Last Updated: July 10, 2023
COLLECTION OF PERSONAL DATA
We collect the following categories of Personal Data:
Identifiers, such as your name, alias, postal address, telephone number, unique personal identifier, online identifier, your written or digital signature, device ID, internet protocol (IP) address, email address, account name, or other similar identifiers as well as demographic information such your state of residence.
Information contained in our customer records, such as, your residence and other demographic data, information you submitted to complete purchases on one of our websites (credit card information or other bank/payment information).
Characteristics of protected classification, such as your race, gender, age, nationality, physical or mental disability, religion, date of birth, income, and family size.
Commercial information, such as information regarding products or services you purchased, obtained, or considered, and your feedback, reviews and/or testimonials about such products or services.
Internet or other electronic network activity information, such as your browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement.
Geolocation data, such as geographic location information about a particular individual or device.
Sensitive information is a type of information that may be afforded special protections under privacy laws. Examples of the sensitive information we may collect includes your social security number and information about your medical history, mental or physical condition, and medical treatment.
Our use and disclosure of certain of your information may be subject to the requirements of the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”) and applicable similar state laws regulating the healthcare industry. Any information that you submit to us that constitutes “Protected Health Information,” as defined by HIPAA, is subject to HIPAA and applicable state law. This Policy does not apply to your Protected Health Information.
USE OF PERSONAL DATA
We or our providers of services such as hosting, data analysis, IT services and infrastructure, customer service, e-mail delivery, auditing and other similar services may use Personal Data we collect from and about you for the following purposes:
- providing you with the Services and information you request;
- enabling users to use our Services and their features;
- administering the Services and your account with us;
- processing and fulfilling your transactions;
- furthering our business purposes, such as quality assessment, data analysis, audits, developing new products and services, enhancing the services, identifying usage trends, and determining the effectiveness of our promotional campaigns;
- responding to your requests, questions, and concerns;
- conducting research surveys and market research;
- developing new features and offerings on the Services;
- sending you marketing and other communications, including information about products and services of ours and of others, that we think might interest you; you may opt-in or out of receiving such notices from us by following the instructions in the Opt-In and Opt-Out section below;
- protecting our rights and property;
- recovering debt and preventing fraud;
- customizing our Services to your interests and history with us;
- other purposes disclosed when Personal Data is submitted to us;
- for any purpose for which we obtain your consent.
To perform the above functions, we may match information collected from you through different means or at different times, and use such information along with information obtained from other sources (including third parties) such as demographic information and updated contact information. We or our service providers may also use your information to assess the level of interest in, and use of, the Site, our e-mails and our other messaging campaigns both on an individual basis and in the aggregate.
DISCLOSURE OF PERSONAL DATA
We may share your Personal Data in the following circumstances:
- with our consulting physicians, psychologists, and other licensed professionals;
- with our third-party service providers that provide services such as hosting, data analysis, IT services and infrastructure, customer service, e-mail delivery, auditing and other similar services;
- when we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud or respond to a government, judicial or other legal request, or to comply with the law;
- in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business.
- to other entities in our corporate family as necessary for the purposes identified above.
We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose Personal Data necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Professionals may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment.
In addition, we may share non-personally identifiable Site usage information (including aggregate data) with others, for their own use, in a form that does not contain Personal Data about you.
HOW IS MY PERSONAL DATA SECURED?
We take the security of your Personal Data seriously. We have implemented appropriate technical and organizational security measures to protect your Personal Data from unauthorized access, use, or disclosure. However, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others.
If you correspond with us by e-mail, text message, or using Web forms like a “contact us” feature on our Site, you should be aware that your transmission might not be secure. A third party could view the information you send in transit by such means. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.
HOW LONG WILL YOU RETAIN MY PERSONAL DATA?
OPT-IN AND OPT-OUT
You may have the right to opt-in to or opt-out of certain of our uses and disclosures of your Personal Data. For example, when you are asked to provide Personal Data on this Site, you may have the opportunity to elect to, or elect not to, receive messages from us by e-mail or text message. If you change your mind after you opt-in, you may tell us that you do not want to receive our promotional messages by emailing us at email@example.com. To opt-out of our SMS text messages, please login to your online profile and opt-out of text message notifications.
DO NOT TRACK DISCLOSURES
Some Web browsers may transmit “do-not-track” (DNT) signals to the Web sites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not change our tracking practices in response to DNT settings in your web browser.
Our third-party partners, such as web analytics companies, collect information about your online activities over time and across our Site and other online properties. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings.
Please review our Policy on Cookies and Tracking Technologies for more information.
LINKS TO THIRD PARTY WEBSITES
The Services may contain links that lead to websites operated by third parties. We are not responsible for these other websites, and privacy policies posted to those websites, not this Policy, will govern the collection and use of your information on them. We encourage you to read the privacy statements of each third-party website to learn about how your information is treated by others.
We are committed to protecting the privacy of children. The Service is not designed or intended to attract anyone under the age of 18. If you are under 18, please do not attempt to register for the Service or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us with Personal Data, please contact us at firstname.lastname@example.org.
California’s “Shine the Light” law (California Civil Code Sections 1798.83-1798.84) permits users that are California residents to request certain information regarding our disclosure of Personal Data to third parties for direct marketing purposes.
NOTICE TO RESIDENTS IN THE EU/EEA/UK
Legal Basis for Processing Personal Data
If you are a resident in the EU, EEA or UK, we may rely on several different legal grounds when collecting and processing your Personal Data, including:
- Consent: We may process your Personal Data where we have obtained your prior, express consent to the processing, and in the case of special categories of data such as your health information, your explicit consent to the processing, in each case where appropriate under applicable law;
- Contractual necessity: We may process your Personal Data where the Processing is necessary to fulfill our contractual obligations to you;
- Compliance with applicable law: We may process your Personal Data where the processing is required by applicable law;
- Vital interests: We may process your Personal Data where the processing is necessary to protect the vital interests of any individual; or
- Legitimate interests: We may process your Personal Data where we have a legitimate interest in the processing.
Your Rights Regarding Your Personal Data
If you are a resident in the EU, EEA or UK, you have certain rights regarding your Personal Data, subject to local law. These include the following rights to:
- access your Personal Data;
- rectify the Personal Data we hold about you;
- erase your Personal Data;
- restrict our use of your Personal Data;
- object to our use of your Personal Data;
- receive your Personal Data in a usable electronic format and transmit it to a third party (right to data portability); and
- lodge a complaint with your local data protection authority.
We encourage you to contact us to update or correct your information if it changes or if the Personal Data we hold about you is inaccurate. You may review, update or modify certain of the Personal Data that is stored in your user account on the Site (if you have one) by logging in to the “My Profile” or similar area of the Site. We may ask you to verify your identity and to provide other details before we are able to provide you the ability to change any information, correct any inaccuracies, or delete any information. Please note that we may be unable to provide you with the full benefit of our Site, or our services, if you do not provide us with your Personal Data. If you would like to discuss or exercise such rights, please contact us at email@example.com.
We may change this Policy from time to time. When we do, we will let you know by posting the changed Policy on this page with a new “Effective Date.” In some cases (for example, if we significantly expand our use or sharing of your Personal Data), we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you. We encourage you to periodically review this page for the latest information on our privacy practices.
If you have any questions or comments regarding our privacy practices, you may contact us at:
Summus Global, Inc.
25 West 39th Street, 8th Floor
New York, NY 10018