: September 15, 2019
When you interact with our Services, you may choose to provide personal health information to one of our health and wellness professionals. We are committed to maintaining the confidentiality of your personal health information, and under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), we must take measures to protect the privacy of your personal information as a Business Associate of our professionals.
We protect your personal information in a number of ways. For example, we authorize access to your personal information by our employees and business associates only to the extent necessary to conduct our business of serving you, such as paying your claims. We take steps to secure our buildings and electronic systems from unauthorized access. We train our employees on our written confidentiality policy and procedures, and employees are subject to discipline if they violate them.
We collect information about you directly from you and automatically through your use of our Services. We may combine information collected from or about you from these various sources.
Information We Collect Directly from You.
We will collect any information that you provide to us through our Services, such as your name, email address, company name, your marketing preferences, and the contents of any message that you submit through our Services.
Information We Collect Automatically Through Our Services.
We automatically collect information about you through your use of our Services, including, without limitation, your Internet protocol (IP) address, the type of browser you are using, information about the device you are using, domain name, the website that led you to our Services, the website to which you go after leaving our Services, your location, and the dates and times you access our Services. Please see our Cookies and Other Tracking Mechanisms section below for more information. We may combine information we collect automatically with information we collect from you directly.1. HOW WE USE YOUR INFORMATION
We may use your information, including personal information, for the following purposes:
Providing and Improving Our Services.
To provide and maintain our Site and provide connected Services; to improve our Services; to develop new features, newsletters or services; to perform technical operations, such as updating our Site; and for other customer service and support purposes.
To communicate with you about your use of our Services, including to respond to your inquiries;
To provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes. Our communications with you may include communications via email and/or telephone.
Research and Analytics.
To analyze how you interact with our Services; to monitor and analyze usage and activity trends; and for other research, analytical, and statistical purposes.
Protecting Rights and Interests.
To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.2. HOW WE DISCLOSE YOUR INFORMATION
We may disclose your information, including personal information, as described to you at the time of collection or disclosure or as follows:
(2B) Service Providers.
We may disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf. For example, we may disclose your information to a service provider that helps us with our email newsletters and promotional materials.
(2C) Business Transfers.
We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.
(2D) Protecting Rights and Interests.
(2E) Legal Compliance.
We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.
(2F) Aggregate and De-Identified Information.
We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.3. COOKIES AND OTHER TRACKING MECHANISMS
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site or our Services. There are two types of cookies: session and persistent cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are browsing the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Services. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Clear GIFs, pixel tags, and other technologies.
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities users of our Services, help us manage content, and compile statistics about usage of our Services. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.4. THIRD-PARTY ANALYTICS
We use Google Analytics
.5. DO NOT TRACK DISCLOSURE
Our Site and Services may not respond to Do Not Track signals. For more information about Do Not Track signals, please click here
. You may, however, disable certain tracking as discussed in the Cookies and Other Tracking Mechanisms
section above (e.g., by disabling cookies).Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page
for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies
. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page
for information about opting out of interest-based advertising and their choices regarding having information used by NAI members
. If you are in the EU, you may opt-out of certain third party cookies that we and other websites may use for targeted advertising through the European Interactive Digital Advertising Alliance (EDAA) Your Online Choices Page
.Opting out from one or more companies listed on the DAA Consumer Choice Page
or the NAI Consumer Opt-Out Page
will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites.6. THIRD-PARTY LINKS
We have taken steps to help protect the personal information we collect. However, no data security measures can guarantee 100% security.8. DIRECT MARKETING
We may send periodic promotional emails to you. You may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.9. YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident then under Cal. Civ. Code § 1798.83 you may request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the 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 at the contact information provided below. In your request, please attest to the fact that you are a California resident and provide a current California address for your response.10. CHILDREN
Our Services are not targeted to children under thirteen (13) years of age and we do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information, we will promptly delete such personal information from our systems.11. INFORMATION FOR EU INDIVIDUALS
The following disclosures apply only to Brief Therapy Center’s processing of personal data about EU residents.
The Data Controller of the information collected through the Site and Services is Brief Therapy Center which is headquartered in the United States at 665 Lytton Ave, Palo Alto, CA 94301. To exercise any rights that you may have with regard to your personal data, please send a request to [email protected]
The legal bases for using your personal Information. We collect your information as a Data Controller when we have a legal basis to do so. The following legal bases pertain to our collection of data:
Our use of your personal data is necessary to perform a contract
or take steps to enter into a contract with you. This applies to our processing activities described at 2A and 2B above.
Our use of your personal data is in our legitimate interest
as a commercial organization to make improvements to our Site and to provide you with access to the Services as you request. This applies to our processing activities described at 2C (save where we need consent by local law) and 2D.
Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation
that we have in particular, where we are required to disclose personal information to a court or regulatory body in the event of an investigation. This applies to our processing activities described at 2E and 2F.
Our use of your personal information is in accordance with your consent
. This applies to our processing activities described at 2C (where required by local law).
If you would like to find out more about the legal bases on which we process personal information, please contact us using the details below.
Your Legal Rights.
Subject to certain exemptions, and dependent upon the processing activity we are undertaking, European Union individuals have certain rights in relation to personal information:
Right to access, correct, and delete your personal information:
You have the right to request access to the personal information that we hold about you and: (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred. You also have the right to request that we correct any inaccuracies or delete your information. We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims.
Right to restrict the processing of your personal information:
You have the right to restrict the use of your personal information when (i) you contest the accuracy of the data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the personal information for the relevant purposes, but we require it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to our personal information use justified on our legitimate interests verification as to whether we have a compelling interest to continue to use your data. We can continue to use your personal information following a request for restriction, where: (a) we have your consent; or (b) to establish, exercise or defend legal claims; or (c) to protect the rights of another natural or legal person.
Right to data portability:
To the extent that we process your information (i) based on your consent or under a contract; and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.
Right to object to the processing of your personal information:
You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.Right to lodge a complain with your local supervisory authority:
You have a right to lodge a complaint with your local supervisory authority if you have concerns how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.undefined
How to Exercise Your Rights:
If you would like to exercise any of the rights described above, please send us a request to [email protected]
In your message, please indicate the right you would like to exercise and the information to which it relates.We may ask you for additional information to confirm your identity and for security purposes before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
Cross-border Transfer of Information.
We maintain servers and systems in the United States hosted by third party service providers. As a result, where the personal information that we collect through or in connection with the Site or the Services is processed in the United States, we will take steps to ensure that the information receives the same level of protection as if it remained within the European Union. You may have a right to receive details of any safeguards that we have where your data is transferred outside the European Union, (e.g. to request a copy where the safeguard is documented, which may be redacted to ensure confidentiality).
Retention of Personal Data and Access.