CLIENT ACCESS OPEN WEBSITE AND ABSOLUTE® WEB-APPLICATION PRIVACY STATEMENT Latest revised: September 7, 2021. INTRODUCTION Toyon Associates, Inc provides a website (the Website) and web-applications (the App). The Website and the App allow our clients and other users to receive the latest updates affecting the government reimbursement industry, review industry analysis, transfer data securely, automate the preparation of Medicare/Medicaid cost report, and access additional services. This Privacy Statement applies to the Website and the App, which are owned and operated by Toyon Associates, Inc. (“Toyon”). This Privacy Statement describes how Toyon collects and uses the personal information you provide on, and other information that is collected from your use of the Website and the App. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. Personal information means information that is individually identifiable. Information that has been de-identified by Toyon or others is no longer personal information and is not covered by the terms of this Privacy Statement. Toyon is committed to protecting the privacy of the users of the Website and the App. We will use and disclose your personal information as stated in this Privacy Statement. SECURITY The Website and the App have security measures in place that are intended to help protect against the loss, misuse, unauthorized access or alteration of information under our control both during transmission and once the information is received. These measures include encryption of data using the Secure Socket Layer (SSL) system. Despite these measures, the confidentiality of any communication or material transmitted to or from us via the Website or the App by Internet cannot be guaranteed. REVISIONS TO THE PRIVACY STATEMENT We may revise this Privacy Statement from time to time as we add new features or modify the way in which we manage information, or as laws change that may affect our services. If we make material changes to our Privacy Statement, we will post notice of this on our Website prior to the changes becoming effective. Any revised Privacy Statement will apply both to information we already have about you at the time of the change, and any personal information created or received after the change takes effect. We include a version number on this Privacy Statement consisting of the date (year, month, and day) it was last revised. We encourage you to periodically reread this Privacy Statement, to see if there have been any changes to our policies that may affect you. WEBSITE AND WEB-APP VISITOR DATA In addition to web logs, described below, Toyon routinely gathers data on website activity, such as how many people visit the site, the web pages, where they come from, how long they stay, etc utilizing a third-party Google Analytics service. The data is collected on an aggregate basis, which means that no personally identifiable information is associated with the data. This data helps us improve our content and overall usage. The information is not shared with other organizations for their independent use. Google and Google Analytics’ privacy policy can be reviewed at https://policies.google.com/privacy COLLECTING, USING, AND DISCLOSING PERSONAL INFORMATION Except as disclosed in this Privacy Statement, we do not collect any personally identifiable information about visitors to the Website and the App. 1. Information Collection Use We collect the following personal information from you: Contact information such as name, e-mail address, mailing address, and phone number Unique identifiers such as user name, e-mail, and password The App allows for preferences information such as user favorites and UI behavior settings Your device location We use and disclose this information to: Send you requested product or service information Respond to customer service requests Administer your account Send you newsletters or e-mail communications Respond to your questions and concerns Improve our website, app, and marketing efforts Conduct internal quality improvement or business analysis Customize your experience on the website or apps 2. Web logs According to industry standard, we gather certain information automatically. We maintain standard Web logs that record data about all visitors and customers who use the Website or the App and we store this information for no longer than reasonably useful to carry out its legitimate business purpose, or as legally required. These logs may contain the Internet domain from which you access the site (such as xfinity.com, att.com, etc.); the IP address which is automatically assigned to your computer when you get on the Internet (a static IP address may be identifiable as being connected to you, while a dynamic address is usually not identifiable); the type of browser and operating system you use; the date and time you visited; the pages you viewed; and the address of the website you linked from, if any. If you sign on to the Website or the App to use secured features, our Web logs will also contain an individual identifier and show the actions performed. All Web logs are stored securely, and may only be accessed by Toyon employees or designees on a need-to-know basis for a specific purpose. Toyon uses Web log information to help us design our Website, apps and services, to identify popular features, to resolve user, hardware, and software problems, to make the Website and the App more useful to visitors and for security purposes. 3. Internet cookies We and our service providers may place Internet “cookies” or similar technologies (JavaScript, HTML5, ETag) on the computer hard drives of visitors to the Website or the App. Information we obtain helps us to tailor our site and the App to be more helpful and efficient for our visitors. For example, we are able to see the navigation path taken by users, and that information allows us to understand user success or challenges with the web experience. The cookie consists of a unique identifier that does not contain information about your health history. We use two types of cookies, “session” cookies and “persistent” cookies, along with other similar technologies. A session cookie is temporary, and expires after you end a session and close your web or app browser. We use session cookies to help customize your experience on our site, maintain your signed-on status as you navigate through our features, and to track actions performed. Persistent cookies remain on your hard drive after you’ve exited from our website, and we may use them for several reasons. For instance, restricting access or storing the UI display behavior within the App. You may have software on your computer that will allow you to decline or deactivate Internet cookies, but if you do so, some features of the Website or the App may not work properly for you. For instructions on how to remove cookies from your hard drive, go to your browser’s website for detailed instructions. In addition, further information regarding cookies may be available on other websites or from your Internet service provider. Safari, Chrome, Firefox, Internet Explorer and iOS browsers are commonly used browsers. DISCLOSURES We may also disclose your personal information: as required by law, such as to comply with a subpoena, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect you or others safety from threats of imminent harm, investigate fraud or other activity in violation of the law, or respond to lawful request by public authorities (including to meet national security or law enforcement requirements) to protect the security and reliability of the Website and the App if Toyon is involved in a merger, acquisition, or sale of all or a portion of its assets. You will be notified via e-mail and/or a prominent notice on our Website or the App of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information to any other third party with your prior consent to do so to Toyon contracted entities to carry out business planning and development and business management and general administrative activities, such as to provide, maintain and personalize our sites and services, and to communicate with you DATA RETENTION We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy statement, including to meet our legal obligations, resolve disputes, and enforce our agreements, unless a longer retention period is required or permitted by law. SOCIAL MEDIA AND LINKS TO THIRD PARTY WEBSITES Our Website may include social media features and links to Toyon accounts on Facebook, Twitter, YouTube, and LinkedIn. These social media sites and their features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy statement of the company providing them. Our Website and the App include links to other websites whose privacy practices may differ from those of Toyon. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit. QUESTIONS, COMPLAINTS, AND CONTACTS If you have any questions about this Privacy Statement, our policies and practices concerning the Website or the App, your rights under this statement, and your dealings with the Toyon’s Website or the App, you can contact Toyon Associates, Inc by telephone at 1-888-514-9312 (toll free) or via e-mail at info@toyonassociates.com “I truly feel that Toyon’s Absolute® will make your reporting more efficient…once you begin working with Absolute, you’ll wonder how you ever worked without it. Absolute also eliminates the annoyance of not being able to find support for work papers because your analysts can easily upload them to Absolute and attach to the applicable sheet.” Antoinette L. Washington, Manager Regulatory Compliance Methodist Health System HERE TO HELP Receive a no obligation consultation on how Toyon can help make your cost reporting simpler, easier, and trusted. 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