This Policy was last updated on November 18, 2019.
12 Keys (referred to herein as “12 Keys,” “we,” “us,” and “our”) is committed to protecting the privacy and security of the information we collect, use, share, and otherwise process as part of our operations. We also believe in transparency, and we are committed to informing you about how we treat your information.
Our “Notice of Privacy Practices” https://12keysrehab.com/ describes how Protected Health Information (PHI) about you may be used and disclosed and the rights you have regarding that information. This Policy serves a different purpose, and it applies to information that is not PHI, which we may collect when you visit our website, https://12keysrehab.com/ (12 Keys 12 Keys Rehab). This Policy does not apply to PHI.
THIS SITE IS INTENDED FOR USERS LOCATED IN THE UNITED STATES, AND IT IS NOT INTENDED FOR USERS LOCATED IN OTHER COUNTRIES, INCLUDING THE EUROPEAN UNION AND THE EUROPEAN ECONOMIC AREA. BY USING THIS SITE, YOU ACKNOWLEDGE AND AGREE THAT YOU ARE USING THE SITE FROM WITHIN THE UNITED STATES.
WHAT INFORMATION DO WE COLLECT?
We collect and use the following information from you for the purposes set forth in the “How Do We Use Your Information” section of this Policy. We may also share this information as set forth in the “How Do We Share Information” section below. However, any information that is PHI is governed by our Notice of Privacy Practices https://12keysrehab.com/ and is not subject to the Policy.
Category Description of Data
Contact Information When you visit the Site, we may ask you for your name, telephone number, email address, or other contact details. Depending on the context in which we collect this information, this information may be PHI.
Cookies and Similar
Technical Data and Location Information
When you visit the Site, we automatically collect information from your browser or your mobile device, which includes [the date and time of your visit, your Internet Protocol (IP) address or device identifier, your browser type, your device type, your location, your operating system, your internet service provider (ISP), URLs of any referring or exited webpages, your domain server, data about which pages you visit, and information about your interaction with the Site]. To learn more about our collection of technical data, please see the “Cookies and Similar Technologies” section of this Policy.
If you receive email communications from us, we use certain tools to capture [data related to if/when you open our message and if/when you click on any links or banners it contains]. Other information collected through this email tracking feature includes: [your email address, the date and time of your “click” on the email, a message number, the name of the list from which the message was sent, a tracking URL number, and a destination page].
Numbers The telephone number(s) displayed on the Site are dynamic, and different numbers appear depending on how you first arrive at the Site. This information is created and stored via cookies and similar technologies. When you call us, we collect your name, phone number, city, the length of our call, and information about how you came to our site based on the dynamic number that you dial. Depending on the context in which we collect this information, this information may be PHI.
Chat Function We use a chat widget through which you can communicate with a member on our admissions team. We will collect your email address, and you may provide other information as you deem appropriate. Depending on the context in which we collect this information, this information may be PHI.
Cookies and Similar Technologies
- First-Party and Third-Party Cookies
A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” cookie). “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Permanent” cookies remain stored on your hard drive until they expire or are deleted by you. Local stored objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website.
First-party cookies are set by the Site, and they can only be read by the Site. Third-Party Cookies are set by a party other than us. The information collected via cookies on the Site includes: [browsing history; search history; internet service provider (ISP); type of computer; type of web browser; URLs of any referring or exited webpages; operating system; information about your interaction with the Site or advertisements on it; data about which pages you visit; the date and time of your visit; your domain server; and your browser type].
- Similar Technologies
In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as users navigate through and interact with the Site:
- Web beacons: These are tiny graphics (sometimes called “clear GIFs” or “web pixels”) with unique identifiers that are used to understand browsing activity. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are rendered invisible on web pages when you open a page.
- Social Widgets: These are buttons or icons provided by third-party social media providers that allow you to interact with social media services when you view a webpage or mobile app screen. These social widgets may collect browsing data, which may be received by the third party that provided the widget and are controlled by third parties.
- UTM Codes: These are strings that can appear in a URL (the “Uniform Resource Locator,” which is typically the http or https address entered to go to a web page) when you move from one web page or website to another, where the string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.
We use Facebook Connect to track Facebook ad-driven visitor activity on the Site. Facebook Connect also gives you the option to post information about your activities to your profile page to share with others within your network by using a single sign-in service to authenticate your identity. You may learn more about Facebook Connect by visiting https://www.facebook.com/policy.php, where you can also find instructions for opting out of receiving advertisements.
- Other Third-Party Technologies
Some third parties may use automated data collection technologies to collect information about you when you browse the Internet. The information they collect about your online browsing activities over time and across different websites and other online services may be associated with your personal information and used to provide you with targeted content. We do not control these third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible party directly or consult their privacy policies.
- Choices About Cookies
We provide you with choices regarding the information you provide to us, and we have created ways to give you control over your information. Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may [choose to not allow cookies via the cookies consent banner or] set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. You may adjust your browser settings to opt-out of accepting a “persistent” cookie and to only accept “session” cookies, but you will need to log in each time you want to enjoy the full functionality of the Site.
To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website at: https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html.
For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/.
HOW DO WE USE YOUR INFORMATION?
Our Notice of Privacy Practices describes how we may use PHI. Where the data is not PHI, we may use the types of information listed above in order to:
- Comply with federal, state, or local laws;
- Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
- Cooperate with law enforcement agencies;
- Exercise or defend legal claims;
- Provide you with the services you have requested;
- Detect fraud and prevent loss;
- Contact you about services that may be of interest to you;
- Establish and maintain your user account with us;
- Manage our relationship with you;
- Allow you to contact us and facilitate your communication with us;
- Respond to your feedback, requests, questions, or inquiries;
- Provide you more tailored advertising;
- Operate the Site and prepare aggregate traffic information;
- Determine and track customer interests, needs, and preferences;
- Improve our customer service and marketing efforts;
- Operate our business;
- Facilitate corporate mergers, acquisitions, reorganizations, dissolutions, or other transfers;
- Ensure safety of person or property;
- Recognize your browser/device and remember your preferences and interactions;
- Operate, enable, and improve the Site and its content/functionality;
- Understand how you interact with the Site and enhance your experience on the Site by providing a more personal and interactive experience;
- Track visits to the Site and usage analytics (e.g. page response times, download errors, length of visit, webpages visited, etc.);
- Track telephone calls and call metrics via dynamic telephone numbers;
- Manage and maintain the security of the Site; and
- Provide notice of changes to the Site or the services we offer or provide through it.
HOW DO WE SHARE AND DISCLOSE YOUR INFORMATION?
Our Notice of Privacy Practices describes how we may disclose PHI. Where the data is not PHI, we may use the types of information listed above in order to:
Category Disclosure Contexts Subsidiaries and Acquisitions
We may share your information with our corporate subsidiaries and affiliates and with their respective officers, directors, employees, accountants, attorneys, and agents. In addition, we may disclose your information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by us about the Site’s users is among the assets transferred. For example, if another company acquires us, we will share your information with that company.
Disclosures With Your Consent
We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your information in this context with your consent.
Disclosures Without Your Consent
We may share your information with our service providers that need access to your information to provide operational or other support services on our behalf. Among other things, service providers may help us to administer the Site; support our provision of services requested by you; provide technical support; send marketing, promotions and communications to you about our services; and assist with other legitimate purposes permitted by law.
HOW LONG DO WE STORE YOUR INFORMATION?
Our Notice of Privacy Practices describes how we maintain PHI. Where the information is not PHI, we will retain and use your information for as long as is necessary to (1) fulfill the purposes for which it was collected, (2) comply with our business requirements and legal obligations, (3) resolve disputes, (4) protect our assets, (5) provide our services, and (6) enforce our agreements.
[When we no longer have a reason for retaining your information, we will securely destroy your information in accordance with applicable law and our policies.] We take reasonable steps to delete the information we collect about you, where we have a legal obligation to do so. To the extent permitted by law, we may retain and use anonymous and aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement.
HOW DO WE PROTECT YOUR INFORMATION?
We have put some security measures in place to protect the information that you share with us from being accidentally lost, used, altered, or disclosed or accessed in an unauthorized manner. From time to time, we review our security procedures to consider appropriate new technology and methods. However, no security system is perfect, and no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Site, and you do so at your own risk. We cannot promise that your information will remain absolutely secure in all circumstances.
If a data breach compromises your information, we will notify you and any applicable regulator when we are required to do so by applicable law.
RIGHTS AND CHOICES ABOUT YOUR INFORMATION
Our Notice of Privacy Practices describes your rights with respect to any PHI we may maintain about you. If you would like to manage, change, limit, or delete other information or if you no longer want to receive any email, postal mail, or telephone contact from us in the future, such requests may be submitted via the Contact Us details at the end of this Policy.
Email Opt-Out. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link available at the bottom of our email communications or by contacting us at [firstname.lastname@example.org] and providing your [name and email address] so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action.
Cookies. You may [choose to not allow cookies via the cookies consent banner or] set your browser to refuse all or some browser cookies or to alert you when cookies are being set. For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/.
Online Tracking. We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. We adhere to the standards set out in this Policy and do not currently respond to “Do Not Track” signals on the Site or on third-party websites or online services where we may collect information.
Accuracy and Updating Your Information. Our goal is to keep your information accurate, current, and complete. If any of the information you have provided to us changes, please let us know via “Contact Us” details provided at the end of this Policy. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate information about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete information that you provide to us.
Complaints. If you believe that your rights relating to your information have been violated, you may lodge a complaint with us by contacting us using the information provided in the “Contact Us” section of this Policy.
No Disclosure of Your Information for Third-Party Advertising. We do not share your information with unaffiliated third parties for promotional purposes.
This Policy is applicable only to the Site, and it does not apply to any third-party websites.
The Site may contain links to, and media and other content from, third-party websites. These links are to external websites and third parties with which we may have no relationship. Because of the dynamic media capabilities of the Site, it may not be clear to you which links are to the Site and which are to external, third-party websites. If you click on an embedded third-party link, you will be redirected away from the Site to the external third-party website. You can check the URL to confirm that you have left this Site.
We cannot and do not (1) guarantee the adequacy of the privacy and security practices employed by or the content and media provided by any third parties or their websites, (2) control third parties’ independent collection or use or your information, or (3) endorse any third-party information, products, services, or websites that may be reached through embedded links on this Site.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE
The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. The Site and our services are not directed to children aged 16 or younger, nor is information knowingly collected from children under the age of 16. No one under the age of 16 may access, browse, or use the Site or provide any information to or on the Site. If you are under 16, please do not use or provide any information on the Site (including, for example, your name, telephone number, email address, or username). If we learn that we have collected or received personal information from a child under the age of 16 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 16, please contact us using the contact information provided below.
For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.
UPDATES AND CHANGES TO THIS POLICY
We reserve the right, at any time and without notice, to add to, change, update, or modify this Policy to reflect any changes to the way in which we treat your information or in response to changes in law. Should this Policy change, we will post all changes we make to this Policy on this page. If we make material changes to how we treat your information, we will also notify you through a notice on the home page of the Site for a reasonable period of time. Any such changes, updates, or modifications shall be effective immediately upon posting on the Site. The date on which this policy was last modified is identified at the beginning of this Policy.
You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, and from time to time, so that you are aware of any changes. Your continued use of the Site after the “Last Updated” date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your information according to the terms of the then-current Policy. If you do not agree with this Policy and our practices, do not access, view, or use any part of the Site.
In Writing: 624 Grassmere Park #11, Nashville, TN 37211
By Telephone: 800-338-5770
By Email: [email@example.com]