PRIVACY POLICY

Last Updated October 5, 2023

1. INTRODUCTION

Center for Health Care Rights (“Organization,” “us,” or “we”) respects the privacy of the visitors to the Center for Health Care Rights website (“website” or “site”). This Privacy Policy (“Privacy Policy” or “Policy”) is an agreement between Center for Health Care Rights and you, as the user of the Center for Health Care Rights website (“you”). This agreement tells you when this Policy is effective, what information we collect from you, how we might use it, how you can review or change the personal information you provided to us, how we may change this Policy, and the steps we take to ensure that your personal information is protected.

This Privacy Policy only pertains to www.healthcarerights.org. Our privacy practices for clients are handled separately.

2. AGREEMENT TO TERMS OF PRIVACY POLICY AND TERMS OF USE

All activities in which you may engage on this website are voluntary. You are not required to provide any personal information to us unless you choose to access features on this site that require the information. If you do not agree with the terms of this Policy or other terms of use on this website, then you should immediately exit this website and discontinue using the site. If you do not agree with the terms of this Privacy Policy and our Terms of Use posted here, please do not provide us with personal information, and leave this website. The Terms of Use of this site are expressly incorporated herein by reference and made a part of this Policy. By using the Center for Health Care Rights website, you signify that you agree to the terms of this Privacy Policy as well as to our Terms of Use.

3. EFFECTIVE DATE OF AND CHANGES TO PRIVACY POLICY

This Privacy Policy is effective as of September 7, 2023 and will remain in effect except with respect to any of its provisions that are changed in the future, in which case the changes will become effective on the date they are posted on the website or we otherwise notify you of the changes. We reserve the right to change this Privacy Policy at any time. Changes, modifications, additions, or deletions will be effective immediately on their posting to this site. You should check this Policy periodically, as its terms may change from time to time. Your continued use of the site after we post any such modifications will constitute your acknowledgment of the modified Policy and your agreement to abide and be bound by the modified Policy. We will also revise the “Last Updated” date found at the beginning of this Privacy Policy when we post changes to it.

4. LIMITATIONS OF THIS PRIVACY POLICY

4.1 POLICY APPLICABLE TO ONLINE ACTIVITIES ONLY. This Privacy Policy does not extend to anything that is inherent in the operation of the Internet, and therefore beyond Organization’s control, and is not to be applied in any manner contrary to applicable law or governmental regulation. This online Privacy Policy only applies to information collected through this site. This Privacy Policy does not apply to any information we may collect from you in any place other than this website, including any information you may share with Organization over telephone, email, or otherwise.

4.2 CALIFORNIA CONSUMER PRIVACY ACT INAPPLICABLE. As a nonprofit organization, the California Consumer Privacy Act is generally inapplicable to Organization. Accordingly, nothing in this Privacy Policy or our Terms of Use will be construed as subjecting Organization to the requirements and/or liabilities of the California Consumer Privacy Act.

5. PERSONAL INFORMATION WE MAY COLLECT

We may ask you for certain information referred to on this site as “personal information,” which includes information that pertains to your identity. Such information may include, but is not limited to, items such as your name, address, email address, phone number, employment status, company affiliation, job title/roles, educational attainment, languages spoken, work experience, volunteer experience, personal interests, insurance sales licensure status, and criminal and civil backgrounds. You may be required to provide personal information to access or use certain parts of our website or features of the site. If you do not provide the requested personal information, you may not be able to access or use the features of the site where such information is requested.

6. GENERAL INFORMATION WE MAY COLLECT

6.1 GENERAL INFORMATION. There may be other instances in which we collect information from you that is more general in nature (“general information”). Such information may include your Internet Protocol (IP) address, which enables us to identify your computer or device on a Transmission Control Protocol/Internet Protocol (TCP/IP) network, which includes the World Wide Web. Your computer has an IP address, which is required in order for you to communicate with others via the internet. Such general information, including the click stream data and cookies, as mentioned below, may be collected from you whenever you access the site, whether or not you provide us with any other personal information.

A set of website features may be accessible from web-enabled mobile devices. The intent is to provide screens that are optimized for the size of the screen and operating systems. On some devices, functionality may be limited. If you access this website through a mobile device, then we may collect information about your mobile device whether or not you provide us with any other personal information.

6.2. CLICK STREAM DATA. When you visit our website, we may also collect “click stream data” (e.g., server addresses, domain names, pages previously visited, interaction with our web pages, time spent on our web pages). This information can be combined with other information we collect about you, which will enable us to analyze and better customize your visits. We may use click stream data for traffic analysis or e-commerce analysis of our website, to determine which features of our site are most or least effective or useful to you.

6.3. COOKIES. We may also use cookies to gather information about your visits to our website and enhance your experience. More information on how we use cookies is available in Section 11.

6.4. HOW WE RESPOND TO “DO NOT TRACK” DISCLOSURES. We are strongly committed to not sharing personal information with third parties. Under this Privacy Policy, we may share your information only under particular situations, as described in this Policy. Because we protect all users in this manner, we do not change our behavior in response to a web browser’s “do not track” signal.

7. USE OF INFORMATION ABOUT YOU

We will primarily use the personal information you provide and any general information we receive from you to provide products and services to you, including, but not limited to, the following:

A. To send you information or materials via email about products, offers, and news we think might interest you. This information may relate to products, offers, and news of Center for Health Care Rights or its licensees or selected commercial partners. We send you this only if you have provided your email address to Center for Health Care Rights. If you no longer wish to receive any emails from us, or if you want to modify your personal data, see Section 12.

B. To analyze visits to the website and learn about the interests of our visitors in aggregate and also on a personal level to better understand your interests and needs, so we can improve our products and services and deliver to you the type of content, features, and promotions that you are most interested in.

C. To process donation to our organization and run fundraising drives and operations in the future.

D. To assess the strengths of potential volunteers.

8. PROTECTION OF YOUR PERSONAL INFORMATION AND GENERAL INFORMATION

8.1. SECURITY MEASURES. In order to protect both the personal information and the general information that we receive from you through our website, we have implemented various security measures, including: (1) utilizing secure transmission of your data that hinders third parties’ ability to intercept it (such as through the https protocol); and (2) only engaging reputable firms to track general user information, such as Google.

8.2. RISK OF INTERCEPTION. Please keep in mind, however, that whenever you give out personal information online, there is a risk that third parties may intercept and use that information. While Center for Health Care Rights strives to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. By using this site, you expressly acknowledge and agree that we do not guarantee the security of any data provided to or received by us through this site and that any personal information, general information, or other data or information received from you through the site is provided to us at your own risk, which you expressly assume.

9. NO USE OF THIS SITE BY PERSONS UNDER 18 PERMITTED

9.1 USE OF WEBSITE. Center for Health Care Rights intends only persons who are 18 years or older to use this website. Any general information provided by a person under the age of 18 and gathered (for example, through the use of cookies) during their visit may be used as indicated in this policy (see Section 6). Center for Health Care Rights is committed to protecting the privacy of children and has no intention of collecting personal data from children under the age of 18. We encourage parents and guardians of children under 18 to regularly check and monitor their children’s use of email and other activities online.

9.2. NOTICE CONCERNING CHILDREN. PLEASE NOTE: We are a general audience site, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a site user is under age 13, we will promptly delete any personal information collected about that user.

10. THIRD PARTIES

10.1. SHARING INFORMATION WITH PERSONS OR ENTITIES WHO MANAGE THIS WEBSITE. Organization’s global and local websites and the personal information and general information collected are managed and controlled by the Operations Director located at 4601 Wilshire Boulevard, Suite 160, Los Angeles, California 90010. The servers that make Organization’s global and local websites available are located in Virginia, United States of America. If you are located outside the United States, please note that the information you provide will be transferred to the Operations Director, and by submitting the information you authorize this transfer. The Operations Director has entered into an agreement with the hosting company in Arizona, United States of America, to provide safeguards for the protection of your data that are consistent with this policy.

10.2. DISCLOSING INFORMATION TO THIRD PARTIES. Except as described in this Policy, we do not sell, trade, or otherwise transfer your personal information or general information to third parties without informing you in advance. We provide some of our services through contractual arrangements with affiliates, services providers, partners and other third parties (collectively, “service partners”). Our service partners may use your personal information to operate our sites and to deliver their services. For example, your data may be transferred to website hosting partners and other parties who assist us in designing and operating the website, executing services (such as for distributing our newsletters), or helping us analyze collected data. We will encourage our service partners to adopt and post privacy policies. However, the use of your personal information by our service partners is governed by the privacy policies of those service partners and is not subject to our control. Please also see Paragraph 6.4 on how we will respond to “do not track” signals.

10.2.1. CATEGORIES OF PERSONAL INFORMATION COLLECTED

The Organization currently collects the following information from newsletter subscribers, donors, and volunteer applicants (as necessary for each category): your name, address, email address, phone number, employment status, company affiliation, job title/roles, educational attainment, languages spoken, work experience, volunteer experience, personal interests, insurance sales licensure status, and criminal and civil background reports.

10.2.2. CATEGORIES OF THIRD PARTIES TO WHOM PERSONAL INFORMATION IS DISCLOSED AND THE CORRESPONDING CATEGORIES OF PERSONAL INFORMATION DISCLOSED

The Organization discloses your name and email address to software vendors that manage our email list distribution in order to distribute our email newsletters and other notices. We may also disclose your name, address, and email address to third-party vendors we engage to assist with fundraising drives or operations. For individuals applying to volunteer with Organization, we may transmit any information collected on the “HICAP Volunteer Counselor Program Application” to companies providing background checks if you consent to such disclosure on that form.

10.2.3. CATEGORIES OF THIRD PARTIES TO WHOM PERSONAL INFORMATION IS SOLD AND THE CORRESPONDING CATEGORIES OF PERSONAL INFORMATION SOLD

We do not sell any personal information to third parties.

10.3. RELEASE OF INFORMATION IN OTHER CIRCUMSTANCES. Center for Health Care Rights will release personal or general information without your consent for security purposes, when required by law, or to prevent imminent harm to any person or entity. We will disclose personal or general information on receipt of a court order or subpoena, or to cooperate with a law enforcement investigation, which may include responding to requests and court orders from jurisdictions outside the United States.

We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful, as determined in our sole discretion. Release of your personal data for security purposes, as described in this agreement, to any person or entity under any circumstances shall be based on a determination made solely by us, exercising our own discretion, permission for which is expressly granted by you to us in accordance with this Policy.

10.4. LINKS TO THIRD PARTIES. For your convenience and to improve usage of the website, we may insert links to third parties on this site. This Privacy Policy does not apply to such third-party websites. These links take you outside our service and off the Center for Health Care Rights’ site and are beyond our control. This includes links from partners that may use Center for Health Care Rights’ logos as part of a co-branding agreement. The sites those links can take you to have their own separate privacy policies and, although we seek to protect the integrity of our site, Center for Health Care Rights is not liable for the content and activities of those sites. Your visits and access to such websites is at your own risk. Please note that those other sites may send their own cookies to users, collect data, or solicit personal information.

10.5. THIRD-PARTY SOFTWARE. Our site also utilizes “content delivery networks” (CDNs) to more efficiently deliver website content to you. When we utilize a CDN, our website delivers standard content from a third-party’s server. For example, to utilize some functionality offered by Google, this website may embed some code that delivers content from Google’s servers. When that happens, a third party may collect some information about you. The third parties offering use of CDNs have their own separate privacy policies and, although we seek to protect the integrity of our site, the Center for Health Care Rights is not liable for data collection by any of those third parties.

11. AUTOMATIC COLLECTION / COOKIES

A cookie is a small string of information that the website you visit transfers to your computer for identification purposes. Cookies can be used to follow your activity on the website and that information helps us to understand your preferences and improve your website experience. You can turn off all cookies, in case you prefer not to receive them.

You can also have your computer warn you whenever cookies are being used. For both options, you have to adjust your browser settings (such as Chrome, Safari, Firefox, Internet Explorer, or other browser). There are also software products available that can manage cookies for you. Please be aware, however, that when you choose to reject cookies, this choice may limit the functionality of the website you visit and you may lose access to some of its features.

12. DELETING OR MODIFYING PERSONAL INFORMATION

You may cancel your registration for our email list at any time by clicking the “unsubscribe” link at the bottom of any such message you receive. However, any information collected on our Donate page, the “HICAP Volunteer Counselor Program Application,” and/or any associated background checks for volunteers will be retained by Organization for risk management and legal compliance purposes.

12.1. Opt Out of the Sale of Personal Information

The Organization does not sell personal information to third parties.

12.2. Update Your Contact Information. We encourage you promptly to update your contact and personal information when it changes.

13. QUESTIONS OR COMMENTS. If you have any questions or comments relating to our website or this Privacy Policy, write Attn: Operations Director, 4601 Wilshire Boulevard, Suite 160, Los Angeles, California 90010.