Do the right thing, every time!
Theia Health Services, Inc. has a commitment to compliance. It is important to us that we provide a principled and compassionate approach to every single individual we serve.
Theia Health Services has a compliance program that requires our employees to do their jobs the right way every day. The program is modeled after the Office of Inspector General’s Seven Elements of an Effective Compliance Program. We screen all potential employees to ensure they meet background screening requirements and are eligible to participate in federal healthcare programs. We distribute our Code of Conduct book during an employee’s first days on the job. We want our employees to understand their responsibility to not only adhere to these principles of conduct, but also actively participate in and promote compliance within their workplace. We are committed to the ideals of our mission and our Code of Conduct. We are equally committed to ensuring that our actions consistently reflect our words. In this spirit, Theia Health Services’ mission is to impact communities for the better and create optimal environments for people in need of assistance through attentive and quality service principles, so that they can live their best life.
We expect all of our colleagues’ actions to reflect the high standards set forth in the Code of Conduct. However, no Code of Conduct can substitute for our own internal sense of ethics, honesty and integrity.
If our employees or contractors find themselves in a situation that “does not feel right,” we encourage them to speak to a supervisor, the next level supervisor, business line management or the compliance department. If an employee does not feel comfortable talking to someone within the company about the issue, he or she can call an external toll-free Compliance Action Line at 866.293.3863 to report concerns 24 hours a day. Callers may remain anonymous when they report their concerns. Employees and contractors can also report anonymously through our website.
Pursuant to section 6032 of the federal Deficit Reduction Act of 2005 (DRA), all contractors and agents of Theia Health must comply with and abide by Theia’s policies for preventing fraud, waste and abuse.
This law applies to any contractor or agent who, on behalf of Theia Health, furnishes or otherwise authorizes the furnishing of Medicaid health care services, supplies products used in Medicaid health care service delivery, or monitors Medicaid health care services provided by Theia Health.
Contractors or agents should download and disseminate the following policies to all employees or sub-contractors involved in Theia Health business activities:
This Website is offered and available to users who are 18 years of age or older. By using this Website, you represent and warrant that you are 18 years of age or older. If you are not 18 years of age or older, you must not use or access this Website.
BrightSpring operates the Website from its headquarters in the United States, and the Website is generally only intended for users within the United States. If you do not reside in the United States or in any of its territories or possessions, you warrant that you will only use the Website in a manner that complies with all laws and regulations applicable to you.
Accessing the Website
We reserve the right to withdraw or amend the Website, and any service or material we provide on the Website, in our sole discretion without notice. We will not be liable if for any reason all or any part of the Website is unavailable at any time or for any period. From time to time, we may restrict access to some parts of the Website, or the entire Website to users.
To access some of the resources that the Website offers, you may be asked to provide certain registration details or other information. It is a condition of your use of the Website that all of the information you provide on the Website is correct, current, and complete.
Changes to the Website
We may update the content of the Website from time to time, but its contents are not necessarily complete or up-to-date. Any of the material on the Website may be out-of-date at any given time, and we are under no obligation to update such material.
Intellectual Property Rights
The Website and its entire contents, features and functionality (including, but not limited to, all information, software, text, displays, images, video and audio, and the design, selection and arrangement thereof) are owned by Theia Health, its licensors or other providers of such material and are protected by United States and international copyright, trademark, patent, trade secret and other intellectual property or proprietary rights laws.
The Theia Health, ProTriage, and iTHEORY are the logos, trademarks, and service marks of Theia Health. You must not use such marks without the prior written permission of Theia Health. All other trademarks, product marks, service marks, designs, and logos used in the Website are the trademarks, service marks, or logos of their respective owners.
Your computer may temporarily store copies of such material in RAM incidental to your accessing and viewing this material.
You may store files that are automatically cached by your Web browser for display enhancement purposes.
You may print one copy of a reasonable number of pages of the Website for your own personal, non-commercial use. Those pages may not be further copied, republished, posted modified, edited, transmitted, distributed, used to create derivate works of, or reverse engineered.
In any way that violates any applicable federal, state, local or international law or regulation (including, without limitation, any laws regarding the export of data or software to and from the United States or other countries).
For the purpose of exploiting, harming or attempting to exploit or harm minors in any way by exposing them to inappropriate content, asking for personally identifiable information, or otherwise.
To transmit, or procure the sending of, any advertising or promotional material without our prior written consent, including any “junk mail,” “chain letter,” “spam,” or any other similar solicitation.
To impersonate or attempt to impersonate Theia Health, a Theia Health employee, another user, or any other person or entity (including, without limitation, by using email addresses or screen names associated with any of the foregoing).
To engage in any other conduct that restricts or inhibits anyone’s use or enjoyment of the Website, or which, as determined by us, may harm Theia Health or users of the Website or expose them to liability.
Additionally, you agree not to:
Modify copies of any materials from the Website.
Delete or alter any notices of copyright, trademark, or other proprietary rights from copies of materials from the Website.
Access or use for any commercial purposes any part of the Website or any services or materials available through the Website.
Use the Website in any manner that could disable, overburden, damage, or impair the Website or interfere with any other party’s use of the Website, including their ability to engage in real-time activities through the Website.
Use any robot, spider, or other automatic device, process, or means to access the Website for any purpose, including monitoring or copying any of the material on the Website.
Use any manual process to monitor or copy any of the material on the Website or for any other unauthorized purpose without our prior written consent.
Use any device, software or routine that interferes with the proper working of the Website.
Introduce any viruses, Trojan horses, worms, logic bombs, or other material which is malicious or technologically harmful.
Attempt to gain unauthorized access to, interfere with, damage or disrupt any parts of the Website, the server on which the Website is stored, or any server, computer or database connected to the Website.
Attack the Website via a denial-of-service attack or a distributed denial-of-service attack.
Otherwise attempt to interfere with the proper working of the Website.
Enforcement and Termination
We have the right to:
Disclose your identity or other information about you to any third party who claims that material posted by you violates their rights, including their intellectual property rights or their right to privacy.
Take appropriate legal action, including without limitation, referral to law enforcement, for any illegal or unauthorized use of the Website.
Without limiting the foregoing, we have the right to fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity or other information of anyone posting any materials on or through the Website. YOU WAIVE AND HOLD HARMLESS BRIGHTSPRING AND ITS AFFILIATES, LICENSEES, AND SERVICE PROVIDERS FROM ANY CLAIMS RESULTING FROM ANY ACTION TAKEN BY ANY OF THE FOREGOING PARTIES DURING OR AS A RESULT OF THEIR INVESTIGATIONS AND FROM ANY ACTIONS TAKEN AS A CONSEQUENCE OF INVESTIGATIONS BY EITHER SUCH PARTIES OR LAW ENFORCEMENT AUTHORITIES.
Reliance on Information Posted
The information presented on or through the Website is made available solely for general information purposes. We do not warrant the accuracy, completeness or usefulness of this information. Any reliance you place on such information is strictly at your own risk. We disclaim all liability and responsibility arising from any reliance placed on such materials by you or any other visitor to the Website, or by anyone who may be informed of any of its contents.
The Website may include content provided by third parties. All statements and/or opinions expressed in these materials, and all articles and responses to questions and other content, other than the content provided by BrightSpring, are solely the opinions and the responsibility of the person or entity providing those materials. These materials do not necessarily reflect the opinion of Theia Health. We are not responsible, or liable to you or any third party, for the content or accuracy of any materials provided by any third parties.
Information About You and Your Visits to the Website
The Children’s Online Privacy Protection Act requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13 years of age. This Website is offered and available to users who are 18 years of age or older. If you are not 18 years of age or older, you must not use or access this Website. We do not knowingly collect or solicit personally identifiable information from children under 13 years of age. If we learn that we have collected personal information from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided personal information to us, please
contact us at:
Chief Compliance Officer
Theia Health Services
Linking to the Website
You may link to our homepage, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval, or endorsement on our part without our express written consent. You may not deep link to any other page other than the Website’s homepage. You may not establish a link from any website that is not owned by you. You agree to cooperate with us in causing any unauthorized framing or linking to cease immediately. You may not cause the Website, or portions of it, to be displayed on, or appear to be displayed on, any other site, for example, framing, deep linking, or in-line linking.
We reserve the right to withdraw linking permission without notice, and we may disable all or any links at any time without notice in our sole discretion.
Links from the Website
If the Website contains links to other sites and resources provided by third parties, these links are provided for your convenience only. This includes links contained in advertisements, including banner advertisements and sponsored links. The placement and appearance of third-party advertisements on the Website is not meant to suggest that BrightSpring endorses or approves of the advertiser, advertisement, advertiser’s site, or any of the products and/or services being advertised. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. If you decide to access any of the third-party websites linked to this Website, you do so entirely at your own risk and subject to the terms and conditions of use for such websites.
Disclaimer of Warranties
You understand that we cannot and do not guarantee or warrant that files available for downloading from the Internet or the Website will be free of viruses or other destructive code. You are responsible for implementing sufficient procedures and checkpoints to satisfy your particular requirements for anti-virus protection and accuracy of data input and output, and for maintaining a means external to our site for any reconstruction of any lost data. TO THE FULLEST EXTENT PROVIDED BY LAW, WE WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE CAUSED BY A DISTRIBUTED DENIAL-OF-SERVICE ATTACK, VIRUSES, OR OTHER TECHNOLOGICALLY HARMFUL MATERIAL THAT MAY INFECT YOUR COMPUTER EQUIPMENT, COMPUTER PROGRAMS, DATA, OR OTHER PROPRIETARY MATERIAL DUE TO YOUR USE OF THE WEBSITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE OR TO YOUR DOWNLOADING OF ANY MATERIAL POSTED ON IT, OR ON ANY WEBSITE LINKED TO IT.
YOUR USE OF THE WEBSITE, ITS CONTENT, AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE IS AT YOUR OWN RISK. THE WEBSITE, ITS CONTENT AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITHOUT ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. NEITHER BRIGHTSPRING NOR ANY PERSON ASSOCIATED WITH BRIGHTSPRING MAKES ANY WARRANTY OR REPRESENTATION WITH RESPECT TO THE COMPLETENESS, SECURITY, RELIABILTY, QUALITY, ACCURACY, OR AVAILABILITY OF THE WEBSITE. WITHOUT LIMITING THE FOREGOING, NEITHER BRIGHTSPRING NOR ANYONE ASSOCIATED WITH BRIGHTSPRING REPRESENTS OR WARRANTS THAT THE WEBSITE, ITS CONTENT, OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE WILL BE ACCURATE, RELIABLE, ERROR-FREE, OR UNINTERRUPTED, THAT DEFECTS WILL BE CORRECTED, THAT OUR SITE OR THE SERVER THAT MAKES IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS, OR THAT THE WEBSITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE WILL OTHERWISE MEET YOUR NEEDS OR EXPECTATIONS.
TO THE FULLEST EXTENT PROVIDED BY LAW, BRIGHTSPRING HEREBY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, STATUTORY, OR OTHERWISE, INCLUDING BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT, AND FITNESS FOR PARTICULAR PURPOSE.
THE FOREGOING DOES NOT AFFECT ANY WARRANTIES THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.
Limitation of Liability
TO THE FULLEST EXTENT PROVIDED BY LAW, IN NO EVENT WILL BRIGHTSPRING, ITS AFFILIATES, OR THEIR LICENSORS, SERVICE PROVIDERS, EMPLOYEES, AGENTS, OFFICERS, OR DIRECTORS BE LIABLE FOR DAMAGES OF ANY KIND, UNDER ANY LEGAL THEORY, ARISING OUT OF OR IN CONNECTION WITH YOUR USE, OR INABILITY TO USE, THE WEBSITE, ANY WEBSITES LINKED TO IT, ANY CONTENT ON THE WEBSITE OR SUCH OTHER WEBSITES, INCLUDING ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO, PERSONAL INJURY, PAIN AND SUFFERING, EMOTIONAL DISTRESS, LOSS OF REVENUE, LOSS OF PROFITS, LOSS OF BUSINESS OR ANTICIPATED SAVINGS, LOSS OF USE, LOSS OF GOODWILL, LOSS OF DATA, AND WHETHER CAUSED BY TORT (INCLUDING NEGLIGENCE), BREACH OF CONTRACT, OR OTHERWISE, EVEN IF FORESEEABLE.
THE FOREGOING DOES NOT AFFECT ANY LIABILITY THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.
Choice of Law and Venue
Limitation on Time to File Claims
Waiver and Severability
SOURCES OF THE INFORMATION WE COLLECT
(a) On our Websites;
(b) In email messages between you and any of the Websites; and
(c) Through cookies included on the Websites.
TYPES OF INFORMATION WE MAY COLLECT; HOW WE COLLECT INFORMATION; AND HOW WE RESPOND TO “DO NOT TRACK” SIGNALS
Types of Information We Collect
We collect several types of information from and about users of our Websites, including information:
- By which you may be personally identified, such as your name, email address, postal address, telephone number, and any other information which you submit voluntarily to us (“Personally Identifiable Information” or “PII”). You may decide whether or not to provide us with PII, but if you choose not to do so, you may not get full functionality from the Website.
- About your Internet connection, the equipment you use to access our Websites and usage details (g., language), and browsing history, such as your navigation within the Websites and which portion(s) of the Websites you used the most.
How We Collect Information
We collect this information in the following ways:
- Directly from you when you voluntarily provide it to us; and
- Automatically when you navigate through the Websites (g., information collected through cookies).
Information That You Provide Voluntarily
We may collect PII information which you submit voluntarily to us. We collect this information directly from you when you provide it to us, such as, for example, when you provide the information:
- On the Websites contact form.
- When you subscribe to a newsletter on the Websites.
- When you otherwise submit it to us, such as when you send us your resume.
- We may also ask you for information when you report a problem on our Websites.
Non-Personally Identifiable Information Collected Automatically
- Details regarding your visit(s) to the Website (g., pages visited),
- Browser information (g., browser name, viewport or viewing pane); and
- User information (g., language).
Google does not identify individual users or associate your anonymized IP address with any other data held by Google. For information regarding how Google uses data when you use our site, see https://policies.google.com/technologies/partner-sites.
By utilizing this Website, you consent to the use of such automatic data collection techniques (e.g., browser cookies). Browser cookies are small files placed on the hard drive of your computer. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Please note that if you turn cookies off, some of the features that make your site experience more efficient may not function properly.
How We Respond to “Do Not Track” Signals
We do not track our visitors over time and across third-party websites. As a result, we do not respond to Do Not Track signals.
HOW WE USE AND/OR DISCLOSE INFORMATION THAT WE COLLECT
We do not sell visitors’ PII. We may use and/or disclose PII we collect about you as follows:
- To present the Websites and their contents to you;
- To provide you with information, products, and/or services that you request from us. For example, when you complete and submit the Contact Us form, we only use that information to respond to your inquiry. By submitting this information to us, you consent to our use of the information to respond to your request. If you complete and submit the Contact Us form for information about a particular service, we will use the information you submit to provide you with that information.
- To fulfill any other purpose for which you provide PII.
- To our contractors and/or vendors, but only for the reason(s) for which you submitted the information to our Websites. These contractors and/or vendors are bound by contractual obligations to keep PII confidential and only use it for the purpose for which we disclose it to them.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- To comply with any court order, law, legal process, to respond to any government or regulatory request, and/or to protect or defend our interests or the interests of users of our Websites.
- If we believe that disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some of all of our assets, whether as a going concern or as part of a bankruptcy proceeding, liquidation, or similar proceeding, in which the information, if any, that we hold about the users of our Websites is among the assets transferred.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
We may use the anonymized information we collect through cookies (e.g., anonymized web browser, operating systems, pages visited) to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
DATA SECURITY AND RETENTION
We have implemented physical, technical, and administrative safeguards to protect the security of the PII that you submit to us through our Websites from accidental loss and unauthorized access, use, alteration, and disclosure. We will only retain PII for the length of time necessary to fulfill the purpose for which the PII was submitted or longer, if required by law.
The security of the information we collect about you also depends on you. For example you are responsible for keeping any passwords related to all of these Websites confidential. The transmission of information via the Internet is not completely secure. We cannot guarantee the security of your PII when it is being transmitted to the Websites. Any information which you transmit to the Websites is at your own risk. We are not responsible for circumvention of any privacy setting or security measures contained on the Websites.
CHILDREN UNDER THE AGE OF 13
These Websites are not intended for children under 13 years of age. No one under age 13 may provide any personal information on the Websites. We do not knowingly collect personal information from children under 13 years of age. If you are under 13 years of age, do not use or provide any information on the Websites or on or through any of the features on the Websites or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name. If we learn that we have collected or received personal information from a child less than 13 years of age without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child less than 13 years of age, please contact our Chief Compliance Officer as follows:
Chief Compliance Officer
Theia Health Services, Inc.
CALIFORNIA PRIVACY RIGHTS
Pursuant to the California “Shine the Light” law, California residents may request certain information regarding businesses’ disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.
Pursuant to the California “Consumer Right to Privacy Act of 2018,” California residents may request the following information from us by contacting us as indicated below:
- The categories of personal information we have collected about the consumer.
- The categories of sources from which we collected personal information.
- Our business or commercial purpose for collecting or selling the information.
- The categories of third parties with whom we share personal information.
- The specific pieces of personal information we collected about the consumer.
California residents may also request that we delete any personal information about them which we have collected from the consumer except information collected in certain situations, such as, for example, to complete the transaction for which the information was provided; provide a good or service requested by the consumer; detect security incidents and protect against malicious, deceptive fraudulent, or illegal activity; comply with a legal obligation; and otherwise use the personal information internally in a lawful manner that is compatible with the context in which the consumer provided the information or the consumer’s expectations based on the consumer’s relationship with us.
CANADIAN PRIVACY RIGHTS
Pursuant to the Personal Information Protection and Electronic Documents Act, Canadian visitors to our Websites may also request an accounting of the third parties to whom personal information about them has been disclosed and the uses that have been made of their information.
LINKS TO THIRD-PARTY WEBSITES
We seek to protect the integrity of our site and welcome any feedback about the third-party website links included on our Websites. You may provide such feedback via the Contact Us link on the homepages of our Websites.
HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (“HIPAA)
To the extent that any of the information we collect on our Websites constitutes Protected Health Information (“PHI”) under HIPAA, we will comply with the requirements of HIPAA and its implementing regulations.
Chief Compliance Officer
Theia Health Services, Inc.