Introduction: Thank you for choosing MyERBill.com, a Payment Portal used primarily by Emergency Room Doctors. MyERBill.com operating under the umbrella of Electric Data Systems, Inc. collectively referred to in this Privacy Statement as ("we" or "MyERBill" or "EDS"). We recognize the importance of protecting the privacy of all information provided by users of our web sites, recipients of our e-mail newsletters, and all of our customers. We created this policy with a fundamental respect for our users’ expectation of privacy and to guide our relationships with our users. This privacy statement discloses the privacy practices for all products and services owned by EDS.
MyERBill.com is an Internet based Bill Payment Portal. We understand that winning and keeping your trust is integral to our success. Our web site is used by Medical Professionals ("Doctors" or "Providers") and Patients. The site contains and collects sensitive patient data. This Privacy Statement outlines the measures we take to protect your privacy so that you can make an informed decision about participating in our program.
What information does MyERBill.com request, and how is this information used?
Registration: There are two distinctly different user categories on this web site. Doctors primarily use the web site for the purpose of generating patient statements with charges for Medical Services and the Patients who receive a statement from the Doctor can go to this web site and pay for a MyERBill.com produced statement. The registration process for Doctors includes personally identifiable information such as name, email, cell, and fax information. Along with the doctor registration process there is also a Medical Group registration process. It contains fee schedule information, address information, contact information, and Payment Gateway (Braintree - A PayPal service) links that are necessary for the correct routing of money receipts from patients. The registration process for providers is not automated and cannot be completed on line. Providers sign up through a manual step by step process that is described in the Provider Section of this web site.
Medical Groups are also required to register at Braintree. This is required before payments can be accepted. During that registration process, Braintree collects information about the Medical Practice. Things like Business Name, Owner or Business Manager, and Banking Information for payment forwarding is recorded during this process. Please read their privacy page as well. It describes how Braintree uses the collected data. After the Braintree registration, MyERBill requires the Braintree API keys to be registered in the MyERBill system. These keys (Merchant ID, Public Key and Private Key), link the Braintree Payment Portal with Medical Group’s bank account. MyERBill does not collect banking details from the Medical Groups.
When a patient is registered into MyERBill we use that information solely for the purpose of including that information on the patient's statement. In addition to the description of the medical service charges and diagnoses information, the provider enters the name of the patient, address, the encounter unique account number that was generated at the facility, email and cell number (email and cell are optional). This information with the exception of the diagnosis’s information is printed on the statement that the patient receives at the time of service. At that same time, the MyERBill.com server assigns an internal statement number and control number to the statement. All of those are printed on the statement as well as a QR Code. The statement link will be emailed and/or sent via SMS to the patient if this is information is provided to the attending provider. When the patient is ready to pay the bill, he or she visits MyERBill.com and enters the Statement Number, Account Number, Control Number and email (optional) into the MyERBill.com server. It validates the information and displays the total amount owed along with a fields where payment details (credit card information) can be entered. Patients are not required to register themselves at Braintree. Payment can be processed simply by entering a credit or debit card along with the card’s expiration date. If the Patient provides an e-mail address, a receipt is sent to that address. Once the card is validated by Braintree, MyERBill.com gets the transaction information with transaction id, paid by, last 4 digits of the credit card number, expiration year, and amount paid by patient. This information is associated with the statement and the statement is then marked as paid if the payment was successfully processed. Patient can also go to the Statement Payment Section by scanning the QR code on the Statement into their smart device/cell phone.
Things we do not collect: We do not collect from patients: Social Security Numbers, Maiden names of mother, birth places, full credit card number or any other information of this nature.
Other: At times, we may contact you to better understand what kind of additional content and services that may interest you. We also compile some of the information that you provide us into aggregate profile data, which we use for market and trend analysis, and other purposes. However, this will not include any personally identifiable information. This aggregate analysis is occasionally shared with our business partners.
Using Your Information Responsibly: MyERBill.com is using your information in a responsible manner. We do not collect any full credit card information or bank information from Patients. The payments are processed through a third-party payment processing company called Braintree - A Paypal service (www.braintreepayments.com). Please read their Privacy Statement for specific information about how they will safeguard and secure your information. MyERBill.com uses a Notification system that securely exchanges information with the payment processor. The information that the payment processing company provides, is logged on our server and used to update your account so that it correctly reflects that you made a payment. You cannot opt out of information disclosure that is necessary to execute, administer or enforce a transaction requested by you. We do not sell your information to 3rd parties. We will not disclose your information to third parties without giving you the opportunity to opt out of certain kinds of disclosures. In general, we will not disclose your personally identifiable information to third parties except to the extent necessary to: 1. Provide you with Bill Payment services; 2. Facilitate credit card transactions; 3. Prevent fraudulent activities; 4. Comply with any applicable law, regulation, or legal process, or; 5. Protect or enforce our rights or the rights of third party service providers.
Surveys & Contests: From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code). Contact information will be used/shared with the contest/survey sponsors to notify the winners and award prizes. Anonymous Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site. Users' personally identifiable information is not shared with third parties unless we give prior notice and choice. Though we may use an intermediary to conduct these surveys or contests, they may not use users' personally identifiable information for any secondary purposes.
Tell-A-Colleague: If a Provider elects to use our referral service for informing a colleague about our site, we ask them for the colleague's name and e-mail address. MyERBill.com will automatically send the colleague a one-time e-mail inviting them to visit the site. MyERBill.com stores this information for the sole purpose of sending this one-time e-mail and tracking the success of our referral program. The colleague may contact MyERBill.com at helpdesk@MyERBill.com to request the removal of this information from our database.
Supplementation of Information: In order for this Web site to properly fulfill its obligation to users it is necessary for us to supplement the information we receive with information from 3rd party sources. For example, to accurately maintain account balances we collect payment detail information from our payment processor. That data contains along with the financial transaction detail, information about you, such as name, address, phone number information and e-mail. It should be noted that the leaving of an e-mail and cell number address at MyERBill.com is optional for patients.
Who uses your information? MyERBill.com Personnel: We store your information in protected computer systems and we allow only authorized MyERBill.com personnel access to this information. In addition, the information is available to the Provider and his company for the purpose of maintaining their own accounting system. Access to information is provided only to MyERBill.com personnel needing the access to complete their job functions. In addition, MyERBill.com personnel are trained on the privacy policy and are held accountable to the privacy policy. Personnel violating these policies may be subject to disciplinary action, up to and including dismissal. Provider access is limited to aggregated information but it does include personally identifiable information. It is not possible to opt-out and not allow the Provider access to this accounting data.
Trusted 3rd Parties: We rely on trusted 3rd parties to fulfill your request to transfer funds. We use a payment processing company called Braintree. We selected them after carefully reviewing several payment processing companies. Braintree has their own Privacy Policy and you are encouraged to become familiar with it as well as MyERBill.com's Policy. All our transactions with 3rd parties are written and conducted in such a manner that your personal information is protected.
Use of Cookies: A cookie is a piece of data stored on the user's computer and it may contain information about the user. Usage of a cookie is in no way linked to any personally identifiable information while on our site. We use session ID cookies. When users close the browser the session ID cookie simply terminates. Cookies are necessary for the correct function of the MyERBill site. If users reject the cookie, they will be unable to use the secure areas of the MyERBill.com site.
Web Server Log File: Like most standard Web site servers we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user's movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information in the log files.
Security - Protecting Your Information
Encryption: When you enter sensitive information, we protect the communication link from your browser to our Web server by using a secure (encrypted) communication session. The encrypted communication is established using secure socket layer (SSL/TLS) technology. In addition, we store all information you provide us on our own protected servers.
Authentication Credentials - Providers: Each provider is provided with a user ID and password that is used to uniquely identify you each time you visit the site or initiate a transaction. This user ID is associated with the medical group that you belong to. If you work for two different groups you must obtain a separate user id and password for each group. We protect your user ID and password authentication credentials during the login process by encrypting the communication link with SSL/TLS.
Password - Providers: Your password is the most important element to authenticate you. We store your password in an encrypted format. Please remember to keep your password to yourself. MyERBill.com will never ask you for your password other than on the Log in Page.
Providing You with Control - Providers: We provide you with limited access to your record so you can view and update some of your information online. The information that you entered during the registration process as a part of the online procedures can be maintained by you online. The registration information that you had to provide via, facsimile or other written means must also be updated in that same manner.
Authentication Credentials - Patients: There is no traditional authentication for patients. Each Provider generated financial transaction is given unique transaction codes that cannot easily be guessed. A six-digit Statement Number along with a facility generated account number and a MyERBill.com control number need to be entered to bring the statement up on the screen. The MyERBill.com web site does not offer any more information about the patient visit than the Patient Statement itself. The three components necessary for Patient access are all printed on the Patient Statement that the system generated.
Choice/Opt out - Providers: You are provided with the choice of not having your information used, disclosed or distributed in a manner that is unrelated to the primary purpose for which the information was provided. For example, when you choose to opt out, you will be taken off of our marketing or promotional list so that you will not receive solicitations for products or services. You are provided a choice to opt out when completing the initial registration form. You can also decide to change your opt out status at any time by logging into the MyERBill.com Web site and accessing the user profile pages. Please understand that on rare occasions it is necessary to send out a strictly service-related announcement. For instance, if our service is temporarily suspended for maintenance, we might send users an e-mail. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.
What else should I know about my privacy: You should be aware that if you voluntarily disclose personal information online in a public area, that information might be collected and used by others. We do not control the actions of our visitors and registered users. If you disclose personal information in a discussion room, forum, or any other publicly accessible place on the Web site, you do so at your own risk and you understand that your submitted information may be collected and used by others.
Linking to other Web Sites: From time to time, the MyERBill.com Web site may provide links to other Web sites, not owned or controlled by MyERBill.com that we think might be useful or of interest to you. We cannot, however, be responsible for the content or privacy practices used by other Web site owners.
Warranty: Please remember that protection of your privacy begins with you. You are solely responsible for maintaining the secrecy of any password you use to register, and you should always be careful and responsible whenever disclosing information online. Although we will use reasonable efforts to safeguard the privacy of your personal information, transmissions made by means of the Internet cannot be made absolutely secure. Also, please note that we do not control the privacy policies of our third-party vendors, our advertisers and other third-party sites to which we provide banner ads and links. Accordingly, MyERBill.com assumes no liability for disclosure of any information due to errors in transmission, unauthorized acts of third parties, or resulting from information provided other than through the Web site.
Changes to MyERBill.com's Privacy Policy: If we change our Privacy Policy and/or the way we use our customers' personally identifiable information then, we will post a notice of the nature of such change on the first page of this Privacy Policy and also on our home page. If, however, we are going to use users' personally identifiable information in a manner different from that stated at the time of collection we will notify users via e-mail. Users will have a choice as to whether or not we use their information in this different manner. However, if users have deleted/deactivated their account, then they will not be contacted, nor will their personal information be used in this new manner.
Your Acceptance of MyERBill.com's Privacy Policy: By using the MyERBill.com Web site or registering with us, you signify your acceptance of this Privacy Policy. If you do not agree with any policy described in this Privacy Policy you should not use this site. We reserve the right to modify this Privacy Statement at any time. Your continued use of any portion of the Web site following notification or posting of such changes will constitute your acceptance of minor changes. This policy ("Privacy Policy") describes our practices regarding information provided by you, and is intended to help you make informed decisions concerning disclosure of information in connection with MyERBill.com's web site and related services ("Web site"). By initially using or registering on the Web site, you agree to be bound by the terms of this Privacy Policy.
Contacting Us about Privacy: If you have questions or concerns about our information privacy practices, please send an e-mail to: contactus@MyERBill.com or call 1-407-688-1025.
E-mail Communication: Please note that Internet e-mail is not a secure mode of communication. Like most non-encrypted communications, Internet e-mail communications may be accessed and viewed by other Internet users without your knowledge and permission while in transit to us. Please do not use e-mail to communicate information to us that you consider confidential.
Privacy Statement
( September, 2019 )
Introduction: Thank you for choosing MyERBill.com, a Payment Portal used primarily by Emergency Room Doctors. MyERBill.com operating under the umbrella of Electric Data Systems, Inc. collectively referred to in this Privacy Statement as ("we" or "MyERBill" or "EDS"). We recognize the importance of protecting the privacy of all information provided by users of our web sites, recipients of our e-mail newsletters, and all of our customers. We created this policy with a fundamental respect for our users’ expectation of privacy and to guide our relationships with our users. This privacy statement discloses the privacy practices for all products and services owned by EDS.
MyERBill.com is an Internet based Bill Payment Portal. We understand that winning and keeping your trust is integral to our success. Our web site is used by Medical Professionals ("Doctors" or "Providers") and Patients. The site contains and collects sensitive patient data. This Privacy Statement outlines the measures we take to protect your privacy so that you can make an informed decision about participating in our program.
What information does MyERBill.com request, and how is this information used?
Registration: There are two distinctly different user categories on this web site. Doctors primarily use the web site for the purpose of generating patient statements with charges for Medical Services and the Patients who receive a statement from the Doctor can go to this web site and pay for a MyERBill.com produced statement. The registration process for Doctors includes personally identifiable information such as name, email, cell, and fax information. Along with the doctor registration process there is also a Medical Group registration process. It contains fee schedule information, address information, contact information, and Payment Gateway (Braintree - A PayPal service) links that are necessary for the correct routing of money receipts from patients. The registration process for providers is not automated and cannot be completed on line. Providers sign up through a manual step by step process that is described in the Provider Section of this web site.
Medical Groups are also required to register at Braintree. This is required before payments can be accepted. During that registration process, Braintree collects information about the Medical Practice. Things like Business Name, Owner or Business Manager, and Banking Information for payment forwarding is recorded during this process. Please read their privacy page as well. It describes how Braintree uses the collected data. After the Braintree registration, MyERBill requires the Braintree API keys to be registered in the MyERBill system. These keys (Merchant ID, Public Key and Private Key), link the Braintree Payment Portal with Medical Group’s bank account. MyERBill does not collect banking details from the Medical Groups.
When a patient is registered into MyERBill we use that information solely for the purpose of including that information on the patient's statement. In addition to the description of the medical service charges and diagnoses information, the provider enters the name of the patient, address, the encounter unique account number that was generated at the facility, email and cell number (email and cell are optional). This information with the exception of the diagnosis’s information is printed on the statement that the patient receives at the time of service. At that same time, the MyERBill.com server assigns an internal statement number and control number to the statement. All of those are printed on the statement as well as a QR Code. The statement link will be emailed and/or sent via SMS to the patient if this is information is provided to the attending provider. When the patient is ready to pay the bill, he or she visits MyERBill.com and enters the Statement Number, Account Number, Control Number and email (optional) into the MyERBill.com server. It validates the information and displays the total amount owed along with a fields where payment details (credit card information) can be entered. Patients are not required to register themselves at Braintree. Payment can be processed simply by entering a credit or debit card along with the card’s expiration date. If the Patient provides an e-mail address, a receipt is sent to that address. Once the card is validated by Braintree, MyERBill.com gets the transaction information with transaction id, paid by, last 4 digits of the credit card number, expiration year, and amount paid by patient. This information is associated with the statement and the statement is then marked as paid if the payment was successfully processed. Patient can also go to the Statement Payment Section by scanning the QR code on the Statement into their smart device/cell phone.
Things we do not collect: We do not collect from patients: Social Security Numbers, Maiden names of mother, birth places, full credit card number or any other information of this nature.
Other: At times, we may contact you to better understand what kind of additional content and services that may interest you. We also compile some of the information that you provide us into aggregate profile data, which we use for market and trend analysis, and other purposes. However, this will not include any personally identifiable information. This aggregate analysis is occasionally shared with our business partners.
Using Your Information Responsibly: MyERBill.com is using your information in a responsible manner. We do not collect any full credit card information or bank information from Patients. The payments are processed through a third-party payment processing company called Braintree - A Paypal service (www.braintreepayments.com). Please read their Privacy Statement for specific information about how they will safeguard and secure your information. MyERBill.com uses a Notification system that securely exchanges information with the payment processor. The information that the payment processing company provides, is logged on our server and used to update your account so that it correctly reflects that you made a payment. You cannot opt out of information disclosure that is necessary to execute, administer or enforce a transaction requested by you. We do not sell your information to 3rd parties. We will not disclose your information to third parties without giving you the opportunity to opt out of certain kinds of disclosures. In general, we will not disclose your personally identifiable information to third parties except to the extent necessary to: 1. Provide you with Bill Payment services; 2. Facilitate credit card transactions; 3. Prevent fraudulent activities; 4. Comply with any applicable law, regulation, or legal process, or; 5. Protect or enforce our rights or the rights of third party service providers.
Surveys & Contests: From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code). Contact information will be used/shared with the contest/survey sponsors to notify the winners and award prizes. Anonymous Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site. Users' personally identifiable information is not shared with third parties unless we give prior notice and choice. Though we may use an intermediary to conduct these surveys or contests, they may not use users' personally identifiable information for any secondary purposes.
Tell-A-Colleague: If a Provider elects to use our referral service for informing a colleague about our site, we ask them for the colleague's name and e-mail address. MyERBill.com will automatically send the colleague a one-time e-mail inviting them to visit the site. MyERBill.com stores this information for the sole purpose of sending this one-time e-mail and tracking the success of our referral program. The colleague may contact MyERBill.com at helpdesk@MyERBill.com to request the removal of this information from our database.
Supplementation of Information: In order for this Web site to properly fulfill its obligation to users it is necessary for us to supplement the information we receive with information from 3rd party sources. For example, to accurately maintain account balances we collect payment detail information from our payment processor. That data contains along with the financial transaction detail, information about you, such as name, address, phone number information and e-mail. It should be noted that the leaving of an e-mail and cell number address at MyERBill.com is optional for patients.
Who uses your information? MyERBill.com Personnel: We store your information in protected computer systems and we allow only authorized MyERBill.com personnel access to this information. In addition, the information is available to the Provider and his company for the purpose of maintaining their own accounting system. Access to information is provided only to MyERBill.com personnel needing the access to complete their job functions. In addition, MyERBill.com personnel are trained on the privacy policy and are held accountable to the privacy policy. Personnel violating these policies may be subject to disciplinary action, up to and including dismissal. Provider access is limited to aggregated information but it does include personally identifiable information. It is not possible to opt-out and not allow the Provider access to this accounting data.
Trusted 3rd Parties: We rely on trusted 3rd parties to fulfill your request to transfer funds. We use a payment processing company called Braintree. We selected them after carefully reviewing several payment processing companies. Braintree has their own Privacy Policy and you are encouraged to become familiar with it as well as MyERBill.com's Policy. All our transactions with 3rd parties are written and conducted in such a manner that your personal information is protected.
Use of Cookies: A cookie is a piece of data stored on the user's computer and it may contain information about the user. Usage of a cookie is in no way linked to any personally identifiable information while on our site. We use session ID cookies. When users close the browser the session ID cookie simply terminates. Cookies are necessary for the correct function of the MyERBill site. If users reject the cookie, they will be unable to use the secure areas of the MyERBill.com site.
Web Server Log File: Like most standard Web site servers we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user's movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information in the log files.
Security - Protecting Your Information
Encryption: When you enter sensitive information, we protect the communication link from your browser to our Web server by using a secure (encrypted) communication session. The encrypted communication is established using secure socket layer (SSL/TLS) technology. In addition, we store all information you provide us on our own protected servers.
Authentication Credentials - Providers: Each provider is provided with a user ID and password that is used to uniquely identify you each time you visit the site or initiate a transaction. This user ID is associated with the medical group that you belong to. If you work for two different groups you must obtain a separate user id and password for each group. We protect your user ID and password authentication credentials during the login process by encrypting the communication link with SSL/TLS.
Password - Providers: Your password is the most important element to authenticate you. We store your password in an encrypted format. Please remember to keep your password to yourself. MyERBill.com will never ask you for your password other than on the Log in Page.
Providing You with Control - Providers: We provide you with limited access to your record so you can view and update some of your information online. The information that you entered during the registration process as a part of the online procedures can be maintained by you online. The registration information that you had to provide via, facsimile or other written means must also be updated in that same manner.
Authentication Credentials - Patients: There is no traditional authentication for patients. Each Provider generated financial transaction is given unique transaction codes that cannot easily be guessed. A six-digit Statement Number along with a facility generated account number and a MyERBill.com control number need to be entered to bring the statement up on the screen. The MyERBill.com web site does not offer any more information about the patient visit than the Patient Statement itself. The three components necessary for Patient access are all printed on the Patient Statement that the system generated.
Choice/Opt out - Providers: You are provided with the choice of not having your information used, disclosed or distributed in a manner that is unrelated to the primary purpose for which the information was provided. For example, when you choose to opt out, you will be taken off of our marketing or promotional list so that you will not receive solicitations for products or services. You are provided a choice to opt out when completing the initial registration form. You can also decide to change your opt out status at any time by logging into the MyERBill.com Web site and accessing the user profile pages. Please understand that on rare occasions it is necessary to send out a strictly service-related announcement. For instance, if our service is temporarily suspended for maintenance, we might send users an e-mail. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.
What else should I know about my privacy: You should be aware that if you voluntarily disclose personal information online in a public area, that information might be collected and used by others. We do not control the actions of our visitors and registered users. If you disclose personal information in a discussion room, forum, or any other publicly accessible place on the Web site, you do so at your own risk and you understand that your submitted information may be collected and used by others.
Linking to other Web Sites: From time to time, the MyERBill.com Web site may provide links to other Web sites, not owned or controlled by MyERBill.com that we think might be useful or of interest to you. We cannot, however, be responsible for the content or privacy practices used by other Web site owners.
Warranty: Please remember that protection of your privacy begins with you. You are solely responsible for maintaining the secrecy of any password you use to register, and you should always be careful and responsible whenever disclosing information online. Although we will use reasonable efforts to safeguard the privacy of your personal information, transmissions made by means of the Internet cannot be made absolutely secure. Also, please note that we do not control the privacy policies of our third-party vendors, our advertisers and other third-party sites to which we provide banner ads and links. Accordingly, MyERBill.com assumes no liability for disclosure of any information due to errors in transmission, unauthorized acts of third parties, or resulting from information provided other than through the Web site.
Changes to MyERBill.com's Privacy Policy: If we change our Privacy Policy and/or the way we use our customers' personally identifiable information then, we will post a notice of the nature of such change on the first page of this Privacy Policy and also on our home page. If, however, we are going to use users' personally identifiable information in a manner different from that stated at the time of collection we will notify users via e-mail. Users will have a choice as to whether or not we use their information in this different manner. However, if users have deleted/deactivated their account, then they will not be contacted, nor will their personal information be used in this new manner.
Your Acceptance of MyERBill.com's Privacy Policy: By using the MyERBill.com Web site or registering with us, you signify your acceptance of this Privacy Policy. If you do not agree with any policy described in this Privacy Policy you should not use this site. We reserve the right to modify this Privacy Statement at any time. Your continued use of any portion of the Web site following notification or posting of such changes will constitute your acceptance of minor changes. This policy ("Privacy Policy") describes our practices regarding information provided by you, and is intended to help you make informed decisions concerning disclosure of information in connection with MyERBill.com's web site and related services ("Web site"). By initially using or registering on the Web site, you agree to be bound by the terms of this Privacy Policy.
Contacting Us about Privacy: If you have questions or concerns about our information privacy practices, please send an e-mail to: contactus@MyERBill.com or call 1-407-688-1025.
E-mail Communication: Please note that Internet e-mail is not a secure mode of communication. Like most non-encrypted communications, Internet e-mail communications may be accessed and viewed by other Internet users without your knowledge and permission while in transit to us. Please do not use e-mail to communicate information to us that you consider confidential.