Updated May 6, 2021
1. THE DATA WE COLLECT ABOUT YOU
Personal Information, means any information about an individual from which that person can be identified. It does not include data where the identity of the individual has been removed or rendered permanently unreadable (anonymous data).
We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, social security number, employer and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services or products you purchased from us.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, email provider, operating system and platform and other technology on the Devices you use to access this website.
- Profile Data includes purchases or orders made by you, your preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services. We collect this data by using Tracking Technologies such as Cookies, Flash cookies and Web beacons. Tracking Technologies may set, change, alter or modify settings or configurations on your Device.
- Marketing and Communications Data includes your preferences in receiving information that might be of interest to you (this is referred to as “marketing”) from us and our third parties and your communication preferences.
IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
Where we need to collect Personal Information by law, or where such information is necessary for MSWC to provide goods or services to you, then your refusal to provide such necessary information may result in our inability to provide you with the requested goods or services. If that is the case, we will notify you.
2. HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, online chats, social media or otherwise. This includes Personal Information you provide when you:
- fill out a MSWC form;
- enroll in MSWC’s services or treatment;
- make a donation;
- paying a bill
- sign up for our events;
- respond to a survey;
- subscribe to our publications;
- request marketing to be sent to you;
- fill out an employment application;
- give us feedback; or
- otherwise volunteer information to MSWC.
- Automated technologies or interactions. As you interact with our MSWC-owned Sites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies, tracking technologies and other similar technologies.
- Third parties or publicly available sources. We may, from time to time, supplement the information we collect directly from you on our MSWC-owned Sites with outside records from third parties. We also receive Technical Data from analytics providers such as Google Analytics (see Website Analytics section).
- Third-Party Links. The MSWC-owned Sites may contain content that is supplied by a third party, and those third parties may collect Usage Information and your device identifier when pages from the MSWC-owned Sites are served to you. In addition, when you are on the MSWC-owned Sites you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the MSWC-owned Sites onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies. Third-party applications may also be available via the MSWC-owned Sites. The owners of these applications may collect Personal Information and other data from you and may have their own policies and practices. We are not responsible for how third-party or their applications collect or use your information and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. These third-party owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us. You may provide updates and changes by contacting us using the Contact us section.
3. HOW WE USE YOUR PERSONAL INFORMATION
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL INFORMATION
We will only use your Personal Information when the law permits such use or for any legitimate business reason. Most commonly, we will use your Personal Information in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you;
- Where it is necessary to further our legitimate business interests, such as:
- To provide you with information or services or process transactions that you have requested or agreed to receive, including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties;
- To enable you to participate in our Services and treatment;
- To process your registration with any of the Services, including verifying your information is active and valid;
- To improve the Services or create new service offerings, to customize your experience on any of the Services, or to serve you specific content that is most relevant to you;
- To contact you about your use of the Services and, in our discretion, changes to any of the Services and/or any of the Services’ policies;
- For internal business purposes such as complying with our internal policies;
- To protect our interests, including establishing, exercising and defending legal rights and claims;
- Where we need to comply with a legal or regulatory obligation; and/or
- Where we have obtained your consent.
We may process your Personal Information for more than one reason depending on the specific purpose for which we collected your Personal Information.
PROMOTIONAL SERVICES FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We may also use your Personal Information for fundraising and to engage in outreach for MSWC events and updates.
We use Google Analytics in connection with our Website to gather data such as age, gender and interests to provide advertising targeted to suit your interests and preferences.
This analytics software helps us target our online ads based on information collected directly from you or by automated means, like cookies (see cookies section).
You may opt out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests, by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at https://support.google.com/adw... and edit or opt-out your Google Display Network ads’ preferences at http://www.google.com/ads/preferences/ .
Google Analytics and Google Tag Manager collect anonymous information that is not used to identify a particular user. This information helps us better understand how visitors use our Website, detect and defend against fraud and other security risks, and present advertisements, products, and/or services of interest to you.
To learn more about how Google Analytics or Google Tag Manager collects and processes data, please visit “How Google uses data when you use our partners’ Site or apps”, located at www.google.com/policies/privacy/partners/. To learn about how to opt-out of Google Analytics, please visit http://tools.Google.com/dlpage/gaoptout/.
We do not share your Personal Information with third parties for third party marketing purposes.
You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails or by contacting us at firstname.lastname@example.org
Where you opt out of receiving these marketing messages, this will not apply to Personal Information provided to us as a result of a service purchase, service experience or other transactions.
COOKIES (Pop up cookie acceptance)
CHANGE OF PURPOSE
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us email@example.com
4. DISCLOSURES OF YOUR PERSONAL INFORMATION
We may have to share your Personal Information with the parties set out below for the purposes set out below. We require third parties to respect the security of your Personal Information and to treat it in accordance with the law.
- External Third Parties:
- You may be presented with an option to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.
- We may use third-party vendors to perform certain services on behalf of us or the Service, such as treatment services, administrative services, fundraising, to facilitate our MSWC-owned Sites and Services; to perform related services, including without limitation, maintenance services, database management, fulfillment, web analytics, and improvement of the features or functionality; or to assist us in analyzing how the MSWC-owned Sites and Services are being used, analytics, and enabling us to send you special notifications or event information. We may provide these vendors with access to user information, including device identifiers and Personal Information, to carry out the services they are performing for you or for us. We require third parties to respect the security of your Personal Information and to treat it in accordance with the law. Third-party analytics and other service providers may set and access their own cookies or similar technologies on your Device and they may otherwise collect or have access to information, potentially including Personal Information, about you.
- When we are required to do so by law.
- Affiliated Entities. We may share your information within MSWC.
Legal Process. Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.
5. DATA SECURITY
We have put in place reasonable security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions, and they are subject to a duty of confidentiality. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that you use our Service and provide us with your information at your own risk.
We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL INFORMATION FOR?
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, and in accordance with our policies surrounding data retention.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
7. YOUR LEGAL RIGHTS
You may opt-out of receiving marketing-related emails by clicking the "unsubscribe" link at the bottom of any email you receive from us or emailing us at firstname.lastname@example.org. If you are having difficulty unsubscribing from our marketing communications, please contact us at Info@mtsinaiwellness.com.
If you opt-out from receiving marketing emails or text messages, we may still need to send you communications about our services, your information, or other matters.
ACCESS, DELETE, OR REQUESTS TO UPDATE PERSONAL INFORMATION
If you believe that the Personal Information that we have collected about you is incomplete, inaccurate, or not up to date, or if you would like to review and/or request changes or deletion of that information, you can contact us at email@example.com. We may not be able to accommodate all requests due to legal or administrative retention requirements.
No fee usually required
You will not have to pay a fee to access your Personal Information. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and respond to your request to access your Personal Information. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
8. CHANGES TO THE PRIVACY NOTICE
9. CONTACT DETAILS
Our full details are:
Full name of legal entity: Mt. Sinai Wellness Center LLC.
Email address: firstname.lastname@example.org
330 Mt. Sinai Dr. Dahlonega, GA 30533
A cookie is a data file placed on a device when it is used to visit the MSWC-owned Sites. A Flash cookie (or locally shared object) is a data file placed on a device via the Adobe Flash plug-in that may be built-in to or download by you to your device. HTML5 cookies can be programmed through HTML5 local storage.
We may use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of the MSWC-owned Sites. They include, for example, cookies that enable you to log into secure areas of MSWC-owned Sites.
- Analytical/performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way MSWC-owned Sites work, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognize you when you return to MSWC-owned Sites. This enables us to personalize our content for you and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to MSWC-owned Sites, the pages you have visited and the links you have followed. We will use this information to make MSWC-owned Sites relevant to your interests. We may also share this information with third parties for this purpose.
Also commonly known as Tracking Pixels are small graphic images or other web programming code (also known as “1x1 GIFs” or “clear GIFs”) may be included in MSWC-owned Sites pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to MSWC-owned Sites, to monitor how users navigate MSWC-owned Sites, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with MSWC-owned Sites, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to MSWC-owned Sites, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
Tracking Technologies Usage. We may use Tracking Technologies for a variety of purposes, including:
- Targeting‑Related. We may use Tracking Technologies to deliver content relevant to your interests on MSWC-owned Sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.
Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies or other Tracking Technologies. For information on disabling Flash cookies go to Adobe’s website www.adobe.com. Please be aware that if you disable or remove these technologies some parts of MSWC-owned Sites may not work and that when you revisit MSWC-owned Sites your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
For more information: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html
To file a complaint if you feel your rights are violated visit www.hhs.gov/ocr/privacy/hippa/complaints/.
Joint Commission: www.jointcommission.org
Mt. Sinai Wellness Center
HIPAA NOTICE OF PRIVACY PRACTICES
Effective Date: February 7, 2022
THIS NOTICE DESCRIBES HOW INFORMATION ABOUT YOU AND YOUR TREATMENT MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.
PLEASE REVIEW IT CAREFULLY.
Mt. Sinai Wellness Center. MSWC is required by law to maintain the privacy and confidentiality of your health information and to provide you with notice of its legal duties and privacy practices with respect to your health information. Please also respect the privacy of others you encounter in treatment.
MSWC collects health information about you and stores it in an electronic health record. This is your medical record. The medical record is the property of MSWC, but the information in the medical record belongs to you. The Health Insurance Portability and Accountability Act (“HIPAA”) requires MSWC to maintain the privacy of your medical record. HIPAA generally requires that any uses or disclosures of information in your medical record be limited to the minimum necessary to the purposes of the uses or disclosures. HIPAA also provides you certain rights with respect to the information in your medical record which are described below.
Information relating to your treatment at MSWC is protected by federal regulations specific to drug and alcohol treatment, which are known as 42 C.F.R. Part 2. These regulations protect the confidentiality of information relating to the identity, diagnosis, prognosis, or treatment of any client in a drug or alcohol treatment program. MSWC may not disclose records relating to your treatment without your written consent, except in narrowly limited circumstances. Under 42 C.F.R. Part 2, the terms of a written consent to disclose information must specify the scope and types of information to be disclosed, the parties to whom the information may be disclosed, the purpose of the disclosure and the timeframe of the consent. You may revoke a consent to disclose information relating to drug and alcohol treatment verbally or in writing at any time.
MSWC may ask for your written consent to disclose treatment information for certain purposes, including releasing treatment information to or obtaining information from your other medical providers, obtaining payment from insurance or other payors, contacting your family either for treatment purposes or in the case of a medical or other emergency. MSWC will not disclose your treatment information for these purposes without your consent.
MSWC may disclose treatment information without your written consent under certain narrow circumstances as permitted by 42 C.F.R. Part 2. For treatment purposes, MSWC is permitted to use and disclose treatment information internally and to entities with which it shares administrative control. MSWC is permitted to share treatment information as necessary with qualified service organizations that agree to maintain the confidentiality of the information. MSWC also may disclose treatment information to outside auditors, regulatory agencies and evaluators and for certain research purposes. MSWC may disclose treatment information without your written consent when necessary in a life-threatening medical emergency and may disclose to report a crime on the premises or against MSWC personnel. MSWC also may disclose client information without consent where the State mandates child abuse and neglect reporting; when cause of death is being reported; or when required by a valid court order that contains specific required findings. MSWC may contact you to share information about MSWC’s treatment services or to send you reminder notices of future appointments for your treatment.
- Your Health Information Rights
In addition to protecting privacy and confidentiality, HIPAA and 42 C.F.R. Part 2 afford you the following rights with respect to your medical record and drug or alcohol treatment information:
- You have the right to a paper copy of this written notice of MSWC’s privacy practices.
- You have a right to request a copy of your treatment record or to receive your health information through a reasonable alternative means or at an alternative location. MSWC requires that all such requests be put in writing. A reasonable fee will be charged for copying your health information.
- You have a right to request that MSWC amend health information that is incorrect or incomplete. If MSWC determines not to amend the health information, it will provide you with an explanation of the reason for the denial and your rights to disagree with the denial.
- You have the right to receive notifications whenever a breach of your unsecured PHI occurs.
- You have a right to request restrictions on otherwise permitted uses and disclosures of your health information. MSWC is not obligated to comply with such requests.
- You may request that we provide you with a written accounting of all disclosures made by us during a specific time period (not to exceed 6 years). We ask that such requests be made in writing on a form provided by our facility. Please note that an accounting will not apply to any of the following types of disclosures: disclosures made with your written consent for reasons of treatment, payment or health care operations; and disclosures made to you or your legal representative, or any other individual involved with your care. You will not be charged for your first accounting request in any 12-month period. However, for any requests that you make thereafter, you will be charged a reasonable, cost-based fee.
- Changes to this Notice of Privacy Practices
MSWC reserves the right to amend this Notice of Privacy Practices at any time in the future, and to make the new provisions effective for all information that it maintains, including information that was created or received prior to the date of such amendment. Until amendment is made, MSWC is required by law to comply with this Notice. Should our privacy practices change, we will provide all current and future clients with a copy of the revised Notice of Privacy Practices
III. Complaints Regarding Privacy Practices
Complaints about this Notice of Privacy Practices or how MSWC handles your health information should be directed to:
Mt. Sinai Wellness Center
330 Mt. Sinai Drive
Dahlonega, GA 30533
If you are not satisfied with the manner in which this office handles a complaint, you may submit a formal complaint to one of the following:
Department of Health and Human Services
Office of Civil Rights
200 Independence Avenue, SW Room 509F, HHH Building
Washington, DC 20201
Bureau of Drug and Alcohol Services
N.H. Department of Health and Human Services
105 Pleasant St.
Concord, NH 03301
You may also address your complaint to one of the regional U.S Department of Health and Human Services Offices for Civil Rights. A list of these offices can be found online at: https://www.hhs.gov/ocr/about-us/contact-us/index.html.