1.   Purpose 

This privacy policy describes how Family First ("us", "we", or "our") collects, uses, or discloses ‘Personally identifiable information’ (PII) through www.family-first.com or our other online or offline services (collectively the "Service"). PII generally refers to 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. This policy also describes your choices about the collection and use of your information. Please read this privacy policy carefully before you start to use our Service. By using the Service, you agree to be bound and abide by this policy and our posted Terms of Service (the “Terms”). Please see Sections 12-14 of our Terms regarding your legal rights in any dispute involving our Service. 

Certain caregiving services we provide are subject to a separate Acknowledgment of Terms and Conditions for Family First’s Solutions, which includes more stringent commitments for the privacy of sensitive caregiving information, and where applicable, those stringent commitments will supersede this policy in the event of any conflict. 

 

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. 

We collect payment information (e.g., credit card) solely for one-time or recurring payments, as applicable. We collect additional information that you provide to us, such as in response to surveys, feedback you provide, or in other communications (via email, web form, mail, phone, social media, etc.);  If you provide us with information regarding another individual, you represent that you have any necessary authorization to give us their information and to permit us to use it in accordance with this policy. 

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 directly from you both online (e.g., our website) and offline (e.g., phone, in-person).  We may also receive information from other third-party sources and social media platforms that you may use to engage with us, as well as from partners or third parties we work with. 

2.4  How do we use your information?  

We may use the information we collect to operate, evaluate, and improve our Service, including  access to our blogs, newsletters, surveys or marketing communication, a rich website browsing experience, customer support and to tailor the content that we provide to you in our Service and communications.   

We also use such information for internal purposes, such as data analysis, audits, developing new products and features, enhancing our website, improving our products and services, identifying usage trends, and determining the effectiveness of our promotional campaigns. 

There are also some administrative purposes, including to inform you about changes to our policies and terms, and to comply with and enforce as needed applicable legal requirements, industry standards, our policies, and our contractual rights. 

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.

In some instances there may be additional purposes that are disclosed to you at the time your information is collected or in a request for your consent. We may use and disclose non-personal, non-individual statistics or demographic information in aggregate form without restriction. 

2.5  How do we protect your information?   

We implement appropriate technical and organizational measures to protect your personal information, including: 

  • Data Encryption: We encrypt data at rest using AES-256 and data in transit using TLS 1.2. 
  • Access Controls: We enforce role-based access controls (RBAC) and multi-factor authentication (MFA) for internal access to sensitive data. 
  • Audit Logging: We log all access to sensitive data, including medical-related data, and regularly monitor for unauthorized access. 
  • Data Minimization: We store only necessary personal data and delete/anonymize unnecessary data after the retention period.
  • Data Retention and Disposal: We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law. After the applicable retention period, personal information will be securely deleted, anonymized, or otherwise disposed of using industry best practices to prevent unauthorized access 
2.6  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. We can also use such information to deliver customized content and advertising to users of the Service whose behavior indicates that they are interested in a particular subject area, and measure the effectiveness of advertisements and web searches. If users reject our cookies, they may still use our website.  These cookies can be removed by following Internet browser help directions.  

When you use the Service, such as our Website, the information we may collect by automated means includes, for example: 

  • Usage Details about your interaction with our Service (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses); 
  • Device Information of a device that you use to connect with our Service (such as device type and unique device identifier, operating system, browser type, and mobile network information); and 
  • Location information where you choose to provide the website with access to information about your device’s location. 

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 for monetary compensation.  

  • We may share online identifiers with analytics and advertising partners through tools running on our Services as described above.  
  • We may share your information as permitted by law, including, for example, with legal affiliates and service providers that we believe need the information to perform a technology, business, or other professional function for us (examples 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, investigate suspected fraud or illegal activity, or to protect ours or others’ rights, property, or safety.   
  • We may transfer information that we maintain in the event of a contemplated or actual sale or transfer of all or a relevant portion of our business or assets. If such an event occurs, we will make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this policy. 

No mobile phone number information will be shared with third parties/affiliates for their marketing or promotional purposes. We may provide such information to service providers providing related support services to us.  

3.2  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. Users are able to change their personal information by emailing us at security@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  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. Our Service is for a general audience and we do not specifically market to children under 13.  If a child has provided us with personal information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 13, please contact us at privacy@family-first.com. 

 

5. International Considerations

Our Service is intended for use in the United States. If you use our Service from outside the United States, you acknowledge and agree that we may transfer your information to and from the United States, including countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this policy regardless of where your personal information is stored or accessed. Notwithstanding the foregoing, we will endeavor to accommodate requests with respect to your information to the extent required by law and otherwise in our reasonable discretion.  

 

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.   

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  security@family-first.com. 

 

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 designed to secure both your information and the physical location of our servers.  All of our users’ information is restricted in our offices and our services providers.  Only our associates who need the information to perform a specific job are granted access to personal information.  Furthermore, all associates are kept up-to-date on our security and privacy practices.   

Incident Response and Data Breach Notification: In the event of a data breach, we have an established incident response plan to assess, mitigate, and contain threats. If required by law, affected users will be notified promptly of any unauthorized access to their personal information. Notification may be through email, website postings, or other means as necessary.

 

11. State-Specific Notices

Certain privacy laws may provide additional rights with respect to the collection and use of personal information collected by businesses: (i) disclose personal information maintained about the individual; (ii) correct or delete personal information maintained about the individual (subject to certain exceptions); (iii) not sell personal information about the individual to a third party (excluding qualified service providers); and (iv) not engage in third party targeted advertising. We do not engage in impactful profiling activities with respect to user’s personal information, do not use sensitive personal information except for the reasons provided, and do not generally provide a financial incentive in return for the collection or use of personal information (except where disclosed with relevant terms at the time of collection). We do not share personal information to third parties for their own direct marketing purposes. It can be unlawful to discriminate against an individual for exercising such rights. Due to our size and operations, we may not be subject to any particular state’s privacy laws, but you can submit such requests to us by emailing our Customer Support at security@family-first.com and we will endeavor to fulfill any obligations that are legally required, otherwise we will respond to such requests in our discretion. 

Note that you may be able to access, correct and delete certain information, as well as address certain profile settings, at the member information page. By indicting that you no longer want to receive Content from us, 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.