PRIVACY POLICY

CareConnect Strategies Privacy Policy

Last Updated: June 27, 2024

CareConnect Strategies (“CareConnect”) values your rights to privacy and to personal data protection and the privacy of our other customers and visitors to www.careconnectstrategies.com website (“Website”), features and services (collectively, with any successor websites, the “Services”). This policy describes the types of information may collect from you or that you may provide when you visit the Website and our practices for collecting, using, keeping, protecting, and disclosing that information. Users of the Services are, collectively, referred to herein as “Users.” This Privacy Policy describes what information CareConnect gathers from you via the Services (the “Information”), how we use that Information, and what we do to protect it. Your Information may include what we refer to as “Performance Information”, which is defined in more detail below and involves certain website an campaigns-related information necessary for performing the Services, and “Personal Information”, which is a limited set of identifying information that allows for communication between Users and CareConnect. When referred to in this Privacy Policy, the term Personal Information includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, including any information that is subject to applicable data protection laws, including, but not limited to, “Personal Information” as defined under the California Consumer Privacy Act, Cal. Civ. Code §§ 1798.100 et. seq., as amended (“CCPA”). Any Personal Information that is collected is limited to use in the ways that are disclosed in this Privacy Statement.

By using the Services, you expressly consent to the Information handling described in this notice. This Privacy Policy is incorporated into and is subject to the CareConnect Terms of Use. Your use of the Services and any Information you provide on the Services are subject to the terms of this Privacy Policy and CareConnect’s Terms of Use.

1. Your Choices

You may decline to share your Information with CareConnect; in that case, CareConnect will not be able to provide you with some of the features and functionality found on the Services. By using the Services, however, you hereby consent to our Terms of Use and this Privacy Policy. You are responsible for always maintaining the secrecy of your unique password and account access information.

2. Our Commitment to Data Security

CareConnect uses certain physical, managerial, and technical safeguards designed to improve the integrity and security of your Information. However, CareConnect also cannot guarantee that such Information may not be accessed, disclosed, altered, or destroyed by unauthorized breach of any of our physical, technical, or managerial safeguards. CareConnect works with authorized service providers to provide website hosting and maintenance as well as other services. To the extent it is necessary for these service providers to complete their contractual obligations to CareConenct, these third parties may have access to or process your Information. CareConnect generally limits their use of your Information to the purpose for which it was shared. Such service providers shall be bound by obligations of confidentiality at least as protective of you and your Information as those contained herein. CareConnect uses all the Information that we collect to understand and analyze the usage trends and preferences of visitors to the Services, to improve the way the Services work and look, and to create new features and functionality. If CareConnect learns of a security systems incident, then we will attempt to notify you electronically so that you can take appropriate protective steps, if the event rises to the level of a breach. CareConnect will post a notice on the Services if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach you should notify us at compliance@careconnectstrategies.com.

3. Information We Collect

CareConnect attempts to limit the Personal Information you provide to an email for communication with you, your name, mobile phone number and lab results. CareConnect uses the Information you provide or that we collect to operate, maintain, enhance, and provide all of the features, Information and services found on the Services. We will use your email address, without further consent, for administrative purposes, for customer service purposes, and to address intellectual property infringement, rights of privacy, or defamation issues. CareConnect will not use your email address or other Personal Information to send promotional messages unless you have opted in or otherwise requested that CareConnect contact you about the CareConnect products and services or other information. CareConnect does not sell, trade, rent or share your Personal Information with other organizations for their marketing or promotional uses without your express consent.

You may provide financial information (such as debit/credit card number, billing information, etc.) on the Services in a purchase. This information is provided to our payment processors for purposes of processing the transaction. CareConnect does not view or store this financial information beyond what is necessary to provide the service or as otherwise directed by you.

We may collect several types of information from and about users of our Website or service, including personal data:

by which you may be personally identified, including your name, postal address, email address, telephone number; or
details of your business, and business dealings and operations, and a record of the communications and meetings you’ve had with CareConnect; or
about your internet connection, and the software or equipment that you use to access our Website; or
about your usage of the Website, including the pages that you view and in some cases information about how you clicked to visit the Website; or
by which you may be pseudonymously identified, including the values of web cookies and mobile device identifiers.

We collect this information:

directly from you when you provide it to us;
directly from publicly available sources;
automatically as you navigate through the Website; and
from third parties, for example, our business partners.

Information you provide to us online-

The information we collect on or through our Website may include:

Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to receive communications, or enquiring about further services.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Your search queries on the Website.

Information we collect through automatic data collection technologies-

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services.

The technologies we use for this automatic data collection may include: cookies or other local storage and web beacons (or “pixels,” on the Website and including in our emails).

Strictly Necessary Cookies

These cookies are essential in order to enable you to move around this Service and use its features. Without these cookies, services you have requested, such as remembering your submitted information, cannot be provided.

Performance Cookies

These cookies collect anonymous information on how people use this Service. For example, we may use Google Analytics cookies to help us understand how individuals arrive at our Servcies, browse or use this Service, and highlight areas where we can improve such as navigation and marketing. The data stored by these cookies never shows personal details from which your individual identity can be established.

Functionality Cookies

These cookies remember choices you make such as the country from which you visit this Service, language, and search parameters. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored. The information these cookies collect may be anonymized, and these cookies cannot track your browsing activity on other websites.

Targeting Cookies or Advertising Cookies

These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks. They remember the websites you visit, and that information is shared with other parties such as advertisers.

We may use different kinds of cookies, including session ID cookies and persistent cookies. Session ID cookies are used to personalize your user experience, and to determine ways to improve our Services and the other products and services we offer. These cookies are deleted when you close your browser session. Persistent cookies are used to collect information such as IP addresses, browser type, Internet Service Provider (ISP), referring/exit pages, platform type, date/time stamp, and a number of clicks.

You can refuse or accept cookies from our Services at any time by activating the settings on your browser. You are always free to decline our cookies if your browser permits, but some parts of the Services may not work properly if you do. Check the “Help” menu of your browser to learn how to change your cookie preferences. To find out more about cookies, visit www.aboutcookies.org.

Many web browsers allow for the use of a “Do Not Track” function to inform websites that you do not want your online activities tracked. Currently, we do not track your or any other users’ Personal Information over time and across third-party websites. We, therefore, do not respond to browser “Do Not Track” signals.

4. How we Use Your Information

We may use information that we collect about you or that you provide to us, on the grounds of the contract between us, legal obligation, your vital interests, or the public interests. The reason for this processing of your personal data may include

to provide you with information, products, or services that you request from us;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; and
to investigate and prevent illegal activities.

We may also use information that we collect about you or that you provide to us with your consent, which is given in relation to a purpose. That purpose may include

to notify you about changes to any products or services we offer or provide; or
in any other way we may describe when you give consent and provide the information.

We may also use information that we collect about you or that you provide to us on the grounds of our legitimate interests. The reason for this processing of your personal data may include

to notify you about changes to any products or services we offer or provide;
to contact you about our own and third parties’ goods and services that may be of interest to you; and
to fulfill any other purpose for which you provide your personal data.

These purposes require that we store personal data for at least 36 months.

If you do not want us to use your information in these ways, then email compliance@careconnectstrategies.com to let us know. In relation to emails you may receive from CareConnect, where your subscription to a CareConnect marketing list has caused you to receive the email, you can remove yourself from the marketing list by using the unsubscribe link that you’ll find in the email itself.

The information we collect automatically is grouped by its purpose into one of three categories, either:

operating the Website; or
measurement; or
advertising.

Automatic data collection for operating the website

Operating the Website includes for the purposes of:

delivering its pages;
allowing you to participate in any interactive features on our Website;
processing and logging your requests;
maintaining the Website and resolving any technical issues that may occur in its operation;
investigating and preventing illegal activities; and may include
personalizing the Website for you including by:
processing and recording the pages you request as you land on them and navigate between them;
logging information about the software and equipment you use to request pages;
storing information about your preferences, thus allowing us to customize the Website according to your individual interests; and
recognizing you when you return to our Website.

Automatic data collection for measurement

Measurement includes for the purposes of:

improving our Website’s technical performance (for example, the speed with which its pages are loading for its visitors);
improving its content performance (for example, where unpopular content may be revealed as having been produced poorly than normal, or reflect the changing needs of our visitors);
testing new versions of the Website (wholly or partially) on a sample of its audience, and measuring the differences in performance between the versions. This involves the storage of information about which version of the website you’ve seen.

Measurement rarely involves the study of any individual, but statistical techniques in measurement do rely on personal data.

Automatic data collection for advertising

Advertising includes for the purposes of collecting information about your online activities on the Website and across third-party websites or other online services so that:

CareConnect can notify you about changes to any Services we offer or provide;
CareConnect can show advertising;
this advertising may be shown to you and personalized in relation to your previous behavior;
CareConnect can measure the delivery and performance of the advertising it places; and
CareConnect can use reporting on the Website’s visitors, including using data collected from across third-party websites, to inform marketing plans and decisions.

5. Disclosure of Information

CareConncet may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. Copyright law), respond to a court order, judicial or other government subpoena or warrant, or cooperate with law enforcement activity. CareConnect also reserves the right to disclose your information that we believe, in good faith, is appropriate or necessary to take precautions against liability; to protect CareConnect and others from fraudulent, abusive, or unlawful uses or activity; to investigate and defend ourselves against any third party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the Service; or to protect the rights, property, or personal safety of CareConnect, our users, or others.

Please note, we do not “share” Personal Information as that term is defined under the CCPA

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal data that we collect or you provide as described in this privacy policy:

To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concerning or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see “What choices do you have about how we use and disclose your information?”
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal data:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our terms and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Data Processors

CareConnect uses these processors as partners in processing your personal data. This list may change from time to time.

Relationships with our clients and customers

HubSpot
GSuite
Office 365
Mailchimp
Amazon Web Services
Google Cloud Platform

The Operation of the Website

Wix.com

Measurement

Google Tag Manager
Google Analytics (but not its “Advertising Features”)
Hotjar

Advertising

Google Analytics (including its “Advertising Features”)
Google AdWords
DoubleClick
Facebook
LinkedIn

8. Third Party Services

The Services may contain features or links to third party websites and services. Any personally identifiable information you provide on third-party sites or services is provided directly to such third party and is subject to that third party’s policies, if any, governing privacy and security, even if accessed through the Services. CareConnect is not responsible for the content or privacy and security policies of third-party sites or services to which links or access are provided through the Services. CareConnect encourages you to learn about third parties’ privacy and security policies before providing them with personally identifiable information.

9. Privacy Settings

Although CareConnect may allow you to adjust your privacy settings to limit access to your Information, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other Users with whom you may choose to share your Information. Therefore, if you choose to post Information using social media, we cannot and do not guarantee that Information you post on the Services will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on our Services. You understand and acknowledge that, even after removal, copies of information that you have posted may remain viewable in cached and archived pages or if other users have copied or stored such information.

10. Storage of Information

Information collected on the Services may be stored and processed in the United States or any other country in which CareConnect or its affiliates, subsidiaries or agents maintain facilities, and by using the Services you consent to any such transfer of Information outside of your country. Except as prohibited by law, we will retain and use your Personal Information for as long as necessary to provide you with the Services or to document our business relationship or otherwise as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

11. International Visitors

The Service is hosted in the United States and is intended solely for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personally identifiable information outside of those regions to the United States for storage and processing, and by providing your personally identifiable information on the Service you consent to that transfer, storage, and processing.

12. In the Event of Merger or Sale

In the event that CareConnect is acquired by or merged with a third-party entity, by using the Services you consent, in any of these circumstances, to the transfer or assigning of the Information that we have collected from you as a User as part of such merger, acquisition, sale, or other change of control.

13. Changes and Updates to this Privacy Policy

This Privacy Policy may be revised periodically without further notice to you, and this will be reflected by a 'last modified' date below. Please revisit this page to stay aware of any changes. In general, we only use your personal Information in the manner described in the Privacy Policy in effect when we received that personal Information. Your continued use of the Services constitutes your agreement to this Privacy Policy and any future revisions. For revisions to this Privacy Policy that may be materially less restrictive on our use or disclosure of personal Information you have provided to us, we will make reasonable efforts to notify you and obtain your consent before implementing such revisions with respect to such Information.

14. Certain State Laws

California, Colorado, Connecticut, and Utah Residents

If you are a resident of the above states, you may have the right, subject to certain exceptions defined in the laws and regulations applicable to you, to request that a company:

Disclose certain information to you about its collection and use of your Personal Information. This right includes information about:
- The categories of Personal Information we collected about you;
- The categories of sources for the Personal Information we collected about you;
- Our business or commercial purpose for collecting that Personal Information;
- The categories of third parties with whom we disclosed, shared, or sold that Personal Information;
- The categories of Personal Information that each recipient received;
- The specific pieces of Personal Information we collected about you;
Provide the Personal Information it has about you in a readily useable format that allows you to transmit the information to another entity without hindrance;
Delete any of your Personal Information that it has collected from you and retained;
Stop selling your Personal Information and refrain from doing so in the future; however, we do not sell your Personal Information;
Correct inaccurate Personal Information it has about you; or
Stop sharing your Personal Information for purposes of cross-context behavioral advertising, targeted advertising, and/or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you; however, we do not share your Personal Information for these purposes;

You may also have the right not to receive discriminatory treatment if you exercise the rights listed herein that are provided to you by your state of residence.

As mentioned, certain information that is governed by other laws, may not be subject to the rights noted above. However, additional rights might be available under those laws and standards. Please contact compliance@careconnectstrategies.com if you would like more information.

Note that CareConnect acts as a “Service Provider” as defined by the CCPA when it collects Personal Information. If we have collected your Personal Information outside of our role as a Service Provider, we will respond to your verified consumer request accordingly.

Additionally, we are not required to respond to a consumer’s requests for access or disclosure of Personal Information more than twice in a twelve (12) month period.

California Civil Code Section 1798.83 permits California residents to request a list of all third parties to which we, during the immediately preceding calendar year, have disclosed certain Personal Information for direct marketing purposes; however, we do not share Personal Information with other people or non-affiliated businesses for their direct marketing purposes.

Nevada Residents

Although we do not sell Personal Information, Nevada residents have the right to submit a verified request directing us not to sell their Personal Information. If you are a Nevada resident, and would like to submit such a request, please send your request through any of the methods noted below.

Exercising Your Rights

To exercise any of the rights described above, you can contact us by emailing us at compliance@careconnectstrategies.com; or when you make a request, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request to the Information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request. Please provide as much of the requested information as possible to help us verify the request. We will only use the information received in a request for the purposes of responding to the request.

Certain states permit their residents to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the data subject’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the data subject. An authorized agent must follow the process described above to make a request. The authorized agent must also verify his/her own identity. We will confirm the agent’s authority with the data subject about whom the request was made.

16. CareConnect Contact Information

Please contact CareConnect with any questions or comments about this Privacy Policy, your personal Information, our third-party disclosure sites, or your consent choices at compliance@careconnectstrategies.com.