Effective date: November 10th, 2019
As noted in the Terms of Service, we do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at firstname.lastname@example.org.
What information does Coa collect?
Information you provide to us:
We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address or phone number, we may send you promotional email offers on behalf of other businesses, or email or text you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by clicking on the “Unsubscribe” link at the bottom of the email or by texting us your desire to opt-out of sms messages.
Use of Protected Health Information
If you have registered with Coa, you have agreed to the Terms of Service which describe our practices and your obligations with regard to your protected health information (“PHI”). Please read and review the Terms of Service and Consent Form carefully as they are a contract between you and Coa. We may use your PHI in the following ways: As part of the Services, we may deliver your PHI to your Therapist. Your Therapist should give you a notice of privacy practices that describe how your Therapist uses and discloses your PHI, including through the Services. Your Therapist's ability to disclose your PHI for these and similar purposes is restricted by applicable federal law and state law, including HIPAA and the applicable privacy laws of the state in which you reside. If you wish to restrict the disclosures that your Therapist makes of your PHI, you should make a request directly to your Therapist. To the extent your PHI becomes part of your Therapist’s health records, you may not be able to delete it. We may also use your PHI to operate our Services, and we may give it to our services providers to assist us in providing Services, for example with regards to scheduling. We may also disclose it if we are compelled to do so by law, including valid legal process.
We may anonymously aggregate your PHI with that of other patients who use the Services, and share such aggregated information with health care providers and their business associates for health care operations purposes, or other purpose(s) in accordance with applicable state and federal law.
In order to maintain the security of your Account, we may monitor and keep a log of access to it, and we may maintain the log until we determine it is no longer needed.
We may use IP addresses and device identifiers to analyze trends, administer the Services and gather broad demographic information for aggregate use. We do not link IP addresses and device identifiers to PII or PHI.
We are permitted to remove personal identifiers from your PII, including PHI, so that it cannot reasonably be used to identify you. We may use your PHI collected through the Services to create de-identified information (i.e., information that does not identify you).
Information collected automatically
Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.
We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.
Information collected from other websites and Do Not Track Policy
Will Coa share any of the Personal Information it receives?
We do not rent or sell your Personal Information in personally identifiable form to anyone, provided that certain Personal Information may be transferred in connection with business transfers, as described below. We may share your Personal Information with third parties as described in this section:
Information that’s been de-identified. We may de-identify your Personal Information so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.
We may deliver a file to you through the Services (known as a “web beacon”) from an ad network. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their site. You may be able to opt-out of web beacon tracking conducted by third parties through our Services by adjusting the Do Not Track settings on your browser; please note that we don’t control whether or how these third parties comply with Do Not Track requests.
Affiliated Businesses: In certain situations, businesses or third party websites we’re affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. One such service may include the ability for you to automatically transmit Third Party Account Information to your Services profile or to automatically transmit information in your Services profile to your third party account; for example, for scheduling of your appointments. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.
Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing company to receive and process your credit card transactions for us. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. Note that an “agent” may also be considered a “partner” in certain circumstances, and would be subject to the terms of the “Information that’s been de-identified” section in that regard.
User Profiles and Submissions: Certain user profile information, including your name, location, and any video or image content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Your account privacy settings may allow you to limit the other users who can see the Personal Information in your user profile and/or what information in your user profile is visible to others. Please remember that any content you upload to your public user profile, along with any Personal Information or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your user name may also be displayed to other users if and when you send messages or comments or upload images or videos through the Services and other users can contact you through messages and comments. Additionally, if you sign into the Services through a third party social networking site or service, your list of “friends” from that site or service may be automatically imported to the Services, and such “friends,” if they are also registered users of the Services, may be able to access certain non-public information you have entered in your Services user profile. Again, we do not control the policies and practices of any other third party site or service.
Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
Protection of Company and Others: We reserve the right to access, read, preserve, and disclose any information that we [reasonably] believe is necessary to comply with law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others.
Is Personal Information about me secure?
Your account is protected by a password for your privacy and security. If you access your account via a third party site or service, you may have additional or different sign-on protections via that third party site or service. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
What Personal Information can I access?
Through reaching out to our support team via email@example.com or through your account settings (once that feature is live), you may access, and, in some cases, edit or delete the following information you’ve provided to us:
- name and password
- email address
- phone number
- credit card and other billing information
The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at firstname.lastname@example.org.
What choices do I have?
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.
You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by sending an email to email@example.com. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
What if I have questions about this policy?
We strive to use any information you provide us thoughtfully to enhance the Service we or our partners provide you. If you have any questions or concerns regarding our privacy policies, please send us a detailed message to firstname.lastname@example.org, and we will try to resolve your concerns.