Notice of Privacy Practices
Concierge Nurse Navigators, (collectively “CNN,” “we,” “us,” or “our”) have adopted this Privacy Policy (the “Policy”) to explain how we collect, use, safeguard, and share Personal Information (as defined below) from or about you (“user,” “you,” or “your”). This Policy covers Personal Information we may gather when you visit our Website at https://www.mynursenavigators.com, or any other sites we manage where this Policy is displayed. This Policy also addresses how we and others may use the Personal Information we collect, under what circumstances we may disclose that Personal Information to third parties, and the instances in which we may allow third parties to collect Personal Information directly via the Website. Depending on your activities when using or accessing our Website, you may from time to time be required to agree to additional terms and conditions.
Please note that this Policy applies to anyone who uses or accesses our Website, regardless of whether you use the Website via a computer, mobile device, tablet, or other medium (collectively, your “Equipment”).
This Policy applies to information we collect:
· Via the Website.
· Via email and other electronic messages between you and CNN via our services.
This Policy does not apply to information collected by:
· Us through any website, content, application, or service we may offer which does not link to this Policy.
· Any third party, including through any application or content (including advertising) that may link to or be accessible from or through our Website.
· Us for any concierge-related services.
Further, this Policy does not govern our handling of health-related information obtained through our concierge services. For information about our practices regarding health-related information, please see your plan documents.
Location of Services
Our Services are hosted in and directed at individuals in the United States. If you reside outside of the United States, you should not access or use our Services and should not share your Personal Information with us.
Acceptance
If you do not agree with this Policy, please do not use our Website. By using our Website, you acknowledge that you have read and accept the terms of this Policy.
Modifications to this Policy
We keep this Policy on our Website. You should review this Policy frequently, as it may change from time to time and without notice. Any changes will be effective immediately upon the posting of the revised Policy and will apply to all Personal Information collected after we post the revised Policy. When you use our Services, you agree to this Policy as it is posted. If you do not agree with any changes to this Policy, please stop using our Services.
Table of Contents
Please use the links below to access the following sections of the Policy that may interest you.
3. Cookies and Other Data Collection Technologies
4. How We Use and Share Information
11. Material Changes
12. Contact Us
13. Sole Statement
1. INFORMATION WE MAY COLLECT
When you use our Website, we may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual (“Personal Information”). Personal Information does not include information that is publicly available or de-identified (“non-personal information”). We reserve the right to use non-personal information for any purpose consistent with applicable law.
Note that information posted to publicly available sites, like social media sites, is not subject to this Policy.
We may collect the following information:
Identifiers. Examples include first name, last name, email address, phone number.
Internet or other electronic network activity information. Examples include browsing history, search history, and information regarding your interaction with an internet website application, or advertisement, language preference, browser type and version, time zone setting and location, browser plug-in types and versions, referring/exit pages, number of clicks, ads viewed, Equipment information such as device type, operating system and platform, and information about the Equipment you use to access our Services.
Employment Information. Such as the name of your employer.
Location Information. Examples include imprecise location information such as your city and state of residence or your zip code.
2. HOW WE COLLECT INFORMATION
We collect Personal Information in the following ways:
Directly from you. For example, when you contact us using the telephone number or email address on our Website; provide feedback; request that we contact you; or request customer service; post comments, photos, videos, or other information to our social media pages; when you review us; or when you otherwise communicate with us.
Automatically from your Equipment. When you access or use our Website, information associated with you and/or your Equipment may automatically be collected or received through device-based tracking technologies such as cookies, pixels, tags, beacons, or other technology.
SMS/MMS. Please note that we will not use any information obtained from third parties to contact you using SMS or MMS, nor will we use third parties to contact you using SMS or MMS for lead generation purposes.
3. COOKIES AND OTHER DATA COLLECTION TECHNOLOGIES
We may automatically receive and store certain types of Personal Information whenever you interact with our Website. For example, we may use “cookies” and “web beacons” (also called “clear gifs” or “pixel tags”), to obtain certain information when you use or access our Website. We may use information collected from these technologies to
· Estimate our audience size and usage patterns.
· Distinguish among users of our Services.
· Store your preferences so we may customize our Website according to your individual interests.
· Speed up your searches.
· Recognize you when you return to our Services.
Cookies are small files that we may transfer to your Equipment’s hard drive or your web browser memory to enable our systems to recognize your browser and to provide convenience and other features to you. We may use cookies to provide additional features or functionality to your experience when you use our Services, for example storing your preferences and other information about you when you use the Website. You may block or limit the storage of cookies via browser controls or other software. You may also delete cookies manually from your device through your internet browser, operating system, or other programs. Please note that some portions of our Services may not function properly or be available if you block or delete certain cookies.
Web beacons (also known as web bugs, clear GIFs, or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies, and may be used to track the online movements of users, when an email has been opened, and to provide other information.
4. HOW WE USE & SHARE INFORMATION
Use and Disclosure of Personal Information
We may use or disclose Personal Information for the following purposes:
· To provide you with Services that you have requested, including providing you updates about the status of the Services you have requested.
· To manage our relationship with you which may include notifying you about changes to our Services, Terms of Use, Privacy Policy, or any other policy we maintain, providing you notices about your account, asking you to provide feedback or take a survey, or addressing any questions you may have about our services.
· To deliver relevant content and messaging to you and to measure or understand the effectiveness of such content and messaging.
· To respond to your requests from us, including to exercise any data subject rights you may have, or to fulfill any other purpose for which you provide it.
· To improve our Website, customer relationships, and experiences.
· To contact you about our own or third parties’ products and services that may be of interest to you.
· With your consent, consistent with applicable law.
· For any other purpose as may be permitted by law or that we describe when you provide the information.
· To comply with any court order, law, or legal process, including responding to any government or regulatory request.
· To enforce our Terms of Use, this Privacy Policy, or other applicable policies or agreements with you.
· To protect the rights, property, or safety of our business, employees, customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.
· To investigate suspected violations of any law, rule or regulation, or the terms or policies for our website.
To Whom We Disclose Personal Information
We may disclose your Personal Information to the following:
Service providers. We may share Personal Information with vendors who help us with certain services, including our Website, customer support, email and text message deployment, research and analytics, data processing, data management, fraud prevention, and survey administration.
Business Partners and other Third Parties. With appropriate consent where required, we may share Personal Information with or make it available to our sponsors, partners, or other third parties in connection with our services.
Law Enforcement, Regulators, Courts, and other Governmental Authorities. We may share any of the categories of Personal Information we collect, pursuant to applicable law, to respond to subpoenas, court orders, legal process, and other law enforcement measures, to comply with other legal obligations, to respond to an emergency, or otherwise to protect our or the rights, property, safety, or security of other parties, visitors to or users of our Website, or the public.
Business or Asset Transfers. If we are involved in a merger, acquisition, transfer of control, bankruptcy, reorganization, or sale of assets, or diligence associated with such matters, we may share Personal Information with relevant stakeholders. For example, if another entity acquires us or all or substantially all of our assets, or assets relating to any of our businesses, your Personal Information may be disclosed to that entity as part of the due diligence process and may be transferred to that entity as one of the transferred assets.
Note that we do not sell or share (as those terms are defined by applicable law) your Personal Information or you Sensitive Personal Information.
5. YOUR RIGHTS AND CHOICES
We have created mechanisms to provide you with the following control over your information:
Marketing Emails: If you do not want us to use your email address to promote or recommend our own products and services, or third parties’ products or services, you may opt-out by replying to any promotional email we have sent you or following the opt-out links on that message. This opt out generally will not apply to information provided to us to provide you the service you requested.
Accessing, Updating, and Deleting Your Information: You may contact us as set forth in the Contact Us section below to request access to, correction of, or deletion of Personal Information about you in our possession or control, consistent with your rights as described below. We may not accommodate a request to change information if we believe the change would violate any law, legal requirement, or negatively affect the information’s accuracy.
Location Information: As noted above, when you use our Website we may automatically collect certain information about your Equipment. This includes the general location of your Equipment through GPS, Bluetooth, or WiFi signals. You may turn off location features on your Equipment.
Cookies and Automatic Data Collection Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. However, if you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly. In some cases, you may be able to set your browser or email program to not download web beacons.
Data Subject Access Rights. Depending on in which state you are resident, you may have the following rights related to your Personal Information. These rights include:
● The right to know what Personal Information we process about you.
● The right to request certain Personal Information that we process about you be deleted.
● The right to request we correct Personal Information we have about you which you believe is incorrect.
● The right to have certain Personal Information we process about you returned to you in an accessible and useable format upon your request, if such request is technically feasible.
● The right to opt-out of having your Personal Information processed in such a way that enables us to create a profile of inferences about you or for targeted advertising purposes.
● The right to limit the use of your Sensitive Personal Information.
● The right to opt-out of the sale of your Personal Information.
● The right to opt-out of any profiling in furtherance of decisions that produce legal or similarly significant effects.
● The right to exercise your data subject rights free from discriminatory treatment, including if you are an employee, applicant, or independent contractor, the right against employment related retaliation for exercising your privacy rights.
California Residents. If you are a California resident, you may have additional personal rights and choices regarding your personal data. For example, California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. It is our policy not to disclose your Personal Information to third parties for the third parties’ direct marketing purposes if you have exercised an option that prevents that information from being disclosed to third parties for those purposes. We provide a cost-free means to exercise this right by contacting us as provided below.
Exercising Your Privacy Rights
To exercise any applicable data subject rights, please submit a request using the contact information provided in the Contact Us section below.
How We Verify Data Subject Rights Requests
We may require that your identity be verified prior to processing verifiable rights requests. If your request requires verification, we will verify your identity by comparing the information we have about you against the information we receive when you submit your request. If we do not have enough information to verify your identity, we may request additional information from you, consistent with applicable law. We may deny a rights request if we are unable to verify your identity.
Authorized Agents
Some states permit their residents to designate an authorized agent to submit requests to exercise certain privacy rights on the individual’s behalf. Even if you use an authorized agent to submit a request on your behalf, pursuant to applicable law, we may still require that you verify your identity depending on the nature of the request and sensitivity of the information at issue.
If you are an authorized agent submitting a request on behalf of an individual, please submit a request using the contact information provided in the Contact Us section below. You must include a copy of the written, signed permission indicating that you are permitted to act on that person’s behalf.
Appealing a Denied Data Subject Rights Request
In some circumstances, we may deny your request to exercise one or more of the rights described above. If you disagree with our decision to deny your request or any portion of your request, you may appeal our decision within sixty (60) days of receipt of notice that your request has been denied. If you submit an appeal to a denied request more than sixty (60) days after you have been notified of our decision to deny the request, we may deny your appeal. If you submit a timely appeal, we will respond within forty-five (45) days of our receipt of your appeal.
If you wish to appeal a decision, please clearly and plainly describe your basis of disagreement with our decision by responding through the same means by which we communicated our decision or by submitting your appeal using the information provided in the Contact Us section below. We will review your appeal and either amend or uphold our decision. In either case, we will provide a written explanation of the reason for the decision. This decision will be final.
6. DATA SECURITY
The security of your Personal Information is very important to us. We use appropriate physical, electronic, and administrative safeguards designed to protect your Personal Information from loss, misuse, and unauthorized access, use, alteration, or disclosure.
We will continue to enhance and update our physical, electronic, and administrative safeguards as necessary. However, the Internet environment is not 100% secure, and we cannot guarantee that information we collect will never be accessed in an unauthorized way.
7. MINORS’ INFORMATION
Our Website is not intended for individuals under 18 years of age. We do not knowingly collect, sell, or share (as those terms are defined by applicable law) the Personal Information of any individual under 18. If you are under 18, do not use or provide any information to us. If you believe we may have any information from or about an individual under 18, please contact us using the information in the Contact Us section below.
8. DATA RETENTION
We will retain and use your Personal information for the period necessary for the specified purpose(s) for which it is collected and to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required by law.
9. THIRD-PARTY WEBSITES
Our Website may contain links to other third-party websites or social media platforms. This Privacy Policy only applies to our Website. If you click a link on our Website that takes you to another website or social media site that we do not control, you should read their privacy policy to confirm you agree with their privacy practices before sharing any personal information with that site.
10. SMS TERMS AND CONDITIONS
By opting into SMS, you are agreeing to receive SMS messages from CNN. This includes SMS messages for customer care and our nurses. Message frequency may vary. Message and data rates may apply. Message “HELP” for help. Reply “STOP” to any message to opt-out of receiving SMS messages from us.
Note, SMS consent is not shared with third parties or affiliates. Further, we will not use any information obtained from third parties to contact you using SMS or MMS, nor will we use third parties to contact you using SMS or MMS for lead generation purposes.
11. MATERIAL CHANGES
As noted above, we may update this Policy from time to time, and we will provide notice of any material changes to the Policy as required by law. All changes will be effective upon posting of the updated Privacy Policy on our Website. If you object to any change to this Policy, please stop using our Services.
12. CONTACT US
If you have any questions about this Privacy Policy or about our privacy practices, or to exercise any of your data subject rights as described in the Your Rights and Choices section above, please contact us using the following information:
By phone: 440-992-7000.
By email: info@mynursenavigators.com.
By mail: 1084 Walnut Blvd. Ashtabula, OH 44004
13. SOLE STATEMENT
This Privacy Policy as posted on our Website is the sole statement of our privacy practices with respect to our Website, and except as otherwise provided in this Policy, no summary, modification, restatement or other version thereof, or other privacy statement or policy, in any form, is valid unless we post a new or revised Policy to our Website.