1 Introduction

SunFire, Inc (“SunFire” or “we” or “us”) provides this Privacy Policy (“Policy”) to inform you (“you”) of our policies and procedures regarding the collection, use, and disclosure of personal information we receive via our website at https://SunFireinc.com (the “Site”) and the services we provide through our applications. The application, Site, and any supporting subdomains are managed and run by SunFire Holdings, LLC. Any information collected by the site is collected by SunFire on our behalf and in compliance with the Policy. Any information collected by our application is done on behalf of the patient or the patient’s insurance provider on the patient’s behalf and is done in compliance with the following sections of this Policy. By using the Site, the application, or our services, you consent to, without limitation, the collection, transfer, processing, storage, disclosure, and other uses outlined in this Policy. This Policy may be updated from time to time without notice and it is suggested you review the Policy at the Site regularly for any changes.

The terms “using” and “processing” of the personal information (as herein defined) may include statistical or other analysis, using or handling in any way, including but not limited to, collecting, storing, evaluating, modifying, deleting, using, combining, disclosing, and/or transferring information within our organization, among our partners, or to third parties.

The Site may contain health or medical-related information. Such information is not a substitute for professional medical advice, diagnosis, or treatment. Always seek the advice of your physician or other qualified health providers with any questions you may have regarding a medical condition.

2 How We Collect and Use Personal Information

2.1 Collection

  1. Information Submitted by You, Information–such as your name, address, phone number, and email address–is not collected as you browse the Site without a registered account unless you have already provided such data through the insurance provider. However, when you register with us on the Site to create an account (“Account”) and become a registered user (“Partner or Customer), you agree to provide us with certain personally identifiable information to complete registration, including without limitation, information that can be used to contact or identify you (“Personal Information”) such as your name, address, phone number, and email address. You agree that SunFire may use any content, including Personal Information, that you submit using the Site, Services, or any APIs for any purpose identified within the privacy notice or this Policy unless explicitly revoked by you per Section 5 of this policy. We communicate these uses to you throughout the Site at the time of collection or registration in addition to this Policy.
  2. Protected Health Information. Any information collected by the Site or disclosed by you through your use of the Site is protected by the Health Insurance Portability and Accountability Act (“HIPAA”). This Site is intended for the collection, access, or disclosure of protected health information and some of the information collected will be used in connection with your enrollment or provider. All Personal Information gathered that is covered by HIPAA will never be sold, leased, rented, or otherwise shared for marketing purposes without your consent.
  3. Log Data and Usage Information. When you visit the Site, whether as a Member or a non-registered user, our servers automatically record information that your browser sends whenever you visit a website generally (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, operating system, and/or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, access times and dates, and other statistics. We use this information to ensure our products and services are functioning as intended and keeping our users’ data safe when submitted on our Site.

2.2 Use

SunFire does not rent, lease, sell (for marketing or financial purposes), or otherwise share Personal Information about you, the Customer, with other persons or non-affiliated companies except to provide products or services you’ve requested, when we otherwise have your permission, or under the following circumstances:

  1. Service Providers 
    We may employ third party companies and individuals to facilitate our services, to provide services on our behalf, to perform site-related services (e.g., without limitation, maintenance services, database management, payment processors, web analytics, and improvement of the services’ features), or to assist us in analyzing how the services are used. These third parties have access to your Personal Information only to perform these tasks on our and your behalf and are obligated not to disclose or use it for any other purpose.
  2. Compliance with Laws and Law Enforcement
    SunFire cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose the information we collect from you to comply with the law, a judicial proceeding, court order, subpoena, or other legal processes.
  3. To Protect Us and Others
    We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety, rights, or property of any person or party, or violations of our Terms of Use or this Privacy Policy.
  4. Improve the Website and Services
    We use this information to enable you to access your registration data on the Website, monitor and analyze the use of the Site and for the Site’s technical administration including security features, to increase site functionality and user-friendliness including access to technical support, and to better tailor the site to our visitors’ needs. For example, we use such information to verify that visitors to the Site meet the criteria required to process their requests.
  5. Business Transfers
    We may sell, transfer or otherwise share some or all of our assets, including your Personal Information, and other information collected from you, in connection with a merger, acquisition, reorganization, sale of assets, or in the event of bankruptcy. We will make our best efforts to give you advance notice and the opportunity to opt-out of the business transfer based on the contact information you have provided.

SunFire will not:

  • release the names of individuals or information that could be linked to an individual, nor will the recipient present the results of data analysis (including maps) in any manner that would reveal the identity of individuals, unless otherwise necessary due to the conditions above, but in no event in violation of any agreements you have made with us in sharing your data;
  • release individual addresses, nor will the recipient present the results of data analysis (including maps) in any manner that would reveal individual addresses, unless otherwise met by conditions above;
  • use the personal information cited above in any manner inconsistent with the authority granted by you when creating your account.

3 Cookies

Like many websites, we use cookies to collect information. However, cookies, of the types listed below, are only used on the marketing webpage located at https://SunFireinc.com. A “cookie” is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies for several purposes as identified below.

The SunFire Application and its URLs, unlike the cookies mentioned above, utilize sessions. Unlike persistent cookies, sessions are deleted from your computer when you log off from the Site and then close your browser.

You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site, the Application, or all functionality of any respective services provided thereby.

4 Your rights

4.1 Changing, Correcting or Deleting Your Information

You, as a member, may review, update, correct or delete information by making the appropriate corrections on the Site. If you delete all such information, then your Account may become deactivated. However, we may retain a copy of your records in our systems to comply with our legal and regulatory requirements.

4.2 Data Access and Portability

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

4.3 Keeping and Deleting Your Data

We will keep your personal information for only so long as is necessary to serve your needs as the Patient and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely.” Please note that if you request the deletion of your Personal Information your request may be subject to further retention due to those conditions mentioned in section 2.2.

4.4 Withdrawing Consent of Processing

If we are processing your Personal Information based on your consent you may withdraw your consent at any time by reaching us using the information in Section 13 below. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit how we use your personal information, in particular, where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing and we are processing the request per our standard procedures to verify its legitimacy.

5 Changing or Deleting your Visitor Information

If you’re a Visitor and your Personal Information changes, or if you no longer desire to receive information about SunFire’s Service, you may have your Personal Information updated or removed from SunFire’s records by emailing compliance@SunFireinc.com or by contacting Us by telephone or postal mail at the contact information listed below in Section 13.

We will respond to your request within 30 days.

6 What Choices Do I Have?

  • You can always opt not to disclose information, even though it may be needed to take advantage of or register for certain features of the Service or other content made available via the Website.
  • You may request deletion of your SunFire account by sending an e-mail to compliance@SunFireinc.com.
  • If you do not wish to receive email or other mail from Us, please indicate this preference during the registration process, by changing your account settings, following the unsubscribe mechanism within the message, or by notifying Us at compliance@SunFireinc.com. Please note that if you do not want to receive legal notices from Us, such as this Privacy Statement, those legal notices will still govern your use of the Web sites, and you are responsible for reviewing such legal notices for changes periodically.

7 Security

Security of your submitted information is one of our top concerns. We have implemented industry-standard precautions to protect our Site, as well as the information we collect, from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We have also implemented access controls to safeguard against unauthorized access to our information systems. Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time. There are also certain steps you should take to safeguard your account and information. For example, you should select a secure password that only you know and should always sign out of your account when finished. Also, you should not grant access to your account to any third parties. It is your responsibility to protect the confidentiality of your password and/or credentials to prevent unauthorized access to your account. You are responsible for all activities that occur under your account and password. You should immediately change your password and notify us if you discover or suspect any unauthorized use of your account.

7.1 Fraud, Waste, and Abuse

SunFire takes pride in responsibly and ethically supporting CMS Part C and D programs. Our commitment is to report any instances of Fraud, Waste, and Abuse and allow any employee, customer, or partner to securely and anonymously, without fear of retaliation, submit a report of Fraud, Waste, or Abuse.

Report Fraud, Waste, or Abuse.

8 International Transfer

Your information will be transferred to and maintained on, computers located in the United States if you are located outside the United States and choose to provide information to us. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. If you no longer agree to the transfer of your information to the United States, please delete your account per the instructions in Section 4.

California Privacy Rights

Effective January 1, 2020, the California Consumer Privacy Act (CCPA) allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ personal information to give consumers access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of the information under certain circumstances. Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information. Please note that any information collected is by the authority and at the instruction of the VA. Please see Section 13 to facilitate requests and how to submit a request. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. For the sake of clarity, all consumer information requests will be routed to the VA as they are the body responsible for holding and maintaining your information. Consistent with California law, you may designate an authorized agent to request on your behalf. To designate an authorized agent to request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification.

We do not sell personal information to third parties. We do allow third parties to collect personal information through our Website and services and share personal information with third parties for the business purposes described in this Privacy Policy, including without limitation advertising and marketing on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices.

9 Customer Testimonials, Comments, & Reviews

We may post customer testimonials, comments, and reviews on our Web sites, which may contain Personal Information. We do obtain the Customer’s consent via email before posting the testimonial, to be able to post their name along with their testimonial. If you wish to update or delete your testimonial, you can contact us at info@SunFireinc.com.

10 Links to Other Websites

The Site may contain links to other websites. If you choose to click on a third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization, or representation of that third party of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites. These other websites may place their cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of Personal Information and the like that you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

11 Children Under 18

We are committed to protecting the privacy of children. We do not collect personal information from any person we know is a child under the age of 18 without prior approval from the parent or guardian. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at compliance@SunFireinc.com.

12 Changes to This Policy

If material changes to this Policy are made, the updated policy will be posted on the site with the accompanying revision date. SunFire may amend or update this Privacy Statement from time to time. you can review the most current version of this Privacy Statement at any time at http://www.SunFireinc.com/privacy/. Use of information We collect is subject to the Privacy Statement in effect at the time such information is used. If we make material changes in the way we use Personal Information, we will notify you by posting an announcement on the Web sites or sending you an email before the change becoming effective. Lack of notification from Us regarding a change to this policy does not invalidate any changes. You must periodically review this policy independently to note any changes. Your continued use of the Service following any such change constitutes your agreement to be bound by such changes to the Privacy Statement. Your only remedy, if you do not accept the terms of this Privacy Statement, is to discontinue use of the Service.

13 Contacting Us

If you have any questions about this Policy, please contact us at compliance@SunFireinc.com.

SunFire has appointed a Lead Privacy Officer responsible for overseeing the implementation of the privacy program across the Company. If you have any questions about this Privacy Statement or SunFire’s Web sites, please contact Us directly at info@SunFireinc.com. Written inquiries may be addressed to:

SunFire, Inc.
Lead Privacy Officer
Christopher.reed@SunFireinc.com
(321) 348-7374

We will reply to your complaint as soon as we can and in any event within 45 days. We are committed to working with you or working to route your request to the appropriate party with regards to the resolution of any complaints or concerns regarding your privacy.