- Important Information and Who We Are
- The Data We Collect About You
- How Is Your Personal Data Collected
- How We Use Your Personal Data
- Disclosures of Your Personal Data
- International Transfers
- Data Security
- Data Retention
- Accessing and Correcting Your Personal Data
- Do Not Track Policy
- Your California Privacy Rights
- Your Canadian Privacy Rights
- Your EEA or UK Legal Rights
- Important information and who we are
- The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). Depending on whether you are a sponsor, donor, provider, or patient, we may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Dataincludes first name, middle name, maiden name, last name, username or similar identifier, date of birth, gender, tax ID/social security number, national practitioner identifier number, copy of provider license, and copy of government-issued photographic identification.
- Contact Dataincludes billing address, mailing address email address, and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you.
- Technical Dataincludes Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, your interests, preferences, possible areas of support, feedback, and survey responses. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your possible areas of support (patients only). By choosing to provide special or sensitive information, you consent to our processing of that information.
- Usage Dataincludes information about how you use our website, products, and services.
- Marketing and Communications Dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences.
- How is your personal data collected?
We use different methods to collect data from and about you, including through:
- Direct interactions.You may give us your Identity, Contact, Financial, and Special Categories of Personal Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
- complete a therapy request form;
- complete a therapy intake form;
- make a donation;
- create an account on our website;
- request marketing or a newsletter to be sent to you;
- enter a competition, promotion, or survey; or
- give us feedback or contact us.
- Third parties or publicly available sources.We will receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- content providers such as YouTube based outside the EU; and
- search information providers such as Google based outside the EU.
- Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services such as PayPal based outside the EU.
- Technical Data from the following parties:
- How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where you have given consent for us to use your sensitive personal data to provide certain services. (You may withdraw your consent for some uses of the sensitive personal data at any time by contacting us.)
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Click hereto find out more about the types of lawful basis that we will rely on to process your personal data. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before collecting sensitive personal data or sending third-party direct marketing communications to you via email. You have the right to withdraw consent to processing your sensitive personal data or to marketing at any time by contacting us. Purposes for which we will use your personal data We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new user||(a) Identity (b) Contact||Performance of a contract with you|
|To register you as a new provider||(a) Identity (b) Contact (c) Profile||Performance of a contract with you|
|To refer you to a provider||(a) Identity (b) Contact (c) Profile||(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) With your explicit consent in the case of sensitive personal data|
|To process your donation including: (a) Manage payments, fees, and charges (b) Collect money donated to us||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to collect your donation)|
|To administer and protect our business and this website (including security, fraud, troubleshooting/technical support, data analysis, testing, system maintenance, support, reporting, and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation|
|To deliver relevant website content to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Technical||Necessary for our legitimate interests (to study how customers use our products/services, and to develop them, to grow our business)|
|To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy)|
- Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes stated in the table (Purposes for which we will use your personal data) above.
- External Third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- International transfers
We are based in the United States of America. We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. Where we do so, and where we are required to under local law, we will put in place appropriate mechanisms to ensure that your personal data receives an adequate level of protection where it is processed. If you are located in the European Economic Area (EEA) or United Kingdom (UK), your personal data may be processed outside of the EEA or UK, including, for example, in the United States, so processing of your personal data will involve a transfer of data outside the EEA or UK. Whenever we transfer your personal data out of the EEA or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU–US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or UK.
- Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Data retention
How long will you use my personal data for? We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements. By law we have to keep basic information about our sponsors, donors, providers, and patients (including Contact, Identity, Financial, and Transaction Data) for seven years after they cease being sponsors, providers, and patients for tax purposes. In some circumstances you can ask us to delete your data: see accessing and correcting your personal dataand your EEA legal rightsbelow for further information. In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- Accessing and correcting your personal data
You may send us an email at firstname.lastname@example.org request access to, correct, or delete any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.
- Do Not Track policy
Do Not Track (“DNT”) is a privacy preference that you can set in your browser. DNT is a way for you to inform websites and services that you do not want certain information about your webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information we collect and that is why we provide you the ability to opt out. But we do not recognize or respond to any DNT signals as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. For more information, visit www.allaboutdnt.com.
- Your California privacy rights
If you are a California resident, you are granted specific rights regarding access to your personal data. California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the name and addresses of all third parties with which we shared personal data in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided above.
- Your Canadian privacy rights
We comply with Canadian Federal and Provincial privacy laws and regulations, including the Personal Information Protection and Electronic Documents Act. We will only use your personal information for the purposes intended and as detailed in this policy unless we have obtained your consent to use it for other purposes. Residents of Canada are notified that the personal data they provide to us is stored in its databases outside of Canada, including in the United States, and may be subject to disclosure to authorized law enforcement or government agencies in response to lawful demand under the laws of that country. You may withdraw your consent to our personal data collection, use, or disclosure, subject to legal and contractual restrictions. You have the right to complain about our personal data handling practices. If you need to contact us about your personal data or believe that we have violated your privacy rights, please contact us at email@example.com. You may visit www.priv.gc.cafor more information about your privacy rights.
- Your EEA/UK legal rights
If you reside in the EEA or UK, under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us. No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Lawful Basis Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contractmeans processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. Third Parties External Third Parties
- Compliance with Laws. We may disclose your information where we are legally required to do so to comply with applicable law, government requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to that information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the website, which will enable them to collect data about how you interact with the website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. For example, we use Google Analytics to help us understand how our customers use the website (you can read more about how Google uses your personal data here: https://www.google.com/int’l/en/policies/privacy/). You can also optout of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Your EEA/UK Legal Rights You have the right to: Request accessto your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correctionof the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasureof your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processingof your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processingof your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transferof your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any timewhere we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.