Privacy

Asembia shares a commitment with the prescribers utilizing the Regranex360 Patient Access Program website, who are HIPAA covered entities (collectively "Covered Entities"), to protect the privacy and confidentiality of Protected Health Information (PHI) in accordance with applicable HIPAA regulations. Asembia is also committed to protecting Personally Identifiable Information (PII) submitted by Users of the Regranex360 Patient Access Program website. This Policy is provided by Asembia to help you better understand how we disclose and protect PHI in accordance with the terms of the Business Associate Agreement and how we protect and use PII. PLEASE NOTE, YOUR USE AND CONTINUED USE OF THE Regranex360 PATIENT ACCESS PROGRAM WEBSITE CONSTITUTES YOUR UNDERSTANDING AND AGREEMENT WITH THIS PRIVACY POLICY.

Safeguards
Asembia's policy is to maintain the confidentiality of PHI received from or on behalf of clients who are HIPAA Covered Entities and with whom we have executed a Business Associate Agreement in accordance with such Agreements and applicable law. Asembia has implemented appropriate administrative, technical and physical safeguards for protecting the privacy of PHI and PII.

Data Collection
www.Regranex360.com collects data manually submitted by the prescriber of office staff through it's website. When visiting www.Regranex360.com a small text file called a "cookie" may be placed on a user's computer. This allows Asembia to collect non-PII data while the user is navigating the website. The following are two types of cookies:

  • Session cookies are temporary data files that expire when the user leaves the Regranex360 Patient Access Program website. When cookies expire, they are automatically deleted from a User's computer.
  • Persistent cookies are multi-session cookies that are stored ongoing on a User's computer.
  • If a user does not want cookies placed on their computer, they can set their browser to block them. You are not required to accept all cookies delivered by the Regranex360 Patient Access Program, but depending on what cookies are not installed, there may be an impact on select features for the website.
  • For each visitor to our site, our servers automatically recognize and store:
    • The visitor's domain name (where possible) and IP address;
    • The date and time of a user's visit;
    • The pages a user visited; and
    • The address of the website a user came from when they came to visit the website,
    • The data or information entered by the user.

We aggregate information on what content each visitor accesses or views. There is no PII in the data above. Asembia uses this information to improve the content and functionality of the website. This data is only available to Asembia web managers and other designated staff who require this information to perform their normal duties in association with the Regranex360 Patient Access Program. In addition, for each user that registers at www.Regranex360.com, we collect PII information necessary to utilize www.Regranex360.com. This includes but is not limited to name, e-mail address, and a password. PHI information submitted through www.Regranex360.com is used to provide services to Covered Entities with such use and disclosure of PHI permitted or required by the BA Agreement and applicable HIPAA regulations.

Use and Disclosure of Data
PII and PHI is transmitted using www.Regranex360.com by user to destination selected entirely by user. These transmissions are made at the sole discretion of user. www.Regranex360.com is not responsible for PII and PHI transmitted to incorrect destinations selected by user. We may use PII and PHI for our management, administration, data aggregation and legal obligations to the extent such use of PII and PHI is permitted or required by the Business Associate Agreement and this Privacy Policy and would not violate HIPAA regulations. We may also share de-identified data and select PII with business partners or potential business partners. No PHI information is shared with business partners or potential business partners, except as otherwise permitted by applicable law and the BA Agreement.

In the event that PII and PHI must be disclosed to a subcontractor or agent, we will ensure that the subcontractor or agent agrees to abide by the same restrictions and conditions that apply to us under the BA Agreement and this Privacy Policy with respect to PII and PHI, including the implementation of reasonable and appropriate safeguards. We may also use PII and PHI to report violations of law to appropriate federal and state authorities, as permitted by the BA Agreement and applicable law. Please direct all questions related to the Privacy Policy of the www.Regranex360.com website to regranex@aspnprograms.com.