Last Updated: May 2018
1. What information do we collect, and how do we collect it?
We and our third party service providers (“Contractors”) may collect certain information from or about you in connection with your use of, or your submissions to or via, the Site (“Collected Information”), including, but not limited to, your name, title, street address, date of birth, health status, company, telephone and fax numbers, credit card number and billing address, and email addresses. In addition, we and our Contractors may retain the content of, and metadata regarding, any correspondence you may have with us or our representatives, regardless of the mode of communication by which such correspondence was made. This information helps us to improve the Site and the online content, materials, and services that we make available on the Site, and to more effectively and efficiently respond to both current and future inquiries.
To use certain features of the Sites or its content, you may need a username and password. You are responsible for maintaining the confidentiality of the username and password, and you are responsible for all activities, whether by you or by others, that occur under your username or password and within your account. We cannot and will not be liable for any loss or damage arising from your failure to protect your username, password or account information. If you share your username or password with others, they may be able to obtain access to your Personal Data at your own risk.
You agree to notify us immediately of any unauthorized or improper use of your username or password or any other breach of security. To help protect against unauthorized or improper use, make sure that you log out at the end of each session requiring your username and password.
We will use our best efforts to keep your username and password(s) private and will not otherwise share your password(s) without your consent, except as necessary when the law requires it or in the good faith belief that such action is necessary, particularly when disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to others or interfering with our rights or property.
We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies”, which are text files placed on your computer, to help the Site analyze how users use the site. You can find out more about how Google uses data when you visit our Site by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/).
We also use Google Analytics Advertiser Features to optimize our business. Advertiser features include: Remarketing with Google Analytics; Google Display Network Impression Reporting; DoubleClick Platform integrations; Google Analytics Demographics and Interest Reporting.
2. How will we use the information you provide to us?
In addition to the uses described above, we and our Contractors may use Collected Information to analyze and improve the content, materials, and services that we make available on the Site, to notify you of changes made to the Site, to evaluate user needs and improve the Site content based on those needs, to provide customer service or support, improve users’ online experience, or support our continuing efforts to offer users the information and services we think they want most. If you contact us for support or assistance, we may use Collected Information for purposes such as verifying whether your system meets the minimum requirements needed to use the Site and our various services.
We may also use e-mail addresses you provide to us in order to send you announcements regarding new products, services, and/or promotions, and informational newsletters. By posting material on any of our interactive areas within the Site, you are opting in to receiving these e-mail announcements. You can choose to unsubscribe to our e-mails at any time by sending an email to unsubscribe to email@example.com.
We may contact you with information that you provide to us based on these lawful grounds for processing:
- Consent. We may contact you if you give us your clear, unambiguous, affirmative consent to contact you.
- Contract. We will contact you under our contractual obligation to deliver goods or services you purchase from us.
- Legitimate Interest. We may contact you if we feel you have a legitimate interest in hearing from us. For example, if you sign up for a webinar, we may send you marketing emails based on the content of that webinar. You will always have the option to opt out of any of our emails.
We will use the Personal Data you give to us in order to process your payment for the purchase of goods or services under a contract. We only use third party payment processors that take the utmost care in securing data and comply with the GDPR.
COLLECTION OF NON-PERSONALLY IDENTIFIABLE INFORMATION
When visitors do not register with or provide any personally identifiable information to HHCA, certain non-personal information about use of the HHCA Website might be collected. “Non-Personal Information” means information that cannot be used to identify a particular individual or contact such individual.
3. With whom do we share the information we collect?
We may share Collected Information with certain of our Contractors (e.g., our web hosting provider) in order to provide the Site to you. We may also share Collected Information with some of our business and marketing partners in furthering our mission as an organization or delivering the content, materials, and services available on or through the Site to you. We and our Contractors may also produce reports on Site traffic or usage patterns and share these reports with our business and marketing partners and others.
We may disclose Collected Information to the proper authorities if we become subject to a subpoena or court order or if we believe we are otherwise legally required to disclose such information. We may also use and disclose information about you to establish or exercise our legal rights, to assert and defend against legal claims, or if we believe such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person.
If all or part of HHCA is sold, merged, or otherwise transferred to another entity, we may transfer Collected Information to such entity as part of that transaction.
Except as otherwise stated above, we will not sell, trade or share a user’s personal information with anyone else, nor will we send mailings on behalf of other organizations, unless the user has given us his or her specific permission to do so.
4. What choices do you have?
When corresponding with HHCA or our representatives, or when making a request for information or otherwise interacting with us or others through the Site, you choose what information to supply, what questions or comments to submit, whether you wish to receive further information, and by what method of communication such information should be delivered. Please take care to share only such information as is needed or that you believe is appropriate. You may contact us as indicated below if at any time you would like to ask us about our data collection and information security practices.
You have the right to:
- Request information about how your Personal Data is being used and request a copy of what Personal Data we use.
- Restrict processing if you think the Personal Data is not accurate, unlawful, or no longer needed.
- Rectify or erase Personal Data and receive confirmation of the rectification or erasure. (You have the “right to be forgotten”).
- Withdraw your consent at any time to the processing of your Personal Data.
- Lodge a complaint with a supervisory authority if you feel we are using your Personal Data unlawfully.
- Receive Personal Data portability and transference to another controller without our hinderance.
- Object to our use of your Personal Data.
- Not be subject to an automated decision based solely on automatic processing, including profiling, which legally or significantly affects you.
You may unsubscribe from our e-newsletters or updates at any time through the unsubscribe link at the footer of all email communications. If you have questions or are experiencing problems unsubscribing, please contact us at firstname.lastname@example.org.
5. How Do We Protect Information Collected About You?
We keep user information on a secured server behind a firewall. When users enter personal information, we use encryption technology, such as Secure Sockets Layer (SSL), to protect such information during data transport. DESPITE HHCA EFFORTS TO PROTECT PERSONAL INFORMATION, WE CANNOT ENSURE OR WARRANT THE SECURITY OF ANY INFORMATION TRANSMITTED TO US, AND USERS DO SO AT THEIR OWN RISK. ELECTRONIC TRANSMISSIONS VIA THE INTERNET ARE NOT NECESSARILY SECURE FROM INTERCEPTION, AND SO WE CANNOT ABSOLUTELY GUARANTEE THE SECURITY OR CONFIDENTIALITY OF SUCH TRANSMISSIONS. THERE IS ALWAYS SOME RISK THAT AN UNAUTHORIZED THIRD PARTY MAY FIND A WAY AROUND OUR SECURITY SYSTEMS OR THAT TRANSMISSIONS OF YOUR INFORMATION OVER THE INTERNET MAY BE INTERCEPTED.
Under California’s "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2017 will receive information regarding 2016 sharing activities).
To obtain this information, please send an email message to email@example.com with "Request for California Privacy Information" on the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.
6. Interactive Areas
HHCA is not liable for information posted in interactive areas of the Site. HHCA provides these interactive areas, such as testimonials, and links to practitioners websites and our business partners websites, to enhance the user experience and build a healthy community around the products and services available through the Site. You acknowledge that, should you participate in such interactive areas, the information you voluntarily post about yourself and supply to third parties in such areas might be accessed, collected and used by third parties other than HHCA or our Contractors.
7. No Use of Our Site by Persons Under 18.
The Site is not intended for use by anyone under 18. No person under 18 should disclose information on this Site. We don’t knowingly collect or use personally identifiable information from children under 18. If a child under 18 has provided us with Collected Information without parental or guardian consent, the parent or guardian should contact us at the email address provided below to remove the information and opt out of promotional opportunities.
8. We may change this Notice.
9. Location of this Site.
This Site is hosted and operated in the United States of America. However, we and our Contractors may, in our effort to provide the Site, store Collected Information in the United States, or we may transfer it to, and store it within, other countries.
Those who access or use the Site from jurisdictions outside the United States do so at their own choice and risk and are solely responsible for compliance with local law. If you are not a resident of the United States, you acknowledge and agree that we may collect and use your personal information outside your home jurisdiction, and that we may store your personal information in the United States or elsewhere. Please note that the level of legal protection provided in the United States or other non-European countries from which you may access our Site may not be as stringent as that under European Union privacy standards or the privacy laws of some other countries, possibly including your home jurisdiction. If you are a resident of the European Economic Area (EEA) or other jurisdiction outside of the U.S., in order to provide our Site, products and services to you, we may send and store your personal information (also commonly referred to as personal data) outside of the EEA, including to the United States. Accordingly, your personal information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. Where such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as within the EEA to the extent feasible under applicable law. By using and accessing our Site, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.
10. Any questions?