FreedomCare Privacy Policy
Effective Date: [09-24-2024]
Effective Date: [09-24-2024]
Freedom Care LLC (“FreedomCare”, “us”, “we”, or “our”) is committed to respecting your privacy and protecting your personal data. FreedomCare is a healthcare company that is innovating and revolutionizing the way home care is delivered. We bring dignity and support to patients needing care in their homes and to the caregivers who care for them.
This Privacy Policy explains the types of personal data we may collect from visitors to and users of our websites, including www.freedomcare.com and all related websites (the “Sites”), FreedomCare mobile applications such as the FreedomCare App (the “Apps”), and web-based services (collectively with Sites and Apps, our “Services”), including our employees and prospective employees. This Privacy Policy also describes how we use personal data, the purpose for sharing and recipients of personal data, and your available choices associated with that information.
We may collect or receive certain personal data and other data about you that is governed by federal law, such as the Health Insurance Portability and Accountability Act (“HIPAA”). Please review our Notice of Privacy Practices, which governs our use, disclosure and access to information protected by HIPAA. This Privacy Policy does not apply to information about how we handle HIPAA-regulated personal health information (“PHI”).
This Privacy Policy also does not apply to third-party websites, mobile applications, products, or services, even if they may link to our Services or our Services may link to them. We recommend you review the privacy practices of those third parties before accessing third party websites and sharing any personal data.
If you are a visually-impaired individual, an individual with another disability, or an individual seeking support in another language, you may access this Privacy Policy by emailing us [email protected].
For the purposes of this Privacy Policy, “personal data” means any information that relates to an identified or identifiable individual, and does not include PHI. The types of personal data we may collect will vary depending on how you interact with our Services. Personal data does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified, or aggregate consumer information. “Publicly available information” includes information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the individual; and information that is made available by a person to whom the individual has disclosed the information if the individual has not restricted the information to a specific audience.
For information on FreedomCare’s privacy practices specific to PHI, please see our Notice of Privacy Practices.
Personal data you provide to us.
We may collect the following personal data about you that you provide us when you use our Services, become a FreedomCare employee, or apply for employment with us, including:
Information that we automatically collect.
Our Services may use cookies and other tracking technologies such as web beacons, embedded scripts, and tags, which collect information from you automatically as you use our Services, including:
Information we collect from others.
We may collect personal data about you from the following entities or individuals:
Aggregated, anonymized, and deidentified information.
We may create aggregated, anonymous, or de-identified data from personal data by removing data components that make the data personally identifiable to you or through obfuscation or other means. Our use of aggregated, anonymized and de-identified data is not subject to this Privacy Policy and may be further controlled by federal health privacy law, as described in our Notice of Privacy Practices.
We use cookies and similar tracking technologies to track the activity on the Service and we hold certain information. Cookies are files with a small amount of data which may include unique identifier. Cookies are sent to your browser from a website and stored on your device. We also use other tracking technologies, such as beacons, tags and scripts to collect and track information and to improve and analyze our Services.
Examples of cookies we use:
You can modify your browser settings to decline or accept cookies. Please note that if you decline cookies, some of our Sites’ features may not function as designed.
Analytics information. We may use Google Analytics or other service providers for analytics services. These analytics services may use cookies to help us analyze how users use the Service. Information generated by these services (e.g., your IP address and other usage information) may be transmitted to and stored by Google Analytics and other service providers on servers in the U.S. (or elsewhere) and these service providers may use this information for purposes such as evaluating your use of the Services, compiling statistic reports on the Service’s activity, and providing other services relating to Services activity and other Internet usage. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.
Third-Party Ad Networks. Certain companies may participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for Interest-based Ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com and its opt-out program for mobile apps at http://www.aboutads.info/appchoices.
In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt out of certain Interest-based Ads delivered by NAI members’ ad networks. To learn more about opting out of such targeted advertising or to use the NAI tool, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Ads, you will continue to receive non-targeted ads. Opting out of one or more NAI or DAA members only means that those selected members should no longer under the NAI/DAA rules deliver certain targeted ads to you. This will affect this and other services, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different device or web browser(s), or use a non-browser-based method of access (e.g., mobile app), your NAI/DAA browser-based opt-out may not, or may no longer, be effective. Mobile device opt-outs will not affect browser-based Interest-based Ads even on the same device, and you must opt-out separately for each device.
We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. Please note that opting out of advertising networks does not necessarily mean that you will not receive advertisements while using our Sites or on other websites.
We do not support Do Not Track functionality. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
We will retain your personal data for as long as necessary for the purposes outlined in this Privacy Policy. This information will be used and retained to the extent necessary to comply with any legal obligations or policies, to resolve disputes, and/or enforce legal agreements. Personal data may also be retained for internal analytic purposes. This information is retained for a shorter period of time, unless it used to enhance security features or improve the functionality of our Services. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you (such as whether you are a current employee or contractor) (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position, including regard to applicable statutes of limitations, litigation or regulatory investigations.
We recognize the importance of protecting the privacy of children’s personal data. You must be at least 18 years old or older to register or use our Sites, including our account features. The Sites are intended for a general audience and we do not knowingly collect personal data from children under age 18 through the Sites. If you are aware that a child under age 18 has provided us with personal data without parental consent, please Contact Us. If we become aware that we have collected personal data from children under age 18 without verification of parental consent, we will take steps to remove that information from our servers.
Although we do not “sell” personal information as defined by Nevada law, Nevada residents nonetheless have the right to request to opt out of the future “sale” of their personal information under Nevada SB 220. If you are a Nevada resident and would like to make such a request, please Contact Us. You must include your full name, email address, and postal address in your request so that we can verify your Nevada residence and respond. In the event we sell your personal information after the receipt of your request, we will make reasonable efforts to comply with such request.
Nevada SB 370 provides Nevada residents with rights to receive certain disclosures and access regarding the collection, use, sale, and sharing of consumer health data, as defined below. For information regarding the consumer health data that we collect, how we use it, what sources it is derived from, to whom we disclose it, as well as the rights of Nevada residents and our responsibilities under SB 370, please see our Consumer Health Data Privacy Notice.
This Notice applies to residents of Colorado, Connecticut, or, Oregon. The provisions contained within this section, in addition to the disclosures throughout the rest of this Privacy Policy, are intended to provide notices in compliance with the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), and the Oregon Consumer Data Privacy Act (“OCDPA”). This section does not apply to certain personal data that is collected from an individual in a business-to-business or employment context, or to information that is that is governed by federal law, such as HIPAA.
A. Our Data Practices
Applicable law provides residents of Colorado, Connecticut, and Oregon rights to receive certain disclosures and access regarding collection, use, sale, and sharing of personal data. The chart below is designed to help connect the dots of how and why we may use different types of personal information.
Category of Personal Information | Processing Purpose(s) | Categories of Third Party Recipients |
---|---|---|
Identifiers, for example:
|
|
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Internet or other electronic network information, for example:
|
|
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Sensitive data, including:
|
|
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Inferences based on the above information |
|
|
We limit our disclosure of the categories of data above to our service providers for one or more business purposes. “Business purposes” means the reasonably necessary and proportionate use of personal data, in a way that is adequate, relevant, and necessary for specific purposes described in this Privacy Policy, compatible with the nature and purpose(s) for the collection, use, and retention of the personal data.
We “sell” or “share” personal data for targeted advertising purposes as those terms are defined under applicable law. You may opt-out of such sharing by following the instructions provided below in How to Exercise Your Rights.
B. Your Privacy Rights
If you are resident of Colorado, Connecticut, or Oregon, you may have the following rights under applicable law in relation to your personal data, subject to certain exceptions.
C. How to Exercise Your Rights.
If you are a U.S. resident and wish to exercise any of the rights described in this section by emailing us at [email protected]. If you are a visually-impaired customer, a customer who has another disability or a customer who seek support in other language, you may access your state-specific privacy rights by emailing us at [email protected].
Except where otherwise noted, we will respond to your request within forty-five (45) days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. As described below, in some states an authorized agent may submit a request to exercise your rights on your behalf.
We do not charge a fee to process or respond to your verifiable consumer request unless its excessive, repetitive, manifestly unfounded, or in accordance with state-specific requirements. 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. You may only make a verifiable or authenticated consumer request twice within a twelve (12) month period. If we have collected information on your minor child, you may exercise the above rights on behalf of your minor child. Additionally, under some state privacy laws, you may designate an authorized agent to submit a request on your behalf. The request must include:
Any request you submit to us is subject to an identification and residency authentication process, as permitted by applicable law. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably authenticate that you are the consumer about whom we collected the personal information. In order to authenticate you, you must provide us with your first and last name and email address. These rights are also subject to various exclusions and exceptions under applicable laws.
Making a verifiable or authenticated consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable or authenticated consumer request to verify the requestor’s identity or authority to make the request. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
D. How to appeal decisions about your rights.
You can appeal our decisions concerning privacy rights requests, as follows:
E. Additional Notice to Connecticut Residents about Consumer Health Data
The CTDPA provides Connecticut residents with rights to receive certain disclosures and access regarding the collection, use, sale, and sharing of consumer health data, as defined below. For information regarding the consumer health data that we collect, how we use it, what sources it is derived from, to whom we disclose it, as well as the rights of Nevada residents and our responsibilities under SB 370, please see our Consumer Health Data Privacy Notice.