Summit Behavioral Healthcare (“SHBC”,” “us”, “we”, or “our”) operates the willingway.com (“Website”), and provides various services to clients in order to manage and care for individuals who suffer from behavioral illnesses, chemical dependencies or addition disorders. Among other services, we offer hospitalization, inpatient treatment, detoxification programs, partial hospitalization programs, and intensive outpatient programs (hereinafter collectively referred to as the “Services”).
Included below is a list of several different types of information for various purposes to provide and improve our Service to you.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Services.
Examples of Cookies and other technologies we may use include, but are not limited to:
Your Cookie Choices
SBHC collects and obtains your information in a few ways: there is information that you choose to give to us, information we obtain through your use of our Services – including our Website – and information we obtain from third parties.
a. Information You Give Us
We collect information that you decide to share with us. At times, we may require you to provide certain information – including Personal Information – in order to use certain parts of our Website, fulfill your requests with us, or provide you with certain Services. For instance, we may require you to provide your name, email address or other contact information when you contact us with a question or comment. Additionally, we may need you to provide certain Personal Information to use other portions of our Services.
b. Information We Obtain When You Use Our Services
As noted above, we collect certain information from you through your use of our Services, such as Usage Data. For instance, in using our Website, we may collect information about the device you use to log into, access, and use the Website. We may collect other Generic Information in relation to how you use our Website or other Services (for example, aggregate metrics on how often certain pages on our Website are accessed and viewed).
We also may collect information through the use of cookie, pixel tags, or other technologies, as described above.
c. Information We Obtain from Third Parties
We may also obtain information about you from our third party service providers who help us provide our Services to you.
SBHC collects, processes (or asks our service providers to process on our behalf), and uses your information to provide the Services we make available to you. We therefore will collect and use your information for a variety of reasons, including:
Such general uses include, but are not limited to:
SBHC does not and will not sell your personal information Please note that SBHC may disclose your information in a number of ways in furtherance of our Services to you. For instance, we may share you information with other healthcare providers to ensure that all necessary information is transferred to facilitate necessary treatment and care.
We may also disclose or share your information for the following purposes:
SBHC takes reasonable, technical, organization, and other measures to protect the personal information we collect from being subject to accidental or unlawful destruction, accidental loss or alteration, disclosure without authorization, and any other unlawful actions taken against otherwise protected information. Moreover, SBHC takes all judicious legal, technical, and organizational measures reasonably necessary to ensure that all personal information is handled with a sufficient level of security. Furthermore, SBHC takes all reasonable measures to protect personal information when it is shared with third parties.
Despite the security measures taken, SBHC cannot guarantee the protection of the data you provide to us.
California Residents. SBHC takes reasonable steps to allow you to exercise your rights pursuant to CCPA. As such, where applicable under relevant law, you are entitled to the following[Moran, Th1] :
Please contact us using the information in the “Contact Information” section at the very bottom of this document, in relation to exercising these rights.
a. Access to Specific Information
California residents have the right to request information from us regarding the manner in which we share certain categories of personal information with this parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address at the conclusion of this policy. You may request the following information:
1. The categories of personal information we collected about you.
2. The categories of sources for the personal information we collected about you.
3. Our business or commercial purpose for collecting that personal information.
4. The categories of third parties with whom we share that personal information.
5. The specific pieces of personal information we collected about you (also called a data portability request).
6. If we disclose or sell your information for a business purpose, you have the right to identify the personal information categories that each category of recipient obtained.
b. Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to limited exceptions. Once we receive a verifiable request, and determine that it is not subject to an exceptions, we will delete your personal information from our records. Please note, personal information involved in the ongoing treatment of our patients, with SBHC or elsewhere, will not be subject to deletion.
Moreover, we may deny your deletion request if retaining the information is necessary for us or any applicable third party to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
3. Debug products to identify and repair errors that impair existing intended functionality;
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
8. Comply with a legal obligation;
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
c. Making a Request
To exercise the access or deletion rights listed above, please submit a verifiable consumer request to us by either:
Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests not submitted through one of the above-listed methods of communication.
Your request will only be processed if you are a California resident, and your identity can be verified. Furthermore, the CCPA does not apply to healthcare or employee information.
This section describes how medical and clinical information (Protected Health Information or PHI) about you may be used and disclosed and how you can get access to this information. Please review it carefully.
When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.
1. Get an electronic or paper copy of your medical record
2. Ask us to correct your medical record
You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this. We may say “no” to your request, but we’ll tell you why in writing within 60 days. Your request can be denied for the following reasons:
3. Request confidential communications
You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address. We will say “yes” to all reasonable requests.
4. Ask us to limit what we use or share
5. You have the right to receive confidential communications based on a reasonable requests by individuals to receive communications of PHI, from us, by alternative means
6. Get a list of those with whom we’ve shared information
7. Get a copy of this privacy notice
8. Choose someone to act for you
9. File a complaint if you feel your rights are violated
For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions. In these cases, you have both the right and choice to tell us to:
If you are not able to tell us your preference we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.
In the following cases, we never share your information unless you give us written permission:
How do we typically use or share your health information?
We typically use or share your health information in the following ways.
We can use your health information and share it with other professionals who are treating you.
We can use and share your health information to run our facility, improve your care, and contact you when necessary.
We can use and share your health information to bill and get payment from health plans or other entities.
How else can we use or share your health information?
We are allowed or required to share your information in other ways – usually in ways that contribute to the public good, such as public health. We have to meet many conditions in the law before we can share your information for these purposes.
We can share health information about you for certain situations such as:
Help with public health and safety issues
Comply with the law
Work with a medical examiner or funeral director
Address workers’ compensation, law enforcement, and other government requests
Respond to lawsuits and legal actions
For more information see: https://www.hhs.gov/hipaa/for-individuals/notice-privacy-practices/index.html.
We exercise no control over and assume no responsibility for the content, privacy policies or practices of any third party site or services.
We reserve the right to amend this privacy notice at our discretion and at any time.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by mailing: Privacy Officer, Summit BHC, 389 Nichol Mill Lane, Suite 100, Franklin, TN 37067. You can also contact the Privacy Officer through the confidential website at summitbhc.ethicspoint.com or phone number (844) 920-1197.