Spaulding Academy & Family Services (“Spaulding”, “us”, “we” or “our”) is committed to protecting the privacy of the users (“user”, “you” or “your”) of its web site, SpauldingServices.org (“Site”). Spaulding’s Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the information you provide to us and in making informed decisions when using our Site. This Privacy Policy will be continuously assessed against new technologies and business practices. This Privacy Policy applies to the Site and governs data collection and usage at the Site. The United States has data protection laws that may not be consistent with those of other countries. By accessing, browsing and/or using the Site, including all content, software, functions, services, materials and information made available on or accessed through the Site, you acknowledge that you have read, understood and agree to be bound by this Privacy Policy. Any information provided by or through the Site will be treated in accordance with this Privacy Policy. By using the Site, you consent to the processing of data about you in the manner and for the purposes set out in this Privacy Policy. Please read it in its entirety.
USE OF COOKIES AND OTHER TECHNOLOGIES
We may employ cookie technology to store and sometimes track information about the users of the Site. Cookies are a feature of web browser software that allows web servers to recognize the computer used to access a web site. Cookies are small pieces of data that are stored by a user’s web browser on the user’s hard drive. Cookies can remember what information a user accesses on one web page to simplify subsequent interactions with that web site by the same user or to use the information to streamline the user’s transactions on related web pages. Most web browsers automatically accept cookies, but you can change your browser to prevent the browser from accepting cookies. If you reject cookies, you may still use the Site, but your ability to use some areas and features/functions of the Site may be limited.
We do not link the information we store in cookies to any personally identifiable information you submit while on our Site. We may use both session ID cookies and/or persistent cookies. We may use session cookies to make it easier for you to navigate our Site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following the directions provided in your Internet browser’s “HELP” file.
Any login areas on the Site require that your browser accept session ID cookies. We use session cookies to verify that you are properly signed in.
We may use web beacons (small pieces of data that are embedded in images on the pages of web sites) and auditing software to track page views and entry and exit points to and from the Site. In addition, we may use web beacons, cookies, customized links and/or similar technologies to determine whether electronic newsletter(s) sent by us to those who have requested them from us have been opened and which links are clicked. Any data collected will only be used in an aggregate form and will not contain any Personal Information, as that term is defined below.
TYPES OF INFORMATION COLLECTED
Through the use of cookie technology or otherwise, we may track and collect information about your computer and software when you visit the Site. This information may include: (i) your IP address; (ii) domain server; (iii) type of computer; (iv) type of web browser; (v) access times; and (vi) referring web sites addresses (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify you. Traffic Data assists us to design and arrange our web pages in the user-friendliest manner and to continually improve our Site to better meet the needs of users.
Spaulding may collect, store and use personally identifiable information (such as name, e-mail address and telephone number) about you via this Site (“Personal Information”) when it is voluntarily submitted to us, such as when you signed up for our newsletter – eNews, contact us to request information, or when you communicate with us by e-mail or otherwise complete online forms or the like. In all such cases you choose whether to provide us with the Personal Information.
You may contact us using traditional means (such as phone or regular mail) and choose not to provide us with any Personal Information through the Site. In such an event, you can still access and use much of the Site. You, however, will not be able to access or use those areas of the Site or participate in online activities that require your Personal Information.
Participation in online activities at the Site may be subject to additional terms, conditions and notices and such activities shall be governed by such terms, conditions and notices. In the event of any conflict, such additional or different terms, conditions and notices will prevail over this Privacy Policy.
VOLUNTARILY PROVIDED PHI
The term “PHI” refers to protected health information, as that term is defined in the HIPAA Privacy Rule (45 CFR Parts 160 and 164). If you complete the Admissions Inquiry Form on the Site and submit it via the Site, you voluntarily provide us with PHI about you or a prospective Spaulding student on whose behalf you submitted the Admissions Inquiry Form (“Prospective Student”). By submitting the Admissions Inquiry Form you represent to us (1) that you are authorized to provide the Prospective Student’s PHI or that the Prospective Student’s parent(s) or legal guardian authorized you to provide us with the Prospective Student’s PHI and (2) that you or the Prospective Student’s parent(s) or legal guardian, as the case may be, consent to Spaulding’s use of such PHI to determine whether Spaulding is a suitable placement for such Prospective Student. Providing PHI via the Admissions Inquiry Form on the Site is always voluntary.
USES AND SHARING OF INFORMATION COLLECTED
Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with the law or legal process served on us; (b) provide you the products, services and/or information that you may have requested; (c) protect our rights or property; (d) enforce our rights; (e) protect the interests of users of the Site, other than you, or any other person; (f) operate or conduct maintenance and repair of our equipment; and/or (g) detect, prevent and/or otherwise address fraud, security or technical issues, as authorized by law; and/or (h) otherwise comply with applicable laws.
In general, we will use Personal Information only for the purpose for which such information was provided to us. We may also use Personal Information to (a) to verify the information you provided to us; (b) to provide you with the information that you have requested; (c) to respond to your inquiries; (d) to contact you when necessary; and (e) to send you information about us, including information related to our products, services, programs or promotional activities, or about third-party products, services, programs or promotional activities that may be of interest to you. In the case of third party products, service, programs or promotional activities, your Personal Information is not transferred to the third party. If you sign up or subscribe to our newsletter(s), we will use your name and e-mail address to send the newsletter(s) to you. You may opt-out of receiving future communications from Spaulding by following the instructions set forth in the opt-out section below.
We may share your Personal Information with third parties that provide services to Spaulding (including general information on the Site, handling and delivering of e-mail communications and newsletter(s), user submitted information processing and/or storage and web site hosting and other application services) as reasonably necessary for them to provide said services. Service providers of Spaulding who have access to Personal Information, however, are required to protect this information in a manner that is consistent with this Privacy Policy and not to use it for any purpose other than to carry out the services they are performing for Spaulding.
We may use Traffic Data to analyze trends, administer the Site, track user’s movement, and gather broad demographic information for aggregate use.
We may provide Traffic Data and/or other aggregate non-personally identifying information to third parties.
Notwithstanding the foregoing, we may transfer, sell or assign information concerning the Site and your use of the Site, including without limitation, Personal Information, to third parties, as a result of the sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation of Spaulding.
ONLINE DONATIONS
We process online donations through PayPal, Inc. (“Paypal”). For information about Paypal, please visit www.paypal.com. Selecting Paypal to make your online donation takes you to Paypal’s website where the donation transaction may be completed. PayPal’s privacy policy will apply to any information you submit during the donation transaction. Spaulding will receive your name, address, e-mail address, phone number and donation amount from PayPal. This information will be used internally by Spaulding to issue a receipt for the donation and will be subject to this Privacy Policy.
OPT-OUT/DISCONTINUE
If you do not wish to receive information or other material from us, you may “opt-out” of receiving these communications by sending us an e-mail at Opt-Out@SpauldingServices.org or by contacting us through our Contact/Find Us page located at www.spauldingservices.org/admissions-referrals/feedback/.
If you sign up/subscribe to our newsletter(s) and you no longer wish to receive our newsletter(s), you may also unsubscribe by following the unsubscribe link located within each newsletter.
CORRECT; UPDATE
If you wish to change or modify information previously provided to us, you may do so by sending us an e-mail at Update@SpauldingServices.org or by contacting us through our Contact/Find Us page located at www.spauldingservices.org/admissions-referrals/feedback/. We will use reasonable efforts to ensure that your information is corrected or updated in our records.
LINKS
The Site contains links to third-party web sites. These links are provided solely as a convenience to you. If you access those links, you will leave the Site. Spaulding does not control those sites or their privacy practices, which may differ from Spaulding’s practices. Spaulding is not responsible for the privacy practices or content of linked third party sites and does not make any warranty or representation regarding the content or accuracy of materials on such sites. Nor does Spaulding make any warranty or representation regarding, nor does it endorse, any linked third-party web sites or the information appearing thereon or any of the products or services described thereon. The personal information you choose to provide to or that is collected by these third parties is not covered by our Privacy Policy. We encourage you to review the privacy policy of any third-party before submitting your personal information. If you decide to access linked third party web sites, you do so at your own risk.
BLOGS/BULLETIN BOARDS/CHAT ROOMS
If you use a blog, bulletin board, chat room or similar public forum on the Site, you should be aware that any Personal Information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the Personal Information you choose to submit in these forums.
SECURITY
The Site has security measures in place intended to protect the loss, misuse and alteration of the information under our control. We use industry standard Secure Sockets Layer (SSL) encryption when collecting your Personal Information, with the exception of information you send via e-mail. We take reasonable steps to safeguard Personal Information we collect from unauthorized access or disclosure and accidental loss or alteration.
Unfortunately, no data transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to us or from our Site, and you do so at your own risk. Once we receive your transmission, we make reasonable efforts to ensure security on our systems.
NOTIFICATION OF CHANGES
We may change our Privacy Policy at any time by updating this posting. Changes to our Privacy Policy will be effective when posted. If at any point we decide to use Personal Information in a manner different from that stated at the time it was collected, we will notify you by e-mail. You will have a choice as to whether or not we use your Personal Information in this different manner. Unless otherwise agreed, we will use Personal Information in accordance with the Privacy Policy under which the information was collected.
POLICIES FOR INDIVIDUALS UNDER 13 YEARS OF AGE
We are committed to protecting the on-line privacy of children. In accordance with the Children’s On-line Privacy Protection Act, we will not knowingly collect any personally identifiable information from children under the age of 13.
ACCEPTANCE OF PRIVACY POLICY
By using the Site, you signify your assent to our Privacy Policy. If you do not agree with this Privacy Policy, please do not use our Site. Your continued use of the Site following posting of changes to these terms will mean you accept those changes.
CONTACT US
If you have any questions or concerns regarding our Privacy Policy or any questions about the security at our Site, you can send an e-mail to Privacy@SpauldingServices.org or contact us through our Contact/Find Us page located at www.spauldingservices.org/admissions-referrals/feedback/.
SPECIAL NOTIFICATION FOR CALIFORNIA RESIDENTS
Users who reside in California and have provided their personal information to Spaulding may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must be submitted to us at CAPrivacy@SpauldingServices.org. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.
Effective Date: March 7, 2012