CHIROPRACTIC LEADERSHIP ALLIANCE INC.
PRIVACY POLICY
Your privacy is our priority. Without your trust in us, you won’t enjoy the value we can provide, so we design our products and services so you can fully trust them and us and allow us to help you reach your goals.
We don’t cut corners with protecting your information. We collect information to help enhance your experience with our products and services and work hard to keep it secure. Please read our policy to ensure you understand what information we collect, why we collect it, how it is used and your choices regarding your information. Our Privacy Policy is written in plain language to help facilitate your understanding.
This Privacy Policy applies beginning November 22, 2019 (“Effective Date”).
1. WHO WE ARE
The company responsible for your information is: Chiropractic Leadership Alliance Inc. (CLA)
2. WHERE THIS PRIVACY POLICY APPLIES
This Privacy Policy applies to websites, apps, events, and other services offered and operated by CLA. All of these will be referred to as “services” in this Privacy Policy. Some services may have their own privacy policies, in which case that policy – not this one – will apply.
3. INFORMATION WE COLLECT
Our purpose is to help you enhance your practice with innovative technologies and tools for measuring results and maintaining open lines of communication with patients, all with the goal of improving patient care. To fulfill our purpose, we must know who you are. In addition to basic information like your name, address, and contact information, we also ask about your practice, staff, modalities, methods, preferences, goals, and finances. On a more technical level, we also collect information about how you use our services, like when you log on, how long you’re engaged with the services, and where you go within the website or app, all so we can improve your user experience.
Information You Give Us:
When using the services, you will provide us certain information. Let us explain:
When you create an account, you will provide us basic identifying information such as your login credentials, name, gender, date of birth, location, etc. As you continue to interact with us, you can share additional information about who you are as a practitioner, as well as content like photos, videos, and even audio recordings. We might request access to your camera or to the photo album you maintain through another service. You might consider some of the information you provide to be sensitive. By choosing to provide this information, you consent to our collection and use of that information.
When subscribing or making purchases directly with us, you’ll provide and we’ll collect and process your billing and payment information such as your debit or credit card number and associated bank.
When you answer our surveys or input responses to questions, we’ll collect and review those inputs to help us improve the services.
If you contact our support team, we may record those interactions and collect the information you provide so we can train our team and improve the quality of our services.
If you want us to communicate with people in your network, we’ll collect that information about those other people to complete that request.
Information We Receive from Others:
In addition to the information you provide us directly, we receive information about you from others, including:
Other Users. Just as you might provide information about other people to us, other users may provide us with information about you as they use our services. For example, if a user asks us to access his/her contacts, and you’re one of them, we may use it to reach out to you on behalf of the user.
Other Partners. We may receive info about you from our partners, for instance when CLA accounts can be created through a partner’s websites (in which case they pass along registration information to us) or where CLA ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).
Information Collected When You Use our Services:
When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:
Usage Information. We gather information about how you use our services, like the dates and times you’ve logged in, features you use, searches, clicks, ads you might find interesting, and so on. We use this information to understand how to improve the services for a better experience for you.
Device Information. We collect information from and about the device(s) you use to access our services, including: hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address); information on your wireless and mobile network connection, like your service provider and signal strength; information on device sensors such as accelerometers, gyroscopes and compasses.
Other information with your permission. Your geolocation (latitude and longitude) can be collected through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of this information may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.
4. HOW WE USE INFORMATION
Our primary purpose for collecting your information is to find ways to improve our services and, therefore, your user experience. We also use your information to help keep you safe and to provide you with advertising that may be of interest to you. For a more detailed explanation of the various reasons we use your information, see below:
- To administer your account and provide our services to you
- To ensure a consistent experience across your devices
- Create and manage your account
- Provide you with customer support and respond to your requests
- Develop, display and track content and advertising tailored to your interests on our services and other sites
- Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you
- Complete your transactions
- Communicate with you about our services, including order management and billing
- Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.
- Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).
- Provide anonymized collected clinical data to individuals and institutions for the purpose of evaluating trends to develop improvements and changes associated with chiropractic and other clinical care models
- To serve you relevant offers and ads
- Hold sweepstakes, contests, discounts or other offers
- Conduct focus groups and surveys
- Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)
- To prevent, detect and fight fraud or other illegal or unauthorized activities
- Perform data analysis to better understand and design countermeasures against these activities
- Retain data related to fraudulent activities to prevent against recurrences
- To ensure legal compliance
- Assist law enforcement as required by law or court order
- Enforce or exercise our rights
The following provide a basis for us to process your information:
- To render our services to you. When you become a user, we have a contract and we use that information to hold up our end of that bargain.
- For legitimate interests. These might include using your information to deduce what offers might be of interest to you. Other legitimate interests include how we administer the services, how we detect and prevent fraud, and for other legal purposes.
- With your consent: As you use the services, we will request your consent now and again. If you want to withdraw that consent, you may contact us at any time to do so.
5. HOW WE SHARE INFORMATION
We may share information you provide with third parties who help us render the services, with CLA affiliates, and, in some cases, legal authorities. For more information about how your information might be shared with others, see below.
With other users:
When posting information flagged as public information, that other users can see, you are sharing with other users. You should be careful with that information and ensure what you share is what you’re comfortable sharing. Once that information is shared, neither you nor we can control what others do with it.
With our service providers and partners:
Third parties help us improve and operate the services by providing support services such as security operations, data hosting, analytics, marketing, advertising, payment processing, and customer service. We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in non-human-readable form to advertising partners.
We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.
For corporate transactions:
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
When required by law:
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
To enforce legal rights:
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
With your consent or at your request:
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human-readable form, under any of the above circumstances. We may also share this information with third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human-readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy.
If emails containing Personal Health Information (“PHI”) are sent outside the protection of an internal network there is considerable potential for PHI to be viewed by unauthorized individuals. This is not a problem when emailing patients, provided consent to use email to send PHI has been obtained from the patient in advance. The patient must have been made aware of the risks of sending PHI via unencrypted email and must have given authorization to use such a potentially insecure method of communication.
6. HOW WE PROTECT YOUR INFORMATION
We work hard to protect you from unauthorized access to or disclosure, modification, or destruction of your personal information. Although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.
We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.
We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately.
7. HOW LONG WE RETAIN YOUR INFORMATION
We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5) and as permitted by applicable law.
In practice, we delete or anonymize your information upon deletion of your account, unless: we must keep it to comply with applicable law; we must keep it to evidence our compliance with applicable law; there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.
8. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES
Cookies are small text files created by a website that are stored on your computer temporarily or permanently so that the website can recognize a user and keep track of that user’s preferences. We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). Our Cookie Policy contains more information on why we use them (to authenticate users, allow them to use their social media accounts, remember their settings and preferences, analyzing site traffic and trends, measuring advertising campaigns) and how you can better control their use, through your browser settings and other tools.
Some web browsers (including Chrome, Safari, Internet Explorer, and Firefox) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and those that do often don’t use the same signals. Because of this inconsistency, many businesses (CLA included) don’t currently respond to DNT signals.
9. CROSS-BORDER DATA TRANSFERS
Sharing of information laid out above sometimes involves cross-border data transfers, for instance to and from the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.
10. YOUR RIGHTS
So that you remain in control of your information, we offer the following tools:
Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the service. If you have any question on those tools and settings, please contact our customer care team for help here.
Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
Deletion. You can delete your account by using the corresponding functionality directly on the service.
We want you to be aware of your privacy rights. Here are a few key points to remember:
Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by contacting us.
Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us.
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer any of the above requests.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user.
Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.
Accountability. In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.
11. RESIDENTS OF CALIFORNIA
If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request here. Please allow 30 days for a response. For your protection and the protection of all of our users, we may require you to provide proof of identity before we can fulfill such a request.
12. CHILDREN’S PRIVACY
Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.
13. PRIVACY POLICY CHANGES
Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.
14. HOW TO CONTACT US
If you have questions about this Privacy Policy, here’s how you can reach us:
CHIROPRACTIC LEADERSHIP ALLIANCE, INC. (“CLA”)
2915 Lake East Drive
Las Vegas, NV 89117
