Effective Date: January 1, 2020
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 addiction 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”).
- Personal Information (also known as “Personal Data”): Personal Information means data about a particular individual or household that identifies, relates to, describes, could be reasonably linked with, or could be used to identify that person or household (or from those and other information either in our possession or likely to come into our possession). It also includes other information that may be associated with your Personal Information, such as your Usage Data (defined below), location, preferences or interests, if that information can be used to identify you or your household.
- Services: As noted above, our Services include the willingway.com website owned and operated by SBHC as well as any services provided, including, but not limited to, on-site guarding, fire and safety services, and corporate risk management.
- Cookies: Cookies are small files stored on your device (computer or mobile device).
- Data Processors: Any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
- User: Any individual who uses our Services and is the subject of Personal Information collected and/or processed.
II. Information Collection and Use
Included below is a list of several different types of information for various purposes to provide and improve our Service to you.
- Personal Information. While using our Services, we may ask you to provide us with or otherwise obtain certain personally identifiable information that can be used to contact or identify you (“Personal Information,” as defined above). Such Personal Information may include, but is not limited to, your name, address, email address, username, and any other information that may identify you.
- Generic Information. Generic information is information that does not directly reveal the identity of a SBHC customer, or visitor to the Website. This information may include Usage Data and other aggregate usage metrics such as total number of Website visitors, pages viewed, and usage patterns within the Website, etc. This may also include information about your device. We may automatically gather some Generic Information from our members, customers, and Website visitors. At times, the combination of various types of data, including Generic information and Usage Data, may enable you to be identified, and may therefore qualify as Personal Information.
- Usage Data: We may also collect information on how you access and use our Services (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Examples of Cookies and other technologies we may use include, but are not limited to:
- Session Cookies – These are cookies that enable our website to keep track of movement from page to page so you do not get asked for information that you have already provided to the Website.
- First Party Cookies – This allows SBHC to remember website configurations about out users (e.g. language preferences).
Your Cookie Choices
III. How We Collect Information
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.
IV. Purposes for Collecting, Processing, and Using Your Information
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:
- To perform a contract with you, or provide those Services you have requested of SBHC.
- You have otherwise given us your consent and permission to do so.
- The collection and processing is in our legitimate interests or the legitimate interests of a third party, and is not outweighed by any applicable rights you may have. For instance, we may use your information to assist with fraud prevention, improve the security of our networks, assist with enhancing the physical security of our customers, and reporting suspected criminal activity to law enforcement. We may also use your information in relation to certain direct marketing events.
To comply with applicable laws, in response to a lawful and enforceable request by a law enforcement, judicial, or other public authority, or in connection with an applicable legal obligation.
V. How We Use Your Information
Such general uses include, but are not limited to:
- Enhancing user experience and functionality on our Website;
- To provide and maintain our Services;
- To notify you about a change to our Services;
- To provide appropriate information to ensure the health and wellness of our clients;
VI. How We Disclose or Share Your Information
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:
- To comply with a legal obligation;
- To prevent or investigate wrongdoing or mistakes in connection with our Services;
- To protect against legal liability;
- When there is a good faith belief that such action is necessary to investigate or protect against harmful activities to our guests, visitors, associates, or property, or to others (including SBHC itself). This may include disclosures to law enforcement to investigate potential criminal activity or other civil violations.
VII. Security of Data
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.
VIII. Your Data Protection and Privacy Rights Under the California Consumer Privacy Act (“CCPA”)
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:
- Right to Access / Disclosure: The right to have access to your Personal Information upon simple request – that is, you may receive a copy of such data upon receipt of a verifiable request, along with other information related to the processing.
- Disclosure of Direct Marketers: The right to have access upon simple request, and free of charge, the categories and names of addresses of third parties that have received Personal Information for direct marketing purposes. SBHC does not disclose your personal information to direct marketers.
- Selling, Sharing, or Disclosing Personal Information: Upon receipt of a verifiable request, to obtain a list of:
- The categories of Personal Information collected about you, sold to third parties, or disclosed to third parties for business purposes;
- The categories of Personal Information sold within the last 12 months;
- The categories of sources from which Personal Information is collected;
- The business or commercial purpose for collecting or selling Personal Information; and
- The categories of third parties with whom Personal Information is shared, sold, or disclosed for a business purpose.
- Right to Correction: The right to correct your Personal Information if you find it is inaccurate, incomplete or obsolete.
- Right to Deletion / “Right to be Forgotten”: The right to obtain the deletion of your Personal Information in the situations set forth by applicable data protection law. This right does not apply to many situations involving medical information where treatment is still ongoing or the information is otherwise necessary.
- Withdraw of Consent to Processing: The right to withdraw your consent to the data processing without affecting the lawfulness of processing, where your Personal Information has been collected and processed based on your consent and not any other basis.
- Right to Object: The right to object to the processing of your Personal Information under certain circumstances, in which case we may ask you to justify your request by explaining to us your particular situation.
- Right to Restrict Processing: The right to request limits to the processing of your data, when allowed by and in circumstances set forth under applicable law.
- Right to Data Portability: The right to have your Personal Information directly transferred by us to a third-party processor of your choice (where technically feasible; may be limited to situations when processing is based on your consent).
- Right to Non-Discrimination. As defined under relevant law, you have a right to non-discrimination in the Services or quality of Services you receive from us for exercising your rights.
Please contact us at the contact us at the information in the “Contact Us” section below in relation to exercising these rights.
IX. Exercising Your CCPA 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:
- 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 share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- 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:
- 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;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
- 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;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- 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:
- Write to: Privacy Officer, Summit BHC, 389 Nichol Mill Lane, Suite 100, Franklin, TN 37067.
- Making a request here.
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.
X. Links to Other Sites
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.
XII. Contact Information
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 at: Privacy Officer, Summit BHC, 389 Nichol Mill Lane, Suite 100, Franklin, TN 37067.