WHAT ARE YOUR RIGHTS?
A new European Union law, called the General called the General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. Accordingly, we have implemented additional transparency and opt-in opportunities to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:
- Right of Access - the right to be informed of and request access to the personal data we process about you;
- Right to Rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
- Right to Erasure - the right to request that we delete your personal data;
- Right to Restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
- Right to Object -
- the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
- the right to object to your personal data being processed for direct marketing purposes;
- Right to Data Portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
- Right not to be subject to Automated Decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
If we send you electronic marketing messages based on your consent or as otherwise permitted by applicable law, you may, at any time, respectively withdraw such consent or declare your objection (“opt-out”) at no cost. The electronic marketing messages you receive from Hip Sobriety (e.g. those sent via email) also will include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails we send to you).
If you have any questions about your privacy, your rights, or how to implement any of the above send us a request at firstname.lastname@example.org.
WHAT INFORMATION DO WE COLLECT AND HOW?
We collect information from you when you register on the Website, place an order, subscribe to our newsletter, contact us via email, respond to a survey or fill out a form on the Website.
When ordering or registering on the Website, as appropriate, you may be asked to enter your: name, e-mail address, mailing address, phone number or credit card information. You may, however, visit the Website anonymously.
Through your use of Hip Sobriety School, when you register for the Hip Sobriety School program you will be asked to opt-in to a series of surveys. Data collected in the surveys includes:
- Tracking the efficacy of HS on substance use
- The impact of the program on mental health
- The impact of the program on other process addictions
- The impact of the program on life satisfaction.
Additionally, we collect data to measure student engagement in the online community and with our online curriculum and events. Data collected includes:
- Attendance to live events (e.g., Q&As, Labs)
- Engagement level in live events (e.g., Q&As, Labs)
- Engagement level in community forum (e.g., Facebook)
The Hip Sobriety Offerings may contain interactive functionality that allows you to post comments, or to upload photographs and other content (your “User Content”), and otherwise to interact with other users. If you use any interactive functionality that requests or permits you to provide us with personal information (including, for example, any services that allow you to post User Content), we collect the information that you provide to us in the course of using these interactive features. You should be aware that any information you provide in email exchanges, social media groups or similarly non-private environments may be read, collected, and used by others who access these areas.
WHAT DO WE USE YOUR INFORMATION FOR?
Any of the information we collect from you may be used in one of the following ways:
- To provide the Hip Sobriety Offerings and information that you request.
- To personalize your experience. Your information helps us to better respond to your individual needs.
- To improve customer service. Your information helps us to more effectively respond to your customer service requests and support needs.
- To process transactions. Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested.
- To send periodic emails. The email address you provide for order processing, may be used to send you administrative information and updates pertaining to your order, in addition to receiving occasional news, updates, related product or service information, etc. from us. If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
- To measure the success of the Hip Sobriety program. Hip Sobriety is dedicated to tracking the results and efficacy of the program and is partnering with Buffalo School of Medicine to determine the Outcomes of our program. The data collected in the surveys you can choose to opt into will be used in this study. Also the engagement and participation data from the course will be used to determine how the community impacts your progress in the program
DO WE DISCLOSE ANY INFORMATION TO OUTSIDE PARTIES?
Information about our users, including personal information, may be disclosed and otherwise transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
HOW DO WE PROTECT YOUR INFORMATION?
We implement a variety of reasonable security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information.
For example, we offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway provider’s database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential.
Please be aware, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any information that you provide to us. You transmit information to us at your own risk, and you are responsible for all personal information you submit to us.
PASSIVE INFORMATION COLLECTION
When you visit our Website or use Hip Sobriety Offerings, some information is collected automatically. For example, when you access our Website, we automatically collect certain information, which may include your browser’s Internet Protocol (IP) address, your browser type, the type of device from which you are visiting the Website, the identifier for any handheld or mobile device that you may be using, the website that you visited immediately prior, the actions you take on our Website, and the content, features, and activities that you access and participate in on our Website. We also may collect information regarding your interaction with e-mail messages, such as whether you opened, clicked on, or forwarded a message.
We may collect this information passively using technologies such as standard server logs, cookies, and clear GIFs (also known as “web beacons”). We use passively-collected information to administer, operate, and improve the Website and our other Hip Sobriety Offerings, and to provide content that is tailored to you. If we link or associate any information gathered through passive means with personal information, or if applicable laws require us to treat any information gathered through passive means as personal information, we treat the combined information as personal information under this Policy. Otherwise, we use and disclose information collected by passive means in aggregate form or otherwise in a non-personally identifiable form.
THIRD PARTY LINKS
Occasionally, at our discretion, we may link to third party websites on our Website or in the Hip Sobriety Offerings. These third party websites have separate and independent privacy policies and may set cookies on your hard drive or use other means of passively collecting information about your use of their services or content. We do not have access to, or control over, these third-party means of passive data collection and have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Website and welcome any feedback about these third party websites.
Our servers and data centers are located in the United States. If you choose to use any Hip Sobriety Offerings from outside the United States, then you should know that you are transferring your personal information outside of your region and into the United States. for storage and processing. By providing your personal information to us through your use of any Hip Sobriety Offerings, you agree to the transfer, storage, and processing of your data in the United States. Also, we may transfer your data from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Hip Sobriety Offerings. You should know that each region can have its own privacy and data security laws, some of which may be less stringent as compared to those of your own region.
Last Updated: May 25, 2018.