THIS IS A WEBSITE PRIVACY POLICY DRAFTED UNDER U.S. LAW. THIS POLICY IS NOT INTENDED TO SATISFY ANY ‘FAIR PROCESSING NOTICE’ OBLIGATIONS THAT YOU MAY HAVE UNDER GDPR OR OTHER APPLICABLE NON-US LAW.
Access TeleCare Privacy Policy
EFFECTIVE DATE: January 1, 2023
In this Privacy Policy (“Policy”), we describe how Access TeleCare Holdings, Inc. (“the Company,” “we,” “us,” or “our”) collects, uses, and discloses information that we obtain about visitors to our website www.accesstelecare.com (the “Site”) and the services available through our Site (collectively with the “Site,” the “Services”).
By visiting the Site, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy.
This Policy may change from time to time (see “Changes to this Policy” below). Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
If you are a California resident, please review the section “Additional Information for California Residents” at the end of this Policy for additional information about our collection, use, and disclosure of personal information and your rights related to your personal information, as set forth by the California Consumer Privacy Act (“CCPA”).
The Information We Collect About You
We collect information about you directly from you and automatically through your use of our Site or Services.
Information We Collect Directly from You
The information we collect from you depends on how you use our Site or Services.
• When you request information or fill out a form on the Site, we will collect your name, email, company name, job title, and state. We may also collect your phone number and any additional information you choose to submit.
• If you contact us, we collect records and copies of your correspondence, including email addresses and other contact information.
• While you are navigating the Site, we may collect your search queries or information about your viewing history.
Customers are not required to have an account to access the Site, but must create one to access the Customer Portal, which is part of the Telemed IQ product and governed by a separate privacy policy available here.
Information We Collect Automatically
We automatically collect information about your use of our Site and Services through cookies and automatic collection technologies, including third-party analytics. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information. Information we collect automatically may include:
• Your IP address;
• Your browser type;
• Your domain name;
• The date and time, as well as the length of time, you visit our Site or use our Services;
• Your referring URL;
• Links you click on within the Site or to enter the Site;
• Web pages you view on the Site; and
• Your device ID.
How We Use Your Information
We may use your information, including your personal information, for the following purposes:
• To respond to your inquiries.
• To tailor the content and information that we may send or display to you, to offer location customization, and to otherwise personalize your experiences while using the Site.
• To send you email marketing communications about our products and services.
• To send you news and newsletters.
• To assist us in advertising on third party websites, mobile apps, and other online services, and to evaluate the success of our advertising campaigns through third-party channels (including our online targeted advertising and offline promotional campaigns).
• To better understand how users access and use our Site, both on an aggregated and individualized basis. For example, we will evaluate which features of our Site are more (or least) used by users, and we will use this information to update or add new features to our Site. We may also use feedback provided by users to update our Services or develop new offerings.
• For research and analytics purposes.
• Where we believe necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of this Policy.
How We Share Your Information
We may share your information, including personal information, as follows:
• Analytics Providers. We disclose personal information to service providers, contractors, or agents who perform functions on our behalf. These service providers include Google Analytics, Hotjar and HubSpot.
We also disclose information in the following circumstances:
• Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.
• In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
• To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
• Aggregate and De-Identified Information. We share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, research, or similar purposes.
Our Use of Cookies and Other Tracking Mechanisms
We and our service providers and contractors may use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you (and our service providers and contractors may do so on our behalf). The technologies we may use for this automatic information collection may include:
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.
• Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session.
• Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The “Help” portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Third Party Analytics. We use automated devices and applications, such as Google Analytics, Hotjar, and HubSpot, to evaluate usage of our Site. We also may use other analytic means to evaluate our Site. We use these tools to help us improve our Site’s performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout. To learn more about HubSpot’s privacy practices, please review the HubSpot Privacy Policy at https://legal.hubspot.com/privacy-policy.
Do-Not-Track. Our systems recognize browser “do-not-track” requests. You may also disable certain tracking as discussed in this section (e.g., by disabling cookies) and opt-out of targeted advertising by following the instructions in the “Ad Networks” section.
Ad Networks
We use network advertisers to serve advertisements on unaffiliated websites and other media (e.g., social networking platforms). This enables us and these network advertisers to target advertisements to you for products and services in which you might be interested. Ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These cookies and other technologies are governed by each entity’s specific privacy policy, not this one. We may provide these parties with information, including personal information, about you.
Users in the United States may opt out of many ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page, the NAI Consumer Opt-Out Page, or the AppChoices tool will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Services or on other websites or online media. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
Third-Party Links
Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
Security of My Personal Information
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
Your Rights and Choices
If you need to update your contact details or other personal information provided to us, please contact us as set forth in the “Contact Us” section below. California residents have certain rights, under California privacy laws, regarding their personal information, which are set forth in the “Additional Information for California Residents” section below.
Marketing Choices. In accordance with applicable law, we may send promotional emails to you. You may opt-out of such communications by following the opt-out instructions contained in the communication. We will process opt-out requests in accordance with applicable law. If you opt-out of receiving promotional emails, we may still send you communications about any services you have requested or received from us, or to respond to your inquiries.
Children Under 13
Our Services are not directed to children under the age of 13, and we do not knowingly collect or maintain personal information online from children we actually know at the time of collection are under the age of 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
Contact Us
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us by email at privacy@accesstelecare.com or by mail at Access TeleCare Privacy, 1717 Main Street, Suite 5850, Dallas, TX 75201.
Changes to this Policy
This Policy is current as of the “Effective Date” set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.
Additional Information for California Residents
In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.
A. Categories of Personal Information Under the CCPA
While our collection, use, and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about California residents in the prior 12 months (from the “Effective Date” above).
Categories and Sources of Personal Information Collected. The table below identifies, generally, the categories of personal information (as defined by the CCPA), we have collected about California residents. For more information about the business or commercial purposes for which we collect and use personal information, please see the “How We Use Your Information” section above.
| Catgegories of Personal Information | Description |
|---|---|
| Identifiers | Includes direct identifiers, such as name, email address, phone number, address and other contact information, company and title, IP address and other online identifiers. |
| Customer Records | Includes personal information, such as name, contact information and communications that individuals provide us for customer service-related purposes. |
| Commercial Information | Includes records of products or services purchased, obtained, or considered, or other purchasing, use histories, or tendencies that an individual provides to us in a customer service communication. |
| Usage Data | Includes Site browsing history, clickstream data, and other usage data and information regarding an individual’s interaction with our Site and our marketing emails and online ads. |
| Inferences | Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, or attitude. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to customers, so that we can better reach them with relevant offers and ads. |
Sources of Personal Information. As further described in the “The Information We Collect About You” section above, we may collect personal information from the following sources:
• Directly from the individual
• Data analytics providers
Disclosures of Personal Information. In the table below, we identify the categories of personal information we have disclosed for a business purpose or “sold” as defined by the CCPA, as well as the categories of third parties to whom we may disclose or sell such personal information. For more information about the business and commercial purposes for which we may disclose and sell (as defined under the CCPA) personal information, please see the “How We Share Your Information” section above. Under the CCPA, a “sale” includes disclosing or making available to a third party personal information, in exchange for monetary compensation or other benefits or value. While we do not disclose personal information in exchange for monetary compensation, we may make certain categories of personal information available in order to receive certain benefits or services, such as when we make browsing information available to third party ad companies (through third-party cookies and tags on our Site) in order to improve and measure our ad campaigns and reach users with more relevant ads and content.
| Categories of Personal Information | Do We Disclose for a Business Purpose? | Do We Sell? | Categories of Third Parties to Whom Information is Sold or Disclosed |
|---|---|---|---|
| Identifiers | Yes | Yes |
|
| Customer Records | Yes | No |
|
| Commercial Information | Yes | No |
|
| Usage Data | Yes | Yes |
|
| Inferences | Yes | Yes |
|
B. California Residents’ Rights
CCPA Rights. In general, California residents have the following rights with respect to their personal information:
• Do-not-sell (opt-out): to opt-out of our sale of their personal information. While we may “sell” personal information as defined by the CCPA, we do not sell personal information about California consumers who we know are younger than 16 years old. California residents may opt out of sales of their personal information by us, by submitting a request to privacy@accesstelecare.com.
• Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.
• Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):
• categories of personal information collected;
• categories of sources of personal information;
• categories of personal information about them we have disclosed for a business purpose or sold;
• categories of third parties to whom we have sold or disclosed for a business purpose their personal information;
• the business or commercial purposes for collecting or selling personal information; and
• a copy of the specific pieces of personal information we have collected about them.
• Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.
Submitting CCPA Requests. California residents may submit CCPA do-not-sell (opt out) requests, requests to know (access), and requests to delete their personal information through one of the following methods:
• By email at privacy@accesstelecare.com
• By phone at 866-904-0645
• By mail at Access TeleCare Privacy, 1717 Main Street, Suite 5850, Dallas, TX 75201.
When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must complete all required fields on our webform (or otherwise provide us with this information via the above toll-free number) to verify your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify his or her identity and the authority of the authorized agent.
For more information about our privacy practices, you may contact us as set forth in the “Contact Us” section above.
