Last updated: January 28, 2022
“HIPAA” means Health Insurance Portability and Accountability Act of 1996, the Health Information Technology for Economic and Clinical Health Act and their implementing regulations as amended from time to time. “Protected Health Information” is individually identifiable health information that is protected by HIPAA and that we receive on behalf of Covered Entities. “Covered Entity” refers to a health plan, healthcare provider or other entity subject to HIPAA.
Information You Provide to Us. We collect information you provide to us through the Services and offline, for example when you create or modify your account, register to use our Services, purchase
products or services from us, request information from us, contact customer support, fill out any form on a Site, or otherwise communicate with us. This information may include:
Information We Collect Automatically. Whenever you interact with our Services, we automatically receive and record information from your browser or device using cookies or similar technologies. This information may include your IP address, geolocation data, device identification, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. To learn more about the cookies and other technologies we use, please see our Statement on Cookies and Similar Technologies below.
The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Services and to deliver a better and more personalized service, including by enabling us to:
We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of a Service, and we can use that knowledge to make the Services more helpful to as many users as possible.
To Provide Services and Information. We use your information to:
Vendors and Service Providers. We may provide information to third-party vendors and service providers that help us operate and manage our Services and deliver products and Services that you purchase through us. These vendors and service providers will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service.
Third-Party Analytics. We use selected third parties to collect data about how you interact with the Services. This information may be used to, among other things, improve the functionality of our Services.
Legal Proceedings. We will share personal information with third party companies, organizations or individuals if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
Web Beacons. A web beacon (also referred to as clear gif, pixel tag or single-pixel gif) is a transparent graphic image used in tandem with cookies that enables us to record a user’s actions. We use web beacons to count users who have visited those pages, verify system and server integrity and for similar statistical measures.
You can set your Internet browser settings to stop accepting new cookies, to receive notice when you receive a new cookie, to disable existing cookies, and to omit images (which will disable pixel tags). Note that the opt-out will apply only to the browser that you are using when you elect to opt out of advertising cookies. Please note, without cookies or pixel tags, you may not be able to take full advantage of all features of our Services.
Some web browsers incorporate a “Do Not Track” feature (“DNT”) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including our Services, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit allaboutdnt.com.
Text Messages and SMS. TurningPoint and those acting on our behalf may send you text (SMS) messages at the phone number you provide us. These messages may include operational messages about your use of the Services, as well as marketing messages. You understand that by providing your mobile phone number, you expressly consent to receive automated text messages from us to the mobile phone number you provide. Consent to receiving text messages is not required in order to be a user. Message and data rates may apply, and you should check the rates of your mobile carrier. You can opt out of receiving text messages by texting STOP in response to any text message. We share your mobile phone number with service providers with whom we contract in order to send you automated text messages, but we will not share your mobile phone number with third parties for their own marketing purposes without your express consent.
As a general matter, we will keep your personal information for as long as necessary to fulfill the purpose for which it was collected. If a law requires us to retain your information for a longer period of time, we will comply with that law. We will also retain your personal information as necessary to protect our legal rights.
We maintain administrative, technical, and physical safeguards designed to protect against unauthorized access, use, modification, and disclosure of your information in our custody and control. No data, on the Internet or otherwise, can be guaranteed to be 100% secure. While we strive to protect your information from unauthorized access, use, or disclosure, we cannot and do not ensure or warrant the security of your information.
Certain California residents have additional privacy rights under the California Consumer Privacy Act (“CCPA”) and the Shine the Light law. To exercise your rights, you will need to follow the directions that are specific to each law.
California Consumer Privacy Act
Note that certain information, such as Protected Health Information and other medical information (as defined under the Confidentiality of Medical Information Act (“CMIA”)), is exempted from the CCPA. This means that we and certain service providers or other recipients may not be required to honor the rights described in this section and instead we comply with our obligations under other laws, such as HIPAA and CMIA.
The CCPA requires that we make certain disclosures about our general collection, use, and disclosure of personal information over the past 12 months. Accordingly, in the past 12 months:
With some exception, you may make a request to exercise the following rights with respect to the personal information we maintain about you:
If you exercise any of these rights, we will not discriminate against you in any way.
We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected personal information. If you have an account with us, we will use our existing account authentication practices to verify your identity. If you do not have an account with us, we may request additional information about you so that we can verify your identity.
You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your personal information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.
Shine the Light
TurningPoint does not share personal information for marketing purposes.