Effective Date: November 15, 2019
Third-Party Advertising on Our Site
Personal Information and Privacy
When you use our Service, you may be creating and maintaining a personal, private area of the application (“Individual Site”). By their very nature, these Individual Sites contain a great deal of personal information about the subject of the Individual Site.
Information You Provide Directly to HCD
When you use the Site, you may provide certain information directly to us. For example, without limitation, when you choose to register a user account, you will be required to provide, among other things, your e-mail address, name, and phone number. We may use this information to suggest services that may be of use to the caregiver or care recipient.
[Certain Information in the Services is Visible to Other Users]
Information that is Automatically Collected
We and third parties may use automated means to collect information about you, your computer or other device that you used to access the Site, and your use of the Site. These automated means include common technologies such as cookies or similar technologies. These technologies help us analyze trends, administer the Site, track Users’ movements around the Site, gather demographic information about our User base as a whole, and otherwise provide you with relevant content (e.g., by gathering your zip or postal code). We may receive reports on an individual as well as aggregated basis based on the use of these technologies by HCD, and any third-party vendors acting on HCD’s behalf.
Cookies and Tokens
Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of local storage (such as browser-based or plugin-based local storage, or application-based local storage on a mobile device). You may be able to restrict or disable certain cookies. Please note, however, that without cookies, you may not be able to use all of the features of our Site.
Our cookies, tokens and similar technologies (collectively, “Tracking Technologies”) also are used for administering the Site, including without limitation, for authentication, to remember Users’ settings, to customize the content and layout of the Site for Users, to contact you about the Site, and to improve our internal operations, the content of our Site and our services. Users may be able to control the use of, or reject or disable, some Tracking Technologies at the individual browser level. If you reject or disable Tracking Technologies, you may still use our Site, but your ability to use some features or areas of our Site may be limited. We use Tracking Technologies to identify your device and keep track of your Internet session with our Site. Using these Tracking Technologies, we may automatically end your session on our Site after a period of inactivity (as determined by us in our sole discretion). We also use Tracking Technologies that allow us to recognize your device when you return to the Site within a certain period of time (as determined by us in our sole discretion) and automatically log you back into your account with us. UNLESS YOU AFFIRMATIVELY LOG OUT of your account PRIOR TO YOUR SESSION ENDING (whether by you or by us), YOU WILL BE AUTOMATICALLY LOGGED BACK IN THE NEXT TIME YOU OR ANY USER OF YOUR DEVICE VISITS OUR SITE within the period of time determined by us. If you do not wish to be automatically logged back in when you (or someone using your device) next initiate a session with our Site (using the same device that is being used for your current session), you should log out of your account (i) prior to ending your session, or (ii) if you will be inactive on our Site for more than a few minutes.
In conjunction with the gathering of data through cookies, Web servers may log records such as your device type, operating system type, device advertising identifier, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The Web server logs also may record the address of the Web page that referred you to our Site, the IP address (and associated city and state or province for the IP address) of the device you use to connect to the Internet, and data about your interaction with our Site, such as which pages you visit.
We may use third-party web analytics services on our Site, such as those of Google Analytics. These service providers use the sort of technology described in this “Information that is Automatically Collected” section to help us analyze how Users use the Site, including by noting the third-party Web site from which Users arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Site.
Collection of Information Across Personal Devices and Applications
Sometimes, we (or our service providers) may use the information we collect—for instance, log-in credentials, IP addresses, hashed email addresses, and unique mobile device identifiers—to locate or try to locate the same unique Users across multiple browsers or devices (such as smartphones, tablets, or computers), or work with providers that do this, in order to better tailor content, features, and advertising (for HCD on other sites), and provide you with a seamless experience across the devices you use to access our services.
Our Use of Information
Use and Storage of Information to Provide You with the Site and Related Services
HCD, and any third party vendors acting on HCD’s behalf, may use and store your Information to perform activities associated with providing you with the Site and related Services such as: (i) registering you to use the Site and otherwise logging you into the Site, including the authentication of your identity, where applicable, and otherwise enabling your access to the Site; (ii) resolving disputes and/or troubleshooting problems including logging into your account to troubleshoot problems or otherwise help you navigate the Site; (iii) verifying your compliance with your obligations in our Terms of Service (available at [include link]) or other HCD policies; (iv) improving the quality of the Site, (v) fulfilling any request you make; (vi) communicating with you; (vii) connecting you with and providing you with information about our Services; (viii) providing you with Site content, including, without limitation, generating recommendations, and processing your preferences and requests; (ix) analyzing, customizing, and personalizing the Site, including through the delivery of tailored content and communications; and (x) otherwise as directed by you or provided for herein. Except where prohibited by law, and only to the extent permitted by HCD’s agreements with applicable business partners of HCD with whom we partner to provide you the Services (“HCD Partners”), we may also use your Information in connection with any other services we make available to you.
Additional Information Regarding Use of Information for Communications with You
If you choose to tell a friend about our Service through our Site, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site.
HCD, HCD Partners, and any third-party vendors acting on HCD’s behalf, may also use your Information to communicate with you (including, without limitation, via email and/or mobile push notifications) about the Site and/or our Services (and related features and functionality) or those of any HCD Partner that is providing services to you. Our communications to you will include, without limitation, contacting you by SMS text message or at the email address(es) that you use to register for our Site to communicate with you regarding the Site and actions that you take in connection with the Site.
Your Choices Regarding Our Communications with You
Creation and Use of Combined Data, De-Identified Data, and Aggregated Data
As permitted by law and by HCD’s agreements with applicable HCD Partners, HCD, and any third-party vendors acting on HCD’s behalf, may aggregate and/or de-identify your Information and/or combine your Information with other information maintained or available to HCD and use or disclose such information as follows:
We may use aggregated or combined data to communicate with you about the Site and/or our products and services and disclose such aggregated or combined data to HCD Partners in connection with providing the Site.
We may also use and disclose de-identified data, de-identified aggregated data, and/or de-identified combined data for any business purpose, which may include, without limitation, improving our products and services, conducting analytics such as evaluating our Site and developing additional benefits, programs, and services, and disclosing to HCD Partners for analytics purposes.
Disclosure of Information
We may share your Information in the following circumstances:
- Disclosures to Service Providers and HCD Partners
HCD, and third party vendors acting on our behalf, may disclose your Information to HCD Partners, third-party service providers, or vendors acting on our behalf for the purpose of providing the Site and related services to you or other Users, including, without limitation, registering you to use the Site (e.g., authenticating your identity), logging you into the Site, providing you with information you have requested through the Site or related services, and connecting you with resources and other services (e.g., transportation or meal services). For example, we may provide your [insert type of Information] to [insert example of HCD Partner], for purposes of [insert purpose related to HCD Partner] . Third-party service providers or vendors acting on our behalf are authorized to use your Information only in connection with providing these services to us or as required by law. For example, we may store your information with a cloud storage service provider, such as Amazon Web Services or similar company.
- Additional Disclosures with Your Consent
- Safety, Security and Compliance with Law
Your Information and the contents of your communications through the Site may be disclosed to third parties as required by law, such as to comply with a subpoena or similar legal process, or when we reasonably believe disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, report improper or unlawful activity, or respond to a government request.
- Subsidiaries and Affiliated Companies
- Sale, Merger or Similar Transaction
We Do Not Control the Privacy Policies of Third Parties
Data Security and Integrity
The security of your Information is important to us. We follow security standards to protect the Information submitted to us from loss, interference, misuse, unauthorized access, disclosure, alteration or destruction, both during transmission and once we receive it. These safeguards vary based on the sensitivity of the Information that we collect, process and store and the current state of technology. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. We also maintain procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current. If you have any questions about data security and integrity on our Site, you can contact us at customerservice@HCD.com.
Be Sure to Log Off When Using Public or Third-Party Computers
As described above, we use Tracking Technologies that automatically log you back into your account with us unless you affirmatively log out of your account prior to your session ending (whether you end your session or we end your session, for example if our Site has “timed out” – i.e. we have ended your session automatically after a period of inactivity as determined by us in our sole discretion). If you log into the Site using a public computer or device, or a computer or device of that belongs to or is shared with another person, you should affirmatively log out of your account. Otherwise, the next user of that computer or device may be able to access your account and your Information in your account if your session has not ended.
Your Use of Persistent Login
We recommend that you log-out after use of the application, if you are concerned about the unauthorized use or disclosure of Information via persistent login.
Managing and Updating Information
To access, review, update and/or delete certain Information, you may contact us at customerservice@HCD.com, and you may update and/or delete certain Information by logging into the Site and updating your account. We will respond to your request within a reasonable and lawful timeframe under the circumstances of your request. Please remember, however, if we have already disclosed some of this Information to third parties, we cannot access that Information any longer and cannot force the deletion or modification of any such Information by the parties to whom we have made those disclosures. Additionally, if you modify certain Information on our Site that we received from a third party, we reserve the right, but are not obligated, to share the updated information back to that third party. As a result, you will need to provide updated information to those third parties if you want to be sure they have your updates.
Certain Information is necessary in order for us to provide the Site and our related Services; therefore, if you delete such necessary Information you will not be able to use the Site or receive our Services. If you wish to have your account deactivated, you may contact us at customerservice@HCD.com. After we receive your request, within a reasonable timeframe under the circumstances of your request, we will deactivate your account; provided, however, that: 1) HCD (and our third-party vendors acting on our behalf), our HCD Partners, and any other applicable third parties may continue to use and share for any purpose de-identified data and aggregated or combined data developed using your Information that has been de-identified and 2) HCD may continue to use Information in your deactivated account for compliance with applicable regulations. Also, please note that even though you may deactivate your account or request the deletion of your Information, we may be required (by law or otherwise, such as to prevent fraud, resolve disputes, or troubleshoot problems) to retain this information, in which case we will comply with your deletion request only after we have fulfilled such requirements. We may also keep a copy of your Information to protect our legal rights, such as in connection with your use of the Site or your agreement to our Terms of Service, as permitted or required by applicable law.
California Do-Not-Track Disclosure Requirements (for California Users)
We are committed to providing you with meaningful choices about the information collected on our Site for third-party purposes. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.
Your California Privacy Rights (for California Users)
California law permits customers of HCD who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write us:
11013 W Broad St.
Glen Allen, VA 23060
We will provide a list of the categories of personal information, if any, disclosed to third parties during the immediately preceding calendar year for third-party direct marketing purposes, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or postal address specified above. You should put “California Privacy Rights” in the subject line and in your request. You must provide us with specific information regarding yourself so that we can accurately respond to the request.
Children; Special California Notice
The Site and Services are not directed to children under the age of 18, and children under the age of 18 years of age are not eligible to use them. Protecting the privacy of children is very important to us. Through the Site and Services, we do not collect Information from people we actually know are under 18 years of age, and no part of the Site or Services is designed to attract people under 18 years of age. If we later learn that an individual has provided us with their information through the Site or Services and they are under 18 years of age, we will take steps to remove that User’s Information from our databases and to prevent the User from utilizing the Site or Services.
If you are a California resident under the age of 18 and are a registered User of our Site, you may request that we remove from our Site any content you post to our Site that can be accessed by any other User (whether registered or not). Please note that any content that is removed from our Site may still remain on our servers and in our systems. To request removal of content under this provision, please send an email to customerservice@HCD.com and provide us with a description of the content and the location of the content on our Site, and any other information we may require in order to consider your request. Please note that removal of content under this provision does not ensure complete or comprehensive removal of the content or information posted on the Site by you.
HIPAA and Equivalent State Laws
You acknowledge that the Health Insurance Portability and Accountability Act (“HIPAA”) and equivalent state health information privacy laws may apply to certain health-related User Content. Please see our HIPAA Notice of Privacy Practices at [insert link] for information regarding how we use and disclose such health information.
Retention of Personal Data