Liberty HealthShare Privacy Policy
Last Updated On: 08/07/24
Introduction
Our Privacy Policy covers types of information Liberty Healthshare (“we” or “us”) may collect from you or that you may provide when you visit (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using our Website, you agree to our Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Children Under the Age of 16
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on our Website or through any of its features or provide any information about yourself to us, including your name, address, telephone number, email address, or any other information by which you might be identified. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@libertyhealthshare.org.
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see California Residents’ Rights for more details.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal Information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
How We Collect Your Personal Information
Direct Collection of Personal Information
The information we collect on or through our Website or directly from you through other means may include:
- Information that you provide by filling in forms on our Website.
- Records and copies of your correspondence (including email address) if you contact us.
- Your search queries on the Website.
- Information submitted when you report a problem with our Website.
- Information submitted when you request further services.
- Your responses to surveys that we might ask you to complete.
- Information required to enter a contest or promotion sponsored by us.
- Information used to create your user account.
- Information provided while using any other interactive features of our Website.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we may limit access to certain pages, or may permit you set certain privacy settings for such information, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Indirect Collection of Personal Information
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including traffic data, logs, location data, other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Recognize you when you return to our Website.
- Speed up your searches.
- Estimate our audience size and usage patterns.
We may collect information automatically using one of the following technologies:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. For further information, visit https://allaboutcookies.org.
- Web Beacons/Tracking Pixels. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
How We Use Your Personal Information
We use information that we collect about you or that you provide to us, including any Personal Information:
- To present our Website and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- In order to process any orders for products or services, we may send your data to, and also use the resulting information from, credit reporting agencies to prevent fraudulent purchases.
- To fulfill any other purpose for which you provide it.
- To notify you about changes to our Website or any products or services we offer or provide though it.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users or consumers is among the assets transferred.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your Personal Information.
- To allow you to participate in interactive features on our Website.
- For any other purpose with your consent.
We may also use your information to contact you about our goods and services that may be of interest to you. If you have agreed to receive marketing, you may always opt out at a later date. If you no longer wish to be contacted for marketing purposes, please contact us at privacy@libertyhealthshare.org. For more information, see Your Personal Information Rights.
Who We Share Your Personal Information With
Disclosure of Personal Information for a Business Purpose
We may share your Personal Information by disclosing it to a third party for a business purpose.
Sale of Personal Information
We do not sell your Personal Information to third parties.
Other Sharing
We may also share your Personal Information:
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users or consumers is among the assets transferred.
- To enforce or apply our terms of use found at https://libertyhealthshare.org/terms-of-use and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Liberty Healthshare, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Data Practices for Prior Twelve Months
Below are details of our data practices during the twelve months prior to the effective date listed at the top of this policy. For each type of Personal Information listed, we provide details regarding collection and any disclosures to third parties for business purposes. We do not include details regarding sales of Personal Information to third parties because we do not sell Personal Information to third parties. Not all types of Personal Information may be collected or received for every individual.
Information That Directly or Indirectly Identifies and Individual |
|
Includes: |
Account Name, Address, Alias, Email Address, Name, Online Identifier, Physical Characteristics, Signature, Social Security Number, and Telephone Number. |
Collection Method: |
We collect this category of Personal Information directly from you either on or through our Website or through other means, indirectly as you navigate through and interact with our Website and from third parties. |
Reason for Collection: |
• The data subject has given consent for us to process this type of Personal Information for one or more specific purposes. • Processing this type of Personal Information is necessary for the performance of services to which the data subject has requested or in order to take steps at the request of the data subject prior to performing services. |
Disclosures: |
• Service Providers |
Protected Classifications Under State or Federal Law |
|
Includes: |
Age, Disability, Marital Status, Religion, and Sex. |
Collection Method: |
We collect this category of Personal Information directly from you either on or through our Website or through other means and from third parties. |
Reason for Collection: |
• The data subject has given consent for us to process this type of Personal Information for one or more specific purposes. • Processing this type of Personal Information is necessary for the performance of services to which the data subject has requested or in order to take steps at the request of the data subject prior to performing services. • Processing this type of Personal Information is necessary for our other legitimate interests or the other legitimate interests of a third party. |
Disclosures: |
• Service Providers |
Location Information |
|
Includes: |
General Physical Location. |
Collection Method: |
We collect this category of Personal Information directly from you either on or through our Website or through other means. |
Reason for Collection: |
• The data subject has given consent for us to process this type of Personal Information for one or more specific purposes. • Processing this type of Personal Information is necessary for the performance of services to which the data subject has requested or in order to take steps at the request of the data subject prior to performing services. • Processing this type of Personal Information is necessary for compliance with a legal obligation we must comply with. |
Disclosures: |
• Service Providers |
Financial and Commercial Information |
|
Includes: |
Bank Account Number, Credit Card Number, Debit Card Number, and Purchasing History. |
Collection Method: |
We collect this category of Personal Information directly from you either on or through our Website or through other means. |
Reason for Collection: |
• The data subject has given consent for us to process this type of Personal Information for one or more specific purposes. • Processing this type of Personal Information is necessary for the performance of services to which the data subject has requested or in order to take steps at the request of the data subject prior to performing services. |
Disclosures: |
• Service Providers |
Education Information |
|
Includes: |
Education Records. |
Collection Method: |
We collect this category of Personal Information directly from you either on or through our Website or through other means. |
Reason for Collection: |
• The data subject has given consent for us to process this type of Personal Information for one or more specific purposes. • Processing this type of Personal Information is necessary for the performance of services to which the data subject has requested or in order to take steps at the request of the data subject prior to performing services. |
Disclosures: |
• Service Providers |
Health Information |
|
Includes: |
Health Data, Health Insurance Information, Medical Condition, and Medical Information. |
Collection Method: |
We collect this category of Personal Information directly from you either on or through our Website or through other means and from third parties. |
Reason for Collection: |
• The data subject has given consent for us to process this type of Personal Information for one or more specific purposes. • Processing this type of Personal Information is necessary for the performance of services to which the data subject has requested or in order to take steps at the request of the data subject prior to performing services. |
Disclosures: |
• Service Providers |
Biometric Information |
|
Includes: |
Behavioral Characteristics, Biological Characteristics, Genetic Information, Other Physical Patterns, Physiological Characteristics, and Sleep Data. |
Collection Method: |
We collect this category of Personal Information directly from you either on or through our Website or through other means and from third parties. |
Reason for Collection: |
• The data subject has given consent for us to process this type of Personal Information for one or more specific purposes. • Processing this type of Personal Information is necessary for the performance of services to which the data subject has requested or in order to take steps at the request of the data subject prior to performing services. |
Disclosures: |
• Service Providers |
Sensory Data |
|
Includes: |
Audio Sensory Information, Olfactory Sensory Information, Other Sensory, Thermal Sensory Information, and Visual Sensory Information. |
Collection Method: |
We collect this category of Personal Information directly from you either on or through our Website or through other means and from third parties. |
Reason for Collection: |
• The data subject has given consent for us to process this type of Personal Information for one or more specific purposes. • Processing this type of Personal Information is necessary for the performance of services to which the data subject has requested or in order to take steps at the request of the data subject prior to performing services. |
Disclosures: |
• NONE |
Internet or Other Similar Network Activity |
|
Includes: |
Interaction With Advertisements and Interaction With Website. |
Collection Method: |
We collect this category of Personal Information directly from you either on or through our Website or through other means and indirectly as you navigate through and interact with our Website. |
Reason for Collection: |
• The data subject has given consent for us to process this type of Personal Information for one or more specific purposes. |
Disclosures: |
• NONE |
Restrictions on Future Collection and Use
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Your Personal Information Rights
Accessing and Correcting Your Information
You can review and change your Personal Information by logging into the Website and visiting your account profile page. You may also send us an email at privacy@libertyhealthshare.org to request access to, correct or delete any Personal Information that you have provided to us. If we cannot delete your Personal Information except by also deleting your user account, you understand that we will delete your user account. We may not accommodate a request to change or delete information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users.
Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use located at https://libertyhealthshare.org/terms-of-use.
HIPAA Business Associate Privacy Policy
Definitions:
- “Covered Entity” means a health plan, healthcare provider, healthcare clearinghouse, or any authorized entity representative that must comply with the HIPAA Privacy or Security Rules.
- “Business Associate” means a person or entity who performs functions or activities for, or provides services on behalf of, a Covered Entity that involve the use or disclosure of PHI.
- “Business Associate Agreement” means a formal written agreement between us and our Covered Entity customers, and/or between us and our Business Associate subcontractors, that requires us and our Business Associate subcontractors to comply with specific protections afforded to the security and privacy of PHI under HIPAA.
- “Service Agreement” means an underlying agreement between us and a Covered Entity to which a Business Associate Agreement applies.
While we are not a Covered Entity, we may work with Covered Entities regulated under the Health Insurance Information Portability and Accountability Act (“HIPAA”) of 1996, as amended, including without limitation the Health Information Technology for Economic and Clinical Health (“HITECH”) Act of 2009 (collectively referred to herein as “HIPAA”). In the process of working with these Covered Entities we may access, receive, process, maintain, archive, and/or transmit information defined by HIPAA as Protected Health Information (“PHI”) and/or Electronic Protected Health Information (“ePHI”) from such Covered Entities (PHI and ePHI are collectively referred to herein as “PHI”). In some situations, we may be considered a Business Associate of a Covered Entity regulated by HIPAA.
We share a commitment with any Covered Entity to protect the security and privacy of all PHI that we obtain. Therefore, the following applies to our practices regarding PHI.
Use and Disclosure of PHI
Provided that such use or disclosure does not violate the applicable Service Agreement, Business Associate Agreement or the HIPAA privacy or security rules as applicable to us, we may:
- use or disclose PHI on behalf of, or to provide services to, Covered Entities for purposes of performing our obligations owed to such Covered Entity;
- use PHI internally for our own internal management, administration, data aggregation and legal obligations;
- disclose PHI to downstream subcontractors or agents that provide supporting services to us, provided that, to the extent required by HIPAA, all such subcontractors and agents will be required to enter into a Business Associate Agreement with us and to comply with the same terms and conditions that apply to our use and disclosure of PHI, including the implementation and maintenance of required HIPAA privacy and security safeguards; and
- disclose PHI for law enforcement purposes, or in response to subpoenas as required by law, and for other national priority purposes when an authorization or opportunity to object is not required by HIPAA.
Safeguards
We have established and maintain appropriate safeguards to prevent the use or disclosure of PHI other than as provided for by our Services Agreements, Business Associate Agreements and HIPAA. These safeguards include administrative, physical and technical safeguards that reasonably and appropriately protect the confidentiality, integrity and availability of the PHI that we access, receive, process, maintain and/or transmit on behalf of appliable Covered Entities.
Examples of such safeguards include but are not limited to:
- Maintaining appropriate clearance procedures and providing supervision to assure that our workforce follows appropriate security procedures;
- Providing appropriate training to our staff to ensure that our staff complies with our privacy and security policies;
- Making appropriate use of encryption when transmitting PHI over the internet;
- Utilizing appropriate storage, backup, disposal and reuse procedures to protect PHI;
- Utilizing appropriate authentication and access controls to safeguard PHI;
- Utilizing appropriate security incident procedures and providing training to our staff sufficient to detect and analyze security incidents; and
- Maintaining a current contingency plan and emergency access plan in case of emergency to assure that the PHI we hold on behalf of a Covered Entity is available when needed.
Mitigation of Harm
In the event of a use or disclosure of PHI that is in violation of the requirements of a Business Associate Agreement, we will mitigate, to the extent practicable, any known, harmful effect resulting from the violation.
Such mitigation will include:
- Reporting any use or disclosure of PHI not provided for by the Business Associate Agreement, and any security incident that we become aware of, to the Covered Entity; and
- Documenting such disclosures of PHI and information related to such disclosures as would be required for a Covered Entity to respond to a request for an accounting of disclosures of PHI in accordance with HIPAA.
Access to PHI
To the extent required by the applicable Service Agreement, Business Associate Agreement, and HIPAA, we will:
- make available to a Covered Entity that information necessary for the Covered Entity to provide individuals with their rights of access, amendment, and accounting of disclosures in accordance with HIPAA; and
- upon request from such Covered Entity, make our internal practices, books and records including policies and procedures relating to the use and disclosure of PHI received from, created by, or received by a Business Associate on behalf of the Covered Entity available to the Covered Entity or the Secretary of the U.S. Department of Health and Human Services for the purposes of determining compliance with the terms of the Business Associate Agreement and HIPAA regulations.
Conflict with Other Provisions of Our Privacy Policy
To the extent that any of the above HIPAA provisions of our Privacy Policy conflict with the remainder of this Policy, the HIPAA provisions prevail with respect to any Covered Entity and our downstream Business Associate subcontractors.
Your State Privacy Rights
In addition to the other rights provided in our Privacy Policy, the following sections describe the additional rights available to residents of certain states.
California
This section applies solely to visitors, users, and others who reside in California. We adopt this section to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended, and any terms defined in the CCPA have the same meaning when used in this section.
This section does not apply to workforce-related Personal Information collected from California-based employees, job applicants, contractors, or similar individuals.
California Data Practices For Prior Twelve Months
Collection
California requires us to expressly disclose whether we have collected any Personal Information from Consumers for specific information categories during the previous twelve-month period. The chart below specifies whether we have collected information for each of these required categories during the twelve months prior to the effective date listed at the top of this policy. Not all types of Personal Information may be collected or received for every individual.
CCPA Category |
Collected |
Identifiers (Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers) |
YES |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories) |
YES |
Protected Classifications (Protected classifications under California or state law, including age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, union membership, or genetic information (including familial genetic information) |
YES |
Commercial Information (Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) |
YES |
Biometric Information (Biometric information, including genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data) |
YES |
Internet or Other Electronic Network Activity (Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website application, or advertisement) |
YES |
Geolocation Data (Geolocation data, including general or precise location, or movements) |
YES |
Sensory Information (Sensory data, including audio, electronic, visual, thermal, olfactory, or similar information) |
YES |
Professional or Employment-Related Information (Professional or employment-related information, including current or past job history, or performance evaluations) |
NO |
Education Information (Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99), including grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records) |
YES |
Inferences (Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes) |
NO |
Sensitive Personal Information (as defined above) |
YES |
Sharing
California requires us to expressly disclose whether we have shared (either through disclosure for a business purpose or sale) any Personal Information collected from Consumers for specific information categories during the previous twelve-month period. The chart below specifies which third parties (if any) we have disclosed for a business purpose each information category during the twelve months prior to the effective date listed at the top of this policy We do not knowingly “sell” Personal Information or Sensitive Personal Information that we collect from you, in accordance with the definition of “sell” in the CCPA, and will treat personal information we collect from you as subject to a do not sell request. There is not yet a consensus as to whether third-party cookies and tracking devices associated with our Websites may constitute a “sale” of your personal information as defined by the CCPA.
CCPA Category |
Disclosures for a Business Purpose |
Sales |
Identifiers |
• Service providers |
• NONE |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
• Service providers |
• NONE |
Protected Classifications |
• Service providers |
• NONE |
Commercial Information |
• NONE |
• NONE |
Biometric Information |
• Service providers |
• NONE |
Internet or Other Electronic Network Activity |
• NONE |
• NONE |
Geolocation Data |
• Service providers |
• NONE |
Sensory Information |
• NONE |
• NONE |
Professional or Employment-Related Information |
• NONE |
• NONE |
Education Information |
• Service providers |
• NONE |
Inferences |
• NONE |
• NONE |
Sensitive Personal Information
CCPA requires additional disclosures relating to Sensitive Personal Information. Under CCPA, Sensitive Personal Information is a subtype of Personal Information consisting of the following specific information categories:
- Government identifiers, such as your Social Security number, driver's license, state identification card, or passport number.
- Complete account access credentials, such as user names, account numbers, or card numbers combined with required access/security code or password.
- Precise geolocation, such as your physical location within a small area (1,850 feet radius).
- Racial or ethnic origin.
- Citizenship or immigration information.
- Religious or philosophical beliefs.
- Union membership.
- Mail, email, or text message contents not directed to us.
- Genetic data.
- Unique biometric information used for identification.
- Health information.
- Sex life, or sexual orientation information.
Collection of Sensitive Personal Information
We may collect or use information that falls with the Sensitive Personal Information categories above to infer characteristics about a person. During the twelve months prior to the effective date listed at the top of this policy, we have collected the categories of Sensitive Personal Information from consumers indicated below. Not all categories may be collected or received for every individual.
- Religious or philosophical beliefs.
- Genetic data.
- Health information.
Sharing Sensitive Personal Information
We may share your Sensitive Personal Information by disclosing it to a third party for a business purpose. During the twelve months prior to the effective date listed at the top of this policy, we have disclosed Sensitive Personal Information for a business purpose to the following categories of third parties:
CCPA Category |
Third Party Categories |
Government Identifiers |
• NONE |
Complete Account Access Credentials |
• NONE |
Precise Geolocation |
• NONE |
Racial or Ethnic Origin |
• NONE |
Citizenship or Immigration Information |
• NONE |
Religious or Philosophical Beliefs |
• NONE |
Union Membership |
• NONE |
Mail, Email, or Text Message Contents Not Directed to Us |
• NONE |
Genetic Data |
• Service providers |
Unique Biometric Information Used for Identification |
• NONE |
Health Information |
• Service providers |
Sex Life, or Sexual Orientation Information |
• NONE |
Sale of Sensitive Personal Information
We do not sell your Sensitive Personal Information to third parties.
Health Information Under CCPA
CCPA does not apply to deidentified patient information that:
- is derived from patient information originally collected, created, transmitted, or maintained under the California Confidentiality of Medical Information Act, HIPAA, or the Federal Policy for the Protection of Human Subjects, also known (“Common Rule”);
- is deidentified using the HIPAA Privacy Rule’s deidentification standards and approved methodologies; and
- will not be reidentified unless reidentification is permitted in accordance with certain permitted exceptions provided in CCPA.
See HIPAA Business Associate Privacy Policy for additional details on how we handle PHI obtained while servicing our Covered Entity customers.
Your Choices Regarding Our Use of Your Personal Information
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (the “right to know”). You may only submit a request to know twice within a 12-month period. Once we receive your request and confirm your identity (see Exercising Your Rights), we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Right to Delete
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Right to Correction
You have a right to correct inaccurate Personal Information we may have retained.
Right to Data Portability
You have a right to a copy of your Personal Information.
Right to Limit Use of Sensitive Personal Information
You have the right to limit the use or disclosure of your Sensitive Personal Data to the following types of activities:
- Perform the services or provide the goods you reasonably expect
- Help ensure the security and integrity of our services, systems, and data, to combat malicious deceptive, fraudulent or illegal acts, and to protect the physical safety of individuals, to the extent the processing is reasonably necessary and proportionate
- For short-term transient use (including non-personalized advertising), so long as the personal data is not disclosed to a third party, is not used for profiling, and is not used to alter an individual’s experience outside the current interaction with us.
- Perform services on our behalf, such as maintaining accounts, providing customer service, processing, or fulfilling orders/transactions, verifying customer information, processing payments, providing financing, providing analytics, providing storage, and similar services.
- Undertake activities to verify or maintain the quality or safety of, or improve, upgrade, or enhance a service or device we own or control.
- Collect or process sensitive data where the collection or processing is not for inferring characteristics about the individual
- Any other activities in accordance with any future regulations that are issued pursuant to U.S. state data privacy laws
We do not use or disclose your Sensitive Personal Data for purposes other than those listed above, without your consent, or as permitted or required under applicable laws. So, we do not offer an ability to limit the use of sensitive data.
Exercising Your Rights
To exercise any of these rights described above, please submit a request by:
- By mailing us at Liberty Healthshare: Data Privacy, 4455 Hills and Dales Rd. NW Canton, OH 44708
- By emailing us at privacy@libertyhealthshare.org
- By calling us toll free at 855-585-4237
Only you, or someone legally authorized to act on your behalf, may exercise any of these rights related to your Personal Information. You may make a request to exercise any of these rights on behalf of your child. Your request to exercise any of these rights must:
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include:
- If you are submitting a request to know categories of personal information or to delete non-sensitive information with a low risk of harm: (i) you must provide at least two pieces of personal information which match information we already hold; and (ii) we must determine that the information matched is reliable for verification purposes.
- If you are submitting a request to know specific pieces of personal information or to delete sensitive information with a high risk of harm: (i) you must provide at least three pieces of personal information which match information we already hold; and (ii) we must determine that the information matched is reliable for verification purposes.
- If you are submitting a request as someone legally authorized to submit such request on behalf of another, we may require you to provide proof of a valid power of attorney under California’s Probate Code, or one of more of the following: (i) proof of the other person’s signed permission to submit the request; (ii) the other person verifying their identity directly with us, or (iii) the other person directly confirms that they have authorized you to submit the request on their behalf.
- If you are making a request to exercise any of these rights on behalf of your child, we will require one of the following: (i) signing and returning a consent form to us; (ii) using a toll-free telephone number, video conference, or otherwise communicating in person with our trained personnel; or (iii) producing a form of government-issued identification to compare against databases of that information.
- We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
- You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
- We will only use the Personal Information provided in the request to verify the requestor's identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us by emailing us at privacy@libertyhealthshare.org or calling us at 855-585-4237.
We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you with a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other State Privacy Rights
This portion of our Privacy Policy applies solely to all visitors, users, and others who reside in one of the following states:
- Colorado
- Connecticut
- Florida
- Oregon
- Texas
- Utah
- Virginia
The states listed above provide their state residents with rights to:
- Confirm whether we process their Personal Information.
- Access and delete certain Personal Information.
- Correct inaccuracies in their Personal Information, taking into account the information's nature and processing purpose (excluding Utah).
- Data portability.
- Opt-out of personal data processing for:
- targeted advertising;
- sales; or
- profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Utah).
- Either limit (opt-out of) or require consent to process sensitive personal data.
The exact scope of these rights may vary by state. To exercise any of these rights, or appeal a decision regarding a consumer rights request, please contact us by emailing us at privacy@libertyhealthshare.org.
Nevada
Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request by emailing us at privacy@libertyhealthshare.org.
How We Protect Your Personal Information
We employ physical, procedural, and technological security measures to help protect your information from unauthorized access or disclosure. We may use encryption, passwords, and physical security measures to help protect your information against unauthorized access and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Governing Law
Our Website is controlled and operated by Liberty Healthshare. We provide our Website for use only by persons located in the United States. We make no claims that the Website or any of its content is accessible or appropriate outside of the United States. Access to the Website may not be legal by certain persons or in certain countries. If you access the Website from outside the United States, you do so on your own initiative and are responsible for compliance with local laws. By choosing to visit our Website or provide your personal information to us, you agree that any dispute over privacy or the terms contained in our Privacy Policy will be governed in accordance with the governing dispute resolution and arbitration provisions in our Terms of Use.
Changes to Our Privacy Policy
We reserve the right to amend our Privacy Policy at our discretion and at any time. It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' Personal Information, we will notify you by email to the primary email address specified in your account and through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. When we make changes to our Privacy Policy, we will post the updated notice on the Website and update the notice's effective date. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and our Privacy Policy to check for any changes. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us:
- By mailing us at Liberty Healthshare: Data Privacy, 4455 Hills and Dales Rd. NW Canton, OH 44708
- By emailing us at privacy@libertyhealthshare.org
- By calling us toll free at 855-585-4237
Liberty HealthShare Donor Privacy Policy
Last Updated On: 08/08/024
Liberty HealthShare is committed to respecting the privacy of our donors. This Donor Privacy Policy applies to all information received by Liberty HealthShare both online and offline and through any giving platform (“platform” includes the Liberty HealthShare website, ShareBox, social media outlets, and mobile applications), as well as any electronic, written, or oral communications.
Information Collected
Here are the types of donor information that we collect and maintain:
- contact information: name, organization/company, complete address, phone number, email address
- donation information: amounts donated, date of donation(s), method and stimulus
- your requests and comments
- information gathered from database modeling firms
- non-personally identifiable information, such as how many hits each Liberty HealthShare website page receives, and if the visitor is repeat or new. This requires that a ‘cookie’ be sent to your web browser.
How Information is Used
Liberty HealthShare uses your data to maintain records of donations, send acknowledgements, mail tax statements to you, send newsletters, notices and direct mail pieces, and for internal marketing purposes. We normally add you to our mailing list, unless you request otherwise. Any third-party vendors are contractually obligated to treat the lists with confidentiality and are prohibited from transferring them elsewhere. We do NOT list individuals’ names in ANY of our publications without prior written consent. We use your written comments/letters occasionally to post on our website (in an anonymous fashion), and to respond to your inquiries. Credit card numbers are NOT retained once processed. By law, donations over a certain amount must be reported on IRS Form 990, Schedule B. We use website statistics to analyze our website usage. We will use your information to comply with the law or in the good faith belief that such action is necessary to conform to the requirements of law or comply with legal process served on us, protect and defend our rights, or act in urgent circumstances to protect the personal safety of others. We will use your information to protect against potential fraud. We may verify with third parties the information collected in the course of processing a donation. If you use a credit or debit card, we may use card authorization and fraud-screening services to verify that your card information and address match the information you supplied to us and that the card being used has not been reported lost or stolen.
No Sharing of Personal Information
Liberty HealthShare will not sell, rent, trade or transfer your personal information to outside organizations. Use of donor information will be limited to the internal purposes of Liberty HealthShare and only to further the mission of Liberty HealthShare. Nevertheless, security measures may not prevent all losses, and Liberty HealthShare is not responsible for any damages or liabilities relating to security failures.
Removing Your Name From Our Mailing List
Please contact us if you wish to be removed from our mailing list. Email privacy@libertyhealthshare.org or call us at 855-585-4237.
Changes to Donor Privacy Policy
We reserve the right to change this Donor Privacy Policy from time to time. When we do, we will note the last update at the top of this Donor Privacy Policy.
You can learn more by reading our general Privacy Policy.