Privacy Policy

Introduction

Your privacy is important to [Practice Name], [Website URL] (the “website”), which is operated by [Legal Entity Name] (“Company,” “we,” “us,” or “our”).

We use the term “personal information” to refer to data we collect that may, directly or indirectly, identify, describe, relate to or be associated with you. This privacy policy (“Privacy Policy”) applies to personal information we collect when you interact with us through different means, including by visiting and using our website. The term “you” refers to any visitor, viewer or user of the website and/or any user of any Product (as defined below). Please note that we cannot control the privacy practices of websites and services we do not own.

Please read this entire Privacy Policy before you visit or use the website or perform any Actions (as defined below). By visiting the website or performing any Actions, you consent to the terms of this Privacy Policy.

Health Information and HIPAA

This Privacy Policy covers information collected through our website and online communications. Protected health information you share with us as a patient, including information in your medical and billing records, is handled under the Health Insurance Portability and Accountability Act (HIPAA) and described in our Notice of Privacy Practices. If this Privacy Policy and our Notice of Privacy Practices conflict with respect to protected health information, the Notice of Privacy Practices controls.

Text Messaging Privacy

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing with subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Information We Collect and How We Collect It

The following describes the categories of personal information we collect and how we collect it.

Information You Provide

We collect information you provide to us directly. This includes information you provide when you (i) request an appointment or receive any free or paid program, product or service from us (each, a “Product”), (ii) sign up to receive emails or text messages, (iii) comment on posts or otherwise communicate with us on any social media platform, (iv) register for events, presentations or classes, (v) fill out any forms, (vi) access public or private membership groups, including those hosted on a third-party platform (e.g., Facebook), (vii) respond to any survey, (viii) participate in any contest or promotion or (ix) contact us by any other means, including an online form, phone call or email (collectively, the “Actions”).

Examples of data we may receive include your first and last name, telephone number, email address, mailing and billing address, date of birth, gender, insurance information, billing and payment information, account name, social media information and other information you provide through forms, survey responses, feedback, reviews and other communications.

Information Collected Automatically

We collect some data automatically when you visit or use our website or open or respond to our emails. For example, we may automatically collect information when you open or respond to our emails, make a choice about communications we send you, visit any page that displays our content, provide information to our service providers or purchase a Product.

Information from Third-Party Sites

We collect some data when you connect with us, comment on or like our posts, or otherwise interact with us on any social media platform, or when you access membership groups hosted on a third-party platform. Examples include your profile information, profile picture, social media handles or nicknames, name, email address, device identifiers and demographic information.

Internet or Other Electronic Network Activity

We automatically collect some data about your computer or mobile device when you access our website. Examples include your Internet Protocol (“IP”) address, browser type and version, cookies, unique device identifiers, information about the referring website, the date, time and length of your visit, the specific pages you visit, how you interact with the website and other diagnostic data. When you access the website through a mobile device, we may also receive the type of mobile device, its unique device ID, your mobile operating system and mobile browser.

Purposes for Collecting Information

We use your information for business and commercial purposes. For example, we may use your information to:

• Schedule, confirm and remind you about appointments.
• Register you for an event, presentation or class.
• Grant you access to a membership group or other account, and maintain and service those accounts.
• Validate and authenticate your profile when you log in to an account or make a purchase.
• Analyze interactions with you to improve quality.
• Secure our website and data.
• Process payment for, communicate about and deliver any Products.
• Personalize your experience with the website.
• Send promotional and marketing communications, including email marketing, if you elect to receive them.
• Improve the design, functionality and ease of use of our website and Products.
• Respond to inquiries, reviews or other feedback you submit to us.
• Provide customer service.
• Conduct research to improve our business processes.
• Administer contests, surveys or promotions.
• Detect security incidents and protect against, stop and prevent fraud and any malicious, deceptive or illegal activity.
• Comply with applicable law, respond to legal and regulatory inquiries and assist law enforcement.

Third Parties We Share Information With

To reiterate: no mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing with subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

We may share your information with the following categories of third parties:

• Analytics providers. Services that help us understand how visitors use the website.
• Business transfers. If the Company or the website is acquired by or transferred to a third party through a sale, merger, acquisition, reorganization, liquidation or consolidation, your personal information may be a transferred asset. We may also share personal information with prospective purchasers to evaluate the proposed transaction.
• Cloud service providers. Services that host and store our data.
• Customer analysis providers. Services that analyze visitor clicks and navigation around the website.
• Customer service providers. Services that help us respond to your questions and requests.
• Email marketing and advertising providers. Including email marketing and campaign providers, marketing software providers, direct mail providers and marketing analytics providers, in order to send you emails, newsletters and other information.
• Fraud prevention partners. Services that help us detect and prevent fraud.
• Government agencies. Government agencies, courts, regulators and law enforcement when we are required to comply with applicable laws, regulations or a legally binding process, or in response to subpoenas, warrants, government inquiries or investigations and court orders. We may also share your information (i) to establish, exercise, protect or enforce our legal rights and those of our agents, employees and affiliates, (ii) to defend against a legal claim, (iii) to protect you, us or third parties against injury, interference, fraud or harm or (iv) to take action related to violations of our policies, including this Privacy Policy and our Terms of Service, or potentially illegal activities.
• Payment processors. Services we use to collect and process payments.
• Public forums. If you choose to leave a post, comment or review on the website, that information will be available to the public, and we may share it outside the website.
• Social media platforms. Platforms such as Facebook. Their use of your information is not governed by this Privacy Policy.
• Technology and other service providers. Vendors that provide technology and other services that help us operate the website and our business.
• Professional advisors. Third parties we have contractual relationships with, such as auditors, consultants and lawyers, who rely on the data to provide us with professional services.
• Third-party partners. Third parties we have partnered with to jointly create or offer a product, service or joint promotion.

We Do Not Sell Your Personal Information

We do not sell, rent or trade your personal information to any third parties, as we value your privacy. We also do not “sell” your personal information as defined by the California Consumer Privacy Act.

Cookies and Other Tracking Technologies

We may collect and access, and may permit our business partners and third-party service providers, such as advertising companies, to collect and access, your IP address, browsing metadata and other numerical identifiers, such as your browser type, version and operating system (collectively, “Browsing Information”). We may also use, place, collect and store, or allow our third-party service providers to use, place, collect and store, cookies, web beacons, remarketing pixel tags or other similar tracking technologies.

We, our business partners and third-party service providers may use this information and these technologies to improve and personalize your experience, understand how you use the website, provide tailored ads, analyze trends and website performance, administer the website, identify you across devices, determine whether you are logged in, provide security and offer a range of features and functionality.

By using the website and not opting out of cookies, you consent to the use of Browsing Information, cookies and other tracking technologies as described in this Privacy Policy. We cannot and do not control the privacy policies and practices of third-party service providers, and we encourage you to visit their websites to learn about their privacy policies.

Your Choices

It is important to us that you understand your choices regarding your personal information.

Opting Out of or Blocking Cookies

Most browsers accept cookies by default, but most also allow you to refuse new cookies, disable cookies or be notified when you receive a new cookie. Instructions can typically be found in your browser’s help section. If you disable cookies, some parts of the website may not work as intended, including your ability to make purchases or receive personalized content.

Managing “Do Not Track”

As required by the California Online Privacy Protection Act (CalOPPA), please note that our systems are currently unable to recognize browser “Do Not Track” signals.

Use of Personal Information

You can request that we delete your personal information at any time, subject to certain exceptions, by contacting us using the details below. You can also (i) request to see the personal information we have about you, (ii) withdraw consent for our use of your personal information, (iii) review and request that we correct or update your personal information, (iv) restrict or limit the processing of your personal information, (v) cancel the processing of your personal information and (vi) request your personal information and transfer it to another controller without any impediment on our part.

Unsubscribing from Email Marketing

When you sign up to receive emails from us, you agree to receive email communications, which may include newsletters and promotional emails. You can opt out at any time by clicking the “unsubscribe” link in any marketing email. Unsubscribing from marketing emails does not unsubscribe you from other emails we may send, such as appointment reminders or messages about Products you purchase.

Other Opt-Out Options

If we send you physical mailings or text (SMS) messages, or contact you by telephone, you can opt out by contacting us using the details below. For text messages, you can also reply “STOP” at any time.

Data Retention

We retain personal information for as long as it is needed to operate our business, to meet our legal and regulatory obligations, or until you ask us to delete it by contacting us using the details below. We cannot control the data retention policies of third parties.

Third-Party Links

For your convenience, our website may link to third-party websites, such as social media platforms. If you click a third-party link, you will be directed to a website we do not own or control. We cannot and do not control the privacy policies, content or practices of those websites, and we encourage you to review their privacy policies directly.

How We Protect Your Personal Information

We maintain reasonable and appropriate physical, technical and procedural safeguards to help keep your personal information safe. However, no method of transmission over the internet or other network is 100% secure, so we cannot guarantee that personal information you transmit will remain secure from misuse or interception in all circumstances. By consenting to this Privacy Policy, you acknowledge that we cannot guarantee that your personal information will be protected from misuse or interception by third parties.

International Data, Transfers and Processing

Our website is intended for individuals located within the United States. Our website servers and service providers may be located outside of your state, province or country, so some of your personal information may be collected, used, transferred, maintained, disclosed and stored outside of your state, province or country. By using this website, you acknowledge and agree that the collection, use, transfer, maintenance, disclosure and storage of your personal information, Browsing Information and communications related to your use of this website are governed by the applicable laws of the United States, which may be less stringent than those of your state, province or country.

Notice About the General Data Protection Regulation (GDPR)

This section applies to individuals covered by the General Data Protection Regulation (“GDPR”), and references to “you” and “your” in this section refer only to those individuals. The GDPR, which took effect on May 25, 2018, provides privacy rights for those inside the European Economic Area. For purposes of this section, “personal information” means any information relating to an individual that can be used, directly or indirectly, to identify that individual.

Legal Basis for Processing Information

We may process personal information when: (i) you have consented to the processing for one or more specific purposes, (ii) processing is necessary to perform a contract you are party to, or to take steps at your request before entering into a contract, (iii) processing is necessary to comply with a legal obligation, (iv) processing is necessary to protect your vital interests or those of another person, (v) processing is necessary to perform a task carried out in the public interest or in the exercise of official authority or (vi) processing is necessary for our legitimate interests or those of a third party, except where those interests are overridden by the need to protect the individual’s personal information. We are happy to tell you which legal basis applies to the processing of your personal information.

Your Rights Under the GDPR

The following summary is provided for your convenience; we do not warrant that it is accurate or exhaustive, and you should not rely on it as a complete list of your rights.

• Right to access. You have the right to learn whether your personal information is being processed and, if so, to access it and learn why it is processed, what categories are collected, who receives it, how long it will be stored and where it came from.
• Right to correction. You have the right to correct inaccurate personal information and to complete incomplete personal information.
• Right to be forgotten. You have the right to ask us to erase your personal information without undue delay in certain circumstances, such as when it is no longer necessary, when you withdraw consent, when you object and there are no overriding grounds, when it was unlawfully processed or when erasure is required by law.
• Right to restrict processing. You have the right to restrict processing in certain circumstances, such as when you contest its accuracy or when processing is unlawful but you prefer restriction over erasure.
• Notification of recipients. If you exercise your right to correction, erasure or restriction, we will notify each recipient we have shared your personal information with, and you may request a list of those recipients.
• Right to data portability. You have the right to receive your personal information in a structured, commonly used and machine-readable format.
• Right to object. You have the right to object to processing in certain circumstances, including processing based on public interest or legitimate interests and processing for direct marketing.
• Right to lodge a complaint. You have the right to lodge a complaint with a supervisory authority, such as your local data protection authority.
• Right to be informed about international transfers. See “International Data, Transfers and Processing” above.
• Right to object to profiling. You have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects concerning you.

To exercise any of these rights, please contact us using the details below. We are required to verify the identity of anyone who makes a request.

Notice to California Residents (CCPA)

This section applies to residents of California, and references to “you” and “your” in this section refer only to California residents. The California Consumer Privacy Act (“CCPA”), which took effect on January 1, 2020, provides privacy rights for California residents. Please refer to the following sections of this Privacy Policy for information you have a right to know under the CCPA:

• Categories of personal information and sources: “Information We Collect and How We Collect It.”
• Business or commercial purposes for collection: “Purposes for Collecting Information.”
• Categories of third parties we share with: “Third Parties We Share Information With.”

The following summary is provided for your convenience; we do not warrant that it is accurate or exhaustive.

• Right to know. You have the right to obtain, free of charge and up to twice a year, information about our collection of your personal information over the past 12 months, including the categories and specific pieces of personal information collected, the categories of sources, our purposes for collecting it, the categories of third parties we share it with and, if applicable, the categories of personal information sold or disclosed for a business purpose.
• Right to delete. You have the right to request that we delete personal information we have collected from you, subject to certain exceptions. When you contact us, please tell us what information you want removed, updated or corrected, and when and how you believe we collected it.
• Right to opt out. You have the right to opt out of the sale of your personal information. We do not sell, rent or trade your personal information, so no opt-out request is necessary.
• Right to non-discrimination. We will not discriminate against you for exercising any of your CCPA rights, including by denying you goods or services, charging you different prices or providing a different level or quality of goods or services.

To exercise any of these rights, please contact us using the details below. We are required to verify the identity of anyone who makes a request.

California “Shine the Light” Law

We do not share your personal information with third parties that we know or have reason to know may use it for direct marketing purposes, as contemplated by California Civil Code § 1798.83.

Notice to Nevada Residents

We do not exchange your personal information for monetary consideration with anyone who will license or sell your personal information to third parties.

Children’s Privacy

This website is not directed to or designed for use by children under the age of 18. If you are under 18, you must not access this website or perform any of the Actions. We do not knowingly collect, use, store or share personal information from children under 18. If you know or have reason to believe that we have collected data from anyone under 18, please contact us so we can remove it.

Changes to This Privacy Policy

We reserve the right to change, amend or modify this Privacy Policy at any time. We will alert you to any changes by posting the effective date of the latest version at the top of this page, at which point the changes become immediately effective. It is your responsibility to check for updates, as your continued use of the website and our Products after this Privacy Policy is amended will constitute your acceptance of the amended Privacy Policy.

Alternative Forms

You may print this Privacy Policy using your browser’s “Print” function.

How to Contact Us

If you have any questions or complaints about this Privacy Policy, or would like to exercise any of your rights, please contact us:

[Legal Entity Name] d/b/a [Practice Name]
[Street Address], [City, State ZIP]
Email: [Email Address]
Phone: [Phone Number]