reproductive Health
Sexually Transmitted Diseases
If the use or disclosure of health information described above in this notice is prohibited or materially limited by other laws that apply to us, it is our intent to meet the requirements of the more stringent law.
Except for uses and disclosures described and limited as set forth in this notice, we will use and disclose your health information only with a written authorization from you. This includes, except for limited circumstances allowed by federal privacy law, not using or disclosing psychotherapy notes about you, selling your health information to others, or using or disclosing your health information for certain promotional communications that are prohibited marketing communications under federal law, without your written authorization. Once you give us authorization to release your health information, we cannot guarantee that the recipient to whom the information is provided will not disclose the information. You may take back or “revoke” your written authorization at any time in writing, except if we have already acted based on your authorization. To find out how to revoke an authorization, use the contact information below under the section titled “Exercising Your Rights.”
What Are Your Rights
The following are your rights with respect to your health information:
You have the right to ask to restrict uses or disclosures of your information for treatment, payment, or health care operations. You also have the right to ask to restrict disclosures to family members or to others who are involved in your health care or payment for your health care. Please note that while we will try to honor your request and will permit requests consistent with our policies, we are not required to agree to any restriction other than with respect to certain disclosures to health plans as further described in this notice.
You have the right to request that we not send health information to health plans in certain circumstances if the health information concerns a health care item or service for which you or a person on your behalf has paid us in full. We will agree to all requests meeting the above criteria and that are submitted in a timely manner.
You have the right to ask to receive confidential communications of information in a different manner or at a different place (for example, by sending information to a P.O. Box instead of your home address). We will accommodate reasonable requests. In certain circumstances, we will accept your verbal request to receive confidential communications; however, we may also require you to confirm your request in writing. In addition, any request to modify or cancel a previous confidential communication request must be made in writing. Mail your request to the address listed below.
You have the right to see and obtain a copy of certain health information we maintain about you such as medical records and billing records. If we maintain a copy of your health information electronically, you will have the right to request that we send a copy of your health information in an electronic format to you. You can also request that we provide a copy of your information to a third party that you identify. In some cases, you may receive a summary of this health information. You must make a written request to inspect or obtain a copy of your health information or have your information sent to a third party. Mail your request to the address listed below. In certain limited circumstances, we may deny your request to inspect and copy your health information. If we deny your request, you may have the right to have the denial reviewed. We may charge a reasonable fee for any copies.
You have the right to ask to amend certain health information we maintain about you such as medical records and billing records if you believe the information is wrong or incomplete. Your request must be in writing and provide the reasons for the requested amendment. Mail your request to the address listed below. If we deny your request, you may have a statement of your disagreement added to your health information.
You have the right to receive an accounting of certain disclosures of your information made by us during the six years prior to your request. This accounting will not include disclosures of information made: (i) for treatment, payment, and health care operations purposes; (ii) to you or pursuant to your authorization; and (iii) to correctional institutions or law enforcement officials; and (iv) other disclosures for which federal law does not require us to provide an accounting.
You have the right to a paper copy of this notice. You may ask for a copy of this notice at any time. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice. If we maintain a website, we will post a copy of the revised notice on our website. You may also obtain a copy of this notice on our website, www.firsthandcares.com or by calling 615-971-5878.
Exercising Your Rights
Contacting your Provider. If you have any questions about this notice or want information about exercising any of your rights, please call 615-971-5878.
Submitting a Written Request. You can mail your written requests to exercise any of your rights, including modifying or canceling a confidential communication, requesting copies of your records, or requesting amendments to your record, to us at the following address:
Firsthand Health, Inc
Attn: Legal Department
524 Broadway, Fl 8, New York, NY 10012
Filing a Complaint. If you believe your privacy rights have been violated, you may file a complaint with us at the following address:
Firsthand Health, Inc
Attn: Legal Department
524 Broadway, Fl 8, New York, NY 10012
You may also notify the Secretary of the U.S. Department of Health and Human Services of your complaint. We will not take any action against you for filing a complaint.
*This Notice of Privacy Practices has been approved by and applies to professional corporations and entities to which Firsthand Health, Inc provides non-clinical management services.
Security and Privacy Terms
firsthand Customer Portal Privacy Policy.
firsthand will ensure security and privacy terms are addressed with customers accessing firsthand information and assets via a portal or application including:
firsthand’s right to monitor, and revoke, any activity related to firsthand assets
The respective liabilities of firsthand and the customer.
User obligations and their acceptance of responsibilities and liabilities prior to accessing, processing, communicating, or managing firsthand's information and information assets.
firsthand will review these terms annually.
HIPAA Privacy Rule
Access and Disclosure of PHI.
firsthand documents and maintains records (PII) that are subject to access by individuals and the titles of the persons or office responsible for receiving and processing requests for access by individuals as organizational records for a period of six (6) years.
When required, consent is obtained before any protected information (e.g. about a patient) is emailed, faxed, or communicated by telephone conversation, or otherwise disclosed to parties external to firsthand.
firsthand will provide a Notice of Privacy Practices to patients where firsthand is not able to rely upon firsthand’s clients’ Notice of Privacy Practices for consent to disclose PHI for treatment, payment, or healthcare operations.
Request to Restrict Disclosure. firsthand permits an individual to request to restrict the disclosure of the individual's PHI to a business associate for the purposes of carrying out payment or healthcare operations and where disclosure is not for purposes of carrying out treatment. firsthand documents restrictions in writing and formally maintains such writing, or an electronic copy of such writing, as an organizational record for a period of six (6) years and a similar record will be maintained by firsthand business associates.
Amendments to PHI. It is firsthand’s policy to allow amendments to be made to an individual’s PHI in accordance with state and federal privacy laws and HIPAA Regulations.
Right to Accounting of Disclosures. It is firsthand’s policy to provide an Accounting of Disclosures of an individual’s PHI when requested by the individual in accordance with state and federal privacy laws and HIPAA regulations, and as directed by firsthand’s client, or respond to an firsthand client request for an Accounting of Disclosures so that firsthand’s client may respond to such a request.
firsthand documents and maintains accounting of disclosures as organizational records for a period of six (6) years, including the information required for disclosure, the written accounting provided to the individual, and the titles of the persons or offices responsible for receiving and processing requests for an accounting.
Privacy Complaints.
It is firsthand’s policy to allow individuals to express concerns and complaints regarding firsthand’s Privacy Policies or Procedures or privacy practices and to respond to such concerns and complaints in a timely and appropriate manner.
PROCEDURE
Updating and Posting of firsthand’s Online and Portal Privacy Policies
At least annually the Chief Privacy Officer (CPO) will review firsthand’s Online Privacy Policy and update contents as necessary, ensuring a mechanism whereby users are able to communicate with firsthand’s senior security and privacy officials in published as part of the Online Privacy Policy.
The date of the policy, as posted to firsthand’s public website www.firsthandcares.com, will be updated to reflect this review date.
firsthand’s Director of IT will post the updated privacy policy to the website and archive old versions for 6 years.
HIPAA Privacy Rule Right to Accounting of Disclosures.
Individuals have the right to receive an Accounting of Disclosures of their PHI.
The Accounting of Disclosures does not have to include disclosures made for the following purposes or to the following recipients:
For Treatment, Payment, or Health Care Operations
To the individual or the individual’s Personal Representative
Authorized by the individual or the individual’s Personal Representative
To notify families of individuals or assist families or and other persons involved in the individual’s care
For national security intelligence, to correctional institutions or to law enforcement authorities that have custody of the individual
As part of a Limited Data Set
Occurring prior to April 14, 2003
Incident to a use or disclosure otherwise permitted or required by these policies
Examples of accountable disclosures include:
Impermissible disclosures known to any firsthand Workforce Members
Disclosures to government agencies performing licensure surveys, etc.
Disclosures made pursuant to a court order or subpoena
Disclosures to law enforcement not involved in custodial care
Disclosures about victims of abuse, neglect, or domestic violence
firsthand must temporarily suspend an individual's right to receive an Accounting of Disclosures if it receives a written statement from a health oversight agency or law enforcement official that such an Accounting to the individual would be reasonably likely to impede the agency's or official’s activities. The time frame for such a suspension is required.
The Accounting of Disclosures will not include disclosures occurring prior to the earlier of
The period specified by the individual, or
April 14, 2003, or
The date six (6) years prior to the individual’s request.
Who May Obtain an Accounting? Only the individual or the individual’s Personal Representative may obtain an Accounting of Disclosures of the individual’s PHI.
Requests Made Directly to firsthand. Upon receiving a request for an Accounting of Disclosures of PHI directly from an individual or an individual’s Personal Representative, firsthand Workforce Member will:
Notify firsthand’s Chief Privacy Officer (CPO) of the request. The CPO will review client contractual requirements for notification requests and pass the request on to the client as required and follow client instructions regarding the restriction request.
Responsibility for Responding to Requests. firsthand’s CPO is responsible for making determinations regarding requests for Accountings of Disclosures.
Charges. firsthand may not charge for the first Accounting of Disclosure request but may charge a reasonable fee based on firsthand’s costs, for any additional Accounting requests received within a twelve (12) month period. For disclosures of PHI maintained in an Electronic Health Record, the charge for disclosure may not exceed labor costs. firsthand’s CPO will determine if a charge is appropriate.
Provision of Accounting. firsthand’s CPO will provide to the requesting individual an Accounting of Disclosures within sixty (60) days of receiving an authorized request. firsthand’s CPO will provide the individual the Accounting of Disclosure that includes the following information:
A brief description of the event including the date of the disclosure
A description of the types of PHI disclosed
Name of entity or person who received the PHI and address if known
The purpose of the disclosure (if applicable)
If the disclosure was unauthorized or impermissible, a brief description of efforts to investigate the disclosure, to mitigate losses and to protect against further PHI disclosures
In addition to the Accounting of Disclosures, other information that may be required by applicable legal requirements such as contact procedures for individuals to ask questions or learn additional information which may include a toll-free telephone number, an email address, website or postal address.
Record Retention. firsthand’s CPO will work with firsthand IT to document and maintain accountings of disclosure as organizational records for a period of six (6) years, including the information required for disclosure, the written accounting provided to the individual, and the titles of the persons or offices responsible for receiving and processing requests for an accounting. A similar record will be kept by all firsthand’s Business Associates that disclose PHI.
HIPAA Privacy Rule Right to Request Restrictions. Individuals have the right to request restrictions on how their PHI is used or disclosed for Treatment or Payment purposes or Health Care Operations. They also have the right to request restrictions on notifying or disclosing information to family, caregivers, friends, or others involved in their care.
Who May Request. Only the individual or the individual’s Personal Representative. Any Workforce Member that receives a notice from an individual or their Personal Representative requesting firsthand to implement a restriction request will forward the request to the CPO.
Requests for Restriction. If an individual requests to restrict use of their PHI, the applicable Workforce Member will forward the request to the CPO who responsible for reviewing client contractual requirements for restriction, passing the request on to firsthand’s client as required, and following client instructions regarding the restriction request.
The CPO will ensure that the request does not restrict permitted or required uses and disclosures that are not subject to a restriction.
If the CPO agrees to grant the restriction request after reviewing client requirements, the CPO will communicate the restriction, in writing, to the applicable Workforce Member who will ensure that the restriction is documented in the individual’s record.
The CPO will extend the restriction to firsthand business associates, as necessary.
Terminating a Restriction. If an individual requests a termination to a restriction, the CPO will:
Ensure that the individual agrees to or requests the termination in writing or, if oral, that the oral agreement is documented in the individual’s record.
Notify firsthand’s client and the applicable Workforce Member to remove the restriction and provide the date that the individual will be or has been informed so that the restriction termination is only effective with respect to PHI created or received after the date the individual has been informed.
Ensure that the individual is informed that the restriction is terminated effective on the date of notification.
Documentation. The CPO will ensure that documentation associated with a restriction that has been granted includes (a) communication and documentation, and (b) any action, activity or designation related to the granting or terminating of a restriction request.
Record Retention. firsthand’s CPO will work with firsthand IT to document and maintain disclosure restriction requests as organizational records for a period of six (6) years. A similar record will be kept by all firsthand’s Business Associates that disclose PHI. Privacy Complaints
Accepting Complaints. Individuals who express concerns or complaints about firsthand’s Privacy Policies or Procedures or privacy practices will be assured that firsthand takes their concerns very seriously and intends to deal with the issue promptly and appropriately.
If the individual wishes to file a complaint regarding firsthand’s Privacy Policies or Procedures or privacy practices, the Workforce Member who receives the complaint will:
Access and complete the privacy complaint form (see Attachment B) and submit the form to the Chief Privacy Officer, or
If preferred by the individual, direct them to anonymously report Policy or Process violations via firsthand email privacy@firsthandcares.com.
Individuals with concerns or complaints regarding firsthand’s Privacy Policies or Procedures or privacy practices will have the right to speak directly with the Chief Privacy Officer.
The individual is entitled to complain directly to the Secretary of DHHS and will be provided, upon request, the address and telephone number of the official or agency designated by DHHS to receive such complaints.
Investigation. The Chief Privacy Officer, or designee, will promptly investigate any privacy related compliant.
Resolving the Privacy Related Complaint. If the complaint is justified, firsthand will take prompt action to ensure that similar problems do not arise in the future.
Appropriate responses may range from changing certain practices, policies, and procedures, providing additional Workforce training, or taking necessary disciplinary action.
If the investigation of the complaint results in a determination that PHI has been improperly disclosed, the Chief Privacy Officer will coordinate the response.
Notice to Person Who Complained. Once the matter is resolved, firsthand’s Chief Privacy Officer, in consultation with legal counsel, may respond to the individual who submitted the complaint.
COMPLIANCE
All firsthand Workforce Members are responsible for reporting violations of this procedure to their manager or the Chief Information Security Officer. All managers are responsible for enforcing this procedure and escalating any violations to the Chief Information Security Officer, whether that violation is observed by the manager directly or reported to the manager by a Workforce Member.
Review of Policy
This document shall be reviewed at least annually, or upon material change to described policy or procedure. Changes, approvals, and annual reviews will follow the firsthand Policy Creation & Approval Policy and procedure.
Exceptions:
Any exception to the policy must be approved by the company Privacy Officer or the Chief Executive Officer in advance.
Non-Compliance
Violations of this Policy will be grounds for discharge or other disciplinary action, adapted to the circumstances of the particular violation. Disciplinary action will be taken against individuals who authorize or participate directly in a violation of the Policy. Disciplinary action also may be taken against any of the violator's managerial superiors, to the extent that the circumstances of the violation reflect inadequate supervision and leadership by the superior.
REGULATORY AND OTHER REFERENCE(s)
U.S. Health Insurance Portability and Accountability Act of 1996 (HIPAA)
HITRUST CSF v9.4.2 (2020)
Per § 164.316(b)(2)(i) this document shall be retained for 6 years from latter of date of creation or date last in effect
NIST Special Publication 800-66 Revision 1 (2008) - Matthew Scholl, Kevin Stine, Joan Hash, Pauline Bowen, Arnold Johnson, Carla Dancy Smith, and Daniel I. Steinberg
Privacy Policy
Protecting your private information is our priority. This Statement of Privacy applies to www.firsthandcares.com (Site) and applications of firsthand and governs data collection and usage. By using the firsthand website or mobile apps , you consent to the data practices described in this statement.
Collection of your Personal Information
We do not collect any personal information about you unless you voluntarily provide it to us. However, you may be required to provide certain personal information to us when you elect to use certain products or services available on the Site. These may include: (a) registering for an account on our Site; (b) entering a sweepstakes or contest sponsored by us or one of our partners; (c) signing up for special offers from selected third parties; (d) sending us an email message; (e) submitting your credit card or other payment information when ordering and purchasing products and services on our Site. To wit, we will use your information for, but not limited to, communicating with you in relation to services and/or products you have requested from us. We also may gather additional personal or non-personal information in the future.
Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through firsthand’s public message boards, this information may be collected and used by others.
Contact Information
Use of your Personal Information
firsthand collects and uses your personal information to operate its website(s) and deliver the services you have requested. firsthand may also use your personally identifiable information to inform you of other products or services available from firsthand and its affiliates.
Sharing Information with Third Parties
firsthand does not sell, rent or lease its customer lists to third parties.
firsthand may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to firsthand, and they are required to maintain the confidentiality of your information.
firsthand may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on firsthand or the site; (b) protect and defend the rights or property of firsthand; and/or (c) act under exigent circumstances to protect the personal safety of users of firsthand, or the public.
Tracking User Behavior
firsthand may keep track of the websites and pages our users visit within firsthand, in order to determine what firsthand services are the most popular. This data is used to deliver customized content and advertising within firsthand to customers whose behavior indicates that they are interested in a particular subject area.
Automatically Collected Information
Information about your computer hardware and software may be automatically collected by firsthand. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the firsthand website.
Use of Cookies
The firsthand website may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize firsthand pages, or register with firsthand site or services, a cookie helps firsthand to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same firsthand website, the information you previously provided can be retrieved, so you can easily use the firsthand features that you customized.
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the firsthand services or websites you visit.
Links
This website and apps contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.
Security of your Personal Information
firsthand secures your personal information from unauthorized access, use, or disclosure. firsthand uses the following methods for this purpose:
SSL Protocol: When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.
We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.
Children Under Thirteen
firsthand does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.
E-mail Communications
From time to time, firsthand may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our Services, we may receive a notification when you open an email from firsthand or click on a link therein.
If you would like to stop receiving marketing or promotional communications via email from firsthand, you may opt out of such communications by “replying STOP”.
Changes to this Statement
firsthand reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, by placing a prominent notice on our site, and/or by updating any privacy information on this page. Your continued use of the Site and/or Services available through this Site after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.
Contact Information
firsthand welcomes your questions or comments regarding this Statement of Privacy. If you believe that firsthand has not adhered to this Statement, please contact firsthand at: privacy@firsthandcares.com