This Customer Portal Privacy Policy explains how Aquila Health PBC (“Aquila,” “we,” “us,” or “our”) processes information associated with authorized users of Aquila’s customer administration, support, reporting, implementation, and service-management portals.
This policy applies to individuals who access a customer portal on behalf of an employer, customer, government agency, health care organization, health information exchange, payer, provider, business partner, or other organization.
The portal is a business service and is not intended for general public use.
Relationship Between Aquila and the Customer
Aquila processes different categories of information in different roles.
Account and Business Relationship Information
Aquila generally determines how it processes portal account information, business contact information, portal security information, and information used to manage Aquila’s relationship with a customer.
For this information, Aquila ordinarily acts as the organization responsible for the processing, subject to applicable law.
Customer-Controlled Data
Customers may submit, connect, transmit, or make information available through the portal or associated Aquila services. This may include business records, technical data, health information, personal information, or other customer content.
For customer-controlled data, Aquila ordinarily acts on the customer’s documented instructions as a service provider, processor, contractor, or HIPAA business associate, as applicable.
The applicable customer agreement, data processing agreement, business associate agreement, statement of work, data use agreement, authorization, or other written instruction controls Aquila’s processing of customer-controlled data.
If this policy conflicts with an applicable written customer agreement concerning customer-controlled data, the written agreement controls.
Information We Process
Portal Account Information
Aquila may process:
- Name
- Business email address
- Telephone number
- Employer or affiliated organization
- Department, title, or professional role
- Username or account identifier
- Authentication information
- Multifactor authentication status
- Account permissions
- Customer organization identifier
- Account status
Aquila does not need access to a user’s plaintext password. Passwords should be stored using appropriate one-way cryptographic protections or managed through an approved identity provider.
Portal Activity and Security Information
We may process:
- Login and logout events
- IP address
- Browser and device information
- Authentication attempts
- Administrative actions
- Reports viewed or exported
- Configuration changes
- API or integration activity
- Support interactions
- Security alerts
- Audit events
- Date and time information associated with portal activity
Portal activity may be visible to authorized administrators of the organization through which you received access.
Portal users should not expect that business activity conducted through a customer account is private from the customer organization that owns or administers that account.
Customer Content
Depending on the services purchased by a customer, customer content may include:
- Organizational records
- Technical and integration information
- Data-quality reports
- System configurations
- User and access-control records
- Health care operations information
- Patient, member, or consumer information
- Protected health information
- Claims or clinical information
- Support files
- Audit and provenance records
- Other data selected by the customer
The customer—not the individual portal user—generally determines which customer content is submitted and for what authorized purposes it is processed.
Support Information
When you request support, Aquila may process the contents of your request, related communications, screenshots, attachments, diagnostic information, and information reasonably necessary to investigate or resolve the request.
Do not place PHI or other sensitive customer data in a support request unless the support channel is approved for that purpose and the information is necessary to resolve the issue.
How Aquila Uses Portal Information
Aquila may use account, business relationship, and portal activity information to:
- Establish and administer accounts
- Authenticate users
- Apply role-based access controls
- Provide purchased services
- Maintain and improve portal functionality
- Provide implementation, support, training, and customer service
- Communicate about service availability and changes
- Monitor performance
- Maintain audit records
- Investigate suspected misuse
- Detect and respond to cybersecurity threats
- Manage contracts, billing, and customer relationships
- Meet legal and regulatory obligations
- Establish, exercise, or defend legal claims
- Conduct internal business planning
- Create aggregated or de-identified operational information
Aquila processes customer-controlled data only for purposes permitted by the applicable customer agreement, documented customer instructions, valid individual authorization, or applicable law.
Aquila does not use customer-controlled PHI or personal health data for unrelated advertising or the independent marketing of third-party products.
Customer Administrators
The customer organization may appoint administrators who can:
- Create or disable user accounts
- Assign permissions
- Review portal activity
- Manage configurations
- Access customer reports or content
- Investigate suspected misuse
- Request that Aquila take action concerning a user account
Questions about access granted by a customer organization should generally be directed to that organization’s administrator.
Aquila may follow instructions from an authorized customer administrator unless Aquila reasonably believes the instruction is unauthorized, unlawful, technically infeasible, or inconsistent with an applicable agreement.
How Information Is Disclosed
Aquila may disclose portal information to:
The Customer Organization
Account, activity, and customer content may be available to authorized representatives of the customer organization.
Service Providers and Subcontractors
Aquila may use vetted providers for cloud infrastructure, communications, identity management, monitoring, security, support, professional services, and other functions.
Where a provider will process customer-controlled data, Aquila will impose contractual restrictions appropriate to Aquila’s role and the applicable customer agreement. Where required, Aquila will enter into a business associate agreement or data protection agreement with the provider.
Integration Partners
Information may be transmitted to an integration, data source, recipient, or other system selected or authorized by the customer.
Legal and Safety Purposes
Aquila may disclose information when reasonably necessary to comply with applicable law or legal process, investigate misconduct, protect a system or person, or establish, exercise, or defend legal claims.
Where legally permitted and contractually appropriate, Aquila may direct a request for customer-controlled data to the customer or notify the customer before disclosure.
Corporate Transactions
Information may be disclosed in connection with a merger, financing, acquisition, restructuring, bankruptcy, sale of assets, due diligence review, or similar corporate transaction, subject to applicable contractual and legal requirements.
Protected Health Information
Aquila may process PHI through a customer portal when Aquila is performing services for a HIPAA covered entity or another business associate.
When Aquila acts as a business associate:
- Aquila’s use and disclosure of PHI is governed by the applicable BAA and HIPAA requirements applicable to Aquila
- The covered entity or upstream business associate determines the permitted purpose of the processing
- Aquila does not independently determine the patient-facing purposes for which the PHI is used
- Individual HIPAA requests generally must be submitted to the covered entity or other organization responsible for the designated record set
- This Customer Portal Privacy Policy is not a HIPAA Notice of Privacy Practices and does not replace the covered entity’s notice
- Aquila may assist a customer with an individual request to the extent required by the BAA or applicable law
Cookies and Portal Telemetry
The portal may use cookies and similar technologies that are necessary to:
- Authenticate users
- Maintain a secure session
- Prevent fraud
- Remember portal settings
- Monitor performance
- Diagnose problems
- Maintain security logs
Aquila does not use customer portal activity or customer-controlled data for cross-context behavioral advertising. Disabling essential cookies may prevent portal access.
De-Identified and Aggregated Information
Where permitted by the applicable agreement and law, Aquila may generate aggregated or de-identified information to:
- Measure service performance
- Improve data quality
- Develop operational benchmarks
- Detect reliability or security trends
- Improve Aquila services
- Conduct lawful research or analysis
Aquila will apply appropriate safeguards against re-identification. Where information was de-identified from PHI, Aquila will apply the applicable HIPAA de-identification standard or another method authorized by the customer and permitted by law.
Pseudonymized data remains subject to applicable contractual and legal protections when it can be attributed to an individual using separately maintained information.
Retention
Aquila retains portal account, activity, and customer-controlled information according to:
- The customer agreement
- Customer instructions
- Aquila’s records-management requirements
- Applicable law
- Security and audit needs
- Dispute-resolution requirements
- Legitimate business needs associated with the customer relationship
Customer-controlled data may be returned, deleted, transferred, isolated, or retained at the end of services as required by the applicable agreement or law.
Aquila may retain information when deletion is not technically feasible from an active backup cycle, provided the information remains protected and is not restored for ordinary business use except as necessary for recovery, security, or legal purposes.
Audit, fraud-prevention, billing, and security records may be retained after account closure when reasonably necessary.
Security
Aquila maintains a risk-based security and privacy program informed by recognized NIST frameworks and designed to protect the confidentiality, integrity, and availability of information.
Controls may include:
- Role-based access
- Least-privilege administration
- Multifactor authentication
- Encryption in transit and at rest
- Logging and monitoring
- Secure software-development practices
- Vulnerability management
- Incident response
- Workforce training
- Vendor risk management
- Periodic testing or assessment
Security controls are selected based on risk, system design, customer requirements, and applicable law. No system can be guaranteed to prevent every security event.
Portal users must protect their credentials, comply with customer security requirements, and promptly report suspected unauthorized access.
Security Incidents
Aquila investigates suspected security incidents and provides notices to customers, regulators, individuals, or others when required by applicable law or contract.
Nothing in this policy creates a notification obligation beyond the applicable legal or contractual requirement.
Portal users should immediately report suspected compromise to [Security Contact].
Individual Privacy Requests
For account and business contact information controlled by Aquila, an individual may submit an applicable privacy request to [Privacy Email].
For customer-controlled information, including most PHI and customer records, requests should ordinarily be directed to the customer organization. If Aquila receives such a request directly, Aquila may:
- Refer the requester to the customer
- Forward the request to the customer
- Ask the customer for instructions
- Take another action required by the applicable agreement or law
Aquila may verify a requester’s identity and authority before acting. Rights are subject to applicable exemptions, thresholds, and limitations.
Aquila is not required to alter a source medical record, claims record, organizational record, or other customer-controlled record unless instructed by the responsible customer or required by law.
Children
The customer portal is intended for authorized workforce members and professional users. It is not directed to children and may not be used by a minor except where expressly authorized by the customer, permitted by Aquila, and supported by all legally required permissions.
United States Processing
Unless an applicable customer agreement states otherwise, Aquila’s customer portals are provided from the United States and information may be processed in the United States.
Any geographic, residency, data-location, or personnel-access restriction applicable to customer-controlled data must be stated in the applicable agreement or service documentation.
Changes to This Policy
Aquila may update this policy as portal practices, services, or legal requirements change.
Aquila will provide additional notice of a material change where required by law or an applicable customer agreement. Changes to customer-controlled data practices remain subject to the customer agreement and cannot be expanded through this public policy alone.