Privacy Policy

EU-US DATA PRIVACY FRAMEWORK AND UK EXTENSION PRIVACY POLICY

Last Updated May 1, 2024

InterOperability Bidco, Inc., dba Rhapsody, provides integration, identity and terminology software solutions to healthcare providers, health IT companies, insurers and health information exchanges. We do not directly request personally identifiable information (PII) about individuals (non-employees) for our own behalf or for any purpose of our own. Rhapsody does not have control over how our customers use the personal information that is disclosed to them. We provide a safe and secure transfer, storage and processing mechanism for such information gathered by our customers to seamlessly flow from one application to another. The origin, storage and transfer of such data is decided by our customers.

Rhapsody is committed to protecting the privacy of individuals in accordance with applicable privacy laws and customer requirements. The purpose of this Privacy Policy is to provide an overarching set of requirements for the organization’s management of PII based on internationally accepted privacy principles, forming the foundation of Rhapsody’s global privacy and data protection program. Rhapsody is subject to the investigatory and enforcement policies of the Federal Trade Commission. This DPF Privacy Policy (the “Policy”) sets forth the privacy principles Rhapsody follows with respect to transfers of personal information from the EEA and the United Kingdom to the United States.

SCOPE

This DPF Privacy Policy (the “Policy”) applies to all personally identifiable information received by Rhapsody in the United States from the EEA and the United Kingdom, in any format, including electronic, paper or verbal.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

  • “Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Rhapsody.
  • “Customer” means any customer of Rhapsody, located in the EEA and the United Kingdom, for whom we host or store personal data on our servers in the United States.
  • “Rhapsody” means InterOperability Bidco, Inc., d.b.a. Rhapsody, its predecessors, successors, subsidiaries, divisions and groups in the United States.
  • “Personal information” means any information or set of information that identifies or could be used by or on behalf of Rhapsody to identify an individual. Personal information does not include information that is encoded or anonymized or publicly available information that has not been combined with non-public personal information.

PRIVACY PRINCIPLES

NOTICE:

Rhapsody does not collect personal information directly from individual data subjects in the EEA or the United Kingdom. Where Rhapsody receives, stores, or processes personal information from our customers in the EEA or the United Kingdom, we will use and disclose such information in accordance with the notices provided by our customers, only if consistent with the DPF Principles, and the choices made by the individuals to whom such personal information relates. We will endeavor, as much as is practicable, to enable our customers to publish and follow the EU Data Protection Directive (and any relevant UK Directives).

CHOICE:

Rhapsody will enable our customers to offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Rhapsody will enable our customers to provide individuals with reasonable mechanisms to exercise their choices.

ACCOUNTABILITY FOR ONWARD TRANSFER:

Rhapsody does not transfer data to third parties outside of its agents. Rhapsody will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant DPF Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), DPF certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada), or any UK Directives if different from EU GDPR. Where Rhapsody has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Rhapsody will take reasonable steps to prevent or stop the use or disclosure. Rhapsody’s accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequent transfers to a third party is described in the Data Privacy Framework Principles. In particular, Rhapsody remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Rhapsody proves that it is not responsible for the event giving rise to the damage.

Please be aware that Rhapsody may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.

SECURITY:

Rhapsody will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction taking into account risks involved in processing and the nature of the personal data.

DATA INTEGRITY AND PURPOSE LIMITATION:

Rhapsody does not use personal information provided by individuals to our customers; however, Rhapsody does not have control over how our customers use the personal information that is disclosed to them. When directed by our customers to process such information, Rhapsody will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Rhapsody will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

ACCESS AND RECOURSE:

EU and UK individuals have the right to access their personal information. Upon request, Rhapsody will assist our customers in granting individuals access to personal information that it holds about them.

ENFORCEMENT AND LIABILITY:

Rhapsody conducts compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Rhapsody determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION

Any questions or concerns regarding the use or disclosure of personal information should first be directed to the data controller in question (our Customer); or if the question or concern is from our Customer, then to Rhapsody at the address given below. Rhapsody will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy.

In compliance with the Data Privacy Framework Principles, Rhapsody commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Frameworks. European Union and United Kingdom individuals with DPF inquiries or complaints should first contact Rhapsody by email at privacy@rhapsody.health.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Rhapsody commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) regarding unresolved complaints concerning our handling of data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf.

Please note that we are subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by Rhapsody to these DPF Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; (c) to the extent expressly permitted by an applicable law, rule or regulation; and (d) to the extent that Rhapsody has limited or no control over the actions of its Customers regarding use of personal information that they have collected.

INTERNET PRIVACY

Rhapsody recognizes the importance of maintaining the privacy of information collected online and has created a “Communications Privacy Policy” governing the treatment of personal information collected through web sites that it hosts. With respect to personal information that is transferred from the European Economic Area or the United Kingdom to the U.S., the “Communications Privacy Policy” is subordinate to this Policy.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to InterOperability Bidco, Inc., d.b.a. Rhapsody by mail to:

InterOperability Bidco, Inc., d.b.a. Rhapsody
100 High Street, Suite 1560
Boston, MA 02110, United States

Attn: Privacy Department
Or by e-mail to:  privacy@rhapsody.health

CHANGES TO THIS DATA PRIVACY FRAMEWORK PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the DPF Principles. When we make changes to this Privacy Policy, we will post the updated Privacy Policy on the website and update the Privacy Policy’s “last updated” date above. It is important that you check back from time to time and make sure that you have reviewed the most current version of this Privacy Policy. 

EFFECTIVE DATE: May 1, 2024

Communications Privacy Policy

Introduction

This Privacy Policy applies to Rhapsody’s use of personal information provided by you to Rhapsody via this website, over the phone, via email, or through any other form of communication with Rhapsody. It also applies to other personal information about you that may be made available to us when you visit our website or our social media pages.

This Privacy Policy does not apply to personal information managed by Rhapsody software applications (including clinical records). Where Rhapsody manages this information on our customers’ behalf, we do so in accordance with data protection laws and strict privacy and security requirements in our contractual agreements with our customers.

Rhapsody is committed to protecting your personal information. Whenever you provide us personal information, we will comply with all applicable data protection and privacy laws in your country.

This Privacy Policy explains:

  • What personal information Rhapsody may collect about you
  • How Rhapsody may use your personal information
  • Who else may see or use your personal information
  • Your rights regarding your personal information

Who are we?

Rhapsody is a global company that develops software solutions to drive data liquidity in healthcare and improve healthcare outcomes. When we refer to ”we” or ”our” or ”Rhapsody” we are referring to our United States based company Interoperability Bidco, Inc and its local subsidiary companies located in the regions we operate in.

If you have any questions about this Privacy Policy you can write to Rhapsody Chief Privacy Officer at privacy@rhapsody.health.

What information will Rhapsody collect about me?

While visiting this website or our social media pages, Rhapsody may collect personal information about you when you order products or services, make requests, and register to receive materials. The types of personal information collected may include your name, your company name, address, telephone number, fax number, email address, contact and billing information, depending on what you provide us. Rhapsody also uses cookies and collects IP addresses (a number that can uniquely identify a specific computer or other network device on the internet) and other information about your computer or device. Please see our Cookies Policy for more information.

What will Rhapsody use my personal information for?

Rhapsody may use your personal information for its legitimate business interests, including the following activities:

Responding to your requests

  • We will use your contact details to provide you with information about our products and services in response to your requests made via the website.

Sales and Marketing

  • We may use your personal information to contact you to see whether you are interested in our products and services, or to send you general information about our products and service, newsletters, invitations to events or updates on Rhapsody and our customers, i.e. customer case studies.
  • You can opt-out of direct marketing emails at any time by using the unsubscribe link in the email, or writing to the Chief Privacy Officer at privacy@rhapsody.health.
  • We may use your information together with other people’s information in anonymized and aggregated form (so that it is not identifiable to you) for marketing and strategic development purposes, and may disclose it to third parties for this purpose. We do not sell or trade your information.

Website and Social Media Management and Improvement

We use cookies and third party analytics services such as Google Analytics on our website and social media pages to:

  • remember your settings during and between visits (for example, your region)
  • see what you are doing on the website and how often you visit
  • allow you to share pages with social networks like Twitter and Facebook
  • block any disruptive use
  • perform data analysis and research to improve our website and services

The use of cookies on our website and how you can reject cookies is explained in our Cookies Policy.

Will Rhapsody share my information with anyone else?

Generally, Rhapsody will not share your personal information outside our organization. Your information may be processed by third party suppliers we use, for example digital marketing and analytics service providers and cloud-based application providers like Microsoft.

Will my personal information leave the country?

Any personal information you provide to us will be held in our third party marketing supplier’s database located in the United States of America, as well as Rhapsody internal systems hosted in the United States of America and/or the cloud-based applications we use hosted in other countries. Your personal information will be accessed by our sales and marketing teams located in our head office in Boston, MA and other Rhapsody offices around the world for the purposes described in this policy. Rhapsody insures that there are adequate privacy and security arrangements in place wherever your information is accessed by way of strict privacy and security obligations in inter-company agreements and in our agreements with third parties. Copies of these agreements are available to you upon request.

How we protect your information

Rhapsody actively seeks to maintain the privacy of our online visitors, and we have constructed and administer this website accordingly. To prevent unauthorized use, maintain data accuracy, and ensure the appropriate use of information, we have put in place appropriate physical, electronic, and administrative procedures to safeguard and secure the information we collect.

How long will Rhapsody keep my information?

We will only hold your personal information in our systems for as long as is necessary to fulfill the purpose you submitted it for. We will not keep your contact details in our databases for longer than three years after the last communication we have had with you.

Your Rights

You have rights under applicable laws to access personal information the company holds about you, and have it corrected where necessary, subject to some exceptions. Depending on the country you reside in, you may also have rights to access your personal information in a portable, electronic format, a right to have your personal information erased, a right to know the third parties with whom your personal information has been shared with and/or a right to object to Rhapsody processing your personal information. You also have rights, under applicable laws, to lodge a complaint with the relevant data protection or privacy authorities if you believe Rhapsody is not handling your personal information in accordance with the law, and you may have rights to compensation in this case. If you wish to exercise any of these rights, please email the Privacy Officer at privacy@rhapsody.health.

What if I am under 18?

If you are aged 18 or under, please get your parent/guardian’s permission before you provide any personal information to Rhapsody. Rhapsody does not knowingly solicit, collect, or accept any information from or about children via this website. If we become aware that a person submitting personal information through any part of our website is a child, we delete the information as soon as we discover it and do not use it for any purpose, nor do we disclose it to third parties.

Since we do not seek to collect any personal information about children, and we delete any information collected inadvertently as soon as we discover that a child has submitted it, we typically retain no information about children that could be reviewed or deleted. If a parent requests review or deletion of information about their child before we have discovered and deleted the information, then we will of course honor that request.

Changes to our Privacy Policy

This Privacy Policy may be updated from time to time. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to submit personal information to Rhapsody.