Online Services Privacy Policy
Effective June 25, 2020
Effective June 25, 2020
Last Mile Health, a non-profit corporation (“Last Mile Health,” “we,” “us,” or “our”) is committed to protecting the privacy of users of the website located at www.lastmilehealth.org or any website or mobile application owned, operated, licensed or controlled by us (the “Online Services”). This privacy policy (the “Privacy Policy”) describes how we gather and use information about visitors to and users of our Online Services (“Users”). This Privacy Policy applies solely to the information that we collect through the Online Services. This Privacy Policy does not address personal information that you provide to us in other contexts (e.g., through a business relationship not handled through the Online Services).
By using the Online Services, you signify your acceptance of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Online Services. Your continued use of the Online Services following the posting of changes to these terms will mean that you accept those changes.
Personal Information
You may use some of our Online Services without telling us anything about yourself. If you contact us, donate to us, or register for an account via the Online Services, we may ask you to provide Personal Information (as defined below), such as your name, address, telephone number or e-mail address. We may also receive Personal Information about you from third parties, such as our affiliates, business partners, or vendors who we engage to help administer the Online Services.
“Personal Information” for purposes of this Privacy Policy is any information relating to you as an identified or identifiable natural person. An “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
From time to time, our Online Services may be configured to collect domain, usage, and Google Analytics information. This data enables us to become more familiar with which users use our services, how often they visit and what parts of the services they utilize most often. Last Mile Health uses this information to improve our Online Services. No personally identifiable information is gathered in this process. This information is collected automatically and requires no action on your part.
Other Information
“Other Information” is any information that is not Personal Information, such as browser information, app usage data (including quiz attempts, scores and course completion), information collected through cookies and other technologies, demographic information, and aggregated information.
We collect Other Information when you submit it to us. It may include your zip code, education, occupation, and interests.
We may also receive Other Information about you from third-parties, including, for example, demographic data, information about your interests, and information about your activities through the Online Services. Each time a User utilizes the Online Services, Last Mile Health collects some information to improve the overall quality of the User’s online experience.
By accessing and using the Online Services, you expressly consent to the storage of cookies, other local storage technologies, beacons or other information on your computer or devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us.
Sensitive Personal Information
Unless specifically requested (for example, in connection with a particular survey), we ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us. Any requested information that includes sensitive information about health, political opinions, ethnicity, race, religion, sex life or sexual orientation can be left unanswered.
If you choose to provide us with Personal Information by completing a form through the Online Services, including, if applicable, account registration, or emailing us, we will use that Personal Information to (i) respond to your question or request, (ii) communicate with you about our organization via email, (iii) send information to you, and (iv) notify you of changes to this Privacy Policy. If you do not wish to receive unsolicited emails or other communications from us, you may contact us at info@lastmilehealth.org and request that your Personal Information be removed from our list.
We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:
Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your data. Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for all the purposes for which we use and disclose Personal Information. We may combine Other Information with your Personal Information, and when we do, we treat the combined information as Personal Information.
Unless you expressly give us permission in writing to do so, Last Mile Health will not sell, rent, license, or trade your Personal Information other than as specified in this Privacy Policy.
The security of your data is very important to Last Mile Health. We have implemented appropriate security measures preventing your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. However, you should know that no web site operator, including Last Mile Health, can fully eliminate security risks associated with Personal Information. While Last Mile Health has endeavored to create a secure and reliable website for users, the confidentiality of any communication or material transmitted to/from the User or via e-mail cannot be guaranteed. We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not yet been adopted, Last Mile Health does not process or respond to “Do Not Track” signals.
If you wish to stop receiving emails or other communications from us, or if you have submitted Personal Information through our Online Services and would like that information deleted from our records, please notify us at info@lastmilehealth.org.
As a convenience to our Users the Online Services may contain links to other sites. The terms of usage and other conditions of use posted on those sites, and not the policies and procedures we described here, apply to those sites. Your linking to any other websites is at your own risk, and you are responsible for learning about and complying with the terms of usage and other conditions posted on those websites.
If you reside or are located in the European Economic Area, you have certain rights in relation to your Personal Information under the applicable European data privacy laws under the General Data Protection Regulation and any other applicable data protection laws which may be amended from time to time (“European Data Privacy Laws”). This section only applies to such users.
Under applicable European Data Privacy Laws, Last Mile Health is the data controller. Under the applicable European Data Privacy Laws, you have the right to ensure your Personal Information is accurate. You have the right to request that we correct any inaccurate Personal Information. You also have the right to request that we delete or restrict the processing of your Personal Information, although we are permitted to retain it where we still have an ongoing purpose to retain it or as otherwise permitted under the European Data Privacy Laws. This may compromise our ability to provide you with our services. You also have the right to transfer your personal information to another service provider subject to the European Data Privacy Laws. We will, following your written request to us, provide you with your relevant Personal Information in a machine-readable format to transfer to another service provider. We will aim to respond to your request within one calendar month of receipt of the request. Where we are unable to do so within the calendar month, we will notify you of our need to extend this timeline. There are certain exemptions and restrictions applicable to the exercise of these rights under the European Data Privacy Laws that enable personal information to be retained, processed or withheld from access and we will inform you of these, if applicable. To make any of these requests or to opt out of receiving marketing communications, please contact us at info@lastmilehealth.org
You have the right to raise a complaint with a supervisory authority in your country of residence if applicable under European Data Privacy Laws.
We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
Last Mile Health is headquartered in the United States. The information you provide to us or that we obtain as a result of your use of the Services is collected in your country and subsequently transferred to the United States or to another country in which we have facilities or our affiliates operate or in which we engage service providers.
Some countries that are not members of the European Economic Area (EEA) are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, including by ensuring that the recipient is either Privacy Shield certified (for US-based providers), or bound by EU Standard Contractual Clauses, to protect your personal data. To obtain a copy of the EU Standard Contractual Clauses click here.
In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.
This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display an effective date on the policy in the upper right corner of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any change to this Privacy Policy regarding use or disclosure of Personal Information, we will provide advance notice via the Online Services. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice.
If you have any questions about this Privacy Policy, the practices of the Online Services, or your dealings with the Online Services, please contact info@lastmilehealth.org.