PROChiroOnlineCE.com Privacy Statement
Effective Date: April 15, 2020
PROChiroOnlineCE.com is a division of Solutions Sports and Spine, Inc.
This Privacy Notice outlines the types of Personal Information and Automatically-Collected Information (defined below) we (Solutions Sports and Spine, Inc) collect and how we use and protect it. This Notice applies to the data collected through your use of www.PROChiroOnlineCE.com (“Site”). Herein, “healthcare professional” refers to licensed, non-medical subscribers to include chiropractors, physical therapists, acupuncturists, bodyworkers, personal trainers, athletic trainers, etc.
Your Agreement. When you use the Site, you, on behalf of yourself and any entity you represent, signify that you have read, understand, and agree to the terms of our current Privacy Notice; to our collection, use, and dissemination of your Personal Information and Automatically-Collected Information as described in this Notice; and to our storage of your Personal Information and Automatically-Collected Information in the United States. If you are acting on behalf of an entity, you must have, and you represent that you have, full authority to bind your entity to this Notice. If you do not have such authority or if you do not agree to all provisions of this Notice, do not use our Site. Throughout this Notice, when we say “use of our Site,” this “use” includes visiting and browsing our Site, logging into your account and using features made available only to users with accounts, and/or providing your Personal Information through the Site and/or through offline contacts with us (such as phone calls). This Notice applies to medical providers and healthcare professionals who subscribe to our services through the Site, individual end users directed to the Site by a medical provider or healthcare professionals, and Site users who merely access and browse the Site.
Changes to this Notice. We may update this Notice from time to time in our discretion. We will post any new Notice here, and you should review this Notice regularly to make sure you are aware of its terms. We will also provide notification of significant changes to this Notice through the Site. If changes are significant and if you have an account, we will also notify you of such changes either (i) via your contact information; or (ii) by requiring that you agree to the revised Notice the next time you log into your account. Your use of the Site following a revision to this Notice constitutes your acceptance of and agreement to the terms of this Notice, as revised. The revisions will apply to all Personal Information and Automatically-Collected Information collected on and after the date on which we post the revised Notice (the effective date and last updated date will appear at the top).
Intended Users. By using our Site, you affirm (i) that you are at least eighteen (18) years old or that you are between the ages of thirteen (13) and seventeen (17) and possess legal parental or guardian consent to use the Site and provide information through the Site; and (ii) that you have authority to agree to this Notice and are competent and capable of understanding, agreeing to, and complying with this Notice. Our Site is not directed to children under age 13, and children under age 13 are prohibited from using the Site. We do not knowingly (i) collect Personal Information or Automatically-Collected Information from anyone under age 13; (ii) contact children under age 13 for marketing purposes; or (iii) sell products or services to children under age 13. If we learn that we have received Personal Information or Automatically-Collected Information from a child under age 13 in violation of this Notice, we will delete that information from our files. If you are a parent or legal guardian of a minor child and you use the Site and provide information about that child and on that child’s behalf, you acknowledge and agree that such information will be treated in accordance with the terms of this Notice.
Information Collected. When you use the Site, you provide us with Personal Information that you actively provide and Automatically-Collected Information that we collect as you use the Site.
Personal Information. To use certain features of the Site, you will have to provide us with information that personally identifies you (“Personal Information”). If you are a medical provider, you will provide us information about you and your business in order to register for a provider account and subscribe to the services offered through the Site. If you are an individual user directed to the Site by your medical provider, you or your medical provider will provide your Personal Information to us through the Site in order to set up an end user account for you. You are never under any obligation to provide us your Personal Information. If you choose not to provide Personal Information, you will not be able to access your account. When you do provide us your Personal Information (or, if you are an individual end user, when you allow your medical provider to provide us your Personal Information to set up an end user account for you), you are authorizing us to use that Personal Information in accordance with the provisions of this Notice and to store your information on our servers located in the United States.
Personal Information includes the following categories of information: 1) Your name and/or company name; 2) Contact Data (such as your home or business address, billing address, e-mail address, phone number); 3) Username and password; 4) Birth date; 5) Your financial information, such as your credit card information or PayPal information; 6) User preferences; and 7) Other information you actively enter into the Site or provide us through offline contacts, such as email or phone call.
b. Automatically-Collected Information. We automatically track, collect, and store the following categories of information automatically when you use the Site (“Automatically-Collected Information”): 1) IP or MAC addresses of computers used to access the Site; 2) Mobile device unique IDs; 3) Domain server; 4) Type of computer and/or device accessing the Site; 5) Type of web browser and/or mobile Internet browser used to access the Site; 6) Type of operating system your computer and/or device uses; 7) Date and time you access the Site; 8) Referring source and/or the site you visited just prior to visiting our Site; 9) The order in which you view the Site pages and actions you take on the Site; and 10) Other similar information about the interaction between your browser and the Site.
Unless otherwise stated in this Notice, Automatically-Collected Information may be combined with the Personal Information you have provided.
Cookies and Web Beacons. We collect Automatically-Collected Information through commonly-used information gathering tools, such as cookies and web beacons.
Cookies. To help make the Site more responsive to the needs of our users, we use a standard feature found in browser software called a “cookie.” When you visit the Site, our servers send a cookie to your computer or other operating device. The cookie is placed on your hard drive or other operating device, and it assigns your computer or operating device a unique, random number that acts as a sort of anonymous ID. Standing alone, cookies do not personally identify you; rather, a cookie identifies the computer or operating device one uses to access the Site. Unless you choose to identify yourself to us, such as by filling out a web form, you remain anonymous to us when browsing the Site; in other words, the cookie alone with not allow us to identify you personally. Broadly speaking, there are two types of browser cookies:
Session cookies are stored in a computer or other device’s memory during a user’s browsing session and are automatically deleted from the user’s computer or device when the browser is closed and the session has ended. These cookies usually store a session ID that does not personally-identify the user. They allow users to navigate the Site efficiently, and they can contain information about Site features used and activities conducted while using the Site.
Persistent cookies are stored on a user’s computer or other device and are not deleted when the browser is closed and session ended. Persistent cookies can be used to retain user preferences for our Site, allowing the preferences to be used in future browsing sessions. These cookies assign a unique ID to a user’s computer or device, and they are used to identify a user upon logging into his or her account. We may use these cookies to remember your personal settings and pre-fill forms for you by saving your preferences for future visits. Standing alone, persistent cookies do not identify the Personal Information of the user; rather, they identify computer IP or MAC addresses and device IDs.
Generally, we use cookies to customize your experience while using the Site. We use cookies to compile aggregate data about user traffic on and user interaction with the Site so we can offer better experiences and tools in the future. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. Each time you log into your account, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser, allowing us to uniquely identify you when you are logged into your account and to process your online transactions and requests. Cookies are required to use your account.
Most browsers automatically accept cookies, but you can block cookies at any time by changing the preferences in your browser and/or delete cookies from your hard drive and mobile device. By blocking and deleting cookies, however, you will be able to browse the Site, but you will not have access to all features of the Site, and features may not function properly. Please refer to your browser for information on how to disable and control cookies.
b. Web Beacons. We may also use “web beacons” (also called clear gifs, pixel tags, and single-pixel tags) to collect Automatically-Collected Information about your use of the Site. The information collected by web beacons allows us to statistically monitor information such as how many people are using the Site and for what purposes. We do not collect Personal Information with web beacons, and we do not link information retrieved from web beacons directly with Personal Information you’ve given us.
c. IP Addresses and Mobile Device IDs. When you visit the Site, we collect your Internet Protocol (“IP”) addresses and mobile device IDs to track and aggregate Automatically-Collected Information. For example, we use IP/MAC addresses and mobile device IDs to monitor the regions from which users navigate the Site. We also collect IP/MAC addresses and mobile device IDs from users when they log into their account on the Site in order to confirm the applicable user’s identity.
Uses of Your Personal Information and Automatically-Collected Information.
a. Personal Information. When you supply us with your Personal Information, we will use it for the express purpose stated when we ask for such Personal Information, to present our Site to you, to allow you to participate in interactive features on our Site, to charge you for services purchased, and to contact you regarding your account or use of the Site. For end user patients and clients referred by medical providers or healthcare professionals, we will not use your Personal Information to contact you for marketing or promotional purposes.
b. Payment for Services. We use your financial information solely to collect payment for services if you are a medical provider subscribing to our services (if you are an individual end user, you do not have to pay to use the services offered through our Site). If you enter financial information through the Site to pay for services, we provide data encryption during the payment process. We only use your financial information to charge you for services you use through the Site. We retain your financial information for as long as you continue to use the Site and services offered through it so we can continue to charge you on a monthly basis. We use a third-party intermediary to manage payment processing. Our third-party payment processor follows Payment Card Industry (“PCI”) standards, and our third–party payment process is PCI-Compliant. Our third-party payment processor is not authorized to use your financial information in any way other than to process payments on our behalf and is required to keep the information confidential. We only share your financial information with our third-party payment processor, your credit card provider, and financial institutions to process payments.
c. Other Uses of Your Personal Information and Automatically-Collected Information. We may use your Personal Information and Automatically-Collected Information to customize and tailor your experience using the Site, displaying content we think you might be interested in and according to your preferences. We may use Personal Information and Automatically-Collected Information to help diagnose problems with the Site, to make the Site more compatible with the technology used by our users, and to analyze statistical use patterns. We also use Personal Information and Automatically-Collected Information as described elsewhere in this Notice.
Information Shared with Third Parties. Except in the circumstances described in this Notice, we do not share, sell, rent, license, trade, or otherwise transfer or disclose your Personal Information with or to any third parties for their promotional purposes or otherwise. We may share de-identified, aggregated Automatically-Collected Information without restriction.
a. Third-Party Service Providers. We share Personal Information and Automatically-Collected Information with our third-party service providers who assist us by performing services related to our operation of the Site (such as hosting, data storage, and security). These third-party service providers are not authorized to use your information in any way other than as described here and are required to keep the information confidential.
b. Third-Party Payment Processor, Credit Card Provider, Financial Institutions. We use a third-party intermediary to manage payment processing. This intermediary is not permitted to store, retain, or use financial information or your other Personal Information except for the sole purpose of payment processing on our behalf. For more information regarding third parties who will have access to your financial information, see the Subsection entitled “Payment for Services” above.
c. Third-Party Analytics Services. We may use third-party analytics services to assist us in better understanding Site users, such as to track and analyze Site feature usage. We only ever provide these service providers with (or allow these service providers to collect on our behalf) Automatically-Collected Information. The recordings will never identify you personally, though they can identify your IP/MAC addresses and device IDs. The information we receive from these third parties may be re-associated with your Personal Information after we receive it back from these third parties. These third parties are not authorized to use your information in any other way and are required to keep the information confidential.
d. Merger, Acquisition, or Sale. We may transfer your Personal Information and Automatically-Collected Information to another entity if we are involved in a merger, acquisition, reorganization, restructuring, or other sale or transfer of all or any portion of its assets or business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. In this event, however, we will not transfer your Personal Information without your permission. Unless you consent otherwise, your Personal Information will remain subject to the promises made in this Notice, even after the transfer. But any Personal Information and Automatically-Collected Information you provide through the Site after the transfer will likely be subject to a new privacy notice, and you should review that notice.
e. Required by Law. We reserve the right to release Personal Information and/or Automatically-Collected Information in order to comply with a mandate contained in the law, which compels us to disclose your Personal Information and which is enforceable in a court of law.
f. Public Areas of the Site. The Site contains areas where users can post content that will be viewed by other Site users, such as our comment boxes located at the bottom of each webpage. You should be aware that when you voluntarily disclose Personal Information on these areas for public viewing, the information may be collected, stored, used, and disclosed by other Site users. Such activities are beyond our control, and we shall have no responsibility for or liability regarding the protection or security of such information. Do not post Personal Information that you want to keep private on these areas of the Site.
Controlling Your Information; Opt-Out Rights.
a. Stop Future Collection of Information. You can stop all future collection of Personal Information and Automatically-Collected Information by discontinuing use of the Site (but see below regarding data retention of earlier-collected data). If you want us to remove your Personal Information from our records, see the paragraph below.
b. Review and Modification of Information; Deleting Information. You can review or modify the Personal Information you have included in your Site account by accessing your account or by contacting us. Please note that your account and all features of the Site may not function properly if we remove any or all of your Personal Information. Further, for individual end users, we cannot control the use of your Personal Information by your medical provider. For example, while we can allow you to modify or delete Personal Information from your account on the Site, we cannot control how the data is maintained and used by your medical provider. You would need to contact your medical provider if you would like them to change their records.
To update a billing profile, please visit your account on the Site to change your billing information and/or contact us via the contact information shown below.
Upon receipt of your request to close your account and/or ask us to delete your information from our databases (or, for individual end users, if your medical provider asks us to close your account or delete your information from our databases, such as if your medical provider stops using our services), we will use commercially-reasonable efforts to delete your account and remove your Personal Information from our databases; however, it may be impossible to remove residual Personal Information (see more information about this in Section 9), in which case we will retain your Personal information and Automatically-Collected Information in accordance with our retention policy described in Section 9. Before we close your account, we will ask if you want us to transfer your Personal Information associated with your account to you. Further, for as long as your Personal Information is in our possession or under our control, you may request that we provide your Personal Information to you at any time. However, once we have closed your account either at your request (or, for individual end users, at the request of your medical provider), we shall have no obligation to maintain a copy of your Personal Information.
Retention and Storage. See the Subsection entitled “Payment for Services” above regarding retention of your financial information. We may retain all other Personal Information and Automatically-Collected Information in our databases until you contact us and ask that we remove your information from our databases (or until your medical provider asks us to close your account or delete your information from our databases, such as if your medical provider stops using our services), unless applicable law requires otherwise. Please note that even after you (or your medical provider) ask(s) us to remove your information from our databases, it may be impossible to remove some Personal Information, such as information tracked in our web server log files and information that may reside in backup files. We may also retain de-identified Automatically-Collected Information even after you request that we remove your Personal Information from our databases, for use in the aggregate and to analyze and improve the Site. Further, if it is impossible to remove some Personal Information or Automatically-Collected Information (or if we choose to retain some de-identified Automatically-Collected Information for use in the aggregate) we may use the same to comply with applicable laws, rules, and regulations; to prevent fraudulent activity; to protect ourselves against liability and to pursue available legal remedies; to resolve disputes; and to enforce our contractual or other rights.
Links to Third-Party Websites, Products, and Services. This Notice applies only to information collected through your use of the Site. The Site may contain links to other websites, products, and services that are not owned or controlled by us. We are not responsible or liable for the privacy practices or other actions of these third parties or their websites, products, or services.
Security of Information. We have generally-accepted industry standard physical, electronic, and procedural security measures in place to protect against the loss, misuse, alteration, or unauthorized access of Personal Information and Automatically-Collected Information we collect and store. These safeguards include, for example, secure login authentication for user accounts on the Site, encryption of data during transmission, firewalls, intrusion detection, and vulnerability scans. The safety and security of your Personal Information also depends on you. You are responsible for keeping your username and password confidential. Please promptly notify us if you become aware that your Personal Information is lost, stolen, or used without permission.
Legal Disclaimer. We cannot guarantee that your information will never be compromised. No Internet or wireless network transmission is ever 100% secure, and no security system can prevent all security breaches. Further, while we employ reasonable measures to protect your information, we do not and cannot guarantee that there will be no unintended disclosures or losses of your information or that unauthorized third parties will not defeat our security measures or use non-public information for improper purposes. In the event of any loss or damage to your Personal Information, your sole and exclusive remedy will be for Solutions Sports and Spine to use commercially-reasonable efforts to replace or restore the lost or damaged Personal Information from our latest backup of such information that we have maintained in accordance with our standard archival procedures.
**This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of SOLUTIONS SPORTS AND SPINE, INC and PROCHIROONLINECE.COM (collectively, “we,” “us,” or “our”) and applies solely to 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 other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
We collect 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, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Personal information does not include:
Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
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 our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
Directly and indirectly from activity on our website (www.hornellp.com). For example, from submissions through our website portal or website usage details collected automatically.
From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities.
To provide you with information, products or services that you request from us.
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
To improve our website and present its contents to you.
For testing, research, analysis and product development.
As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We 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.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category I: Professional or employment-related information.
We disclose your personal information for a business purpose to the following categories of third parties:
Our affiliates.
Service providers.
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any personal information.
Your 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.
Access to Specific Information and Data Portability Rights
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, 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 or commercial purpose for collecting or selling 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 sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
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, 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 providers 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.
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 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.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising 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:
Contacting us via email at [email protected]
Only you or a person registered with the California Secretary of State that you authorize 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. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. 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. 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 select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly 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.
Non-Discrimination
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.
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 notify you by email or through a notice on our website homepage.
Contact Information.
Solutions Sports and Spine, Inc
2600 NE Multnomah St.
Portland, Oregon 97232
Unenforceability. If any part of this Notice is determined to be invalid, illegal, or unenforceable, pursuant to applicable law, then the invalid, illegal, or unenforceable provision will be deemed superseded by a valid, legal, and enforceable provision that most closely matches the intent of the original provision, and the remainder of this Notice shall continue in full force and effect.
©2020 Solutions Sports and Spine, Inc All rights reserved.