1.   Purpose 

This privacy policy has been compiled to better serve those interested in how ‘Personally identifiable information’ (PII) is used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle Personally Identifiable Information in accordance with our website.  

 

2.   Use of Information 

In order to make your experience on our Website as valuable as possible, registration is recommended.  During registration you will be asked to provide certain required and optional contact information, demographic information and unique identifiers.  We use this information so that the Content that we make available to you through our Website is only the content that you have requested and is tailored to your needs.  We also collect non-personal information from you about your use of our Website, emails and special promotions that we send to you.   

2.1  What We Collect 

What personal information do we collect from the people that visit our website, blog or app? When registering on our site, you may be asked to enter your name, email address, phone number or other details to help resolve your caregiving challenges.  

We store information that we collect through log files and/or third parties to create a profile of our users.  A profile is stored information that we keep on individual users that detail his/her viewing preferences.  Consequently, collected information is tied to the user’s personally identifiable information to provide offers and improve the content of our Website for users. This profile is used to tailor a user’s visit to our Website, and to direct pertinent marketing promotions to the user. 

2.2  Aggregate Data 

We create aggregate data about visitors to our Website to assist us in developing and improving our Website and Content.  We also use aggregate data for market analysis. We may provide information from our Website in aggregate form, with personal identifying information removed, to third parties.  For example, we may tell a health care partner what percentage of our users reside in a particular geographical area or we may provide information to a potential advertiser of a product that would appeal to a diabetes patient about what percentage of our users are utilizing the diabetes health content.  Depending on our agreement with the third parties, we may or may not charge our partners for this information. 

2.3  When Do We Collect it?  

We collect information from you when you fill out a form or enter information on our site.  

2.4  How do we use your information?  

We may use the information we collect when you register for services to facilitate the granting of access to our blogs, newsletters, surveys or marketing communication, provide a rich website browsing experience, or use certain other site features.  

We may target our advertising or marketing depending on information we have about you.  For example, a user we know is a woman may receive advertising for products targeted at women that a male user will not see, or a user that we know has utilized the dressing assessments may receive advertising for dressing aides.(although in neither case will the advertiser have access to any individually identifiable information about you through us without your permission).  Information about users’ visits to our Website, such as number of times they have viewed an ad (but not necessarily user name, address or other personal information), may be provided to advertisers who serve ads to users on our Website.

2.5  Do we use ‘cookies’?  

A cookie is a piece of data stored on the user’s computer tied to information about the user.  We use cookies on this Website to recognize you for simplified log in, to ease your navigating the website and to chronicle utilization of our website. If users reject our cookies, they may still use our website.  These cookies can be removed by following Internet browser help directions. 

This privacy statement covers the use of cookies by this Website.  Please be aware that we are not responsible for the use of cookies by any advertisers or other third parties who are linked to this Website.  We encourage our users to be aware when they leave our Website and to read the privacy statements of each and every website that that they visit.You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Each Web browser can be a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies. If you disable cookies, some features will be disabled that make your site experience more efficient and some of our services will not function properly.  

 

3.   Third Parties 

In addition to sharing aggregate data we may share some other kinds of information with third parties. 

Promotional/Special Offers. If you affirmatively consent to receive e-mails from a third party business through the use of an opt-in box, we may provide that business with your name and email address.   
Business Transfers. If we transfer a business unit (such as a subsidiary) or an asset (such as our Website) to another entity, we will transfer all or part of the information we hold to them but will require them to agree to honor the applicable terms of this privacy policy. 
Legal Requirements. We may release personal information, if, in our judgment after review by an attorney, the release is compelled by law or regulation, or if the release is necessary to prevent the death or serious injury of an individual. 
Subsidiaries.  WE may disclose personal information to its corporate subsidiaries and sister corporations. Any personal information provided to subsidiaries or sister companies of WE will be treated by those subsidiaries in accordance with the terms of this privacy statement.

3.1  Third Party Disclosure  
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information, unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties have formally committed to keep information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.  However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.  

3.1  Third Party Links  

We do not include or offer third party products or services on our website.  

3.3  Google  

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en. We have not enabled Google AdSense on our site but we may do so in the future.   

3.4  Notifications 

Users will be notified of any privacy policy changes on our Privacy Policy Page. Users are able to change their personal information by emailing us at privacy@family-first.com  

 

4.   Tracking 

4.1  “Do Not Track” Signals 

We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.  

4.2  Third Party Behavioral Tracking  

It’s also important to note that we do not allow third party behavioral tracking.  

4.3  COPPA (Children Online Privacy Protection Act)  

When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under 13.  

 

5.   Fair Information Practices  

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.  

In order to be in compliant with Fair Information Practices we will take the following responsive action, should a data breach occur:  

We will notify the users via email within 7 business days  
We will notify the users via in site notification within 7 business days  
We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.  

 

6.   CAN SPAM Act  

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and imposes penalties for violations. We collect your email address in order to:  

Send information, respond to inquiries, and/or other requests or questions.  
To be in accordance with CANSPAM we agree to:  
NOT use false, or misleading subjects or email addresses  
Identify the message as an advertisement in some reasonable way  
Include the physical address of our business or site headquarters  
Monitor third party email marketing services for compliance, if one is used.  
Honor opt-out/unsubscribe requests in a prompt manner. Allow users to unsubscribe by using the link at the bottom of each email  

If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.  

In the event you have questions about this privacy policy or would like to report an incident or compliance concern, please contact security@family-first.com. 

 

7.   Communications from our Website 

7.1  Confirmation

We send all new users a welcoming email to verify passwords and usernames as well as to confirm the information that the user has chosen to receive.  

7.2  Promotional/Special Offers

Sometimes we may communicate offers to selected groups of users on behalf of other businesses.  When we do this, we do not give that business your name and contact information.  In other situations, we may provide you an opt-in box to consent to receiving an email from a business, and we make clear that by opting in you consent to submitting your data to that third party.  You can always opt-out of receiving such emails at the time you register or at any time; see Choices/Opt-out below for more details about opting-out. 

7.3  Website and Service Announcements

We communicate with our users for Website and service announcement updates.  We may send you an announcement of the introduction of a new service through our Website that may be of interest to you.   On rare occasions it also may be necessary to send out a strictly service related announcement.  For instance, if our service is temporarily suspended for maintenance we might send users an email.  Generally, users may not opt-out of these communications, though they can deactivate their account.  However, these communications are not promotional in nature. 

7.4  Customer Service

We communicate with users on a regular basis to provide the requested Content and in regard to issues relating to their account we reply via email or phone, in accordance with the users wishes. 

 

8.   Choice / Opt-Out 

Our users are given the opportunity to ‘opt-out’ of having their information used for purposes not directly related to our Website at the point where we ask for information.  

Users who no longer wish to receive the additional information and special offers may opt-out of receiving these communications by emailing us at 

 

9.   Links 

Our Website may contain links to other websites. Please be aware that we not responsible for the privacy practices of such other websites.  We encourage our users to be aware when they leave our Website and to read the privacy statements of each and every website that collects personally identifiable information.  This privacy statement applies solely to information collected by our Website. 

 

10.   Security 

Protecting your privacy and personal information is a top priority.  We have taken careful measures to secure both your information and the physical location of our servers.  All of our users’ information is restricted in our offices.  Only our associates who need the information to perform a specific job are granted access to personally identifiable information.  Furthermore, all associates are kept up-to-date on our security and privacy practices.  Every quarter, as well as any time new policies are added, our associates are notified and/or reminded about the importance we place on privacy, and what they can do to ensure our users’ information is protected. 

 

11.   Correcting/Updating/Deactivating Personal Information 

If a user’s personally identifiable information changes or if a user no longer desires to receive the Content, we provide a way to correct, update or deactivate a user’s personally identifiable information.  This can usually be done at the member information page or by emailing our Customer Support at security@family-first.com  By indicting that you no longer want to receive the Content, you will continue to receive additional information and special offers.  If a user also no longer wishes to receive the additional information and special offers, see Choices/Opt-out above for more details about opting-out.

 

12.   Notification of Changes to Privacy Policy 

If we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.  We will use information in accordance with the privacy policy under which the information was collected.  

If, however, we are going to use users’ personally identifiable information in a manner different from that stated at the time of collection we will notify users via email. Users will have a choice as to whether or not we use their information in this different manner.  However, if users have opted out of all communication with our Website, then they will not be contacted, nor will their personal information be used in this new manner.  In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our Website notifying users of the change. In some cases where we post a notice we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices.