Privacy Policy

A. PURPOSE OF THE NOTICE

THIS NOTICE DESCRIBES HOW PROTECTED HEALTH INFORMATION (PHI) ABOUT YOU MAY BE SHARED, USED AND DISCLOSED BY AND BETWEEN THE ABOVE AFFILIATED ENTITIES, YOUR RIGHTS REGARDING THIS INFORMATION AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY. THIS NOTICE HAS BEEN REVISED DUE TO THE PASSAGE OF THE PRIVACY REQUIREMENTS RELATED TO THE OMNIBUS RULE.

We respect the privacy of your personal PHI and are committed to maintaining your confidentiality. This Notice applies to all information and records related to your care that we have received or created. It extends to information received or created by our employees, staff, volunteers, and business associates when acting as our agent. This Notice informs you about the possible uses and disclosures of your personal PHI as well as your rights and our obligations regarding your personal PHI.

We are required by law to:

• Maintain the privacy of your personal PHI
• Provide you this detailed Notice of our legal duties and privacy practices relating to your personal PHI
• Abide by the terms of the Notice that are currently in effect
• Notify you of a breach of your unsecured PHI

B. HOW WE MAY USE AND DISCLOSE YOUR PHI:

We may use and disclose your personal PHI for purposes of treatment, payment, and health care operations. We have described these uses and disclosures below and provide examples of the types of uses and disclosures we may make in each of these categories.

For Treatment. We will use and disclose your personal PHI when providing you with treatment and services. We may disclose your personal PHI to organization and non-organization personnel who may be involved in your care, such as physicians, nurses, nurse aides, and physical therapists. For example, a nurse caring for you will report any change in your condition to your physician. We also may disclose personal PHI to individuals who will be involved in your care after you leave the organization. Authorization is required for the release of psychotherapy notes.

For Payment. We may use and disclose your personal PHI so that we can bill and receive payment for the treatment and services you receive from the organization. For billing and payment purposes, we may disclose your personal PHI to your representative, insurance or managed care company, Medicare, Medicaid or another third-party payer. For example, we may contact Medicare or your health plan to confirm your coverage or to request prior approval for a proposed treatment or service.

For Health Care Operations. We may use and disclose your personal PHI for organization operations. These uses and disclosures are necessary to manage the organization and to monitor our quality of care. For example, we may use your personal PHI to evaluate our organization’s services, including the performance of our staff.

For Services by Business Associates. There are some services that are provided through contracts with Business Associates or Agents. Examples include our accountants, consultants, and attorneys. When these services are performed, we may release your personal PHI to them so that they can perform the job we’ve asked them to do. However; we require them to appropriately safeguard your information as well.The Skilled Nursing Center Directory. Unless you object, we will include certain limited personal PHI about you in our village/organization directory. This information may include your name, your location, your picture, your telephone number, and email address. Our directory does not include specific medical information about you. We may release information in our directory to people who ask for you by name. We may provide the directory information to any member of the clergy. You may opt out of the directory at any time by contacting the Privacy Officer.

C. USES AND DISCLOSURE OF HEALTH INFORMATION IN SPECIFIC SITUATIONS

Appointment Reminders. We may use or disclose your health information for purposes of contacting you to remind you of a health care appointment.

Treatment Alternatives & Health-Related Products and Services. We may use or disclose your health information for purposes of discussing with you treatment alternatives or health-related products or services that may be of interest to you. For example, if you are a resident of our The Skilled Nursing Center for purposes of a post-surgical hip replacement, we may talk with you about a gait training program that we offer at our The Skilled Nursing Center to improve your walking and balance.

Individuals Involved in Your Care or Payment for Your Care. Unless you object, we may disclose your personal PHI to a family member, personal representative, or close personal friend, including clergy, who is involved in your care, including those listed as your emergency contacts, personal representative or another person involved in your care of your location and general condition including leaving a message such as on an answering machine for the number provided.

Family Members and Friends. We may disclose your health information to individuals, such as family members and friends, who are involved in your care or who help pay for your care. We may make such disclosures when:  (a) we have your verbal Agreement to do so; (b) we make such disclosures and you do not object; or (c) we can infer from the circumstances that you would not object to such disclosures. For example, we will share information about you with your spouse or other family member after giving you an opportunity to agree or object.

We also may disclose your health information to family members or friends in instances when you are unable to agree or object to such disclosures, provided that we feel it is in your best interests to make such disclosures and the disclosures relate to that family member or friend’s involvement in your care. For example, if your medical condition prevents you from either agreeing or objecting to disclosures made to your family or friends, we may share information with the family member or friend that comes to visit you at our The Skilled Nursing Center, but we will share only that information which relates to their involvement in your care.

Disaster Relief. We may disclose your personal PHI to an organization assisting in a disaster relief effort.

There are certain instances in which we may be required or permitted by law to use or disclose your health information without your permission. These instances are as follows:

As Required By Law. We will disclose your personal PHI when required by law to do so.

Public Health Activities. We may disclose your personal PHI for public health activities. These activities may include, for example:

Reporting to a public health or other government authority for preventing or controlling disease, injury, or disability, or reporting abuse or neglect;

Reporting to the federal Food and Drug Administration (FDA) concerning adverse events or problems with products for tracking products in certain circumstances, to enable product recalls or to comply with other FDA requirements;

To notify a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition; or

For certain purposes involving workplace illness or injuries.

Reporting Victims of Abuse, Neglect or Domestic Violence. If we believe that you have been a victim of abuse, neglect, or domestic violence, we may use and disclose your personal PHI to notify a government authority if required or authorized by law or if you agree to the report.

Health Oversight Activities. We may disclose your personal PHI to a health oversight agency for oversight activities authorized by law. These may include, for example, audits, investigations, inspections and licensure actions or other legal proceedings. These activities are necessary for government oversight of the health care system, government payment or regulatory programs, and compliance with civil rights laws.

Judicial and Administrative Proceedings. We may disclose your personal PHI in response to a court or administrative order. We also may disclose information in response to a subpoena, discovery request, or other lawful process; efforts must be made to contact you about the request or to obtain an order or agreement protecting the information.

Worker’s Compensation. We may disclose your health information to worker’s compensation programs when your health condition arises out of a work-related illness or injury.

Law Enforcement. We may disclose your personal PHI for certain law enforcement purposes, including:

• As required by law to comply with reporting requirements;
• To comply with a court order, warrant, subpoena, summons, investigative demand or similar legal process;
• To identify or locate a suspect, fugitive, material witness, or missing person;
• When information is requested about the victim of a crime if the individual agrees or under other limited circumstances;
• To report information about a suspicious death;
• To report information about criminal conduct occurring at the organization;
• To report information in emergency circumstances about a crime; or
• Where necessary to identify or apprehend an individual in relation to a violent crime or an escape from lawful custody.
• To law enforcement if you are an inmate in a correctional institute or under the custody of law enforcement.

Research. We may allow personal PHI of residents from our own organization to be used or disclosed for research purposes provided that the researcher adheres to certain privacy protections. We may remove information that identifies you and use it to study health care and delivery without learning who the specific residents are. Your personal PHI may be used for research purposes only if the researcher is collecting information in preparing a research proposal, if the research occurs after your death, or if you authorize the use or disclosure.

Fundraising Activities. We may use certain personal PHI you provide to contact those listed for marketing or fundraising purposes. We may disclose personal PHI to a foundation related to the organization so that the foundation may contact you to raise money. In doing so, we would only release contact information, such as names, addresses, and phone numbers. You have the right to respond to such communication by opting out of receiving any further such communication.

Coroners, Medical Examiners, Funeral Directors, Organ Procurement Organizations. We may release your personal PHI to a coroner, medical examiner, and funeral director or, if you are an organ donor, to an organization involved in the donation of organs and tissue.

Decedent Information; PHI. will be released after your death as per your wishes prior to death. HIPAA no longer applies fifty years after your death.

To Avert a Serious Threat to Health or Safety. We may use and disclose your personal PHI when necessary to prevent a serious threat to your health or safety or the health or safety of the public or another person. However, any disclosure would be made only to someone able to help prevent the threat.

Military and Veterans. If you are a member of the armed forces, we may use and disclose your personal PHI as required by military command authorities. We may also use and disclose personal PHI about foreign military personnel as required by the appropriate foreign military authority.

National Security and Intelligence Activities: Protective Services for the President and Others. We may disclose personal PHI to authorized federal officials conducting national security and intelligence activities or as needed to provide protection to the President of the United States, certain other persons or foreign heads of states or to conduct certain special investigations.

Secretary. We may disclose PHI to the Secretary of Health and Human Services if requested.

Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may use or disclose your health information to the correctional institution or to the law enforcement official as may be necessary (i) for the institution to provide you with health care; (ii) to protect the health or safety of you or another person; or (iii) for the safety and security of the correctional institution.

Photo and Marketing Activities: If you sign an authorization allowing us to do so, resident photos/videos of you may be taken during various social events and may be used and/or posted in various marketing materials, newsletters, media coverage, bulletin boards, Legacy Pointe websites, and social media sites. This permission extends both to electronic/internet usage as well as printed, filmed, and taped materials. By signing this, you consent to the taking and using of such photographs, films, audio and/or video and other materials. You also understand that you may be identified in any use of these materials.

Death Notices and Memorial Notices. If you sign an authorization allowing us to do so, death and memorial notices will be posted in various locations, such as, publications, and resident bulletin boards throughout the Health Care Center to notify residents of deaths of neighbors and friends and times of memorial services.

Birthdays. If you sign an authorization allowing us to do so, your birthday will be posted in the community.

Disclosures to Members of the Media or Entertainment Vendors. If you sign an authorization allowing us to do so, your first and last name, as well as photographs and/or video recordings of you, may be shared with members of the media or entertainment vendors for their own marketing or publicity purposes that could include social media, publications, newsletters, brochures, website, and other marketing materials.

D. USES AND DISCLOSURES PURSUANT TO YOUR WRITTEN AUTHORIZATION

Except for the purposes identified above in Sections B through D, we will not use or disclose your health information for any other purposes unless we have your specific written authorization. You have the right to revoke a written authorization at any time as long as you do so in writing. If you revoke your authorization, we will no longer use or disclose your health information for the purposes identified in the authorization, except to the extent that we have already taken some action in reliance upon your authorization.

E. YOUR RIGHTS REGARDING YOUR HEALTH INFORMATION

You have the following rights regarding your health information. You may exercise each of these rights, in writing, by providing us with a completed form that you can obtain from the business office. In some instances, we may charge you for the cost(s) associated with providing you with the requested information. Additional information regarding how to exercise your rights, and the associated costs, can be obtained from the business office.

Right to Request Restrictions: You have the right to request restrictions on our use or disclosure of your personal health information for treatment, payment, or health care operations. You also have the right to restrict the personal health information we disclose about you to a family member, friend or other person who is involved in your care of the payment for your care. We are not required to agree to your requested restriction (except that while you are competent you may restrict disclosures to family members or friends). If we do agree to accept your requested restriction, we will comply with your request except as needed to provide you with emergency treatment.

Right to Inspect and Copy. You have the right to inspect and copy health information that may be used to make decisions about your care. We may deny your request to inspect and copy your health information in certain limited circumstances. If you are denied access to your health information, you may request that the denial be reviewed.

Right to an Accounting of Disclosures. You have the right to request an accounting of the disclosures of your health information made by us. This accounting will not include disclosures of health information that we made for purposes of treatment, payment or health care operations or pursuant to a written authorization that you have signed.

Right to Restrictions for Disclosure for Out of Pocket Payment. We must agree to requests for restriction of providing personal PHI to a health plan for payment of health care operations, items or services for which you have paid for out of pocket in full. This information can only be released with written authorization.

Rights Regarding Use and Disclosure of Genetic Information for Underwriting. The organization is prohibited from using or disclosing genetic information other than for long-term care policies. This does not include the presence of an actual disease.

Right of Access to Personal Health Information. You have the right to inspect and obtain a copy of your medical or billing records or other written information that may be used to make decisions about your care, subject to some limited exceptions. We may charge you for our costs in copying and mailing your requested information.

Right to Request Confidential Communications. You have the right to request that we communicate with you about your health care in a certain way or at a certain location. For example, you can ask that we only contact you by mail.

Right to a Paper Copy of this Notice.  You have the right to receive a paper copy of this Notice. You may ask us to give you 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.

We may deny your request to inspect or receive copies in certain limited circumstances. If you are denied access to personal health information, in some cases you will have a right to request review of the denial. A licensed healthcare professional designated by the organization who did not participate in the decision to deny would perform this review.

Rights Regarding Psychotherapy Notes. Authorization is required for the use and disclosure of psychotherapy notes.

Rights Regarding Marketing/Sale of PHI. Uses and disclosure for marketing purposes and uses that constitute a sale of PHI require an individual’s authorization.

Right to Receive an Electronic Copy of Personal PHI. You have the right to receive an electronic copy of personal PHI if that is the format in which the information is stored.

Right to Request Amendment. You have the right to request the organization amend any personal health information maintained by the organization for as long as the information is kept by or for the organization. Your request must be made in writing and must state the reason for the requested amendment. Both old and new information will be kept.

Right to Notice of Breach: You have the right to be notified in the event a breach occurs involving or potentially involving your unsecured health information and inform you of what steps you may need to take to protect yourself.

We may deny your request for amendment if the information:

Was not created by the organization, unless the originator of the information is no longer available to act on your request;

• Is not part of the personal health information maintained by or for the Skilled Nursing Center
• Is not part of the information to which you have a right of access or,
• Is already accurate and complete, as determined by the Skilled Nursing Center
• If we deny your request for amendment, we will give you a written denial including the reasons for the denial and the right to submit a written statement disagreeing with the denial.

Right of Notification. You have the right to receive notification that your personal PHI has been compromised as per current regulations.

Complying with the law. We will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we’re complying with federal privacy law.Respond to lawsuits and legal actions. We can share health information about you in response to a court or administrative order, or in response to a subpoena.

F. FOR FURTHER INFORMATION

We are required by law to maintain the privacy and security of your protected health information.

We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.

We must follow the duties and privacy practices described in this notice and give you a copy of it.

We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.

G. QUESTIONS OR COMPLAINTS

If you have any questions regarding this Notice or wish to receive additional information about our privacy practices, please contact our Privacy Officer at Legacy Pointe at UCF The Skilled Nursing Center. If you believe your privacy rights have been violated, you may file a complaint with our The Skilled Nursing Center or with the Secretary of the Department of Health and Human Services (HHS). To file a complaint with our The Skilled Nursing Center, contact our Privacy Officer at Legacy Pointe at UCF The Skilled Nursing Center. All complaints must be submitted in writing. You will not be penalized for filing a complaint. We will not retaliate against you if you file a complaint.

H. CHANGES TO THIS NOTICE

We will promptly revise and post this Notice whenever there is a material change to the uses or disclosures, your individual rights, or legal duties, or other privacy practices stated in this Notice. We reserve the right to change this Notice and to make the revised or new Notice provisions effective for all personal health information already received and maintained by the organization as well as for all personal health information we receive in the future. We will post a copy of the current Notice in a clear prominent location and on our website.

I. QUESTIONS

If you have any questions about this Notice or would like further information concerning your privacy rights, please call (407) 917-6418

J. WEBSITE PRIVACY NOTICE

Legacy Pointe at UCF (“Community,” “We,” “Us”) respects your privacy and is committed to protecting it through our compliance with the following Privacy Policy. This policy describes:

• The types of information we may collect from you or that you may provide when you visit our website (http://www.legacypointeatucf.com; “website”) or via email, text or other electronic messages between you and the Community.
• Our practices for collecting, using, maintaining, protecting and disclosing that information.
• Our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your only recourse is not to use our website. However, you do have the option to opt-out of some tracking (see: “Choices About How We Use and Disclose Your Information”).

By accessing or using the website, you agree to this privacy policy

K. INFORMATION WE COLLECT

We collect several types of information from and about users of our website, including information:

• That is about you but individually does not identify you, such as your age, gender and interests; how you came to the website (e.g., search engine, third-party website, media campaign or email); and the pages and features of the website you use.
• By which you may be personally identified, such as name, postal address, email address or telephone number (“personal information”).
• About your Internet connection, the equipment you use to access our website, and your location.

We collect this information:

• Automatically as you navigate through the site. Information collected automatically may include IP addresses and information collected through cookies, Web beacons and other tracking technologies (see: “Usage Details, IP Addresses and Cookies and Other Technologies”).
• Directly from you when you provide it to us (see: “Information You Provide to Us”).
• From third parties, for example, our business partners.

L. USAGE DETAILS, IP ADDRESS, AND COOKIES AND OTHER TECHNOLOGIES

As you navigate through and interact with our website, we may automatically collect certain information about your equipment, browsing actions and patterns. The information we collect automatically is statistical data and does not identify any individual. It helps us improve our website and deliver better and more personalized future services by enabling us to:

• Estimate our audience size and usage patterns.
• Analyze and develop the Community’s sales and marketing strategy, determine how visitors find the Community and its website, the user’s interest regarding the Community’s services, and how to improve the Community’s website.
  • Speed up your searches
  • Recognize you when you return to our website.

We do not collect personal Information automatically, but we may tie this information to personal information about you that we collect from other sources or that you provide to us. The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). Cookies are a technology of Web browser software that allows Web servers to recognize the computer used to access a website. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate settings on your browser. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.

Flash Cookies. Certain features of our website may use locally stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our website. Flash cookies are not managed by the same browser settings used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Choices About How We Use and Disclose Your Information.”

Information You Provide to Us

The information we collect on or through our website may include:

• Information that you provide by filling in forms on our website. This includes, but is not limited to, information provided when you submit a request for information or to be contacted by the Community; a request for materials from the Community (e.g., DVDs, white papers and brochures); registering for an event; or subscribing to email communication.

• Records and copies of your correspondence (including e-mail addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our website and of the fulfillment of your orders.

How We Use Your Information

The Community and/or its agents use information that we collect about you or that you provide to us, including any personal information:

• To provide you with information, products or services that you request from us.
• To fulfill any other purpose for which you provide it.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We never sell your personal information.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

This website uses Google Analytics to track website activity and visitor behavior. If you want to opt-out of being tracked by Google Analytics, you may use the Google Analytics Opt-out Browser Add-on. Google Analytics also collects data about visits to the website via the DoubleClick cookie and Floodlight tags. This information is being used to provide demographic and interest data about visitors to the website and to target online display advertisements on third-party websites. Using Google’s Ads Settings, visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads.

Promotional Offers from the Community. If you do not wish to have your contact information used by the Company to promote our own services, you can follow the link to unsubscribe from mailing lists at the bottom of email communication; send an e-mail to marketing@legacypointeatucf.com stating your request; call 407-917-6418 and ask to be removed from marketing lists. This opt-out does not apply to information provided to the Community as a result of entering into a residence agreement, providing health records or other transaction.

Accessing and Correcting Your Information. To review and change your personal information, you may call us at 407-917-6418 or send us an e-mail at marketing@legacypointeatucf.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Data Security. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website.

Minors. No portion of Legacy Pointe at UCF’s website, services and agency services is directed towards minors (individuals below the age of 18). The company does not solicit any information about minors, nor does it market to minors.

Enforcements. Questions or complaints about Legacy Pointe at UCF’s privacy policy, as well as concerns about the Community’s enforcement of the policy, can be directed to:

Legacy Pointe at UCF
c/o Sales and Marketing Department
2110 Hestia Loop
Oviedo, FL 32765
407-917-6418