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PRIVACY POLICY
Last Updated: May 27, 2024

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AS WELL AS YOUR CHOICES AND RIGHTS. IF YOU DO NOT AGREE WITH THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SITE OR THE REGISTRY.

THE SITE AND THE REGISTRY ARE INTENDED FOR INDIVIDUALS LOCATED IN THE UNITED STATES AND AUSTRALIA. THEY ARE NOT INTENDED FOR INDIVIDUALS LOCATED IN OTHER COUNTRIES, INCLUDING THE EUROPEAN UNION, THE EUROPEAN ECONOMIC AREA, AND THE UNITED KINGDOM.

INTRODUCTION

Institute for Chronic Traumatic Brain Injury, LLC (“we,” “us,” and “our”) is committed to protecting the privacy of individuals and the security of the personal information that we collect, use, hold, disclose, process, and otherwise handle as part of fulfilling our organizational mission. We also believe in transparency, and we are committed to telling you about how we treat the personal information that we collect and process.

This Privacy Policy (the “Policy”) describes our practices for handling the personal information collected when you visit one of our websites that link to this Policy (collectively, the “Site”) and if you decide to participate in our voluntary data registry for individuals who have experienced chronic traumatic brain injuries (the “Registry”).

If you are in Australia, we are committed to dealing with your personal information in accordance with the Privacy Act 1988 (Commonwealth of Australia) (“Australian Privacy Act”) and the Australian Privacy Principles (“APPs”).

HOW DO WE COLLECT, USE, AND DISCLOSE PERSONAL INFORMATION?

We collect information about you and your interactions with us. The types of personal information we may collect about you will depend upon the nature of our interaction with you. We may collect personal information directly from you or from a third party such as your family, friends, or caregivers. We will only collect your personal information from a third party with your consent. If the personal information we collect includes sensitive information, we will ask for your consent to collect this sensitive information unless the law allows us to collect the information without your consent. We collect, use, and disclose personal information as described in this Section.

Cookies and Similar Technologies

 

What are first and third-party cookies? A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” cookie). “Session” cookies are temporarily stored on your device and remain there until they expire at the end of your browsing session. “Persistent” cookies remain stored on your device until they expire or are deleted by you. Local shared objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you are visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.

 

What are “similar technologies”? In addition to cookies, there are other data collection technologies, such as Internet tags, web beacons, pixels (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as you navigate through and interact with a website. For example, web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about your browsing, such as which advertisement, page, or publisher sent you to the receiving website.

 

What cookies and similar technologies are in use on the Site? The Site uses cookies and similar technologies and discloses information contained in those cookies to operate and improve the Site and operations; to provide our content, services, and functionality; to ensure the privacy and security of our Site and services; to honor our terms of service and contracts; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to improve our marketing efforts; to assess our marketing campaigns; to enhance your experience and provide you with a more personal and interactive experience; to create, use, retain, and disclose de-identified and/or aggregated data; to determine user interests and needs; and to recognize your device and remember your preferences.

 

Google Analytics. We use Google Analytics to collect and process statistical data about the number of people using the Site and to better understand how they find and use the Site. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions. The information stored is reduced to a random identifier. Any data collected is used in accordance with this Policy and Google’s privacy policy. You may learn more about Google Analytics by visiting https://www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245. You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy at: https://www.google.com/policies/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page located at https://support.google.com/analytics/answer/181881?hl=en.

 

Google Tag Manager. The Site uses Google Tag Manager, which allows marketed website tags to be managed using an interface. The tool itself (which implements the tags) does not use cookies and does not register identifiable data. The tool causes other tags to be activated which may, for their part, register personal data under certain circumstances. Google Tag Manager does not access this information.  Google Tag Manager is subject to the Google Privacy Policy located at https://www.google.com/intl/en/policies/privacy.

 

Google Marketing. We use certain Google marketing technologies to track user activity on the Site and to serve personalized advertisements. Your browser is assigned an ID used to track the ads that have been served to your browser and to identify those on which you’ve clicked. The cookies enable Google and its partners to select and display ads based on your browsing behavior. For more information    on    how    Google    uses    this    information,    you    can    visit https://policies.google.com/technologies/ads, https://support.google.com/displayvideo/answer/7621162, and https://support.google.com/google-ads/answer/7548399?hl=en. To block certain ads served by Google, please visit https://support.google.com/ads/answer/2662922. Google’s Privacy Policy is available at: https://www.google.com/policies/privacy.

 

Other third-party technologies. Some third parties may use data collection technologies to collect information about you when you browse the Internet. We do not control these third parties’ technologies or how they may be used. If you have questions about targeted content, you should contact the responsible party directly or consult their privacy policies.

 

Choices about cookies and similar technologies. Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being stored. These settings may affect your enjoyment of the Site’s functionality. Adjusting the cookie settings may not fully delete all of the cookies that have already been created. To delete them, you should review your web browser settings after you have changed your cookie settings. The links below provide additional information about how to disable cookies or manage the cookie settings:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09 

Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac and https://support.apple.com/en-us/HT201265

For more information about how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/. You may learn more about internet advertising practices and related consumer resources at https://youradchoices.com/control, https://thenai.org/about-online-advertising/faq, and http://www.networkadvertising.org/choices.

 

Other Disclosures. In addition to those disclosures set out in the table above, where permitted by applicable law, we may disclose your personal information in the following contexts. However, we will only disclose Registry Information as set out in the table above.

Other Processing Activities. We will  also collect, hold, use, and process your personal information described above to:

  • Comply with applicable laws;

  • Comply with civil, governmental, regulatory, and legal inquiries, warrants, orders, subpoenas, summonses, and/or other process;

  • Cooperate with law enforcement agencies;

  • Facilitate corporate mergers, acquisitions, reorganizations, dissolutions, and similar transactions;

  • Obtain and maintain insurance coverage and professional advice;

  • Investigate, prevent, and take action regarding illegal activities, fraud, safety of person or property, and/or a violation of our contracts or terms, all in accordance with applicable laws;

  • Establish, exercise, or defend legal rights or claims; and

  • Other purposes to which you may consent from time to time.

 

Location of Personal Information. We are located in the United States, and your personal information will be transferred to, stored in, and processed in the United States. If you are located in Australia, this may include disclosure of your personal information to recipients outside of Australia, including to recipients in the United States. We store your information in the United States using a service provider named CereHealth Corporation. By using the Site or participating in the Registry, you agree and consent to the storage and processing of your personal information in the United States, which may not offer the levels of protection required in other countries. If you are located in Australia, in general, we will obtain your express written consent prior to disclosing any of your personal information outside of Australia. Where we are unable to obtain your express written consent to disclose information outside of Australia, we will take reasonable steps to ensure that any such person to whom personal information is disclosed will deal with that information in a way that is consistent with the APPs.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We will keep your personal information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to fulfill our organizational mission, and to enforce our agreements.

 

We will delete information where required by law. Also, we may delete your information if we believe it is incomplete, inaccurate, or that our continued storage of it is contrary to our objectives or legal obligations. We will destroy or de-identify your personal information if we no longer need it for any purpose for which it was collected, provided we are not otherwise required to retain the information under applicable law.

 

Please note, unless prohibited by law, we will retain and use de-identified and/or aggregated information for as long as is permitted under applicable law.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We have adopted security measures that are designed to protect the personal information under our control. From time to time, we review our security procedures and consider new technologies and methods.

 

But, no security system is perfect, and no data transmission is 100% secure. Although we strive to protect personal information, we cannot guarantee or warrant the security of any information transmitted to or from the Site or the Registry. Your use of the Site and Registry is at your own risk. We cannot guarantee that your data will remain secure in all circumstances.

 

If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.

YOUR RIGHTS AND CHOICES

Please use the “Contact Us” details provided at the end of this Policy to exercise your rights and choices under this Policy. We honor requests when we are required to do so under applicable law.

 

Email Preferences. We may send you emails where permitted by applicable law. If you do not want to continue receiving emails from us, including electronic marketing communications, you may opt-out by clicking the “unsubscribe” button at the bottom of our emails or by contacting us at info@chronictbihelp.com. If you contact us by email, please include your name and contact information in your request, and we will respond in accordance with applicable law.

 

Update Your Information. Our goal is to keep your information accurate, current, and complete. If any of your General Contact Information changes, please let us know via any of the “Contact Us” details at the end of this Policy. If any of your Registry Information changes, please contact us via telephone at the number provided in the “Contact Us” section of this Policy. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete personal information that you provide to us.

 

Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.

 

California. Under California Civil Code § 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us, once each calendar year, information about the information we shared (if any) with other businesses for direct marketing uses. We do not currently share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the California’s “Shine the Light” requirements, and only information regarding covered sharing (if any) will be included in our response. As a part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at info@chronictbihelp.com

 

Nevada. Nevada residents may submit a verified request to us at info@chronictbihelp.com to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law.

In addition, Nevada residents have the following rights regarding Registry Information and may excise these rights by submitting a request to us at info@chronictbihelp.com. We will take steps to authenticate the request, and we may request that you provide additional information to confirm your identity. We honor requests in compliance with applicable law. If your request is denied, you may appeal our decision by contacting us at info@chronictbihelp.com.

  • Confirm whether we are collecting, sharing or selling consumer health data relating to you;

  • Provide you with a list of all third parties with whom we have shared consumer health data relating to you or to whom we have sold your consumer health data;

  • Cease collecting, sharing or selling consumer health data relating to you; and

  • Delete consumer health data concerning you.

 

Washington. Washington residents have the following rights regarding Registry Information and may exercise these rights by submitting a request to us at info@chronictbihelp.com. We will take steps to authenticate the request, and we may request that you provide additional information to confirm your identity. We honor requests in compliance with applicable law. If your request is denied, you may appeal our decision by contacting us at info@chronictbihelp.com.

  • Confirm whether we are collecting, sharing, or selling consumer health data concerning you and to access the data, including a list of all third parties and affiliates with whom we have shared or sold your consumer health data and an active email address or other online mechanism that you may use to contact these third parties;

  • Withdraw consent from our collection and sharing of your consumer health data; and

  • Have your consumer health data deleted.

 

Australia. Australia residents may access or request correction of the personal information that we hold about you by contacting us as set out in the “Contact Us” section below. There are some circumstances in which we are not required to give you access to your personal information. There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material). We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate and up to date. If we refuse to provide you with access to your record or to update your record in the way you request, we will provide you with written reasons. If we refuse to correct or update your information, you may request that we make a note on your record that you are of the opinion that the information is inaccurate, incomplete, out of date, irrelevant or misleading, as the case may be.

 

If you have any questions or complaints about how we handle your personal information or think that your privacy has been affected, you should contact us using the “Contact Us” information below to raise your complaint or concern. If you make a complaint, we will consider your complaint and determine whether it requires further investigation. We will endeavor to notify you of the outcome of this investigation, and any subsequent internal investigation, within a reasonable period after the complaint is made. If you remain unsatisfied with the way in which we have handled your privacy complaint or concern, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (“OAIC”) Additional details about how to lodge a complaint with the OAIC can be found at https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us.

THIRD PARTY SITES AND SERVICES

This Policy only applies to the Site and Registry. It does not apply to any websites, applications, or services provided by third parties.

 

The Site may include links to, or content from, third parties. These links are to external resources and third-party websites that have their own privacy policies. It may not always be clear which links are to external third-party websites. If you click on a third-party link, you will be redirected away from the Site. You can check the URL to confirm whether you have left the Site.

 

We cannot and do not (1) guarantee the privacy or security practices of third parties or any content provided by third parties; (2) control third parties’ collection or use or your information; or (3) endorse any third-party information, products, services, applications, or websites.

 

Any information provided by you or collected from you by a third party will be governed by that party’s privacy policy and terms of use. You should review their privacy policy and terms of use carefully.

CHILDREN

We are a non-profit organization, and our Site and services and the Registry are not directed to children under the age of 13, and we do not knowingly collect information from children under the age of 13. No one under the age of 13 may access, browse, or use the Site or Registry, or provide any information to us. If we learn that we have collected or received personal information from a child under the age of 13 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and to delete it. If you believe we have any received information from a child under the age of 13, please contact us using the “Contact Us” details provided below.

If you reside in the United States, for information about the Children’s Online Privacy Protection Act, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

UPDATE AND CHANGES

We may update this Policy from time to time. If we change this Policy, we will post the revised version on our Site. Any changes, updates, and modifications will be effective immediately upon posting. If we make material changes, we may also notify you through a notice on the Site’s homepage, and/or we may send you an email regarding the updates.

 

You should read this Policy carefully before using the Site or Registry, and you should review it from time to time so that you are aware of its current terms. Your continued use of the Site or Registry after the “Last Updated” date will constitute your acceptance of and agreement to any changes and to our collection, use, and sharing of your personal information according to the then-current Policy. If you do not agree with this Policy, you should not use the Site or Registry.

CONTACT US

For more information or if you have questions about this Policy, you may contact us using the information below:

               

Attention:           

 

Mail:                  Institute for Chronic Traumatic Brain Injury

                           777 East Wisconsin Avenue Suite 3500

                           Milwaukee, WI 53202

 

Phone:               +1 (608) 447-8444

Email:                info@chronictbihelp.com

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