PRIVACY POLICY
Posted: November 05, 2024
Effective Date: November 05, 2024
This notice describes the Privacy Policy of SureAdhere (“SureAdhere” or “We”) when Users (“You”) use our websites, mobile application, web application, software, and services (“ Services”).
We define the following as our Services:
Secure.sureadhere.com (hereinafter referred to as “Web Application”)
Mobile application on Android and iPhone (hereinafter referred to as “Mobile Application”)
Sureadhere.com (hereinafter referred to as “Information Website”)
Here we describe how we collect, use, and handle your information when you use Services.
If you're using our Services for an organization, you're agreeing to this Privacy Policy on behalf of that organization.
If you're using our Services to provide services, software, and content for someone else, you're agreeing to this Privacy Policy on their behalf.
IF YOU OR THE ORGANIZATION YOU REPRESENT DON'T AGREE TO BE BOUND TO THIS PRIVACY POLICY, YOU SHOULD NOT USE OUR SERVICES
OWNER
All Data submitted or shared by the User during the use of the Services is the exclusive property of the User. Hence the Users are the Owners of the Data. SureAdhere does not claim any ownership rights over the User Data.
The Company will collect and process User Data solely for the purpose of providing the Services to the User. The Company will take reasonable measures to protect the confidentiality and integrity of the User Data. The Company will implement and maintain appropriate technical and organizational measures to safeguard User Data against unauthorized access, alteration, disclosure, or destruction.
The User shall have the right to access, correct, amend, or delete their User Data at any time through the Service. The Company will promptly comply with any such request by the User, subject to applicable laws and regulations.
WHAT WE COLLECT
Types of Data Collected by Services
Personal Information
Our Services may collect Personal Information by itself or through third parties. Personal Information includes name, postal address, email address, phone number, fax number, username, password, demographic information (such as your gender and occupation) Complete details on each type of Personal Information collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically by our Information Website.
Cookies
Our Web and Mobile Application does not collect any cookies.
Our Informational Website (www.sureadhere.com) may log information using "cookies." Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Information Site. This type of information is collected to make the Information Website more useful to you and to tailor the experience with us to meet your special interests and needs.
Users are responsible for any third-party Personal Data obtained, published or shared through Services and confirm that they have the third party's consent to provide the Data to SureAdhere.
MODE AND PLACE OF PROCESSING THE DATA
Methods of processing
SureAdhere takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to SureAdhere, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Services (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by SureAdhere. The updated list of these parties may be requested from SureAdhere at any time
Legal basis of processing
SureAdhere may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes. Note: Under some legislations SureAdhere may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law; provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which SureAdhere is subject to; processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in SureAdhere;
processing is necessary for the purposes of the legitimate interests pursued by SureAdhere or by a third party.
In any case, SureAdhere will gladly help to clarify the specific legal basis that applies to the processing, and in particular, whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at SureAdhere’s s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by SureAdhere to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with SureAdhere using the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore
Personal Data collected for purposes related to the performance of a contract between SureAdhere and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of SureAdhere’slegitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by SureAdhere within the relevant sections of this document or by contacting SureAdhere
SureAdhere may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, SureAdhere may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.
THE PURPOSE OF PROCESSING
The Data concerning the User is collected to allow SureAdhere to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Data transfer outside the EU, Hosting, and backend infrastructure and Managing contacts and sending messages.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
SERVICES USED FOR PROCESSING OF DATA
Personal Data is collected for the following purposes and using the following services:
Analytics
SureAdhere uses analytics partners, including Google Analytics and Hubspot to analyze some of the Usage information we collect.
If you do not consent to our analytics partners having access to your information, please let us know at privacy-sureadhere@dimagi.com
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Services to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Services.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Microsoft Azure (Microsoft Corporation)
Microsoft Azure is a hosting service provided by Microsoft Corporation.
Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CPRA (CCPA amendment): internet information.
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Twilio (Twilio, Inc.)
Twilio is a phone numbers management and communication service provided by Twilio, Inc. Personal Data processed: phone number.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CPRA (CCPA amendment): identifiers.
This processing constitutes:
a sale according to the CCPA and the VCDPA
a sharing according to the CPRA (CCPA amendment)
targeted advertising according to the VCDPA
Sendgrid (Sendgrid)
Sendgrid is an email address management and message sending service provided by Sendgrid Inc. Personal Data processed: email address.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CPRA (CCPA amendment): identifiers. This processing constitutes:
a sale according to the CCPA and the VCDPA
a sharing according to the CPRA (CCPA amendment)
targeted advertising according to the VCDPA
THE RIGHTS OF THE USER
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of, or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month
ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Services or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, Services may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, Services and any third-party services may collect files that record interaction with Services (System logs) using other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
Services does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Services and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
INFORMATION FOR EU, UK and SWISS CITIZEN
Data transfer outside the EU
SureAdhere is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to the European Union’s General Data Protection Regulation, adopted as Regulation (EU) 2016/679 of the European Parliament on April 14, 2016, to take effect on May 25, 2018, and which was further amended on June 4th, 2021 (“GDPR”). Any such Data transfer is based on one of the legal bases described below.
Users can inquire with SureAdhere to learn which legal basis applies to which specific service.
Data transfer to countries that guarantee European standards (Services)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.
Personal Data processed: various types of Data.
Category of personal information collected according to the CPRA (CCPA amendment): internet information.
Data transfer abroad based on standard contractual clauses (Services)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by SureAdhere according to “standard contractual clauses” provided by the European Commission. This means that Data recipients have committed to processing Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact SureAdhere through the contact details provided in the present document.
Personal Data processed: various types of Data.
Category of personal information collected according to the CPRA (CCPA amendment): internet information.
Data transfer abroad based on consent (Services)
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via Services.
Personal Data processed: various types of Data.
Data Privacy Framework
SureAdhere complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF (UK-U.S. DPF), and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. SureAdhere has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. SureAdhere has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
In the context of an onward transfer to third parties, SureAdhere has responsibility for the processing of your information it receives. SureAdhere shall remain liable under the EU-U.S. DPF, the UK-U.S. DPF, and Swiss-U.S. DPF if a third party processes your information in a manner inconsistent with the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-U.S. DPF, unless proven that SureAdhere is not responsible for any processing inconsistent with EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-U.S. DPF. . SureAdhere’s liability extends only to trusted third parties and analytics partners that SureAdhere relies on to deliver our Services. SureAdhere shall not be liable for third parties that you independently select or use in conjunction with SureAdhere’s Services.
In compliance with the EU-U.S. Data Privacy Framework (hereinafter “EU-U.S DPF”) Principles, SureAdhere commits to resolve complaints about our collection or use of your personal information. EU, UK and Swiss individuals with inquiries or complaints regarding our EU-U.S. DPF, the UK-U.S. DPF and the Swiss-U.S. DPF, policy should first contact SureAdhere at privacy@dimagi.com.
In compliance with the EU-U.S. DPF, the UK-U.S. DPF and the Swiss-U.S. DPF, has further committed to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive acknowledgement of your DPF Principles-related complaint from us within 45 days, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.
The EU-U.S. DPF, the UK-U.S. DPF and the Swiss-U.S. DPF, also provides the option for EU, UK and Swiss individuals to invoke binding arbitration to determine whether has violated its obligations under the EU-U.S. DPF Principles and whether any such violation remains fully or partially unremedied (“residual claims”). As a self-certified organization in the EU-U.S. DPF, the UK-U.S. DPF and the Swiss-U.S. DPF, is required to arbitrate claims pursuant to EU-U.S. DPF, the UK-U.S. DPF and the Swiss-U.S. DPF,’s Recourse, Enforcement and Liability Principle.
SureAdhere is subject to oversight by the U.S. Department of Commerce including but not limited to U.S. Federal Trade Commission.
INFORMATION FOR CALIFORNIAN CONSUMERS
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Services and, if the case may be, its parent, subsidiaries, and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the "California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term “personal information“ as defined in the California Consumer Privacy Act (CCPA/CPRA).
Notice at collection
Categories of personal information collected, used, sold, or shared
In this section, we summarize the categories of personal information that we've collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.
Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers and internet information.
We do not collect sensitive personal information.
We will not collect additional categories of personal information without notifying you.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of Services and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer actual damage.
How long do we keep your personal information?
Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.
How we collect information: what are the sources of the personal information we collect?
We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use Services.
For example, you directly provide your personal information when you submit requests via any forms on Services. You also provide personal information indirectly when you navigate Services, as personal information about you is automatically observed and collected.
Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
How we use the information we collect: disclosing of your personal information with third parties for a business purpose
For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CPRA (CCPA amendment).
We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
Sale or sharing of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CPRA (CCPA amendment).
This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.
For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CPRA (CCPA amendment).
Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CPRA (CCPA amendment), does not constitute a sale or sharing of your personal information.
Your right to opt out of the sale or sharing of your personal information and how you can exercise it
We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request. Such requests can be made freely, at any time, without submitting any verifiable request. To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on Services.
If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.
Your privacy rights under the California Consumer Privacy Act and how to exercise them
The right to access personal information: the right to know and to portability
You have the right to request that we disclose to you:
the categories of personal information that we collect about you;
the sources from which the personal information is collected
the purposes for which we use your information;
to whom we disclose such information;
the specific pieces of personal information we have collected about you.
You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:
the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on Services, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so – provided that this is technically feasible and doesn’t involve a disproportionate effort.
The right to correct inaccurate personal information
You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information
You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.
The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)
We will not discriminate against you for exercising your rights under the CPRA (CCPA amendment). This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.
However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.
To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.
For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.
If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority. You can submit a maximum number of 2 requests over a period of 12 months.
How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.
Should we deny your request, we will explain to you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
INFORMATION FOR VIRGINIA CONSUMERS
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act" (the "VCDPA"), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the VCDPA.
Categories of personal data processed
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.
Sale of your personal data
For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale.
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
For our purposes, the word "targeted advertising" means "displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests" as defined by the VCDPA.
To find out more details on the processing of your personal data for targeted advertising purposes, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request. To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data. correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a minor under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such a decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
DEFINITIONS AND LEGAL REFERENCES
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through Services (or third-party services employed in Services), which can include: the IP addresses or domain names of the computers utilized by the Users who use Services, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The natural or legal person, public authority, agency, or other body who accesses, uses, or interacts with the Services who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Owner
The natural or legal person, public authority, agency, or other body who shares or submits all the Data submitted during the use of the Service
Data Controller
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Services.
Unless specified otherwise, the Owner of the Data is also the Data Controller
Services (or this Application)
Unless specified otherwise, the Owner of the Data is also the Data Controller
The means by which the Personal Data of the User is collected and processed.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to Services, if not stated otherwise within this document.
CONTACT INFORMATION
This privacy policy relates solely to Services, if not stated otherwise within this document.
We welcome your comments or questions about this privacy policy. You may also contact us at our address:
Dimagi Inc585 Massachusetts Ave. Suite 3Cambridge, MA 02139privacy-sureadhere@dimagi.com