Last updated April 2023
- Summit County Public Health Values Your Privacy
MEDICAL DISCLAIMER: IF THIS IS A MEDICAL EMERGENCY, PLEASE IMMEDIATELY CALL EMERGENCY PERSONNELL (911) TO GET PROMPT MEDICAL ATTENTION. DO NOT RELY ON ELECTRONIC COMMUNICATIONS OR THIS WEBSITE FOR ASSISTANCE IN REGARD TO YOUR IMMEDIATE, URGENT MEDICAL NEEDS.
- Data Collection
General Information We Collect and How We Use It
We collect Visitor Information when you use our Site. Sometimes you may submit information to us yourself, other times it may be collected automatically. Our handling of your Visitor Information is generally limited to providing you with public-health related information and public-health related services and programs. You are not required to provide SCPH the personal data that we request, but if you choose not to do so, we may not be able to provide you with our services, or with a high quality of service, or respond to any inquiries you may have.
Information Collected When You Use Our Site
Your Visitor Information may be collected, used, and shared. As detailed below, the type of Visitor Information collected may vary based on how it was gathered, but may include, among other things, your name, email address, address, phone number, date of birth, employment history, account credentials, and other information that you voluntarily submit (e.g., when you submit information via our Careers in Public Health, Contact, requesting records or submitting general inquiries), information automatically collected about your usage of our Site that does not include personally identifiable information (e.g., the content that you choose to view and how you interact), and information about you that third parties may share with us if such third parties have previously received your consent to do so. In general, your personally identifiable Visitor Information means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. It does not include (i) publicly available information from government records; (ii) de-identified or aggregate information; or (iii) certain other personal data protected by other sector-specific state or federal laws.
Moreover, we automatically collect certain information when you visit, use or navigate the Site. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your Internet Protocol (IP) address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our and other technical information. This information is primarily needed to maintain the security and operation of our Site, and for our internal analytics and reporting purposes.
We may collect several categories of information from and about our membership applicants and/or users of our Site, including:
- Identity and Contact Information – We collect or use this information, including, but not limited to, your first name and last name, phone number, date of birth, account login credentials, address and email address.
- Payment Card Information – We may collect or use this information, including, but not limited to, your first and last name, billing address, and cardholder data.
- Technical Data and Unique Device Identifiers – We collect IP addresses, operating system information, links clicked, pages visited, browser type, time zone setting, browser plug-in types, and referring websites of visitors to our Site (when possible).
- Non-Identifying Information – We collect information that is about you but does not individually identify you, such as aggregate information about pages visited, length of time spent on our Site and its webpages, etc.
We collect your Visitor Information through various means, including through:
- Information submitted by you via use of our Site;
- Registration into our text-messaging services;
- General inquiries from our Contact webpage;
- Submission of requests for proposals;
- Requests for certain records;
- Applications submitted by you via our Careers in Public Health webpage;
- Social media plugins; and
- Web-tracking and website analytics technologies, such as cookies and web beacons.
SCPH may collect Visitor Information that is voluntarily provided by you or with your permission. For example, we may ask you for information, such as your name, e-mail address, and phone number when you contact us. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. You always have the option not to provide the information we request. If you choose not to provide the information we request, you can still visit the Site, but you may be required to provide your information by other means if we need such information to provide our services to you.
Occasionally, we may survey visitors to our Site. The information from these surveys is used in aggregate form to help us understand the needs of our visitors, so that we can improve our site. We generally do not ask for information in surveys that would personally identify you. If we do request contact information for follow-up, you may decline to provide it. If survey respondents provide personal information (such as an e-mail address) in a survey, it is shared only with those people who need to see it to respond to the question or request. We do not save this personal information for any other reason.
Payment Card Industry Data Security Standard (PCI-DSS)
We follow the Payment Card Industry Data Security Standard (PCI-DSS) when handling credit card data. SCPH currently accepts VISA, MasterCard, Discover, and American Express credit cards as authorized payment methods for certain services including but not limited to record requests. All payment transactions are processed by our third-party payment processor, ACI Worldwide, Inc., in adherence to PCI-DSS, and other applicable standards. SCPH at its sole election may discontinue support for any payment method or it may support additional payment methods (i.e., Apple Pay, Google Wallet or Amazon Payments).
Our web pages may contain electronic images known as web beacons (invisible images often referred to as pixel tags or clear GIFs) on the Site in order to recognize users, assess traffic patterns, identify preferred content, and measure Site engagement. We may also include web beacons in our e-mail messages in order to count how many e-mail messages have been opened, for example.
Some of these web beacons may also be placed by third-party service providers to help determine the effectiveness of advertising campaigns. These web beacons may be used by third-party service providers to place a persistent cookie on your computer. This allows the service provider to recognize your computer each time you visit certain web pages and compiles anonymous information in relation to those page views, which in turn enables us and our third-party service providers to learn which advertisements bring you to our website and how you use the Site.
Our servers log information about your IP address, your browser type, and the current URL you are requesting. This information is always provided by your browser and automatically logged. These log files are stored in a secure location and used in our internal analysis of traffic patterns.
Cookies and Similar Tools
Cookies fall into the subcategories below.
Essential Cookies. Certain cookies are used for specific purposes that are essential to your secure use and navigation of the Site. Without them, SCPH may not be able to provide core Site functions and features to you, and the Site would not operate as well as you or SCPH would like. These cookies collect and use information such as your server preferences, single-session data and corresponding identifier, web beacons and log files, and other credential-related information. Essential cookies also help inform SCPH whether you require, or have already been served, an affirmative consent request in connection with our data policies. Essential cookies also include analytics cookies, which provide us data that allows SCPH to better understand its users and improve the Site based on what we have learned from that data.
Preference Cookies. Other cookies are used to collect and process information about your preferences and similar choices in connection with the Site in order to optimize your browsing experience. Preference cookies include social media cookies, which collect information about your social media usage and other data you may have provided in connection with such usage (if you access the Site through a social media website or mobile application, you may have social media cookies). If you wish to modify or change your social media cookies, please visit the appropriate social media website and review the settings related to your applicable social media account(s).
- Data Usage
Use of Your Information
We collect, process and disclose your Visitor Information only for specific and limited purposes. For example, to respond to inquiries received from the use of any contact forms on the Site, to schedule appointments, to process employment applications, to develop and improve our services, communication methods and the functionality of our Site.
Our primary goal in collecting, using, and sharing Visitor Information is to provide our services to you, enhance your experience on the Site, support the Site, and improve its features, performance, and other elements. We will not use your Visitor Information without a valid legal basis to do so, and we will only process your Visitor Information in a way that is compatible with and relevant to the purpose for which it was collected and authorized.
Your Visitor Information may be used for the purposes outlined below.
To Facilitate and Improve Our Services
To respond to general inquiries and to provide customer support when needed, we collect or use the following information, including your first and last name, email address, phone number, address, date of birth and other voluntarily inputted information. To process your payments for physician services, we may collect cardholder information including first and last name, billing address, and cardholder numbers. Additionally, your Visitor Information may be used to present the Site and its content to you, request feedback, and for any other purpose with your consent.
To Provide Communications to You
From time to time, we may provide e-mails highlighting new features, promotions, or content on the Site to those users who have expressly provided us with their permission to send such communications. For instance, we may communicate with you by email in response to your inquiries or send you service-related announcements based on Visitor Information you provide to us. We may also use your Visitor Information to send you updates and other promotional communications with your consent. If you no longer wish to receive those email updates, you may opt-out at any time of receiving them by following the instructions included in each communication (usually in the form of an “unsubscribe” link), or email us at email@example.com to update your personal contact preferences. Note that unsubscribing from our emails will not prevent you from receiving transactional emails relating to support, or service requests.
As Necessary to Provide Information or Services
We may occasionally hire other companies to provide limited services on our behalf, such as handling the processing of information submitted on any contact or career/employment form on the Site, handling the processing of information submitted through the Patient Login Portal, handling the processing of information submitted on any form to schedule appointments, the delivery of any mailings or correspondence, processing transactions, or performing statistical analysis of our services. We provide those companies the information they need to deliver the service. In some instances, these companies may collect information directly from you and you will be notified of the involvement of the external service provider. Such companies are subject to agreements that require them to maintain the confidentiality of your information and they are prohibited from using that information for any other purpose. We reserve the right to not track how you interact with any of the provided services.
Sharing of Information
You may be requested to voluntarily provide certain Visitor Information during your use of our Site. If you choose to do so, that Visitor Information may be shared with SCPH and its affiliates as well as business partners and vendors providing hosting, other web-based services, or payment processing services for SCPH.
SCPH may use third parties to provide e-mail messaging, text messaging, account management and hosting services for the Site. When you sign up for services, we will share your Visitor Information as necessary for the third party to provide that service. These third parties are prohibited from using your Visitor Information for any other purpose. If you do not want your information to be shared, you can choose not to allow the transfer of your information by not using that particular service.
In the Event of Change in Ownership or Control
As Required By Law
SCPH may disclose your personal information if required to do so by law, such as to comply with a subpoena or in the good faith belief that such action is necessary to conform to the edicts of the law, investigate fraud or comply with a judicial proceeding, court order, or legal process served on SCPH, or to protect and defend the rights or property of SCPH.
Legal Bases for Data Usage
SCPH will not process your Visitor Information without a lawful basis to do so. In general, SCPH will process your Visitor Information on any of the following legal bases:
- Consent – We may process your data if you have given us specific consent to use your personal information for a specific purpose.
- Legitimate Interests – We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract – Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Legal Obligations – We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests – We may disclose your information where we believe the processing is necessary in order to protect your vital interests or those vital interests of another natural person.
More specifically, we may need to process your data or share your personal information in the following situations:
- Business Transfers – We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
When we collect and use your personal data for the purposes mentioned above or for other purposes, we will inform you before or at the time of collection. Where appropriate, we will ask for your consent to process your Visitor Information. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.
- Data Protection
How We Protect Your Information
SCPH takes the security of your Visitor Information very seriously. We take every effort to protect your personal information from misuse, interference, loss, unauthorized access, modification or disclosure. Our measures include adhering to data security standards, including but not limited to the Payment Card Industry Data Security Standard, implementing appropriate access controls, investing in the latest information security capabilities to protect the IT environments we leverage, and ensuring we encrypt and anonymize personal data wherever possible. Access to your Visitor Information is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third parties.
Your information may be stored on servers owned and operated by SCPH and its affiliates or by cloud/software service providers (“SaaS Services”) and located in the United States. Our SaaS Services are committed to using industry-standard physical, electronic, and organizational safeguards to protect information against loss or theft as well as unauthorized access and disclosure to protect individuals’ privacy and to employing security techniques to protect such data from unauthorized access. We follow generally accepted industry standards to protect the Visitor Information submitted to us, both during transmission and once we receive it. When entering Visitor Information on the Site, look for the secure icon (typically an image of a lock) and ‘https’ designation in the address box of your browser window that indicates you are on a secure page.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Any transmission of personal information by you is at your own risk. We are not responsible for circumvention of any privacy settings or security measures on our Site.
BEYOND OUR REASONABLE CARE TO SAFEGUARD YOUR INFORMATION WHILE IN TRANSIT, SCPH CANNOT AND DOES NOT GUARANTEE THE ABSOLUTE SECURITY OF ELECTRONIC COMMUNICATIONS OR TRANSMISSIONS, SINCE ANY TRANSMISSION MADE OVER THE INTEREST BY ANY ORGANIZATION OR INDIVIDUAL RUNS THE RISK OF INTERCEPTION.
- Data Retention
How Long We Keep Your Information
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (e.g., because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. We will actively review the personal data we hold and delete it securely, or in some cases, anonymize it when there is no longer a legal, business, or consumer need for it to be retained.
- Privacy Rights and Considerations
You should review the privacy policies of any third parties before you provide any personal information or complete any transaction with such parties. Please contact each third-party provider directly if you have any questions about their privacy policies or the information they require for you to complete any transaction.
Children’s Online Privacy Information
CHILDREN’S ONLINE PRIVACY PROTECTION ACT (“COPPA”) NOTIFICATION
Our Site is not designed for persons under the age of eighteen (18). We are not responsible for any access or use of the Site by children or minors under the age of 18. No one under age 18 may provide any personal information to or on our Site. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on our Site or through any of their features, use any of the interactive features of our Site, or provide any information about yourself to us, including your name, address, telephone number, email address or any other personal information about you. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under the age of 18, please contact us as outlined below.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Site, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of this Site. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records and delete any associated accounts. If you become aware of any data we may have collected from children under age 18, please contact us.
Residents of the European Union
If you are a resident of the EU, you have specific rights concerning your Visitor Information under the GDPR as outlined in more detail below. Further information and advice about your rights can be obtained from the data protection regulator in your country.
If you are a resident of the EU, under GDPR, you have the right to:
- Request SCPH allow you to access the personal data belonging to you that it processes;
- Request SCPH change or modify the data it processes about you when you believe the data is inaccurate;
- Request SCPH erase any personal information about you that it has collected;
- Request SCPH restrict the processing of your personal information under certain conditions;
- Request SCPH deliver the personal data it holds about you in a commonly used format and request that such data be transmitted to another controller;
- Request SCPH cease processing your personal data through an objection; and
- Request SCPH not subject you to a decision based solely on automated processing.
If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://edpb.europa.eu/about-edpb/about-edpb/members_en#member-pl.
If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
If you would like to exercise your rights under GDPR, you may contact SCPH as outlined below under the section for “Contacting Data Controller.”
Residents of California
If you are a resident of California, under the California Consumer Privacy Act and California Privacy Rights Act (collectively, “CCPA”), you have the right to:
- Request SCPH to disclose the categories and specific information that it has collected about you;
- Request SCPH to delete any personal information about you that it has collected;
- Request SCPH not to share your personal information at any time (the “right to opt-out”);
- Request SCPH to correct any inaccurate personal information it maintains about you; and
- Request SCPH to restrict its use and disclosure of your sensitive personal information.
If you would like to exercise your rights under the CCPA, you may contact SCPH as outlined further below. SCPH may not discriminate against you if you exercise any of your rights under the CCPA.
Residents of Colorado
If you are a resident of Colorado, under the Colorado Privacy Act (“CPA”), you have the right to:
- Request SCPH to allow you to opt-out of data processing for targeting advertising, sale or profiling using your personal data;
- Request SCPH to grant you access to any data that we have collected about you;
- Request SCPH to correct any data that we have collected about you that is incorrect or outdated;
- Request SCPH to delete any data collected about you that we hold; and
- Request SCPH to provide your data in a format that allows it to be transferred to another entity.
If you would like to exercise your rights under the CPA, you may contact SCPH as outlined further below.
Residents of Connecticut
If you are a resident of Connecticut, under the Connecticut Data Privacy Act (“CTDPA”), you have the right to:
- Request SCPH to confirm whether we are processing your personal data, and to provide access to any such data we may process about you;
- Request SCPH to provide you with a copy of your personal information in a portable and readily usable format;
- Request SCPH to correct any inaccuracies in any personal data we hold about you;
- Request SCPH to delete personal data that is provided by, or obtained about, you; and
- Request SCPH to allow you to opt0out of the processing of your personal data for purposes of targeted advertising, the sale of your personal data, and profiling in furtherance of solely automated decisions that produce significant effects.
If you would like to exercise your rights under the CTDPA, you may contact SCPH as outlined further below.
Residents of Utah
If you are a resident of Utah, under the Utah Consumer Privacy Act (“UCPA”), you have the right to:
- Request SCPH to grant you with access to the personal data we hold about you;
- Request SCPH to delete your personal data that you have provided to us;
- Request SCPH to provide you with a copy of your personal data that you have provided to us in a format that is portable, readily usable and transferable;
- Request SCPH to allow you to opt-out of the processing of your personal data for the purposes of targeted advertising, or the sale of your personal data.
If you would like to exercise your rights under the UCPA, you may contact SCPH as outlined further below.
Residents of Virginia
If you are a resident of Virginia, under the Virginia Consumer Data Privacy Act (“VCDPA”), you have the right to:
- Request SCPH to confirm whether we process your personal data, and to allow you with access to any such data;
- Request SCPH to delete any of your personal data that we hold;
- Request SCPH to correct any inaccuracies in the personal data we hold about you;
- Request SCPH to provide the data we hold about you in an easy, portable form for transferability;
- Request SCPH to allow you to opt-out of the processing of your personal data for targeted advertising;
- Request SCPH to allow you to opt-out of the sale of your personal data; and
- Request SCPH to allow you to opt-out of profiling based upon your personal data.
If you would like to exercise your rights under the VCDPA, you may contact SCPH as outlined further below. SCPH may not discriminate against you if you exercise any of your rights under the VCDPA.
Residents of Nevada
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request by emailing us at firstname.lastname@example.org. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
Residents of Canada
If you are a resident of Canada, under the Personal Information Protection and Electronic Documents Act (“PIPEDA”), you have the right to:
- Request SCPH to provide you with access to the personal information we hold about you;
- Request SCPH to correct any inaccurate or outdated personal information we hold about you;
- Request SCPH to delete any inaccurate personal information we hold about you; and
- Request SCPH to withdraw your consent to any activities for which you have previously consented.
When we collect information from you, you may inform us if you do not wish to be contacted for marketing/market research purposes in accordance with Canadian Anti-Spam Legislation. If you do not want to receive promotional information from us or our representatives, please use the unsubscribe option in your user account or the email you received, or email us at email@example.com to update your personal contact preferences.
If you would like to exercise your rights under the PIPEDA, you may contact SCPH as outlined below.
- Revisions and Updates
We may update this privacy notice from time to time as necessary to reflect customer feedback, changes in our services, and changes in the law. The updated version will be indicated by a revised “Last updated” date and the updated version will be effective as soon as it is accessible.
Contacting Data Controller
SUMMIT COUNTY PUBLIC HEALTH
1867 W. Market Street
Akron, Ohio 44313
ATTENTION: PRIVACY OFFICER
By Email: firstname.lastname@example.org
SCPH will use commercially reasonable efforts to promptly respond and resolve any problem or question.
© Copyright 2023, SUMMIT COUNTY PUBLIC HEALTH, All Rights Reserved.