Helper Privacy Policy

LAST MODIFIED: DECEMBER 16, 2019

Introduction

Netsmart Technologies, Inc. (“Company”) respects your privacy and is committed to protecting it through our compliance with this privacy policy (“Privacy Policy”). The purpose of this Privacy Policy is to inform you about the types of information we may collect from you or that you may provide when you visit our website and our practices for collecting, using, maintaining, protecting, and disclosing that information.

 

Consent

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our website. By accessing or using our website, you agree to the Privacy Policy, and you consent to the use of your information in accordance with the Privacy Policy. 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, so please check the policy periodically for updates.

 

Applicability

This Privacy Policy applies to individuals who use our Company website. This Privacy Policy relates only to websites owned by our Company, not to any third-party website or service linked to our website. We are not responsible for the content or privacy compliance of third-party websites or applications. You should check those websites or applications for their privacy statements.

This Privacy Policy applies to information we collect:

• On our Company website.
• In email, text, and other electronic messages between you and our Company website.
• Through mobile and desktop applications you download from our Company website, which provide dedicated non-browser-based interaction between you and this website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

 

Your California privacy rights

If you are a California resident, California law may provide you with additional rights regarding our use of your information. We are required by the California Consumer Privacy Act of 2018 (CCPA) to provide this notice to you. To learn more about your California privacy rights, visit CCPA Privacy Notice.

 

Information for children under 13

Our website is not intended for children under 13 years of age. We do not knowingly collect information from children under 13. If you are under 13, do not use or provide any information on this website. If you believe we might have any information from or about a child under 13, please contact us at privacy@ntst.com.

 

Information we collect

We collect information from you in three ways: (1) directly from you (2) with cookies and (3) with tracking technologies. We collect several types of information from and about users of our website. Our website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device Information.

 

Information you provide

Through your interaction with and use of this website, you may provide us with information on an individual basis. The information you provide through our website may include:

• Information collected automatically as you navigate through our website. This may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• Information that you provide by filling in forms on our website. This includes information provided at the time of using our website, registering through our website, subscribing to our services, posting material, or requesting information.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our website and of the fulfillment of your requests.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons

 

How we use cookies and other tracking technologies

Our Company or third parties we contract with may use persistent identifiers such as cookies and other tracking technologies to collect certain information about visitors to our website and interactions with our online content or applications, including advertisements. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your Information or they may collect information, including Information, about your online activities over time and across different websites and other online services.

 

How we use personal information we collect

We may use or disclose the Information we collect for one or more of the following purposes:

• To present our website and its contents to you.
• To market and promote products or services provided by our Company or affiliated companies.
• To provide you with information, products, or services that you request from us.
• To fulfill a purpose as described to you when collecting your Information.
• To provide you with notices about your account.
• To carry out our obligations and enforce our rights arising from any agreements entered into between you and us.
• To allow you to participate in interactive features on our website.
• To improve our website or services.
• To conduct market research.
• To fulfill any other purpose for which you provide it.

We may use the information we have collected from you to enable us to display advertisements to our target audiences. Even though we do not disclose your information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet the target criteria.

 

How we share personal information with other parties

We do not sell your information to third parties. We do not share your information with third parties for their promotional or marketing purposes. We may disclose information that we collect, or you provide as described in this Privacy Policy:

• To comply with legal requirements and corporate transactions.
• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our website users is among the assets transferred.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our Company, our customers, or others. This includes exchanging information with other companies for the purposes of fraud protection.
• For any other purpose disclosed by us when you provide the information.

 

Security and your personal information

We have implemented measures designed to secure your information from accidental loss and from unauthorized access, use, alteration, and disclosure. We use physical, electronic and administrative safeguards to protect your information. The safety and security of your information also depends on you. 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. We urge you to be careful about giving out information in public areas of the website such as message boards. The information you share in public areas may be viewed by any user of the website.

 

International transfers

If you are visiting our site from outside the United States, be aware that your information will be transferred to, and maintained on, computers located within the United States. The collection, use, retention and any other processing of your information will be governed by United States law and further by the specific jurisdictions within the United States where that information is stored, unless otherwise specified.

 

Changes to our Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated Privacy Policy on the website and update the policy’s “Last Modified” date. You are responsible for regularly reviewing the terms of the Privacy Policy to stay informed of changes or modifications of the Privacy Policy. Your continued use of our website following the posting of changes constitutes your acceptance of such changes

 

How to contact us

We understand you may have questions regarding your information. You may contact us at:
Mail: Netsmart Technologies, Inc., Attn: Privacy Office, 11100 Nall Ave, Leawood, KS, 66211
Email: privacy@ntst.com,
Phone: (800) 842-1973 and select the Privacy Office option for any privacy-related questions.

 

Privacy Notice for California Residents

LAST MODIFIED: DECEMBER 16, 2019

This Privacy Notice for California Residents supplements the information contained in the Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“Consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

 

Information we collect

Our website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, Company’s website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute	A 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 card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data	Physical location or movements.	NO
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	YES
J. Non-public education information	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

 

Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, such as:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete on our website.
• Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers.

 

Our use of personal information

We may use or disclose the personal information we collect for one or more of the following purposes:

• To present our website and its contents to you.
• To market and promote products or services provide by our Privacy Policy or affiliated companies.
• To provide you with information, products, or services that you request from us.
• To fulfill a purpose as described to you when collecting your personal information.
• To provide you with notices about your account.
• To carry out our obligations and enforce our rights arising from any agreements entered into between you and us.
• To allow you to participate in interactive features on our website.
• To improve our website or services.
• To conduct market research.
• To fulfill any other purpose for which you provide it.

We may use the information we have collected from you to enable us to display advertisements to our target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet the target criteria.

Company will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

Sharing personal information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories:

• Service providers
• Data aggregators
• Third parties

 

1. Disclosures of personal information for a business purpose

We share the following categories of personal information with third parties:

• A: Identifiers
• B: California Customer Records personal information categories
• C: Protected classification characteristics under California or federal law
• F: Internet or other similar network activity
• J: Non-public education information

 

2. Sales of personal information

We do not sell your personal information to third parties.

 

Your California Consumer rights and choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

 

1. Right to access to specific information and data portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.

 

2. Right to request deletion

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception 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 good or 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.
• Comply with a legal obligation.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• 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.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

3. Exercising your access, data portability, and deletion rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Submitting an online request at California Resident Data Rights Request.
• Emailing us at privacy@ntst.com.
• Calling us at (800) 842-1973 and selecting the Privacy Office menu option.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer 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.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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. Making a verifiable consumer request does not require you to create an account with us.

 

4. Response timing and format rights

We attempt to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will provide your personal information in a format that is readily useable and allows 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 noticeably 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.

 

5. Personal information sales opt-out and opt-In rights

We do not sell your personal information to third parties.

 

6. Non-discrimination rights

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-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.

 

Changes to our privacy notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the website and update the notice’s “Last Modified” date. You are responsible for regularly reviewing the privacy notice(s) to stay informed of changes or modifications of the privacy notice(s).

 

Contact Information

If you have any questions about this notice or wish to exercise your rights under California law, please contact us at:

Online Rights Request: Click California Resident Data Rights Request
Email: privacy@ntst.com
Phone: (800) 842-1973 and select the Privacy Office option.