LAST UPDATED: MARCH 23, 2020
PARTICULARLY IMPORTANT INFORMATION
WHO WE ARE: For the purpose of applicable data protection legislation, the data controller of your personal data is CLEAR Child Psychology of 11001 W. 120th Ave, Suite 400, Broomfield CO 80021.
MUST READ SECTIONS: We draw your attention in particular to the sections entitled “International Data Transfer” and “Your Rights.”
CHANGES TO THIS POLICY: We will post any modifications or changes to the Policy on our Sites/Services. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will notify you via email and/or post a notice on our Sites/Services prior to such changes(s) taking effect.
1. PURPOSES OF PROCESSING
What is personal data?
We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the UK Data Protection Act 1998/the European Data Protection Directive 95/46/EC/General Data Protection Regulation 2018 and any successor legislation, this includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number. Personal data also includes individually identifiable health information as defined by the US Health Insurance Portability and Accountability Act of 1996, as amended, and its implementing regulations (collectively, “HIPAA”), such as name, address, social security number, credit card account number, and other information provided to register for use of the Services, in combination with information about you or your child’s medical or mental health history, treatment or payment for health services provided or 2 179093102 v3 obtained by CCP in connection with a consultation with one of our licensed psychologists.*
Why do we need your personal data?
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the Sites/Services.
2. COLLECTING YOUR PERSONAL DATA
We collect information about you in the following ways:
Information You Give Us. This includes:
- the personal data you provide when you take one of our quizzes or assessments, such as your answers to questions related to your levels of concern as they relate to a child’s mental health and well-being;
- the personal data that may be contained in any consultation (whether in-person, over the phone or video chat) between you and one of our licensed psychologists, licensed professionals or coaches;
- the personal data you provide on the contact information form on company website or parent portal pages;
- the personal data you provide when you report a problem with our Sites/Services or when we provide you with customer support;
- the personal data you provide when you make a purchase thorough our Sites/Services; and
- the personal data you provide when you correspond with us by phone, email or otherwise.
Information We Get from Others. We may also get information about you from other sources, for example, if you have agreed to share information with one of our partners or with another licensed psychologist in our referral network we may add this to information we get from our Sites/Services. We also get information from you from the raters you that you add to your to assessments.
Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Sites/Services. For example, when visiting our Sites/Services, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Sites/Services, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Sites/Services. We may collect this information about you using cookies. Please refer to the sections on cookies.
Automated Decision Making and Profiling.
We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfil obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object. Personal data may also be collected by CCP via email, telephone, or website forms, to facilitate the scheduling of a consultation with one of our licensed psychologists, licensed providers, or coaches, or referral to other healthcare providers.
What are cookies?
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Sites/Services.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Sites/Services; and (2) third party cookies, which are served by service providers on our Sites/Services, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Cookies we use
our Sites/Services uses the following types of cookies for the purposes set out below:
|Essential Cookies||These cookies are essential to provide you with services available through our Sites/Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Sites/Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.|
|Functionality Cookies||These cookies allow our Sites/Services to remember choices you make when you use our Sites/Services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Sites/Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Sites/Services.|
|Analytics and Performance Cookies||
These cookies are used to collect information about traffic to our Sites/Services and how users use our Sites/Services. The information gathered does not identify any individual visitor. It includesthe number of visitors to our Sites/Services, the websites that referred them to our Sites/Services, the pages they visited on our Sites/Services, what time of day they visited our Sites/Services, whether they have visited our Sites/Services before, and other similar information. We use this information to help operate our Sites/Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Sites/Services.
We use Google Analyticsfor this purpose. Google Analytics usesits own cookies. It is only used to improve how our Sites/Services works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConc eptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our Sites/Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
|Targeted and advertising cookies||
These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.
You can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices.
If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com/uk/.
If you do not accept our cookies, you may experience some inconvenience in your use of our Sites/Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Sites/Services.
3. PIXEL TAGS
We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Sites/Services to track the actions of users on our Sites/Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Sites/Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.
4. DO NOT TRACK SIGNALS
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Generally. We may use other companies to serve third-party advertisements when you visit and use the Sites/Services. These companies may collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the Sites/Services and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies.
Targeted Advertising. In order to serve offers and advertisements that may interest you, we may display targeted advertisements on the Sites/Services, or other digital properties or applications in conjunction with our content based on information provided to us by our users and information provided to us by third parties that they have independently collected. We do not provide personal data to advertisers when you interact with an advertisement.
Your Ad Choices. Some of the third party services providers and/or advertisers may be members of the Network European Interactive Digital Advertising Alliance (“EDAA”) Self-Regulatory Program for Online Behavioural Advertising. To learn more, visit http://www.edaa.eu/edaa-for-users which provides information regarding targeted advertising and the “opt-out” procedures of EDAA members.
6. USING YOUR PERSONAL DATA We may use your personal data as follows:
- to operate, maintain, and improve our Sites/Services, products, and services;
- to respond to your comments and questions and to provide customer service;
- to send information including technical notices, updates, security alerts, and support and administrative messages;
- with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may optout of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you nonmarketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
- as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
- as described in the “Sharing of your Personal Data” section below
7. SHARING YOUR PERSONAL DATA
We may share your personal data as follows:
- Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so (including without limitation written consents and authorized obtained in connection with a consultation with one of our licensed psychologists) or where otherwise permitted by law. These third parties may include our licensed psychologists and other healthcare providers for the purpose of providing the Services or making referrals.
- Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
- Affiliates. We may share some or all of your personal data with our affiliates, in which case we will require our affiliates to comply with this Policy. In particular, you may let us share personal data with our affiliates where you wish to receive marketing communications from them.
- Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
- Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to 7 179093102 v3 respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
8. ANONYMOUS DATA
When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze usage patterns in order to make improvements to our Sites/Services.
USER GENERATED CONTENT
If you provide feedback to us, we may use and disclose such feedback on our Sites/Services , provided we do not associate such feedback with your personal data. If you have provided your consent to do so, we may post your first and last name along with your feedback on our Sites/Services. We will collect any information contained in such feedback and will treat the personal data in it in accordance with this Policy.
9. INTERNATIONAL DATA TRANSFER
Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Site/Application(s)/ Services, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 17 below.
We will only retain your personal data as long reasonably required for you to use the Sites and/or to provide you with the Services unless a longer retention period is required or permitted by law (for example for regulatory purposes). 8 179093102 v3
12. SENSITIVE PERSONAL DATA
If you send or disclose any sensitive personal data to us when you submit user generated content to our Sites/Services, you consent to our processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content to our Sites/Services.
- Opt-out. You may contact us any time to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of some of the Sites/Services may be ineffective upon opt-out.
- Access. You may access the information we hold about you at any time via your profile/account or by contacting us directly.
- Amend. You can also contact us to update or correct any inaccuracies in your personal data.
- Move. Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
- Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
If you wish to exercise any of these rights, please contact us using the details in Section 17 below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for regulatory or recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at: firstname.lastname@example.org . We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
14. CONTACT INFORMATION
We welcome your comments or questions about this Policy. You may contact us in writing at email@example.com .
* We conduct assessments in Arizona, Colorado, Delaware, Georgia, Illinois, Missouri, Nebraska, Nevada, New Hampshire, Oklahoma, Pennsylvania, Texas, Utah and Virginia. In addition to this list, each state has guidelines regarding telepsychology. For example, many states will allow for interjurisdictional practice for up to 30 days. Given that a certain state allows for interjurisdictional practice or telepsychology, CCP is likely able to provide services there, and will do so while complying with all state-specific guidelines.