COMPLIANCE & GOVERNANCE

Privacy Policy

EFFECTIVE DATE: OCTOBER 29, 2026 JURISDICTION: STATE OF ARIZONA DOCUMENT REF: PD-AZ-POL-001

1. Operational Overview

This Privacy Policy explains how Payer Delta Arizona ("Payer Delta", "we", "us", or "our") collects, protects, utilizes, and manages business information obtained through this website (payerdelta.summithillholdings.com) and our administrative communications.

Payer Delta Arizona provides commercial denial recovery analytics, revenue integrity surveillance, and administrative appeal preparation for specialty medical practices and billing teams. In compliance with legal disclosure standards, Payer Delta Arizona is operated by Jentlemens LLC, an Arizona limited liability company with principal offices in Mesa, Arizona.

2. Zero-PHI Website Intake Policy

Strict Safe Harbor Notice: Do Not Transmit PHI Via Website

This public website, our contact links, and our introductory scheduling calendar are not HIPAA-designated repositories. Healthcare providers and prospective practice managers are strictly instructed NOT to submit Protected Health Information (PHI), patient medical records, Social Security Numbers, or raw clinical documentation through public web forms or unencrypted email channels.

Our website is designed for initial operational inquiries. Introductory calls and preliminary assessments focus strictly on practice operational volume, specialty mix, commercial payer distribution, and administrative denial backlog. If clinical or claim documentation is subsequently evaluated, it must strictly follow our Safe Harbor De-Identification protocol or our executed HIPAA Business Associate Agreement (BAA) protocol.

3. Information We Collect

We collect only the business contact information voluntarily provided during introductory communication:

  • Professional Contact Data: Practice name, representative name, professional title, corporate business email address, phone number, and physical practice location.
  • Operational Inquiries: High-level practice specialty (e.g., orthopedic surgery, ambulatory surgery, physical therapy), primary commercial payers, and estimated denial volume.
  • Technical Telemetry: Standard server access logs, IP addresses (utilized exclusively for rate limiting, DDoS defense, and infrastructure security), browser user-agent, and anonymized referral headers.

We do not use invasive tracking cookies, third-party advertising pixels, or cross-site fingerprinting scripts.

4. How We Use Information

Information collected via the website is used exclusively for legitimate business purposes:

  1. To schedule, confirm, and conduct 15-minute introductory operational calls.
  2. To evaluate whether a practice qualifies for our Free Denial Snapshot or commercial denial recovery services.
  3. To coordinate the execution of mutual Non-Disclosure Agreements (NDAs) and formal HIPAA Business Associate Agreements (BAAs).
  4. To comply with applicable Arizona statutory requirements, professional standards, and legal accounting obligations.

5. HIPAA & Dual-Track Security Architecture

Payer Delta adheres to a strict dual-track security model to eliminate data leakage and maintain absolute regulatory compliance:

Operational Track Data Boundary Permitted Documentation
Track 1: Zero-PHI Mode
(Free Denial Snapshot)		 Safe Harbor De-Identification
(45 C.F.R. § 164.514(b))		 Scrubbed 835 remittance summaries with all 18 HIPAA identifiers removed. Includes only CPT/HCPCS, CARC/RARC, billed/paid dollars, and payer names. Zero EHR access.
Track 2: Active BAA Mode
(Contracted Recovery)		 Executed HIPAA BAA
(45 C.F.R. § 164.504(e))		 Encrypted TLS 1.3 / AES-256 data exchange. Cryptographic patient tokenization, isolated memory execution, and 6-year statutory retention schedule.

For detailed technical and operational specifications, review our complete HIPAA & Data Security Protocol.

6. Data Security & Records Retention

Payer Delta employs rigorous physical, technical, and administrative safeguards:

  • Encryption in Transit: All website traffic and communications mandate TLS 1.3 encryption with strict HTTP Strict Transport Security (HSTS).
  • Encryption at Rest: Internal analytical workspaces and records utilize AES-256 encryption with full-disk workstation protection.
  • Retention Schedule: Administrative communications and compliance manifests are retained in accordance with Arizona statutory requirements (A.R.S. § 12-2297) for a minimum of six (6) years, after which records are cryptographically destroyed pursuant to NIST SP 800-88 guidelines.

7. Third Parties & Non-Sale of Data

Absolute Non-Sale Guarantee

Payer Delta Arizona never sells, rents, licenses, trades, or brokers commercial client lists, practice contacts, or operational data to any third party, data aggregator, or advertising network.

We disclose business contact information only to service providers under strict confidentiality agreements who assist in operating our infrastructure (such as secure cloud hosting and scheduling integrations), or when legally compelled by valid subpoena, court order, or binding regulatory mandate under Arizona or federal law.

8. Practice & Consumer Privacy Rights

Representatives of healthcare practices that have communicated with Payer Delta may at any time:

  • Request a summary of the business contact information we maintain on file.
  • Request the correction, updating, or deletion of corporate contact details.
  • Opt out of any follow-up emails, quarterly intelligence updates, or operational briefs.

9. Contact & Compliance Inquiries

For questions regarding this Privacy Policy, our data protection firewalls, or to exercise your information rights, contact our compliance desk:

Payer Delta Arizona — Compliance & Legal Desk
Attn: Data Privacy Officer
1155 S Power Rd, Ste 114 #595
Mesa, AZ 85206
Administrative inquiries: Schedule Administrative Consultation ↗