Privacy Policy

Privacy Policy Effective as of February 5, 2020

PLEASE READ THIS PRIVACY POLICY AND THE RELATED TERMS OF SERVICE CAREFULLY BEFORE USING THIS WEBSITE.

User Agreement

This “Site” (as defined herein) is operated by Commonwealth Alternative Care Inc. on its own behalf or in combination with one of its affiliates (collectively referred to herein, solely for ease of reference, as “CAC”, “us” or “we”). This privacy policy (“Privacy Policy”) applies to your use of our website located at https://www.commonwealthaltcare.org and any other online and mobile websites, blogs and interactive applications operated by CAC that are related to https://www.commonwealthaltcare.org (collectively, the “Site”) (unless a different policy is provided on a particular site or application, in which case such different policy shall govern and control). This Privacy Policy discloses what type of information is collected, the methods used to collect it, how CAC utilizes the information to better serve all interested parties and the choices you have about the way your information is collected and used. Please read this Privacy Policy carefully. Your use of the Site indicates that you have read, accepted and unconditionally agreed to the CAC privacy practices, as outlined in this Privacy Policy and any other applicable terms. The Terms of Service for this Site, located at https://www.commonwealthaltcare.org, are incorporated herein by this reference. For purposes of this Privacy Policy, personally identifiable information (“PII”) is personal information about an individual, such as a first and last name, phone number, email address or other individually identifiable information within the meaning of the Federal Trade Commission’s Online Privacy Protection Rule found at 16 CFR 312.2. Every user hereby agrees that all information you provide, including but not limited to age, shall be truthful and correct.

Information We Collect

CAC strives to provide our visitors with information relevant to their particular desires, needs and/or interests. The information we gather helps us to better serve our purpose. CAC collects personally identifiable information, such as your email address, name, home or work address or telephone number. CAC also collects anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, and preferences. Providing us with PII about yourself is voluntary, and you can always choose not to provide certain information, but then you may not be able to take advantage of or participate in some of the Site’s features. CAC actively and passively gathers, analyzes and/or stores PII and other information generally by way of a few different sources: (1) the PII voluntarily submitted by visitors when using or registering to use or receive our services or offers, or when submitted to us via our contact form; and (2) by tracking and analyzing online and mobile data and activity through mechanisms that identify site usage, user location, device type, browser types, IP addresses, and other data. We do not collect PII through advertisements on our Site, and the PII we collect is not shared with third parties except as set forth herein. We will make reasonable efforts to destroy, erase or make anonymous any PII that is no longer required to fulfill the original purpose for which it was originally collected.

Usage Information

When your computer or mobile device contacts our web servers (for example, when you visit this Site, or view an HTML email), our web servers automatically collect usage information. Such usage information includes information about how our visitors use and navigate our Site. It can include the number and frequency of visitors to each web page and the length of their stays, browser type, location, device type, referrer data that identifies the web page visited prior and subsequent to visiting our Site, and IP addresses (see below for more information on IP addresses). We also may determine the applicable technology available in order to serve you the most appropriate version of a web page, email, advertising or promotional announcement or similar service. This information is used by CAC for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Site.

Browser Cookies

Like many websites, we may use browser “cookies.” Cookies are a website’s way of remembering who you are and help you personalize your online experience. One of the primary purposes of cookies is to provide a convenience feature to save you time. A cookie is a small text file that is stored on your computer’s hard drive or stored temporarily in your computer’s memory. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. Cookies cannot be used to run programs or deliver viruses to your computer. There are two kinds of cookies: those that are “session” oriented and those that are “persistent.” Session cookies are deleted from your computer when you close your browser. Persistent cookies retain information for later use tomorrow, next week, next month, or whenever they are set to expire. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. We use cookies to help us to identify account holders and to optimize their experience on our Site. Also, we will use cookies to monitor and maintain information about your use of this Site. Most web browsers accept cookies automatically. You can delete cookies manually or set your browser to automatically delete cookies on a predetermined schedule. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Site.

Use of IP Addresses

An IP address is a number that is assigned to your computer, device or network when you are linked to the Internet. When you request pages from this Site, our servers log your IP address. We may use IP address for a number of purposes, such as system administration, to report aggregate information to our business partners or to audit the use of the Site. We may associate your IP address with the PII you provide. We also may collect and store information about you that we receive from other sources to enable us to update and correct the information contained in our database and to provide product recommendations and special offers that we think will interest you.

Sensitive Information

CAC secures the PII you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. No website, Internet transmission, computer system or wireless connection is completely secure, however. CAC cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Your use of the Site is at your own risk. Whenever you give CAC sensitive or confidential information, CAC will take commercially reasonable steps to protect the information by establishing a secure connection with your web browser. CAC uses an industry standard security protocol for encrypting sensitive information. When personal information is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. Unfortunately, no security measures are perfect or impenetrable, and data transmission over the Internet cannot be guaranteed 100% secure. We cannot and do not ensure or warrant the security of any information you transmit to CAC, and you do so at your own risk.

External Links

CAC may contain links to, or advertisements about, non-CAC websites. Other sites may also reference, advertise, or link to CAC Sites. CAC does not endorse or sponsor other websites, is not responsible for the privacy practices or the content of non-CAC sites, expressly disclaims any statements or assertions made on such websites, and denies all liability associated with your use of, and the content on, such other websites and advertisements. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through other websites. We encourage you to be aware of when you leave this Site and to read the privacy policies of each and every website that you visit.

Consent to Processing

By using our Site, participating in any of our services and/or providing us with your information, you consent and agree to the collection, transfer, storage and processing of your information to and in the United States. You understand that the technical processing and transmission of this Site may involve (a) transmissions over various networks; and (b) changes to conform and adapt to technical requirements of connecting networks or devices.

Children

We recognize the importance of safeguarding the privacy of children and encourage parents to check and monitor their children’s use of online activities regularly. The Site supports and complies with the Children’s Online Privacy Protection Act (“COPPA”) and other applicable laws. The Site is not aimed at nor intended for children under the age of 18. If you are under the age of 18, please do not use the Site. If CAC discovers that a person under the age of 18 has provided CAC with any PII, CAC will use commercially reasonable efforts to delete such person’s PII from its system.

Sharing Information

CAC does not sell, rent or lease its customer lists to third parties. If you opt in to receive communications from a third party, your information will be subject to the third party's privacy policy and not this Privacy Policy. Therefore, if you later decide that you do not want that third party to use your information, you will need to contact the third party directly. In addition, CAC may share your information with third parties under the following circumstances:

Third parties providing services on our behalf: We may engage third parties to perform services in connection with the operation of our business. Examples of these services include: (a) content providers; (b) product customization, (c) marketing and promotional material distribution, (d) website evaluation, (e) data collection, storage, management, analysis and, where applicable, cleansing, and (f) any other services designed to assist us in maximizing our business potential. These third parties may have access to this Site’s user information, including PII, to the extent it is needed to perform their duties and functions.
CAC Security: We may release information about our users, including PII, without notice when legally required to do so, at the request of governmental authorities conducting an investigation or to verify or enforce compliance with the policies governing our Site and applicable laws. We may also disclose such user information whenever we believe disclosure is necessary to protect the rights, property or safety of CAC or any of our respective affiliates, business partners, customers or others.
Aggregate Information: We may disclose non-identifying, aggregated user statistics to third parties for a variety of purposes, including describing our services to prospective partners and other third parties. Examples of such non-personal information include the number of users who visited this Site during a specific time period or viewed a specific product through this Site.

Corporate Change

In addition, we reserve the right to disclose, share and/or otherwise transfer user information, including without limitation PII, in connection with a corporate merger, acquisition, consolidation, the sale of a portion of our business or the sale of substantially all of CAC’s assets, or other fundamental corporate change, whatever form it may take. You will be notified via email or prominent notice on our Site prior to a change of ownership or control of your personal information, if your personal information will be used contrary to this policy. For clarification and the removal of doubt, CAC specifically reserves the right to transfer or share a copy of PII collected pursuant to this Privacy Policy from this Site, off-line or otherwise, to the buyer of that portion of its business relating to that information.

Third Party Advertisements

We may from time to time use various outside ad-serving or other companies to serve advertisements and/or collect certain anonymous information when you visit our Site. These companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use a cookie or third party web beacon to collect this information. Our Site does not recognize browser “Do Not Track” signals, but several of our service providers who utilize these cookies or beacons on our web sites enable you to opt out of this behavioral advertising. This web usage information may be combined with other ad delivery information the ad-server has collected from your visits to our Site and other websites not affiliated with CAC. This non-personally identifiable information is used as part of the ad-serving process for reporting, and to select and direct the ads you see on our Site and on other websites not affiliated with us. To learn more about how to opt out of the behavioral advertising conducted by these providers, you can visit http://www.networkadvertising.org/.

How Can I Access, Correct and Update Personal Information?

You can access, correct and update certain personal information that you have provided to us, if any, by emailing us via the “Contact Us” link in the Site menu: https://www.commonwealthaltcare.org/contact. Please be aware that we will process your request as quickly as we reasonably can, but it may not be possible to update our systems immediately. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons.

Your Choices/Unsubscribe

You will have an opportunity to unsubscribe from receiving promotional/loyalty program material from this Site by clicking on an “unsubscribe” hyperlink contained in promotional/loyalty program emails we send you. Additionally, you may email us via the “Contact Us” link in the Site menu: https://www.commonwealthaltcare.org/contact. Because customer lists often are prepared well in advance of an offering (sometimes a few months before the offer is made), you may continue to receive some offers after you send us a request not to use your information for specified marketing purposes. Please be aware that we will process your request as quickly as we reasonably can, but it may not be possible to update our systems immediately. We appreciate your patience and understanding in giving us time to meet your request. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons.

Revisions to Privacy Policy

We reserve the right, in our sole discretion, to modify, update, add to, discontinue, remove or otherwise change any portion of this Privacy Policy, in whole or in part, at any time. When we amend this Privacy Policy, we will revise the “last updated” date located at the top of this Privacy Policy. For changes to this Privacy Policy that we consider to be material, we will prominently display on the Site homepage notice of the “Updated Privacy Policy.” If you provide information to us or access or use the Site in any way after this Privacy Policy has been changed, you will be deemed to have unconditionally consented and agreed to such changes. The most current version of this Privacy Policy will be available on the Site and will supersede all previous versions of this Privacy Policy. CAC encourages you to periodically review this Privacy Policy to be informed of how CAC is protecting your information.

Choice of Law

This Privacy Policy, including all revisions and amendments thereto, is governed by the internal laws of the United States, Commonwealth of Massachusetts, without regard to its conflicts or choice of law principles which would require application of the laws of another jurisdiction.

Arbitration

By using this Site in any way, you unconditionally consent and agree that: (1) any claim, dispute, or controversy (whether in contract, tort, or otherwise) you may have against the officers, directors and employees of CAC and its parents, subsidiaries, affiliates (all such individuals and entities collectively referred to herein as the “CAC Entities”) arising out of, relating to, or connected in any way with the Site or the determination of the scope or applicability of this agreement to arbitrate, will be resolved exclusively by final and binding arbitration administered by JAMS and conducted before a sole arbitrator in accordance with the rules of JAMS; (2) this arbitration agreement is made pursuant to a transaction involving interstate commerce, and shall be governed by the Federal Arbitration Act (“FAA”), 9 U.S.C. §§ 1-16; (3) the arbitration shall be held in Massachusetts; (4) the arbitrator’s decision shall be controlled by the terms and conditions of this Privacy Policy and any of the other agreements referenced herein that the applicable user may have entered into in connection with the Site; (5) the arbitrator shall apply Massachusetts law consistent with the FAA and applicable statutes of limitations, and shall honor claims of privilege recognized at law; (6) there shall be no authority for any claims to be arbitrated on a class or representative basis, arbitration can decide only your and/or the applicable CAC Entity’s individual claims; the arbitrator may not consolidate or join the claims of other persons or parties who may be similarly situated; (7) the arbitrator shall not have the power to award punitive damages against you or any CAC Entity; (8) in the event that the administrative fees and deposits that must be paid to initiate arbitration against any CAC Entity exceed $125 USD, and you are unable (or not required under the rules of JAMS) to pay any fees and deposits that exceed this amount, CAC agrees to pay them and/or forward them on your behalf, subject to ultimate allocation by the arbitrator. In addition, if you are able to demonstrate that the costs of arbitration will be prohibitive as compared to the costs of litigation, CAC will pay as much of your filing and hearing fees in connection with the arbitration as the arbitrator deems necessary to prevent the arbitration from being cost-prohibitive; and (9) with the exception of subpart (6) above, if any part of this arbitration provision is deemed to be invalid, unenforceable or illegal, or otherwise conflicts with the rules of JAMS, then the balance of this arbitration provision shall remain in effect and shall be construed in accordance with its terms as if the invalid, unenforceable, illegal or conflicting provision were not contained herein. If, however, subpart (6) is found to be invalid, unenforceable or illegal, then the entirety of this arbitration provision shall be null and void, and neither you nor CAC shall be entitled to arbitrate their dispute. For more information on JAMS and/or the rules of JAMS, visit their website at www.jamsadr.com.