Last
modified: August 1, 2023
Overview
This North
Star Health Alliance (“North Star“, “us”, “we” or “our”) Privacy Policy (or the
“Policy”) is designed to inform you about the types of information we collect,
how we collect, use, process, and disclose that information, and the choices
you can make about how we collect, use, process, and disclose your personal
information. We are committed to respecting your privacy. Please read this
Policy carefully and, if you have any questions, comments, or concerns, please
contact us using the information provided in the <<Contact
Us>> section at the end of this Privacy Policy.
This
Privacy Policy applies to personal information collected on our website,
https://northstarhealthalliance.com/ (the “Website”), through our website, and
anywhere else this Privacy Policy is posted. Although there are links from the
Website to other websites, such as the websites of our partners or sponsors,
this Privacy Policy applies only to this Website and not to websites operated
by others[KG1] .
When
using our Website, you may choose to interact with features from third parties
that operate independently from North Star such as social media links and links
to third-party websites. North Star has no control over and is not responsible
for the privacy practices of such third parties. This Privacy Policy does not
apply to the extent North Star does not own or control any linked websites or
features you visit or use. We recommend that you familiarize yourself with the
privacy practices of these third parties.
If you
reside in or are located in the European Economic Area (“EEA”), the United
Kingdom (“UK”), Canada, or anywhere else other than in the United States, our
Website and services are not directed to you and not intended for your use. If
we learn we have collected or received personal information from a non-U.S.
resident, we will delete that information.
Table
of Contents
- Overview
- Children Under the Age of 18
- This Website Privacy Policy
- Personal Information We May
Collect
- Personal Information You Provide
to Us
- Information We May Collect
Indirectly
- Information Collected from Other
Sources
- Use of Personal Information
- Sale or Sharing of Personal
Information
- To Whom Your Personal Information
May be Disclosed
- Disclosure of Personal Information
in the Preceding 12 Months
- Cookies and Similar Technologies
- Cookie Policy
- Choices About How We Use and
Disclose Your Information
- Accessing and Correcting Your
Information
- Your State Privacy Rights
- Your Nevada Privacy Rights
- Your California Privacy Rights
- California “Shine the Light”
- Exercising Your Privacy Rights
- To Exercise Your Right to Opt-In
- To Exercise Your Right to Opt-Out
- Opting-Out of Non-Essential Email
or Text Communications
- Response Timing and Format
- Requests Submitted by Authorized
Agents
- Appeal Process
- Notice of Financial Incentives
- “Do-Not-Track” Signals
- Data Security
- Changes to Our Privacy Policy
- Contact Information
Children
Under the Age of 18
Neither
the Website nor the Services are directed to or intended for persons under 18
years of age, unless such person has obtained the consent of such person’s
parent or guardian. We do not knowingly collect personal information from
persons under 18. If you are under 18, do not use or provide any information on
this Website or through any of its features, register on the Website, make any
purchases through the Website, or provide any information about yourself to us,
including your name, address, telephone number, email address, or any screen
name or user name you may use.
If we
receive any information from a visitor under the age of 18 without the consent
of the visitor’s parent or guardian, we will delete all information about that
visitor from our system as quickly as possible. No information collected from
users under the age of 18 is used for any marketing or promotional purposes
whatsoever. If you believe we might have any information from or about a child
under 18, please contact using the information provided in the <<Contact
Us>> section.
If you
are under the age of 18 and would like to use our Website and Services, have
your parent or guardian contact us using the information provided in the <<Contact
Us>> section so that we may obtain the affirmative consent
of your parent or guardian to the collection and use of your personal
information as set out herein.
California
residents under 16 years of age may have additional rights regarding the
collection and sale of their personal information. Please see <<To
Exercise Your Right to Opt-In>> or <<Your
California Privacy Rights>> for more information.
This
Website Privacy Policy
This
Policy applies to information we collect:
On
this Website;
In
email, text, and other electronic messages between you and this Website;
Through
our digital properties, services we offer, our events, and virtual sessions
(collectively, our “Services”); and
When
you interact with our advertising and applications on third-party websites and
services, if those applications or advertising include links to this Policy.
It
does not apply to information collected by:
Us
offline or through any other means, including on any other website operated by North
Star or any third party; or
Any
third party (including our affiliates, partners, and sponsors), including
through any application or content (including advertising) that may link to or
be accessible from or through the Website.
Please
read this Policy carefully to understand our policies and practices regarding
your personal information and how we will treat it. By using the Website or
Services, you agree to us collecting, using, storing, disclosing and otherwise
processing your personal information in accordance with this Privacy Policy. If
you do not consent to the collection, use, storage, disclosure or other
processing of your personal information as described in this Policy, you should
discontinue using our Website and not provide your personal information. This
Policy may change from time to time (see <<Changes to Our
Privacy Policy>>). Your continued use of this Website after we
make changes is deemed to be acceptance of those changes. Please check the
Policy periodically for updates.
Personal
Information We May Collect
Our
Website collects information that identifies, relates to, describes,
references, is reasonably capable of being associated with, is linked, or could
reasonably be linked, directly or indirectly, with a particular consumer,
household or device (“personal information” or otherwise referred to in certain
privacy laws as “personal data”). Personal information does not include publicly
available information from government records; de-identified or aggregated
consumer information; and information excluded from the privacy laws in effect
for states within the United States and federal U.S. privacy laws (or
collectively “U.S. privacy laws”), such as health or medical information
covered by the Health Insurance Portability and Accountability Act of 1996
(“HIPAA”), as amended, the California Confidentiality of Medical Information
Act, clinical trial data, qualifying research data, personal information
covered by certain sector-specific privacy laws, including the Fair Credit
Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information
Privacy Act, and the Driver’s Privacy Protection Act of 1994.
We
collect various types of information from and about users of our Website in
order to provide and improve the Website and Services we offer and to
communicate with you about our offerings.
We may
require certain personal information where, for example, it is necessary under
law to perform the Services or a contract with you, to enroll you in an event,
or to provide you with information you have requested.
We may collect the following categories of personal information:
- Identifiers, such as:
- name,
- postal address,
- email address,
- phone numbers,
- unique personal and online identifiers,
- IP address,
- mobile device information (e.g., unique device identifier assigned to the device, mobile carrier, operating system, and other device attributes)
- Personal Information Categories Listed in the California Customer Records statute, such as name, phone numbers, employment, employment history
- Characteristics of Protected Classifications Under U.S. State or Federal Law, such as, age, national origin, disability
- Commercial Information, such as, products or services purchased or considered, credit/debit card number, other purchasing or consuming tendencies
- Internet or Other Electronic Network Activity, such as:
- browsing history,
- search history,
- advertisement interaction,
- website interaction,
- application interaction
- Geolocation Data, such as, IP address, physical location, or GPS signals broadcast by your mobile device
- Usage Information, such as which pages on our Website you access, the frequency of access, what you click on while on our Website, and when you accessed the Website
- Professional and Employment-related Information, such as business contact details
- Inferences drawn from other
personal information, such as a profile reflecting preferences,
characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities, and aptitudes
We collect personal information in the following ways:
- Directly from you when you provide it to us;
- Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies or other tracking technologies; and
- From third parties, for example,
our service providers.
Personal
Information You Provide to Us
We collect personal information you provide to us through the Website or as part of the Services through the following methods:
- If you ask a question or make a request through this website, you may be asked to provide your name, email address, and a message;
- If you interact with our Website by sharing on a social media platform, we may collect the information that you post. Please note that your comments will also be visible to the public, so you should never share personal information that you would like to keep private;
- If you send us an email, we will collect your email address and any information that you provide in the email;
- Personal information that you provide to us directly;
- For any other purpose with your
consent.
We do
not collect biometric information or sensory data. We do not collect non-public
education information (per the Family Educational Rights and Privacy Act (20
U.S.C. § 1232g, 34 C.F.R. Part 99)).
If you
provide any personal information about another individual to us, you are
responsible for making sure that you have the authority to do so and to allow
us to use their personal information in accordance with this Policy.
Information
We May Collect Indirectly
We automatically collect and store certain types of information about your equipment, browsing actions, and patterns, as well as your use of the Website and Services, such as through the use of “cookies,” pixels and other tracking technologies. Examples of the type of information we may collect automatically include:
- IP address of the device you are using;
- Device ID;
- Location of your device;
- Browser type;
- Internet service provider; and
- Content interaction information,
such as files or content viewed, time spent viewing content, and download
information.
We may
collect information we collect automatically that does not personally identify
you, but we may maintain or associate it with personal information we collect
in other ways or receive from third parties.
We use the automatically collected information to help us to improve our Website and Services and deliver better and more personalized experiences with the Website and our Services, including by enabling us to:
- Estimate our audience size and usage patterns;
- Provide information and marketing that may be of interest to you;
- Store information about your preferences, allowing us to customize our Website and Services according to your individual interests;
- Speed up your searches;
- Recognize you when you return to
our Website so that we can return you to where you were on the Website.
See
our <<Cookie Policy>> for more detail about
information we collect automatically.
Information
Collected from Other Sources
We may receive information from other sources, such as through social media, third-party platforms and forums, contacts, and business partners. Examples of the types of information we may receive from other sources are:
- Personal information, such as your name, personal and professional mailing address, email and phone number
- Profile information, comments, and similar information provided to or on social networks and other forums that connect to us.
- Interests, demographic data, and purchasing behavior.
- Information collected from you offline or through other channels. For example:
- Information
you provide over the phone, such as when we discuss our Services with
you.
Some
of the information we collect may, when combined with other information, be
personal information that could be used to identify you. Such information is
treated as personal information.
You
are responsible for ensuring the accuracy of personal information you provide
to us. Inaccurate information may affect your ability to use the Services,
including the information you receive when using the Services and our ability
to contact you.
Use of
Personal Information
We
use, store, and otherwise process the information we collect to provide and
improve our Website and Services, to support our business functions, to fulfill
legal obligations we may have to you or others, and to personalize, provide,
measure and improve our advertising and marketing.
Some examples of how we may use the personal information we collect include:
- To respond to your inquiries and provide support;
- To present our Website and its contents to you;
- To provide you with information or services that you request from us, such as email alerts and updates, or other marketing information or opportunities;
- To provide information about products or services in which you may be interested;
- To provide you with information about us, our Services, and our business activities;
- To comply with any applicable COVID-19 tracing efforts;
- For customer service and customer support purposes;
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection activities;
- To facilitate payment or delivery of services requested;
- To help prevent transactional fraud;
- To provide you with support and respond to your inquiries, such as to investigate and address your concerns, and monitor and improve our responses;
- To create, maintain, customize and help secure your account with us;
- To manage your account and provide you with notices regarding the Services;
- To provide, personalize, measure, and improve your experience with our Website and to deliver content, product and service offerings based on your advertising customization preferences;
- To help maintain and improve the safety, security, and integrity of our Website and Services;
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website or Services is among the assets to be transferred;
- For testing, research, analysis, and product development, such as to develop and improve our Website, Services, databases, other technology assets, and other offerings;
- To respond to law enforcement requests as required by applicable law, court order or governmental regulation;
- To support our general business operations;
- To notify you about changes to our Website or Services;
- As described to you when collecting your personal information;
- To fulfill any other purpose for which you provide it;
- For any other purpose with your consent; and
- For any other lawful purpose.
We may
also use your personal information to contact you about our own or
third-parties’ goods and services that may be of interest to you or to enable
us to display advertisements to our advertisers’ target audiences. If you click
on or otherwise interact with an advertisement, the advertiser may assume that
you meet its target criteria. For more information about how third-parties
might collect your information or make assumptions about whether you meet its
target criteria, please see our <<Cookie Policy>>.
If you do not want us to use your personal information in this way, please
adjust your preferences in your user account profile, if you have one. For more
information about exercising your rights with respect to your personal information,
please see <<Your State Privacy Rights>>.
Sale
or Sharing of Personal Information
Sale
of Personal Information
We do
not intentionally sell personal information about visitors to the Website.
However, some exchanges of your personal information to third parties may be considered a “sale” under certain state privacy laws. We may share or sell (if considered a sale under certain state privacy laws) the personal information we collect for one or more of the following purposes:
- To respond to your inquiries and provide support;
- To present our Website and its contents to you;
- To provide you with information or services that you request from us, such as email alerts and updates, or other marketing information or opportunities;
- To provide you with information about us, our Services, and our business activities;
- To provide information about products or services in which you may be interested;
- To comply with any applicable COVID-19 tracing efforts;
- For customer service and customer support purposes;
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection activities;
- To facilitate payment or
delivery of services requested;
- To help prevent transactional fraud;
- To provide you with support and respond to your inquiries, such as to investigate and address your concerns, and monitor and improve our responses;
- To create, maintain, customize and help secure your account with us;
- To manage your account and provide you with notices regarding the Services;
- To provide, personalize, measure, and improve your experience with our Website and to deliver content, product and service offerings based on your advertising customization preferences;
- To help maintain and improve the safety, security, and integrity of our Website and Services;
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website or Services is among the assets to be transferred;
- For testing, research, analysis, and product development, such as to develop and improve our Website, Services, databases, other technology assets, and other offerings;
- To respond to law enforcement requests as required by applicable law, court order or governmental regulation;
- To support our general business operations;
- To notify you about changes to our Website or Services;
- As described to you when collecting your personal information;
- To fulfill any other purpose for which you provide it;
- For any other purpose with your consent; and
- For any other lawful purpose.
To
Whom Your Personal Information May be Disclosed
We may share your personal information by disclosing it to a third party for a business purpose. We make these disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. We make these disclosures where it is required in order for us to perform our obligations under our contract with you, where it is required to provide the Services you requested, where it is required by law, or where we have another legitimate interest in doing so, including, but not limited to, as follows:
- To our affiliates (such as companies that we own, that own us, or companies that share common ownership with us);
- To consultants, service providers, and other third parties that perform services on our behalf, such as credit card payment processors, event planners and coordinators, data management and storage providers, marketers and advertisers, analytics and research companies, and professional advisors, including Data Analytics (such as Google Analytics and DoubleClick), Social Networks (such as LinkedIn and Twitter), Hosting Services, Ad Network, Sales and Marketing Tools, and ClickDimensions;
- To law enforcement agencies, regulators, and courts in response to a court order, subpoena, regulatory requirements or similar legal process, to report any activities we reasonably believe to be unlawful, or as otherwise required by law;
- To combat fraud or criminal activity, and to protect our rights, users, and business partners, or as part of legal proceedings affecting North Star;
- To another entity in connection with a merger, transfer of data assets, reorganization, divestiture, financing, dissolution, or similar corporate event involving all or part of our business;
- To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes;
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our company, our customers, or others;
- Where it is necessary to respond to a public health emergency, or in an emergency, to protect the safety of your health and property;
- To a reasonable extent, for purposes of carrying out news reporting and media monitoring for public interests;
- For any other purpose disclosed by us when you provide the information; and
- Otherwise with your consent.
Disclosure
of Personal Information in the Preceding 12 Months
Sharing
of Personal Information
In the
preceding twelve (12) months, we have shared for a business purpose the
following categories of personal information to the categories of third parties
indicated in the chart below:
Category of Personal Information |
Third Parties with Which We Have
Shared in the Past 12 Months |
Identifiers – (e.g. Name, alias,
unique personal identifier, online identifier, Internet Protocol (IP)
address, email address, account name, social security number, driver’s
license number, passport number, or other similar identifiers) |
Affiliates, Service Providers,
Business Partners, Social Media |
Customer Records Information — (e.g.Name, signature, social
security number, physical characteristics or description, address, telephone
number, passport number, driver’s license or state identification card
number, insurance policy number, education, employment, employment history,
bank account number, credit or debit card number, other financial
information, medical information, health insurance information) |
Affiliates, Service Providers,
Business Partners, Social Media |
Characteristics of Protected
Classifications Under federal or applicable state law — (e.g.Race, religion, sexual
orientation, gender identity, gender expression, age) |
N/A |
Commercial Information — (e.g.Records of personal
property, products or services purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies) |
Affiliates, Service Providers,
Business Partners, Social Media |
Biometric Information — (e.g.Hair color, eye color,
fingerprints, height, retina scans, facial recognition, voice, and other
biometric data) |
N/A |
Internet or Other Electronic Network
Activity — (e.g.Browsing history, search history, and information regarding
a consumer’s interaction with an Internet website, application, or
advertisement) |
Affiliates, Service Providers,
Business Partners, Social Media |
Geolocation Data |
Affiliates, Service Providers,
Business Partners, Social Media |
Audio, electronic, visual, thermal,
olfactory, or similar information |
N/A |
Professional or employment-related
information |
Affiliates, Service Providers,
Business Partners, Social Media |
Non-public education information
— (e.g.Information that is not “publicly available personally
identifiable information” as defined in the California Family Educational
Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99)) |
N/A |
Inferences — Inferences that could be used to
create a profile reflecting a consumer’s: Preferences Characteristics
Psychological trends Predispositions Behavior Attitudes Intelligence
Abilities Aptitudes |
Affiliates, Service Providers,
Business Partners, Social Media |
“Service Providers, Business Partners, and Social Media” include Data Analytics, Hosting Services, Ad Network, Sales and Marketing Tool, and Social Networks. We have shared this personal information for the following reasons:
- To respond to your inquiries and provide support;
- To present our Website and its contents to you;
- To provide you with information or services that you request from us, such as email alerts and updates, or other marketing information or opportunities;
- To provide you with information about us, our Services, and our business activities;
- To provide information about products or services in which you may be interested;
- To comply with any applicable COVID-19 tracing efforts;
- For customer service and customer support purposes;
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection activities;
- To facilitate payment or delivery of services requested;
- To help prevent transactional fraud;
- To provide you with support and respond to your inquiries, such as to investigate and address your concerns, and monitor and improve our responses;
- To create, maintain, customize and help secure your account with us;
- To manage your account and provide you with notices regarding the Services;
- To provide, personalize, measure, and improve your experience with our Website and to deliver content, product and service offerings based on your advertising customization preferences;
- To help maintain and improve the safety, security, and integrity of our Website and Services;
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website or Services is among the assets to be transferred;
- For testing, research, analysis, and product development, such as to develop and improve our Website, Services, databases, other technology assets, and other offerings;
- To respond to law enforcement requests as required by applicable law, court order or governmental regulation;
- To support our general business operations;
- To notify you about changes to our Website or Services;
- As described to you when collecting your personal information;
- To fulfill any other purpose for which you provide it;
- For any other purpose with your consent; and
- For any other lawful purpose.
Sensitive
Personal Information
We do
not collect the following Sensitive Personal Information: race or ethnicity;
religion; citizenship; genetic data; biometric data used to identify a person;
precise geolocation; personal information of children; union membership; SSN;
DL or passport number; financial account with password or security code; and
contents of mail, email or texts (unless a business is the intended email recipient).
If,
however, tracking your website activity of searches and interests in health or
medical areas is considered Sensitive Personal Information, we may sell or
share such information. You have a right to opt-out of the sale or sharing of
such information. See <<To Exercise Your Right to
Opt-Out>>.
Cookies
and Similar Technologies
We, as well as third parties that provide content or other functionality for our Website, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Website. These technologies allow us to understand who has interacted with us and also help us to operate our Website and Services more efficiently. These technologies also help us deliver online advertising to you.
- Cookies. Our Website use cookies that fall into the following categories: Strictly Necessary, Performance, and Marketing and Advertising. For more information on cookies, please see our <<Cookie Policy>>.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Website that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page.
- Interest-based advertising. We may permit third parties to use technologies on our Website to collect information about your device and your use of our Website to advertise products and services to you that are tailored to your perceived interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. Such third parties act on our behalf, and we may grant them the right to use your information for their own purposes.
- Marketing. We may use ClickDimensions for marketing automation in order to improve user experience and provide the Services to customers. For more information on how ClickDimensions uses your information, please see ClickDimensions’ Privacy Policy, at https://clickdimensions.com/about/privacy-policy/.
- Analytics. We also may use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics for our Website and to develop content. For more information on how Google uses your information, please see Google’s Privacy Policy, at https://policies.google.com/privacy?hl=en-US, and Google’s Advertising Policy, at https://policies.google.com/technologies/ads?hl=en-US.
- Social Media. Our Website may include social
media features, such as Twitter, LinkedIn, or other widgets. These social
media companies may recognize you and collect information about your
visit to our Website, and they may set a cookie or employ other tracking
technologies. Your interactions with those features are governed by the
privacy policies of those companies.
Cookie
Policy
Overview
Cookies
are small data files created by web browsers and downloaded onto your computer
or other device when you access a website. Cookies help make your browsing
experience with our Website more personal. Different cookies serve different
purposes, such as recognizing your devices, storing information about your
preferences, identifying the geographic location of a user, tracking browsing
habits and preferences to deliver personalized advertising, recalling
information entered on forms, login pages, shopping carts or other features of
the Website, helping us understand how the Website is being used, and generally
improving your browsing experience on the Website.
Categories
of Cookies:
There
are different ways to classify cookies, including based on when they expire or
whether they are managed by us or a third party.
Type of Cookie |
Description |
Persistent Cookies |
Persistent Cookies stay on your
computer or mobile device until you delete them. |
Session Cookies |
Session Cookies expire once you
close your web browser. |
First Party Cookies |
First Party Cookies are those that
may be managed by North Star and originate from our Website. |
Third Party Cookies |
Third Party Cookies originate with
service providers or business partners providing services on or through our
Website, and can be used by these third parties to recognize your device when
it visits other websites. Third Party Cookies may also be used for other
purposes, such as analytics, advertising, and social media features. |
Why do
we use cookies?:
We use
cookies to learn how you interact with our Website and to improve your
experience and provide you additional functionality on the Website. Certain
things we do using cookies include subjects such as remembering your language
preference, remembering Services you may have requested, and providing you with
content and advertisements consistent with your interests.
What
type of cookies do we use?:
Strictly Necessary |
These cookies are necessary for the
Website to function and cannot be switched off in our systems. Strictly
necessary cookies are typically set in response to actions or services that
you request, such as setting your privacy preferences, logging in, filling
out a form, or putting items in a shopping basket. Strictly necessary cookies
can also be used to manage sessions on load balanced servers or to ensure
user requests are routed consistently to the correct server. |
Performance Cookies |
Performance cookies are sometimes
called analytics cookies. We use these cookies to count visits and traffic
sources so we can measure and improve the performance of our Website,
including determining whether or not a user is new or returning,
distinguishing users from one another, calculating new and returning visitor
statistics. These cookies help us to know which pages are the most and least
popular on the Website and to see how visitors move around the Website. For
example, we use Google Analytics to help us understand how frequently the
same people revisit the Website, how the Website is found (from advertising
or referring websites), and which pages are most frequently viewed. All
information collected through these performance cookies is aggregated and
anonymous. This information is combined with data from a large number of
other users to create an overall picture of Website use, and is never
identified individually or personally and is not linked to any other
information we store about you. For more information about Google Analytics,
or how to opt-out of Google Analytics cookies, please visit Google’s Privacy
Policy and Opt-out page. |
Tracking, Marketing and Advertising
Cookies |
We may partner with third party
advertisers who may use tracking pixels that set cookies to assist with
delivering online advertising relevant to your interests. We or our
advertising partners may build a profile of your interests and show you
targeted advertisements on other sites. You can opt-out of almost all
advertising cookies by updating your preferences on www.aboutads.info. |
How Do
Third Parties Use Cookies on our Website?:
We
work with third parties to provide certain services on the Website. These third
parties include: Data Analytics (including Google Analytics and DoubleClick),
Social Networks (such as LinkedIn and Twitter), Hosting Services, Ad Network,
Sales and Marketing Tools, and ClickDimensions.
Third
parties may use their own cookies to collect information about your actions on
our Website and/or the advertisements you click on. They may use this
information to deliver advertisements they believe are most likely of interest
to you based on content you have already viewed. Third parties may also use
this information to measure the effectiveness of certain advertisements. North
Star does not control such third party cookies. To disable or reject the third
parties cookies, you should refer to their own websites and policies.
For
more information on how some of our third party service providers collect and
use information please refer to their privacy policies.
How do
I Control Cookies?:
If you
choose, you can set your browser to reject cookies or you can manually delete
individual or all of the cookies on your computer by following your browser’s
help file directions. However, if your browser is set to reject cookies or you
manually delete cookies, this may alter your access and use of some of the
pages and features on our Website.
You
may also reject or block all or specific types of cookies from our Website by
setting your preferences on our Website. You can change those preference at any
time.
You
may also visit https://allaboutcookies.org/ or https://www.aboutcookies.org/
for details on how to delete, reject, or block cookies and for further
information on cookies generally.
Your Choices in Relation to Tracking and Online Advertising
- Users can visit Ad Settings (google.com), https://adssettings.google.com, for more information about its settings.
- Users can visit Google Analytics Opt-out Browser Add-on Download Page, https://tools.google.com/dlpage/gaoptout, for information on how to opt-out of Google Analytics
- To opt-out of third-party interest-based advertising from advertisers and third parties that participate in certain self-regulatory programs, please visit the Network Advertising Initiative, at https://thenai.org/opt-out/, and the Digital Advertising Alliance, at https://digitaladvertisingalliance.org/. Opt-outs are generally device and browser specific, meaning that you will need to opt-out on each device and browser you use. Please note, even if you opt-out of interest-based advertising, you will continue to receive ads, but they will not be targeted to your interests. Users of mobile applications may opt-out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoice mobile app, https://apps.apple.com/us/app/appchoices/, and selecting the user’s choices.
- You can set your browser to
refuse all or some browser cookies, or to alert you when cookies are
being sent. If you disable or refuse cookies, please note that some parts
of this site may then be inaccessible or not function properly.
Choices
About How We Use and Disclose Your Information
We
strive to provide you with choices regarding the personal information you
provide to us. We have created mechanisms to provide you with the following
control over your information:
Disclosure
of Your Information for Third-Party Advertising. If you do not want
us to share your personal information with unaffiliated or non-agent third
parties for promotional purposes, you can opt-out by See <<Contact
Us>>.
Promotional
Offers from the North Star. If you do not wish to have your
email address or other contact information used by North Star to promote our
own or third parties’ products or services, you can opt-out by <<Contact
Us>>. If we have sent you a promotional email, you may send us a
return email asking to be omitted from future email distributions. This opt-out
does not apply to information provided to North Star as a result of a purchase
of the Services.
Targeted
Advertising. If you do not want us to use information that we
collect or that you provide to us to deliver advertisements according to our
advertisers’ target-audience preferences, you can opt-out by <<Contact
Us>>. For this opt-out to function, you must have your browser
set to accept all browser cookies.
Residents
of certain states, such as California, Colorado, Connecticut, Nevada, Utah, and
Virginia may have additional personal information rights and choices. Please
see <<Your State Privacy Rights>> for more
information.
Accessing and Correcting Your Information
- You can review and change your personal information by logging into the Website and visiting your account profile page
- You may also send us an email to the email address specified in the <<Contact Us>> section of this Privacy Policy to request access to, correct, obtain, or delete any personal information that you have provided to us. In some instances, we cannot delete all your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement, cause the information to be incorrect, or the request is otherwise subject to a legal exception.
- Please see <<Your
State Privacy Rights>> for more information.
Your
State Privacy Rights
State
consumer privacy laws may provide their residents with certain rights regarding
our use of their personal information. To learn more about California
residents’ privacy rights, see <<Your California Privacy
Rights>>and<<California “Shine the Light”>>.
Colorado, Connecticut, Utah, and Virginia each provide their residents with rights to:
- Confirm whether we are processing your personal information;
- Access your personal information;
- Delete personal information concerning you;
- Obtain your personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. Some states’ privacy laws may limit the number of times per year that you are allowed to exercise this right.
- Opt-out of the processing of your personal information, or authorize another person to opt-out on your behalf, for:
- targeted advertising; or
- the sale of personal information.
- Not be discriminated against for exercising any of your
state privacy rights.
If you choose to exercise any of your state privacy rights, we will never retaliate by:
- Denying you services or decreasing the availability of services;
- Charging you higher prices or rates for services or imposing penalties;
- Providing you with a different level or quality of services; or
- Suggesting that you may receive
a different price or rate for services or a different level or quality of
services.
However,
we may offer you certain financial incentives permitted by law that can result
in different prices, rates, or quality levels (see <<Notice of
Financial Incentives>>). Any legally-permitted financial
incentive we offer will reasonably relate to your personal information’s value
and contain written terms that describe the program’s material aspects.
Participation in a financial incentive program requires your prior opt-in
consent, which you may revoke at any time. We do not currently provide any such
incentives.
Colorado, Connecticut, and Virginia also provide their residents with rights to:
- Opt-out of the processing of your personal information, or authorize another person to opt-out on your behalf, for profiling in furtherance of decisions that produce legal or similarly significant effects;
- Correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information; and
- Appeal our refusal to honor your
exercise of these rights within a reasonable time.
The
parents or guardians of residents of Virginia, and the parents or guardians of
Colorado residents under the age of thirteen (13), may exercise the above
rights on behalf of the resident.
If you
are a resident of the above states, you may exercise your privacy rights by
following the procedures set forth in <<Exercising Your
Privacy Rights>>, <<To Exercise Your Right to
Opt-Out>>, and <<Appeal Process>>.
For
more information about your state privacy rights, see:
The
Colorado Privacy Act (CPA) (Colo. Rev. Stat. Ann. § 6-1-1306) (effective July
1, 2023)
The
Connecticut Act Concerning Personal Data Privacy and Online Monitoring (CTDPA)
(Section 6(c)-(e), Session Law 22-15 (effective July 1, 2023))
The Utah
Consumer Privacy Act (UCPA) (Utah Code § 13-61-201) (effective December
31, 2023)
The
Virginia Consumer Data Privacy Act (VCDPA) (Va. Code Ann. § 59.1-577)
Your
Nevada Privacy Rights
Under
NRS 603A.340, Nevada provides its residents with a limited right to opt-out of
certain personal information sales, including personal information such as your
first and last name, postal address, email address, telephone number, SSN, an
identifier that allows you to be contacted either physically or online, or any
other information about you that, in combination with an identifier, makes the
information personally identifiable. Nevada residents who wish to exercise this
sale opt-out right may submit a request by using the information provided in
the <<Contact Us>> section below. However,
please know we do not currently sell data triggering that statute’s opt-out
requirements.
Your
California Privacy Rights
To the
extent provided for by law and subject to applicable exemptions, you have the
following rights in relation to the personal information about you that we have
collected:
Right
to Access: You have the right to request disclosure of the personal information
listed concerning your Right to Know.
Right
to Correct: You have the right to request that we correct inaccurate personal
information. In considering this request, we take into account the nature of
the personal information and the purposes of the processing of the personal
information. We will use commercially reasonable efforts to correct the
inaccurate personal information as you have requested.
Right to Delete: You have the right to request that we delete your personal information. Subject to certain exceptions, we will endeavour to delete your personal information and direct any service provider to delete your personal information. Once we receive your request and confirm your identity (see <<Exercising Your Privacy Rights>>), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful
uses of that information that are compatible with the context in which
you provided it.
We
will delete or de-identify personal information not subject to one of these
exceptions from our records and will direct our service providers to take
similar action. We do not provide these deletion rights for
business-to-business (B2B) personal information, unless otherwise required to
do so by applicable law.
If you
would like to exercise your right to deletion, you can call, email or write us
as set out in the <<Contact Us>> section.
Right to Know Personal Information Shared and To Whom: For the prior 12 months, you have the right to request disclosure of:
- The categories of personal information that we collected about the you;
- The categories of personal information that we sold or shared about you;
- The categories of third parties to whom the personal information was sold or shared, by category of personal information for each category of third parties to whom the personal information was sold or shared; and
- The categories of personal
information that we disclosed about you for a business purpose and the
categories of persons to whom it was disclosed for a business purpose.
You
may make up to two (2) requests to know within a 12-month period. If you would
like to exercise your rights, you can call, email, or write us as set out in
the <<Contact Us>> section.
Right
to Opt-Out: You have the right to direct us not to sell or share your personal
information (see <<To Exercise Your Right to Opt-Out>>).
However, we do not sell your personal information.
Right
to Opt-In: If you are between the ages of 13 and 16 years of age, you have the
right to opt in, or to have a parent or guardian opt in on your behalf, to the
selling and sharing of your personal information (see <<To
Exercise Your Right to Opt-In>>).
If you
have exercised your right to opt-out of the sharing of your Personal
Information, you have the right to opt-in to the sharing of your personal
information, see <<To Exercise Your Right to Opt-In>>.
Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of the rights described above. In response to you exercising these rights, we will not:
- Deny you services;
- Charge you higher prices or rates for services because of exercising your consumer rights; to your data, including through granting discounts or other benefits, or imposing penalties
- Provide you a different level or quality of services; or
- Suggest that you may receive a
different price or rate for services or a different level or quality of
services.
However,
we may offer you certain financial incentives permitted by law that can result
in different prices, rates, or quality levels (see <<Notice of
Financial Incentives>>). Any legally-permitted financial
incentive we offer will reasonably relate to your personal information’s value
and contain written terms that describe the program’s material aspects.
Participation in a financial incentive program requires your prior opt-in
consent, which you may revoke at any time. We do not currently provide any such
incentives.
California
“Shine the Light”
In
addition to the rights described above, California’s “Shine the Light” law
permits California residents to request certain information regarding our
disclosure, if any, of certain categories of personal information to third
parties for their direct marketing purposes during the immediately preceding
calendar year. To make such a request, please contact us as set out in
the <<Contact Us>> section, Attn:
California Shine the Light Inquiry. This request may be made no more than once
per calendar year.
Exercising
Your Privacy Rights
Verification: Only you, or someone legally authorized to act on your behalf, may make a request to exercise your privacy rights. We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require you to login to your account or we must be able to match certain information you provide us to the information we maintain about you. Your 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 of such person; and
- Describe your request with
sufficient detail that allows us to properly understand, evaluate, and
respond to it.
Certain
requests may require us to obtain additional personal information from you. 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. We will only use personal information
provided in the request to verify the requestor’s identity or authority to make
the request.
Authorized
Agents: You can empower an “authorized agent” to submit requests on your
behalf. We will require the authorized agent to have a written authorization
confirming their authority pursuant to the relevant legal regulations.
Method: To
exercise any of your state privacy rights, including the rights to know, access, correct, delete,
or obtain your personal information, please email or write to
us as provided in the <<Contact Us>> section
below.
To
Exercise Your Right to Opt-In
You
can opt-in to the selling or sharing of your personal information by clicking:
<<opt-in
to SELLING OR SHARING my personal information >>
or by
contacting us via the information in the <<Contact Us>> section
of this Privacy Policy.
To
Exercise Your Right to Opt-Out
You
can opt-out of the selling or sharing of your personal information by clicking:
<<Do
Not SELL OR share My Personal Information>>
or by
contacting us via the information in the <<Contact Us>> section
of this Privacy Policy. You may also exercise your opt-out rights by managing
your preferences, as set out in the <<Cookie Policy>>.
Please note that there are some categories of personal information that are
required and that may not be subject to the opt-out rights, such as personal
information needed to complete a transaction you requested. This is disclosed
further in the <<Your State Privacy Rights>> section.
Opting-Out
of Non-Essential Email or Text Communications
If you
do not wish to receive email or text communications from us, you may opt-out of
receiving such communications by emailing or writing to us as provided in
the <<Contact Us>> section below. You may
also reply to the email or text in question and request that you receive no
further correspondence from us. You may follow this same procedure to change or
update information you have previously provided to us.
Your
election not to receive promotional and marketing correspondence from us will
not (a) preclude us from corresponding with you, by email, text or otherwise,
regarding your existing or past relationship with us, nor (b) preclude us, including
our employees, contractors, agents and other representatives, from accessing
and viewing your personal information while maintaining and improving the
Website.
Response
Timing and Format
We
endeavor to substantively respond to a verifiable consumer request within
forty-five (45) days of its receipt. If we require more time (up to another 45
days), we will inform you of the reason and extension period in writing prior
to the expiration of the original 45 days.
We
will deliver our written response electronically to the email address we have
on file for you, regardless of the email address from which you submitted the
request.
Any
disclosures we provide will only cover the twelve- (12) month period preceding
our receipt of your request. The response we provide will also explain the
reasons we cannot comply with a request, if applicable. For data portability
requests, we will select a format to provide your personal information that is
readily useable and should allow you to transmit the information from one
entity to another entity.
We do
not charge a fee to process or respond to your verifiable consumer request
unless it is excessive, repetitive, or manifestly unfounded. If we determine
that the request warrants a fee, we will tell you why we made that decision and
provide you with a cost estimate before completing your request.
Requests
Submitted by Authorized Agents
In certain circumstances, you are permitted to use an authorized agent, as that term is defined by applicable state privacy law, including, but not limited to, the California Consumer Privacy Act, the California Privacy Rights, the Colorado Privacy Act, or the Connecticut Act Concerning Personal Data Privacy and Online Monitoring Act (“Authorized Agent”), to submit requests on your behalf where you provide sufficient evidence that the requestor is an authorized agent with written permission to act on your behalf and you successfully verify your own identity with us. An Authorized Agent can make a request on the subject consumer’s behalf by:
- For requests to know and delete:
(1) providing a valid power of attorney under the laws of the subject
individual’s state of residence; or (2) providing sufficient evidence to
show that the subject consumer has (i) provided the Authorized Agent signed
permission to act on their behalf, (ii) verified their own identity
directly with us, and (iii) directly confirmed with us that they have
provided the Authorized Agent permission to submit the request on their
behalf; and
- For requests to opt-out: submitting
a signed permission demonstrating that the Authorized Agent has been
authorized by the subject consumer to act on their behalf.
Appeal
Process
If we
refuse to take action upon your request to exercise any of your state privacy
rights, you may appeal our decision within a reasonable period after you
receive notice of our decision. To initiate an appeal, please contact us using
the information in the <<Contact Us>> section
and inform us that you would like to appeal our decision. Within forty-five (45)
days after we receive your appeal, we will inform you of any action taken or
not taken in response to your appeal, and we will provide you with a written
explanation of the reasons in support of our response.
If
your appeal is denied, we will also provide you with an online mechanism, if
available, or other method through which you may contact your state attorney
general to submit a complaint, should you wish to do so.
Notice
of Financial Incentives
From
the time to time, we may run sweepstakes, contests, or other offers and
promotions (collectively, “Programs”) that may be deemed “financial incentives”
in relation to our collection of personal information under applicable U.S.
privacy laws. A business may offer financial incentives for the collection, sale
or deletion of personal information, provided it is not unjust, unreasonable,
coercive or usurious, and is made available in compliance with applicable
transparency, informed consent, and opt-out requirements. We may run
sweepstakes or contests from time to time. Please refer to the terms and
conditions of each Program for additional information about the Program,
including how eligible consumers can opt-in or opt-out of the Program at any
time. In order to enter a Program, you may be required to provide us or a
service provider acting on our behalf with certain personal information, such
as identifiers including your name and contact information (“Rewards Data”). If
you submit your entry in accordance with the applicable Program’s rules, you
may be entered into the Program and will get a chance to win a prize or receive
another benefit from us. The value of Rewards Data is related to the value of
your information and the costs associated with offering the Program.
“Do-Not-Track”
Signals
Some
web browsers may transmit “do-not-track” signals to Website with which the user
communicates. The Website does not monitor or identify “do not track signals”
from your computer, and such signals will not impact the operation of this
Website. If you wish to ensure that you are not being tracked while you use the
Website, please see the <<Choices About How We Use and
Disclose Your Information>> and <<To
Exercise Your Right to Opt-Out>> sections of this Privacy
Policy.
Data
Security
We
protect the personal information we may collect from the Website by using
industry standard security precautions against loss and unauthorized access,
destruction, use, modification or disclosure of that information. We comply
with the security safeguards detailed in our computer security policies and
procedures, and routinely monitor that compliance. When credit card or other
financial information is transmitted over the Internet we use industry standard
SSL (secure socket layer) encryption to protect that information.
You
also share certain responsibilities to ensure the safety and security of your
information. Where we have given you (or where you have chosen) a password for
access to certain parts of our Website, you are responsible for keeping this
password confidential. We ask you not to share your password with anyone. If
you have an account with us and have reason to believe your password has been
obtained by a third party without your consent, please reset your password in
your account settings and/or the device(s) you use to access the Website. You
may also contact us immediately through the contact information in the <<Contact
Us>> section to inform us of this issue.
Unfortunately,
the transmission of information via the internet is not completely secure.
Although we do our best to protect your personal information, we cannot
guarantee the security of your personal information transmitted to our Website.
Any transmission of personal information is at your own risk. We are not
responsible for circumvention of any privacy settings or security measures
contained on the Website.
Changes
to Our Privacy Policy
We may
revise this Privacy Policy from time to time as we add new features or as laws
change that may affect our Website or Services. If we make material changes to
this Privacy Policy, we will post a new version number at the beginning of this
Privacy Policy, including the date (year and month) the Policy was last
revised. You are responsible for periodically visiting our Website and this
Privacy Policy to check for any changes.
Contact
Information
If you
have any questions, concerns, or comments about this Privacy Policy, or to
exercise any of your state privacy rights, contact us at:
Compliance
Officer
1573
Mallory Lane, Suite 200
Brentwood,
TN 37027
Phone:
615-371-7979
Email: info@northstarhealthalliance.com