(Last Updated: 7/10/2019)
WE AT CRR VALUE KEEPING YOUR PERSONAL INFORMATION CONFIDENTIAL AND USING IT SOLELY IN THE CONTEXT OF PROVIDING COACHING TO SUPPORT INDIVIDUALS AND COUPLES DEALING WITH BETRAYAL.
BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE SITE, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT LOG INTO OR ACCESS THIS SITE AND DO NOT SUBMIT ANY INFORMATION TO US.
For the purposes of applicable data protection laws including the EU General Data Protection Regulation (“GDPR”), the data controller is: Center for Relational Recovery, LLC located at 19 East Market St. Leesburg VA 20176.
In case you have any questions or concerns after reading this privacy statement, please do not hesitate to contact us at firstname.lastname@example.org. We appreciate your feedback.
WHAT INFORMATION DO WE COLLECT AND WHY?
The Personal Information collected includes demographic information, such as your name, phone number, and email address. Primarily, the collection of your Personal Information assists us in creating your User Account and providing a platform whereby you can access materials and programs designed to help in your recovery. If you enroll in one of CRR’S recovery programs, CRR also collects Personal Information from you with respect to the details of your relationship in order to assist in tailoring and providing you with relationship and recovery information, online resources, and in-person services.
We may also use this information to (1) communicate with you about and manage your User Account; (2) store data; (3) comply with the law; (4) respond to requests from public and government authorities; (5) to enforce our terms and conditions; (6) manage and improve our operations and applications; (7) provide additional functionality; (7) protect our rights, privacy, safety or property, and/or that of you or others; and (8) allow us to pursue available remedies or limit the damages that we may sustain.
Credit Card Information
CRR will collect and use information obtained from credit card transactions only for business purposes. These business purposes include the payment of fees for access to online courses and subscriptions on the Website.
Protecting Your Credit Card Information
The credit card information provided by you to CRR will be stored in a confidential manner. Our employees may access such information only when there is an appropriate business reason to do so, such as when a refund must be issued back to the credit card. We maintain physical, electronic and procedural safeguards to protect your information, and our employees are required to follow these privacy standards.
Disclosure of Your Credit Card Information
CRR does not disclose any nonpublic credit card information (such as credit card number and their expiration dates) about you to anyone, except as required by law. We disclose information only when it is necessary for the conduct of CRR, State or Federal government business, or under circumstances where disclosure is required by law. Information may also be disclosed for audit purposes, to regulatory agencies or for other general administrative services. We do not disclose information about you to other entities who may want to sell their products to you.
WHERE IS YOUR PERSONAL INFORMATION STORED?
Information CRR collects through our Site will be stored on secure servers.
WILL CRR SHARE YOUR PERSONAL INFORMATION WITH ANYONE ELSE?
Yes, with third parties that help us power our Site
CRR has a limited number of service providers and other third parties (“Business Partners”) that help us run various aspects of our business. These Business Partners are contractually bound to protect your Personal Information and to use it only for the limited purpose(s) for which it is shared. Such third-party uses may include, but are not limited to, the provision of services such as data hosting, IT services, and billing management.
Yes, with third parties and the government when legal or enforcement issues arise
Yes, with third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of CRR’s corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings).
If we share your Personal Information with a third party other than as provided above, you will be notiﬁed at the time of data collection or transfer, and you will have the option of not permitting the transfer.
HOW LONG WILL CRR RETAIN THE INFORMATION?
Personal Information, Generally
We store your Personal Information for as long as you maintain a User Account and up to ﬁve (5) years after the account is closed. At the end of this ﬁveyear retention period, we will remove your Personal Information from our databases and will request that our Business Partners remove your Personal Information from their databases.
However, once we disclose your Personal Information to third parties, we may not be able to access that Personal Information any longer and cannot force the deletion or modiﬁcation of any such information by the parties to whom we have made those disclosures. Written requests for deletion of Personal Information other than as described should be directed to email@example.com. We retain anonymized data indeﬁnitely.
We may also collect information using pixel tags, web beacons, clear GIFs or other similar technologies. These may be used in connection with some Site pages and HTMLformatted email messages to, among other things, track the actions of Site users and email recipients, and compile statistics about Site usage and response rates.
HOW DOES CRR PROTECT MY PERSONAL INFORMATION?
CRR is committed to protecting the security and conﬁdentiality of your Personal Information. We use a combination of reasonable physical, technical, and administrative security controls to maintain the security and integrity of your Personal Information, to protect against any anticipated threats or hazards to the security or integrity of such information, and to protect against unauthorized access to or use of such information in our possession or control that could result in substantial harm or inconvenience to you. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure. As a result, we cannot ensure the security of information you transmit to us. By using the Site, you are assuming this risk.
The information collected by CRR and stored on secure servers, is protected by a combination of technical, administrative, and physical security safeguards, such as authentication, backups, and access controls. If CRR learns of a security concern, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us or by an inapp notiﬁcation. Depending on where you live, you may have a legal right to receive such notices in writing.
NOTWITHSTANDING ANY OF THE STEPS TAKEN BY US, IT IS NOT POSSIBLE TO GUARANTEE THE SECURITY OR INTEGRITY OF DATA TRANSMITTED OVER THE INTERNET. THERE IS NO GUARANTEE THAT YOUR INFORMATION WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. THEREFORE, WE DO NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY INFORMATION YOU TRANSMIT TO US AND YOU TRANSMIT SUCH INFORMATION AT YOUR OWN RISK.
HOW SHOULD YOU PROTECT YOUR PERSONAL INFORMATION?
We will NEVER send you an email requesting conﬁdential information such as account numbers, usernames, passwords, or social security numbers, and you should NEVER respond to any email requesting such information. If you receive such an email purportedly from CRR, DO NOT RESPOND to the email and DO NOT click on any links and/or open any attachments in the email, and notify CRR support at firstname.lastname@example.org.
You are responsible for taking reasonable precautions to protect your user ID, password, and other User Account information from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies. You should immediately notify CRR at email@example.com if you know of or suspect any unauthorized use or disclosure of your user ID, password, and/or other User Account information, or any other security concern.
EU Data Citizen Rights
You have the right under certain circumstances:
- to receive communications related to the processing of your personal data that are concise, transparent, intelligible and easily accessible;
- to be provided with a copy of your personal data held by us or your healthcare provider;
- to request the rectification or erasure of your personal data held by us or your healthcare provider without undue delay;
- to request that we or your healthcare provider restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal data by us or your healthcare provider, including the right to object to marketing;
- to request that your Personal Information be moved to a third party;
- to receive your Personal Information in a structured, commonly used and machine-readable format
- to lodge a complaint with a supervisory authority
Where the processing of your Personal Information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at firstname.lastname@example.org.
HOW CAN YOU UPDATE, CORRECT OR DELETE YOUR PERSONAL INFORMATION?
You can change your email address and other contact information by editing your proﬁle in the Site. If you need to make changes or corrections to other information, you may email email@example.com. Please note that in order to comply with certain requests to limit use of your Personal Information, we may need to terminate your account with us and your ability to access and use the Services, and you agree that we will not be liable to you for such termination or for any refunds of prepaid fees paid by you.
Although we will use reasonable efforts to do so, you understand that it may not be technologically possible to remove from our systems every record of your Personal Information. The need to back up our systems to protect information from inadvertent loss means a copy of your Personal Information may exist in a nonerasable form that will be diﬃcult or impossible for us to locate or remove. Backups of that data will remain associated with your account and in our archive servers. You can deactivate your account by emailing firstname.lastname@example.org.
INFORMATION SUBMISSION BY MINORS
We do not knowingly collect personal information from individuals under the age of 18 and the Site is not directed to individuals under the age of 18. We request that these individuals not provide personal information through the Site. If you are aware of a user under the age of 18 using the Site, please contact us at email@example.com.
CHANGES TO THIS POLICY