PRIVACY POLICY
Welcome. This Privacy Policy (“Policy”) applies to all websites operated by Promises Behavioral Health, LLC and/or any of its subsidiaries and affiliates (“Company,” “we,” “us,” or “our”), including without limitation www.promisesbehavioralhealth.com (“Sites”).
This Policy has been created in order to demonstrate and inform you of our firm commitment to privacy. The following Policy describes how we collect, protect, and use information we receive from visitors to the Sites or prospective consumers. This Policy applies to information collected through this Sites as well as information about you collected through any other means, including information you may provide to us other than on the Sites.
BY ACCEPTING THIS POLICY AND USING THE SITES, YOU AGREE TO AND ARE BOUND BY THE TERMS, CONDITIONS, POLICIES, AND NOTICES CONTAINED IN THIS POLICY, INCLUDING WITHOUT LIMITATION CONDUCTING THIS TRANSACTION ELECTRONICALLY AND A CHOICE OF TENNESSEE LAW.
COMPANY MAY MODIFY THIS POLICY AT ANY TIME, AT ITS DISCRETION, AND MODIFICATIONS ARE EFFECTIVE UPON BEING POSTED ON THE SITES. YOU ARE RESPONSIBLE FOR REVIEWING THIS POLICY PERIODICALLY TO ENSURE THAT YOU ARE AWARE OF ANY CHANGES TO IT BECAUSE YOUR CONTINUED
USE OF THE SITES WILL MEAN THAT YOU ACCEPT SUCH CHANGES. IF YOU DO NOT AGREE WITH THIS POLICY, OR ANY SUBSEQUENT MODIFICATIONS TO THE POLICY, OR ARE YOUNGER THAN EIGHTEEN (18) YEARS OLD, YOU MUST NOT ACCESS OR USE THE SITES OR DISCLOSE ANY PERSONAL INFORMATION THROUGH THE SITES.
1. CONSENT
By using the Sites, you signify your agreement to the terms of this Policy. If you do not agree with this Policy, you may not disclose any personal information through the Sites.
2. THE INFORMATION WE COLLECT
There are two kinds of information Company may obtain about you:
- Anonymous Information: “Anonymous Information” is data in a form that does not permit direct association with any specific individual. Anonymous Information is aggregate data that websites and applications use to administer their sites and services and the contents thereon and therein. It may include such information as your browser or device type, your Internet Protocol (IP) address (if not deleted, clipped, or anonymized), log file information, cookie information, and similar tracking technologies. Company may from time to time collect or retain third parties to help us collect and aggregate anonymous information.
- Device Information. Company may collect non-personal information about the computer, mobile device, or other device you use to access the Sites, such as IP address, geolocation information, unique device identifiers, browser type, browser language, and other transactional information. Web servers automatically identify your device by its IP address. Company does not link IP addresses to any PII (as defined below), even if such information is voluntarily provided by a user or visitor. The Sites also may gather anonymous “traffic data” that does not personally identify you, but that may be helpful for marketing purposes or for improving the products and services Company offers.
- Cookie and Web Beacon Information. As is the case with many websites and web-based applications, the Sites use a technology called “cookies,” which are small data files that are downloaded onto your computer or mobile device. The use of cookies is standard on the Internet, and allows us to tailor your visits to the Sites to your individual preferences. When you access the Sites, a web beacon allows us to capture certain additional types of information about your activities and use of the Sites over time, such as which web pages you choose to visit. Company also may contract with third-party service providers who assign cookies and/or web beacons to conduct site tracking for Company and collect information about your visits to the and use of the Sites over time as well as your visits to other websites in order to provide marketing analytics about goods and services of interest to you, your preferences, how you share information about Company products and services with others, and to improve our marketing efforts. Company may combine such information about your visits to and use of the Sites as well as your visits to other websites with PII (as defined below) that Company or its third-party providers collect about you, such as your user ID, name, email address, and mailing address. Although most web browsers automatically accept cookies, you can change your browser to prevent cookies or notify you whenever you are sent a cookie. However, if you disable or block cookies on your browser, certain features on the Sites may not work correctly.
- Third-Party Social Media Information. If you choose to access, visit, and/or use any of Company’s pages on social media platforms such as Facebook, Twitter, or Instagram (“Social Media Platforms”), Company may receive aggregate information and analysis about visitors’ usage of the pages on such Social Media Platforms.
- Personally Identifiable Information: Personally identifiable information (“PII”) is any information that can be used to identify or contact a specific individual and any other information about that individual (which may include your name, postal address, e-mail address, or telephone number). You provide your PII to Company in a variety of ways when you interact with the Sites. Sometimes this personal information is needed when you subscribe to Company email communications, comment on blogs, or when you contact Company. For example, you may be asked to provide the following information:
- Email Correspondence. Company offers visitors to the Sites the opportunity to sign up to receive email notices, promotions, and other communications from Company. In order to sign up for these communications, Company asks for your contact information, such as name, email address, and zip code. Company also may offer the opportunity for you to receive other communications that Company thinks may be of interest to you.
- Other Communications. Scattered throughout the Sites are links or forms that can be used to contact Company so you can comment, make a complaint, make suggestions, or ask questions. Your name, email address, address, and/or phone number may be requested on these forms. Company may store information from email on file, but does not currently sell or license this information with third parties without express authorization from you.
- Third-Party Social Media Platforms. You may choose to provide PII through Social Media Platforms, including without limitation your name, phone number, or address when you communicate with Company or other participants on the Social Media Platforms, post suggestions or comments for Company, or enter a sweepstakes or contest through the Social Media Platforms (if any). For example, if you post a comment on Company’s Facebook page or send us a message on Twitter, we may collect that information as described in this Policy and may link information about such interactions with other publicly available information included in your profile on such Social Media Platforms, such as your name, user ID, geolocation, purchase history, likes, networks, list of friends, and birthday. This information will also become part of your profile or account as maintained by Company. However, please note that this Policy does not cover the privacy and security practices of the Social Media Platforms on which Company has pages, including without limitation Facebook, Twitter, and Instagram. Please carefully review the privacy policies and terms of service on such Social Media Platforms before using, visiting, or interacting with others on such Social Media Platforms. Please remember that any information you share on our pages or in general on Social Media Platforms becomes public information, and you should exercise caution when deciding whether to disclose your personal information in such a manner. In addition, when you interact with the Sites through Social Media Platforms or third-party social media applications, sharing products or content through Social Media Platforms by sharing or liking such products or content, our third-party providers may combine information concerning such activities with other information about you such as your user name, gender, referring website, geographic location, and other information obtained through other third-party websites you visit as well as your public profile(s) on such Social Media Platforms. Such information will also become part of your profile or account as maintained by Company.
3. HOW WE USE GATHERED INFORMATION
A. Anonymous Information is used internally for the administration, troubleshooting, data analysis, auditing, and research of the Sites to help improve the quality, design, and information provided to you. Some examples of the kinds of anonymous information Company may collect include information about your usage of features of the Sites and other data generated during your interactions with the Sites. We may share such aggregated, non-PII, such as demographics and general analytics regarding usage of the Sites, with existing and prospective business partners, clients, and advertisers as well as our third-party service providers who help us run the Sites and features on the Sites, or otherwise in our business. None of the anonymous information Company shares will contain any information that identifies you individually.
We also may use “cookies,” which are small data files that are downloaded onto your computer or mobile device, used to tailor your use of the Sites and your preferences, authenticate your access, and display relevant information, and/or web beacons (also known as pixel tags or clear GIFs), which are unique identifiers that allow us to capture certain additional types of information about your activities and use of the Sites over time, such as which webpages you choose to visit.
Some browsers have a “do not track” feature that lets you indicate that you do not wish to have your online activities tracked. These features are not yet uniform, so we do not currently respond to such features or signals. Therefore, if you select or turn on a “do not track” feature in your web browser or block or delete tracking cookies, Company and its third-party providers may continue collecting information about your online activities as described in this Policy.
Company may combine such information about your visits to and use of the Sites, as well as your visits to other websites, with PII that we or our third-party providers collect about you, such as your username, name, email address, and mailing address.
B. Company collects PII about you only when you voluntarily provide such information, or when such information is provided to us on your behalf.
We may use the information collected to notify you of changes made to our Sites, to send you promotional materials, and to determine what information and services users want the most. If you contact us for assistance or support, we may use your information to provide service and support to you. Company also may provide the information to third parties who assist us in contacting customers about special offers and other Company services, programs, or events that would likely be of interest to you. We may share PII, such as demographics, with existing and prospective business partners and advertisers that may be of interest to you.
If you choose to access the Sites while you are logged into your account with a Social Media Platform, Company’s third-party providers may collect certain information about your activities and profile on such Social Media Platform, including without limitation your visits to and conversations and comments about specific pages, products and services, shares and referrals you make for specific pages, products and services, and your purchases of specific products or services. This information may be combined with other information available on your profile on Social Media Platforms, including without limitation your name, profile picture, gender, networks, user ID, list of friends, birthday, likes and preferences, education history, work history, current city, hometown, interests, relationship status, and any other information you have made available on the Social Media Platforms and will become part of your profile as maintained by Company.
Company also may disclose PII if we are required to do so by law or we in good faith believe that such action is necessary to (i) comply with the law or with legal process; (ii) protect and defend our rights and property; (iii) protect against misuse or unauthorized use of Sites; or (iv) protect the personal safety or property of our users or the public. Please note Company may not provide you with notice prior to disclosure in such cases.
4. WITH WHOM WE MAY SHARE YOUR INFORMATION
A. Company may from time to time contract with third parties to assist us in collecting, maintaining, and managing our user information and providing analytics regarding your interactions with the Sites and other third-party websites so that we may improve the Sites and the services we offer, and you may be directed to a third-party site or service that will directly collect such information for such purposes. Company does not control such sites or services and is not responsible for the actions of third parties, and each such third-party site or service maintains its own independent privacy and data collection and use policies and practices. If you visit or use a site or service that is linked to from the Sites, Company encourages you to consult and review that site’s or service’s privacy policy before providing any personal information.
Company also may use (and may contract with third-party service providers to help us use) your information on an aggregate basis – without personal identifiers – and other usage information that is useful in developing new features and content for the Sites or other products and services developed by or on behalf of Company. In addition, we reserve the right to use and publish your information on an aggregate basis without personal identifiers and to perform statistical analyses of user behavior (on an aggregate basis) in order to measure interest in and use of the various areas and features of the Sites.
For example, Company may contract with service providers to serve ads on our behalf across the Internet. They collect information about your use of the Sites. They also may use information about your visits to the Sites and other websites to improve the features and functionality we make available through the Sites. In all cases, however, Company will only use your information as permitted by law.
We also may use Google Analytics, a service provided by Google, Inc., to gather information about how you and other users engage with the Sites. For more information about Google Analytics, please visit www.policies.google.com/technologies/partner-sites.
B. We may be required to transfer or disclose PII to third parties without prior consent if required by law, such as a court ordered subpoena, search warrant, or other court order, or if required by exigent circumstances. Without limiting the foregoing, Company may share your PII our third-party service providers, or governmental agencies or bodies, or third parties representing the foregoing upon request, solely in connection with your use of the Sites.
5. OPT-OUT
Company supports the right of our visitors to choose. If you decide that you do not wish to receive special offers or promotional communications, you can contact us at info@promises.com or at the address provided below, indicating that you no longer want to receive information relating to the Sites.
Your opt-out request may take up to ten (10) business days to process, and you may receive communications from us or our third-party service providers in the meantime.
6. ACCESS AND CORRECTION
You have a right to know about the personal information that Company holds about you, including the right to correct, amend, or delete the information that we have on file if it is incorrect. If you wish to exercise these rights please contact us by email or postal mail at the addresses below.
7. SECURITY
The Sites incorporate appropriate safeguards to protect the security, integrity, completeness, accuracy, and privacy of the personal information we have collected. We have put in place reasonable precautions to protect information from loss, misuse, and alteration. While on a secure page, the lock icon on the bottom of web browsers such as Google Chrome, Mozilla Firefox, and Microsoft Internet Explorer becomes locked, as opposed to unlocked, or open, when you are just “surfing.” Security of information communicated by or to us over the Internet is of utmost concern to us; unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Please note that your email or other electronic correspondence with us through the Sites, like most, if not all, non-encrypted Internet communications, may be accessed and viewed by other Internet users, without your knowledge and permission, while in transit to us. For that reason, to protect your privacy, please do not use email or the contact forms provided through the Sites to communicate information to us that you consider confidential. While we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us or through the Sites, and you do so at your own risk. Once we receive your transmission, we will use reasonable efforts to ensure its security on our internal systems. Depending on the nature of the inquiry, your communication may be discarded or archived. If you wish, you may contact us instead via telephone at the numbers provided throughout the Sites.
8. DISCLOSURE OF INFORMATION THROUGH BUSINESS TRANSFERS
As Company continues to develop its business, we may buy, merge, or partner with other companies or businesses, and in so doing, acquire customer information. In such transactions, user information may be among the transferred assets. Similarly, in the unlikely event that a portion or substantially all of Company’s assets are sold or transferred to a third party, such information (including your email address) would likely be one of the transferred business assets.
9. OUR COMMITMENT TO CHILDREN’S PRIVACY
Protecting the privacy of children is very important to Company. The Children’s Online Privacy and Protection Act of 1998 (“COPPA”) defines a “Child” as anyone under the age of 13. We strictly adhere to COPPA. For that reason, we do not collect or maintain information obtained through the Sites from those we actually know are under 13, and no part of the Sites are structured to attract anyone under 13.
10. EXTERNAL LINKS
The Sites may provide links and/or ad banners to various websites or sponsors that we do not control for your convenience. When you click on one of these links, you will be transferred out of the Sites and connected to the website of the organization or company that you selected. Company is not responsible for the nature, quality, or accuracy of the content or opinions expressed in such websites, and such websites are not investigated, monitored, or checked for quality, accuracy, or completeness by us. Inclusion of any linked website on the Sites does not imply or express an approval or endorsement of the linked website by us, or of any of the content, opinions, products, or services provided on these websites. Even if an affiliation exists between the Sites and a third-party website, we exercise no control over linked site. Each of these linked websites maintains its own independent privacy and data collection policies and procedures. While we expect our partners, advertisers, and affiliates to respect the privacy of our users, we cannot be responsible for the actions of third parties. If you visit a website that is linked to the Sites, we encourage you to consult that website’s privacy policy before providing any personal information and whenever interacting with any website.
11. SPECIAL NOTICE TO NON-UNITED STATES USERS
If you are located outside the United States of America and are using the Site, you should be aware that your personal information will be transferred to the United States of America, the laws of which may be deemed by your country to have inadequate data protection. If you are located in a country outside the United States of America and voluntarily submit personal information to Company, you thereby consent to the general use and onward disclosure of such information as provided in this Policy and to the transfer of that information to and storage of that information in the United States of America.
12. CONSENT AND JURISDICTION
The Sites are controlled, operated, and administered entirely within the United States. By using the Sites, you signify your agreement to the terms of this Policy. If you do not agree with this Policy, please do not disclose any personal information through the Sites. This Policy and the use of the Sites are governed by the laws of the State of Tennessee, without giving effect to its conflicts of law provisions. Any claim related to the Sites or this Policy shall be brought in a federal or state court in Nashville, Tennessee, within one year after the claim arises. Users of the Sites consent to the jurisdiction and venue of such courts as the most convenient and appropriate for the resolution of disputes concerning this Policy. This Policy and the notices outlined herein are not intended to and do not create any contractual or other legal rights in or on behalf of any third party.
13. SPECIAL NOTICE TO CALIFORNIA RESIDENTS
Under the California Civil Code, residents of the State of California that have provided any PII to Company have the right to request a list of all third parties to which we have disclosed PII during the preceding year for direct marketing purposes. Alternatively, the law provides that if we have a privacy policy that gives either an opt-out or opt-in choice for use of PII by third parties (such as advertisers or affiliated companies) for marketing purposes, we may instead provide you with information on how to exercise your disclosure choice options. We qualify for the alternative option; we have established this Policy that provides you with details on how you may either opt-out or opt-in to the use of your PII by third parties for direct marketing purposes.
If you are a California resident and request information about how to exercise your third party disclosure choices, please send a request to info@promises.com with a preference on how our response to your request should be sent.
14. MODIFICATIONS TO PRIVACY POLICY
Company may change, modify, add, and/or delete all or portions of this Policy at any time, at its discretion, and modifications are effective upon being posted on the Sites. If we decide to change this Policy, we will post those changes on the home page of the Sites and any other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. You are responsible for reviewing this Policy periodically to ensure that you are aware of any changes to it. If we make material changes to this Policy, we will notify you by means of a notice on the Sites’ home page.
15. ACCOUNT REVISIONS, REVOKING, AND DELETING PERSONAL INFORMATION
Company welcomes your questions, comments, and all feedback pertaining to your privacy or any other issue with regard to the Sites.
At any time, you may revoke your consent, cease further use of your email address to send you updates, and direct us to delete the information you have supplied. Although it is not always possible to remove or modify such information, we will make reasonable efforts to do so. If you have given us information for one of those third parties we mentioned above and we have already passed it on, we cannot delete or change the information.
In the event that you have given us PII in the past and then have second thoughts or want to update it, you may send an email or contact us by regular mail:
Promises Behavioral Health
103 Powell Court, Suite 100
Brentwood, Tennessee 37027
Attn: Legal Department
Last Updated: July 26, 2019