HBRA CT respects the privacy of its customers and the visitors and users of its website. This Privacy Policy is intended to inform you of our policies and practices regarding the collection, use and disclosure of any Personal Information or Personal Health Information (as those terms are defined below) we obtain about you based upon your use of our websites, products or services. Your privacy is important to us, and we pay close attention to the use and sharing of Personal Information and Personal Health Information. You should read this policy before providing any information to us, as it describes the information we gather, how we use and disclose that information and the measures we take to protect it.
By visiting our websites or using our products or services, you agree to the terms of this Privacy Policy.
You expressly consent to the use and processing of your Personal Information and Personal Health Information according to this Privacy Policy. Personal Information and Personal Health Information may be processed by us or our vendors or other third parties in the United States, the country where it was collected as well as other countries where laws regarding processing of Personal Information and Personal Health Information may be less stringent.
INFORMATION WE COLLECT
In providing our products and services to you, we may collect the following types of information:
“Personal Information,” or information about you that may be used to identify you or that can uniquely be associated with you, such as your name, address, e-mail address, phone number and other non-public information relating to such information. For certain products or services, we also collect credit card or payment account information.
“Personal Health Information,” or health-related information about you (such as weight, blood pressure or glucose levels, lab results, medications and health history) that you give us or that we receive from third parties.
You may choose to directly disclose Personal Information or Personal Health Information through this Site, for example by using our public message boards. Information shared on the message boards will be accessible to the public and your information may be collected and used by others. Please only disclose information on the public message boards that you are comfortable sharing under these conditions.
We act as a service provider to our customers and may process and store on behalf of our customers Personal Information or Personal Health Information, or both, that our customers collect about third parties (or about you). We do not own that Personal Information or Personal Health Information.
We may gather navigational information during each visitor’s use of our site. In the process of gathering navigational information, non-personally identifiable information (e.g., domain type, browser version and service provider and the like) may be collected. The navigational information tells us about the use of our site by visitors, including the areas of our site that are most visited or the time of a last visit to a page on our site. It also tells us about the effectiveness of our site and services (e.g., the time it takes a visitor to connect to our site or download pages). The navigational information helps us better understand a visitor’s experience and improve upon that experience by recognizing and delivering more of the features, services and products our visitors prefer. We may provide this statistical information to third parties, but such information is not combined with personally identifying information without your consent.
When we provide communications services including emails or texts to you or to those businesses that offer the services to consumers, we may gather information necessary to provide those services such as your mobile or other telephone number, communications made to subscribe or unsubscribe to those services and other information and other information relating to your or other consumers’ use of the services. We also may receive information about you or others’ use of SMS services from wireless carriers, operators or our clients including an end user’s mobile telephone number and, in some cases, additional information such as a user’s geographic location, personal information number (PIN), or electronic and physical mailing addresses. Additionally, we process message content transmitted through the SMS services that may contain personal information communicated or received by an end user.
You are responsible for ensuring the accuracy of the Personal Information and Personal Health Information that we collect from you. Inaccurate information will affect the use and effectiveness of our products and services and our ability to contact you.
Our servers may automatically collect information, such as Internet Protocol (IP) addresses, browser type, pages visited, access times, duration of visit, referring URL, platform, links accessed, timestamp and exit page information (“Automated Information”) with respect to each visitor to the websites, whether or not the visitor is a logged-on user, repeat visitor, etc.
We may receive Personal Information or Personal Health Information about you from other sources, such as telephone or from other parties such as vendors and third party providers. We may add this information to the information we have already collected about you with the effort to improve our products and services.
What Personal Data is Collected and How Personal Data is collected
When we say “Personal Data” we mean this to include “personal information” (often referred to as “PI”) and/or “personally identifiable information” (sometimes called “PII”) as defined or described in different privacy laws around the world (and in the U.S.).
Purposes for Which the Data is Used and by Whom
Third parties (such as NextRoll, Pearl Diver) may place cookies on the browser used by the visitor in order to serve targeted advertising and for measurement and analytics purposes.
How Visitors Can Control the Collection of their Data by NextRoll & Pearl Diver
Visitors can decline to have personal data collected via third party tracking technologies by navigating to the settings feature in their browser and declining all third party cookies or declining third party cookies from specific sites, or, for mobile, limiting ad tracking or resetting the advertiser identifier via the privacy settings on their mobile device.
You are using Cross-Device
Your information is being used for our own marketing purposes. Our advertising Partner, NextRoll, Inc., performs a hash of your email address in order to serve targeted advertising to other devices connected to you (via cross-device tracking). By submitting this form, you acknowledge NextRoll, Inc.’s hashing and cross-device activity.
HOW WE USE AND DISCLOSE INFORMATION
In general, we use information collected, including Personal Information and Personal Health Information, to provide our products and services, to respond to requests that you make, to inform you of other products or services available, to conduct research about your opinion of our services, to process transactions and to enable us to serve you more effectively. We do not use or disclose your Personal Information and Personal Health Information except as described in this Privacy Policy or as required by law or legal process.
You control who can access your Personal Health Information. If you choose to, you can share your information with others. We will not sell, rent, or share your Personal Information or Personal Health Information without your explicit consent, except as otherwise provided in this Privacy Policy. We may access and/or disclose your Personal Information and Personal Health Information, with or without notice, if we believe such action is necessary to: (a) comply with the law or legal process served on us; (b) protect and defend our rights or property (including the enforcement of agreements between you and us); or (c) act in urgent circumstances to protect the personal safety and welfare of our customers or members of the public.
We may also use the Personal Information and Personal Health Information that we obtain from you or from other sources for the following purposes:
To Provide and Improve Our Website, Products and Services
We use the information that you provide for such purposes as responding to your requests, improving our websites, products and services, and communicating with you. We may use your information to deliver information to you that, in some cases, is targeted to your interests. We may ask you to provide us voluntarily with additional information regarding your personal or business interests, experience or requests, which we may use to customize our service for you. We may combine your information with information that we collect from other companies (such as demographic data) to improve and personalize services. We may collect information for auditing, research and analysis in order to maintain, protect and improve our websites, products and services.
To Track Site Traffic Information
As you navigate our websites, we may collect certain passive information, including your IP address, browser type and operating system. We may use your IP address to monitor your usage of the site, and at times choose to directly communicate with you via a chat functionality. We may also use cookies and navigational data such as Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and the solutions and information for which you searched and viewed. This type of information is collected to make our products and services more useful to you. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). While you will still be able to use our websites if you disable Cookies in your browser, certain parts of our websites may not function as effectively. After you register and enable Cookies, we may associate this information with personal information that we have collected from you.
In addition, we may use non-business IP addresses and other Automated Information collected to track aggregate information regarding website traffic. We do not collect any Personal Information or Personal Health Information via a user’s non-business IP address. One of the uses for which this data may be gathered is for statistical purposes so that we may analyze trends and performance over time.
To Transfer Information for Legal Purposes
We may need to disclose certain information to comply with a legal requirement (such as a law, regulation, court order, subpoena or search warrant) in the course of a legal proceeding or in response to a law enforcement agency request. If we undergo a change of control (whether by merger, sale or otherwise), or a sale or transfer of our stock, assets or business, Personal Information or Personal Health Information could be sold or transferred as part of that transaction and your Personal Information or Personal Health Information could be used by the purchaser or other recipient of such information. We also may use or disclose information to resolve disputes, investigate problems, or enforce our Terms of Use, purchase agreements, or other agreements we may enter with you. At times, we may review the status or activity of multiple users to do so.
For Data Aggregation
We may disclose aggregated, non-personal data generated from our websites, products and services to third parties. Depending on the circumstances, we may or may not charge third parties for this aggregated, non-personal data. You grant us the right to accept payment or other remuneration for such data. We require parties with whom we share aggregated, non-personal data to agree that they will not attempt to make this information personally identifiable.
For Use With Third Parties
We may hire third parties to provide services on our behalf, such as performing statistical analysis, developing websites and answering customer service and billing questions. We will give those third parties only the Personal Information or Personal Health Information they need to deliver the service for which they have been hired. We may also share your Personal Information and Personal Health Information with vendors or other third parties for them to provide you with offers that we think you will find valuable. We will require such third parties to maintain the confidentiality of any information we provide.
To drive traffic to your website and to make your website easier to find, we will disclose keywords about your business, your business name, general and specific descriptions about your business, information about your location, and information about your products and services to third-party services and to the public.
We may also use third parties to maintain and store your Personal Information to process any payment you make to us. Generally, these third parties are required not to use your Personal Information other than to provide the services requested by us.
For Use By Subsidiaries and Affiliates
We have subsidiaries and other companies under a common control (collectively, “affiliates”). We may share some or all your Personal Information and Personal Health Information with these affiliates, in which case we will require them to honor this Privacy Policy.
SHARING YOUR INFORMATION
If you grant access to your Personal Information or Personal Health Information to other individuals, websites or health care professionals, these other individuals, websites or health care professionals will be able to access your information and store a copy of it. Any copies of your information will be governed by that individual’s, website’s or health care professional’s privacy policy. Others may be able to view your information from such copies. If you do not want information about you, including Personal Information, to be shared in this manner, do not use this feature. You may disconnect your account from a third party account at any time. We are not responsible for the use of your information by others to whom you grant access to such information.
PROTECTING THE CONFIDENTIALITY AND SECURITY OF INFORMATION
We are committed to protecting the security of your information. We have adopted commercially reasonable security measures consistent with industry practice that are designed to assist in protecting against the loss, misuse and alteration of your Personal Information and Personal Health Information which is under our control. As you know, no security system or system of transmitting data over the Internet can be guaranteed to be 100% secure. Accordingly, you should not expect that any information provided to us or to any third party will always remain private.
Do Not Track Browser Setting
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a single website. For these purposes tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time.
How browsers communicate the Do Not Track signal is not yet uniform. As a result, we may not interpret or respond to Do Not Track signals communicated by your browser. Even so, as described more fully throughout this Privacy Policy, we limit our use and collection of your personal information.
For a description of Do Not Track protocols for browsers and mobile devices, or simply to learn more about the choices available to you, you can visit the All About Do Not Track website: https://allaboutdnt.com/.
HOW TO UNSUBSCRIBE
Should you decide to stop receiving e-mail communications or newsletters from us, you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail. If at any time you wish to unsubscribe from any communications from us, you may do so by contacting us at [email protected]. Despite your indicated e-mail preferences, we may send you e-mail regarding updates to legal notices applicable to the account you created with us. From time to time, we may contact you by telephone to offer you products or services which we believe may be valuable to you. Should you prefer not to receive such calls, please advise the representative who contacts you or contact customer care at [email protected]
From time to time we may contact you to offer products or services that we believe may be valuable to you. Should you prefer not to receive such calls, please so advise the representative who contacts you.
Should you wish to discontinue receiving SMS or text messages, you may communicate your preference by using the unsubscribe feature provided for that service.
PRIVACY OF MINORS
We do not knowingly collect or maintain information provided by children under the age of majority in their jurisdiction of residence, and in any event does not knowingly collect information provided by or relating to children under the age of 18. If a child has provided us with personally-identifying information without parental or guardian consent, the parent or guardian should contact us and we will remove the information.
LINKS TO OTHER SITES
Our provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. We have no control over, do not review, and cannot be responsible for these outside websites or their content. Please be aware that the terms of our Privacy Policy do not apply to these outside websites.
CONTACT US
Should you have any questions or concerns regarding this Privacy Policy, please contact us as follows:
HBRA CT
PRIVACY POLICY UPDATES
We may revise this Privacy Policy at any time, in our sole discretion, by posting an amended Privacy Policy on our websites. Any changes that we make to this Privacy Policy will be effective immediately upon posting. You should check this page periodically for changes to the Privacy Policy. If you object to any such changes, you must cease using our websites, products and services. Continued use of our websites, products or services following notice of any such changes shall indicate your acknowledgment of such changes and agreement to be bound by the terms and conditions of such changes.
NOTICE FOR CALIFORNIA USERS
The following supplements the information contained in this Privacy Policy, and applies solely to all visitors, users, customers and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and California Civil Code, Section 1798.83. Any terms defined in the CCPA and Section 1798.83 of the California Civil Code have the same meaning when used in this notice.
California Civil Code, Section 1798.83
A business subject to California Civil Code section 1798.83 is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of personal information disclosed, for the third parties’ direct marketing purposes.
If you are a California resident and would like to make such a request, please send an email to [email protected].
The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted by email at [email protected], in writing at Department of Consumer Affairs, Consumer Information Division, 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
California Consumer Privacy Act of 2018
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We 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.
Making a verifiable consumer request does not require you to create an account with us. 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 personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Types of verifiable consumer requests:
Access to Specific Information – once we receive and verify your request based on the criteria herein, 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.
The specific pieces of personal information we collected about you (also called a data portability request).
If we disclosed your personal information for a business purpose, identifying the personal information categories that each category of recipient obtained.
Data Portability – we will select a format to provide your personal information that is readily useable and transmittable.
Deletion – we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Personal Information Sales Opt-Out and Opt-In Right – We do not sell your personal information.
How to Exercise Your Rights
Click here for CCPA Do Not Sell Requests
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Calling us at (860) 500-7796
Contacting us at [email protected]
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 the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
ADDITIONAL RIGHTS
You may have other privacy protections under applicable state laws. To the extent these laws apply, we will comply with them when we share information about you.
Effective as of: August 1, 2021