St Tammany Health System Privacy
Notice
Effective Date: 10-10-2023
St Tammany Health System (“we” or “us”) is committed to protecting
the privacy of all individuals (“you”
or “your”) who utilize the App (as
defined in the End User License Agreement). This statement explains how we and
our service providers (“we” or “us”) collect, use, and safeguard the
information you may provide to us via the App.
1.
WHAT
INFORMATION DO WE COLLECT FROM YOU?
We may collect certain information related to
your use of the App. We collect personal information and non-personal
information (collectively referred to as “information”
throughout this Privacy Notice).
When we use the term “personal information” in this Privacy Notice, we mean information
about you that is personally identifiable to you, including information that is
considered “protected health information” under Federal law, if any. We collect
the following personal information from you:
●
Your precise geolocation within St
Tammany Health System facilities as of a specific date and
time.
As stated above, we also collect information
that does not identify you (“non-personal
information”). The information we collect is limited to technical
information. When you access the App from a mobile device, we may collect
non-personal information from your use of the mobile device, including:
●
The date and time use of the App
started and stopped;
●
The route taken while using the App;
●
Your mobile device manufacturer,
model, and operating system and version;
●
Any errors detected while using
the App;
●
Any wi-fi signal observed (if
using an Android device); and
●
The version of the App and map used;
In order to collect
the above information, we, or our service providers (such as Purple Wifi),
utilize certain tracking technologies, such as Bluetooth beacons, WiFi, and
geomagnetic positioning.
2.
HOW YOUR
INFORMATION IS USED
We collect, retain, and use your
personal information for the following purposes:
●
To provide you the services and
products you requested;
●
To operate and improve the App;
●
To respond to an inquiry from you;
●
To create aggregated,
non-personal information, or to create de-identified information;
●
To comply with applicable laws, regulations
or legal process;
●
To comply with requests of
relevant regulatory and law enforcement and/or other governmental agencies or
authorities; and
●
To enforce our End User License
Agreement; and/or to protect the rights, property, or safety of St Tammany
Health System and other users of the App.
We may use any non-personal
information for purposes permitted by and subject to applicable law, since
non-personal information cannot identify you as an individual. For example, we
may use non-personal information collected to monitor visitor traffic patterns
and App usage and to improve the App. We may also use non-personal information
in the aggregate to create summary statistics that help us analyze App usage
trends, determine technical design specifications, arrange the App in a
user-friendly way, and identify system performance or problem areas. We also
use non-personal information to protect the security and integrity of the App.
3.
WHEN WE
SHARE YOUR PERSONAL INFORMATION
●
We share your information in the following
circumstances:
●
Service
Providers. We may
share your information with affiliated and unaffiliated companies (such as
Purple Wifi) that perform tasks on our behalf related to our business. Such
tasks include analyzing usage data, fixing errors in the App, and protecting
the security and integrity of the App. Third-party service providers receive
your information as necessary to perform their role, and we instruct them not
to use your information for any non-permitted purposes.
●
As
Required by Law. We will disclose your information as necessary or appropriate,
including as required by law, regulation, subpoena, court order, legal process
or government request; to enforce our End User License Agreement, including
investigations of potential violations thereof; to detect, prevent or otherwise
address fraud, security or technical issues; when we believe in good faith that
disclosure is necessary to protect your safety or the safety of others; to
protect our rights, to investigate fraud, or to respond to a government
request.
●
Business
Transfers. We may,
in the future, sell or otherwise transfer some or all of
its assets to a third party. The information we obtain from you via the App may
be disclosed to any potential or actual third-party purchasers of such assets
and/or may be among those assets transferred in accordance with applicable law.
4.
YOUR
PRIVACY CHOICES
Depending on where you live, you may have the
following rights with respect to your personal information, to the extent
applicable to the App:
·
Access
·
Data portability
·
Erasure
·
Correction
·
Opt out of sales of personal information
For a description of these rights, please see
the applicable chart in Section 10 of this Privacy Notice. In addition, you may have the right to opt
out of targeted advertising and profiling, to the extent that profiling makes
decisions that produce legal or similarly significant effects concerning you.
To exercise any of these rights available to you, see Section 12 below.
5.
CHILDREN
The App prohibits children under 13 to become users, and we do not collect information from
children. By using the App, you represent that you are not under the age of 13.
Any information we receive from users we believe to be under the age of 13 will
be purged from our database.
6.
THIRD
PARTY WEBSITES
St Tammany Health System may reference or provide links to third
party websites or St Tammany Health System ’s
other websites. You should review the privacy notices posted on such sites, as
those privacy notices will control once you are directed to those websites.
Please be aware that St Tammany Health System does not control, nor are we
responsible for, the privacy notices or information practices of third parties
or their websites.
7.
RETENTION
We have policies and procedures
relating to the retention of personal information based upon a classification
scheme consisting of business functions and process areas, and the classification
and types of data and records. We retain personal information for as long as we
reasonably require it for business and legal purposes. In determining data
retention periods, we consider contractual and legal obligations, and the
expectations and requirements of customers, vendors, suppliers
and others who disclose their personal information with us. When we no longer
need personal information, we securely delete or destroy it.
8.
SECURITY
We employ security systems designed to
protect the personal information we receive from you from unauthorized
disclosure. We make commercially reasonable efforts to keep your personal information
secure using appropriate technical, physical and
organizational measures to prevent against unlawful
use, alteration, unauthorized access accidental destruction and loss. No
transmission of data over the internet is guaranteed to be completely secure.
Due to the nature of the internet, we cannot guarantee that information, during
transmission through the internet or while stored on its system or otherwise in
its care, will be absolutely safe from intrusion by
others, such as hackers. Because
security is important to both St Tammany Health System and
you, we will always make reasonable efforts to ensure the security of our
systems.
9.
UPDATES
We may update this Privacy Notice from time
to time to reflect changes to our information practices. We will provide you
with advance notice of a major change prior to your access of any portion of
the App. For example, we may (i) require
that you re-accept the updated version of this Privacy Notice, (ii) send you an
electronic notification advising of the update to this Privacy Notice, or (iii)
include a notice on the App. We do not
ordinarily provide advance notice of a minor change.
We encourage you to periodically review this
page for the latest information on our privacy practices. You can tell when
changes have been made to the Privacy Notice by referring to the “Effective
Date” legend on top of this page.
10.
CALIFORNIA
RESIDENTS
This section supplements the
information above and applies solely to California residents whose personal
information is subject to California Consumer Privacy Act, as amended by the
California Privacy Rights Act and its regulations (“CCPA”).
During the last twelve (12)
months, St Tammany Health System collected
the following categories of personal information from California consumers:
●
Geolocation data; and
●
Sensitive personal information, including
precise geolocation.
St Tammany Health System collects the categories of
personal information listed above from the following categories of sources:
●
Directly from you; and
●
Our service providers.
St Tammany Health System collects the categories of
personal information listed above for the following business and/or commercial
purposes:
●
Providing the requested services, such as
operating the App or responding to inquiries;
●
Enhancing your user experience;
●
Monitoring and maintaining the security and
functionality of the App; and
●
For compliance and legal obligations, and to
exercise our legal rights.
During the last 12 months, St Tammany Health
System has disclosed personal
information in accordance with the below chart:
Categories
of Personal Information We Collect
|
Categories of Third Parties to Which
We Disclose Personal Information for a Business or Commercial Purpose
|
Categories
of Third Parties to Which We May Sell or Share Personal Information
|
Geolocation
data
|
Service
providers
|
We do
not sell or share personal information.
|
Sensitive
personal information, including precise geolocation
|
Service
providers
|
We do
not sell or share personal information.
|
Please see Section 7 with regard to our data retention practices.
We will not collect additional
categories of personal information or use the personal information collected
for materially different, unrelated, or incompatible purposes without providing
notice to the California consumer, unless required or permitted by applicable
laws.
We also do not knowingly sell or
share personal information of consumers under the age of 16.
Subject to certain exceptions, if
you are a resident of California, you may have the following rights:
Privacy
Right
|
Description
|
Notice
|
The right to be notified of
what categories of personal information will be collected at or before the
point of collection and the purposes for which they will be used and shared.
|
Access
|
The right
to request the categories of personal information that we collected in the
previous twelve (12) months, the categories of sources from which the
personal information was collected, the specific pieces of personal
information we have collected about you, and the business purposes for which
such personal information is collected and shared. You may also have the
right to request the categories of personal information which were disclosed
for business purposes, and the categories of third parties in the twelve (12)
months preceding your request for your personal information.
|
Data Portability
|
The right to receive the
personal information you have previously provided to us.
|
Erasure
|
The right to have your personal
information deleted. However, please be aware that we may not fulfill your
request for deletion if we (or our service provider(s)) are required or
permitted to retain your personal information for one or more of the
following categories of purposes: (1) to complete a transaction for which the
personal information was collected, provide a good or service requested by
you, or complete a contract between us and you; (2) to ensure our website
integrity, security, and functionality; (3) to comply with applicable law or
a legal obligation, or exercise rights under the law (including free speech
rights); or (4) to otherwise use your personal information internally, in a
lawful manner that is compatible with the context in which you provided it.
|
Correction
|
You
have the right to request that we correct any incorrect personal information
that we collect or retain about you, subject to certain exceptions. Once we
receive and confirm your verifiable consumer request (see below), we will
correct (and direct any of our service providers that hold your data on our
behalf to correct) your personal information from our records, unless an
exception applies. We may deny your correction request if (a) we believe the
personal information we maintain about you is accurate; (b) correcting the
information would be impossible or involve disproportionate; or (c) if the
request conflicts with our legal obligations.
|
Automated
Decision Making
|
You
have the right to request information about the logic involved in automated
decision-making and a description of the likely outcome of processes, and the
right to opt out. St Tammany Health System does not currently engage in
any automated decision-making practices.
|
To Opt
Out of Sales or Sharing of Personal Information
|
St
Tammany Health System does not sell or share your
personal information. If we did, you would have the right to opt-out of the
sale and sharing of your personal information. When you opt-out
of sales, we will not share your personal information with our advertising
vendors or marketing partners.
However, for personal information already shared, you will need to
submit your access, deletion, and opt-out requests to each partner
individually. When you opt out of sharing, we will not share your personal
information with third parties for purposes of cross-context behavioral
advertising.
|
Limit
Use of Sensitive Personal Information
|
St
Tammany Health System does not use or disclose
sensitive personal information other than to provide our services to you.
However, if we used or disclosed sensitive personal information for other
purposes, you would have the right to opt out.
|
Only you or a person who is authorized to act on your behalf
(“Authorized Agent”) may make a request related to your personal information.
Requests may also be made on behalf of a minor child. Requests must:
●
Provide sufficient information that allows St
Tammany Health System to reasonably verify the requestor is
the person about whom the Personal Information is collected or an Authorized
Agent and
●
Describe the request with sufficient detail
that allows St Tammany Health System to
properly understand, evaluate, and respond to it.
●
You, or your Authorized Agent, may submit
requests to St Tammany Health System by sending an email to St Tammany Health
System at sths.play@gmail.com.
●
St Tammany Health System cannot
respond to requests or provide personal information if it is unable to verify a
requestor’s identity or authority to make the request and confirm the personal
information relates to the requestor. Making a request does not require you to
create an account with St Tammany Health System. Personal information provided
for identity verification for such requests will only be used to verify your
identity or authority to make the request.
●
Identity Verification Requirements. In order to verify your identity, you may need to submit
certain information. St Tammany Health System will
match this information against information St Tammany Health System has
previously collected about you to verify your identity. If an Authorized Agent
is being utilized for a request, St Tammany Health System will
require proof of the Authorized Agent’s authority. If we are unable to verify
your identity, your request may be denied.
●
Depending on the nature of the personal information which is the subject of your request, our
verification process may include using existing authentication practices or
matching two or three additional data points, and may also include submitting a
declaration.
●
Non-Discrimination. St
Tammany Health System will not discriminate against you for
exercising any rights under applicable privacy law.
●
Appeals: If you
are not satisfied with the resolution of your request and would like to submit
an appeal, please submit your appeal using the information provided above.
11.
USERS
FROM OUTSIDE THE UNITED STATES
This App is hosted in the United States and is
governed by United States law. If you are using the App from outside the United
States, please be aware that your information may be transferred to, stored,
and processed in the United States where our (or our service provider’s)
servers are located. The data protection and other laws of the United States
and other countries might not be as comprehensive as those in your country. By
using the App, you consent to your information being transferred to our
facilities and to the facilities of those third parties with whom we share it
as described in this Privacy Notice.
12.
QUESTIONS
REGARDING THIS PRIVACY NOTICE
If you have any questions regarding this
Privacy Notice please contact St Tammany Health System at
sths.play@gmail.com or the following address and phone number:
St
Tammany Health System
Attn:
Privacy Officer
1202 S.
Tyler St. Covington, LA 70433
Email: sths.play@gmail.com
Phone: