Privacy Policy
LAST MODIFIED: DECEMBER 16, 2019
Introduction
Netsmart Technologies, Inc. ("Company") respects your privacy and is committed to
protecting it through our compliance with this privacy policy (Privacy Policy ). The
purpose of this Privacy Policy is to inform you about the types of information we may collect
from you or that you may provide when you visit our website and our practices for collecting,
using, maintaining, protecting, and disclosing that information.
Consent
Please read this Privacy Policy carefully to understand our policies and practices regarding your
information and how we will treat it. If you do not agree with our policies and practices, your
choice is not to use our website. By accessing or using our website, you agree to the Privacy
Policy, and you consent to the use of your information in accordance with the Privacy Policy. This
policy may change from time to time (see Changes to Our Privacy Policy).
Your continued use of this website after we make changes is deemed to be acceptance of those
changes, so please check the policy periodically for updates.
Applicability
This Privacy Policy applies to individuals who use our Company website. This Privacy Policy
relates only to websites owned by our Company, not to any third-party website or service linked to
our website. We are not responsible for the content or privacy compliance of third-party websites or
applications. You should check those websites or applications for their privacy statements.
This Privacy Policy applies to information we collect:
- On our Company website.
- In email, text, and other electronic messages between you and our Company website.
- Through mobile and desktop applications you download from our Company website, which provide
dedicated non-browser-based interaction between you and this website.
- When you interact with our advertising and applications on third-party websites and services
, if those applications or advertising include links to this policy.
Your California privacy rights
If you are a California resident, California law may provide you with additional rights regarding
our use of your information. We are required by the California Consumer Privacy Act of 2018
(CCPA) to provide this notice to you. To learn more about your
California privacy rights, visit CCPA Privacy Notice .
Information for children under 13
Our website is not intended for children under 13 years of age. We do not knowingly collect
information from children under 13. If you are under 13, do not use or provide any information
on this website. If you believe we might have any information from or about a child under 13,
please contact us at privacy@ntst.com.
Information we collect
We collect information from you in three ways: (1) directly from you (2) with cookies and (3)
with tracking technologies. We collect several types of information from and about users of our
website. Our website collects information that identifies, relates to, describes, references, is
capable of being associated with, or could reasonably be linked, directly or indirectly, with a
particular consumer or device Information.
Information you provide
Through your interaction with and use of this website, you may provide us with information on an
individual basis. The information you provide through our website may include:
- Information collected automatically as you navigate through our website. This may include
usage details, IP addresses, and information collected through cookies, web beacons, and
other tracking technologies.
- Information that you provide by filling in forms on our website. This includes information
provided at the time of using our website, registering through our website, subscribing to
our services, posting material, or requesting information.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through our website and of the fulfillment of your
requests.
You also may provide information to be published or displayed (hereinafter, "posted")
on public areas of the Website, or transmitted to other users of the Website or third parties
(collectively, "User Contributions"). Your User Contributions are posted on and transmitted to
others at your own risk. Although we limit access to certain pages you may set certain privacy
settings for such information by logging into your account profile, please be aware that no
security measures are perfect or impenetrable. Additionally, we cannot control the actions of
other users of the Website with whom you may choose to share your User Contributions. Therefore,
we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized
persons
How we use cookies and other tracking technologies
Our Company or third parties we contract with may use persistent identifiers such as cookies and
other tracking technologies to collect certain information about visitors to our website and
interactions with our online content or applications, including advertisements. These third
parties may use cookies alone or in conjunction with web beacons or other tracking technologies
to collect information about you when you use our website. The information they collect may be
associated with your Information or they may collect information, including Information, about
your online activities over time and across different websites and other online services.
How we use personal information we collect
We may use or disclose the Information we collect for one or more of the following purposes:
- To present our website and its contents to you.
- To market and promote products or services provided by our Company or affiliated companies.
- To provide you with information, products, or services that you request from us.
- To fulfill a purpose as described to you when collecting your Information.
- To provide you with notices about your account.
- To carry out our obligations and enforce our rights arising from any agreements entered into
between you and us.
- To allow you to participate in interactive features on our website.
- To improve our website or services.
- To conduct market research.
- To fulfill any other purpose for which you provide it.
We may use the information we have collected from you to enable us to display advertisements to
our target audiences. Even though we do not disclose your information for these purposes without
your consent, if you click on or otherwise interact with an advertisement, the advertiser may
assume that you meet the target criteria.
How we share personal information with other parties
We do not sell your information to third parties. We do not share your information with third
parties for their promotional or marketing purposes. We may disclose information that we collect,
or you provide as described in this Privacy Policy:
- To comply with legal requirements and corporate transactions.
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring,
reorganization, dissolution, or other sale or transfer of all of Company's assets,
whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding,
in which personal information held by Company about our website users is among the assets
transferred.
- To comply with any court order, law, or legal process, including to respond to any
government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or
safety of our Company, our customers, or others. This includes exchanging information with
other companies for the purposes of fraud protection.
- For any other purpose disclosed by us when you provide the information.
Security and your personal information
We have implemented measures designed to secure your information from accidental loss and from
unauthorized access, use, alteration, and disclosure. We use physical, electronic and
administrative safeguards to protect your information. The safety and security of your
information also depends on you. Where we have given you (or where you have chosen) a password
for access to certain parts of our website, you are responsible for keeping this password
confidential. We ask you not to share your password with anyone. We urge you to be careful about
giving out information in public areas of the website such as message boards. The information
you share in public areas may be viewed by any user of the website.
International transfers
If you are visiting our site from outside the United States, be aware that your information will
be transferred to, and maintained on, computers located within the United States. The
collection, use, retention and any other processing of your information will be governed by
United States law and further by the specific jurisdictions within the United States where that
information is stored, unless otherwise specified.
Changes to our Privacy Policy
We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make
changes to this Privacy Policy, we will post the updated Privacy Policy on the website and
update the policy's "Last Modified" date. You are responsible for regularly reviewing the
terms of the Privacy Policy to stay informed of changes or modifications of the Privacy Policy.
Your continued use of our website following the posting of changes constitutes your acceptance
of such changes
How to contact us
We understand you may have questions regarding your information. You may contact us at:
Mail: Netsmart Technologies, Inc., Attn: Privacy Office, 11100 Nall Ave, Leawood, KS,
66211
Email: privacy@ntst.com
Phone: (800) 842-1973 and select the Privacy Office option for any privacy-related
questions.
Privacy Notice for California Residents
LAST MODIFIED: DECEMBER 16, 2019
This Privacy Notice for California Residents supplements the information contained in the
Privacy Policy and applies solely to all visitors, users, and others who reside in the State of
California ("Consumers" or "you"). We adopt this notice to comply with the California
Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when
used in this notice.
Information we collect
Our website collects information that identifies, relates to, describes, references, is capable
of being associated with, or could reasonably be linked, directly or indirectly, with a
particular consumer or device ("personal information"). In particular,
Company's website has collected the following categories of personal information from its
consumers within the last twelve (12) months:
Category |
Examples |
Collected |
A. Identifiers |
A real name, alias, postal address, unique personal identifier, online identifier, Internet
Protocol address, email address, account name, Social Security number, driver's
license number, passport number, or other similar identifiers. |
YES |
B. Personal information categories listed in the California Customer Records statute
|
A name, signature, Social Security number, physical characteristics or description,
address, telephone number, passport number, driver's license or state
identification card number, insurance policy number, education, employment, employment
history, bank account number, credit card number, debit card number, or any other
financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|
YES |
C. Protected classification characteristics under California or federal law |
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or
creed, marital status, medical condition, physical or mental disability, sex (including
gender, gender identity, gender expression, pregnancy or childbirth and related medical
conditions), sexual orientation, veteran or military status, genetic information (including
familial genetic information). |
YES |
D. Commercial information |
Records of personal property, products or services purchased, obtained, or considered, or
other purchasing or consuming histories or tendencies. |
NO |
E. Biometric information |
Genetic, physiological, behavioral, and biological characteristics, or activity patterns
used to extract a template or other identifier or identifying information, such as,
fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other
physical patterns, and sleep, health, or exercise data. |
NO |
F. Internet or other similar network activity |
Browsing history, search history, information on a consumer's interaction with a
website, application, or advertisement. |
YES |
G. Geolocation data |
Physical location or movements. |
NO |
H. Sensory data |
Audio, electronic, visual, thermal, olfactory, or similar information. |
NO |
I. Professional or employment-related information |
Current or past job history or performance evaluations. |
YES |
J. Non-public education information |
Education records directly related to a student maintained by an educational institution
or party acting on its behalf, such as grades, transcripts, class lists, student
schedules, student identification codes, student financial information, or student
disciplinary records. |
YES |
K. Inferences drawn from other personal information |
Profile reflecting a person's preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
NO |
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA's scope, such as:
- health or medical information covered by the Health Insurance Portability and Accountability
Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or
clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair
Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial
Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of
sources:
- Directly from you. For example, from forms you complete on our website.
- Indirectly from you. For example, from observing your actions on our website or interactions
with our advertisers.
Our use of personal information
We may use or disclose the personal information we collect for one or more of the following
purposes:
- To present our website and its contents to you.
- To market and promote products or services provide by our Privacy Policy or affiliated
companies.
- To provide you with information, products, or services that you request from us.
- To fulfill a purpose as described to you when collecting your personal information.
- To provide you with notices about your account.
- To carry out our obligations and enforce our rights arising from any agreements entered into
between you and us.
- To allow you to participate in interactive features on our website.
- To improve our website or services.
- To conduct market research.
- To fulfill any other purpose for which you provide it.
We may use the information we have collected from you to enable us to display advertisements to
our target audiences. Even though we do not disclose your personal information for these
purposes without your consent, if you click on or otherwise interact with an advertisement, the
advertiser may assume that you meet the target criteria.
Company will not collect additional categories of personal information or use the personal
information we collected for materially different, unrelated, or incompatible purposes without
providing you notice.
Sharing personal information
We may disclose your personal information to a third party for a business purpose. When we
disclose personal information for a business purpose, we enter a contract that describes the
purpose and requires the recipient to both keep that personal information confidential and not
use it for any purpose except performing the contract.
We share your personal information with the following categories:
- Service providers
- Data aggregators
- Third parties
1. Disclosures of personal information for a business purpose
We share the following categories of personal information with third parties:
A: Identifiers
B: California Customer Records personal information categories
C: Protected classification characteristics under California or federal law
F: Internet or other similar network activity
J: Non-public education information
2. Sales of personal information
We do not sell your personal information to third parties.
Your California Consumer rights and choices
The CCPA provides consumers (California residents) with specific rights regarding their personal
information. This section describes your CCPA rights and explains how to exercise those rights.
1. Right to access to specific information and data portability
You have the right to request that we disclose certain information to you about our collection
and use of your personal information over the past 12 months. Once we receive and confirm your
verifiable consumer request (see Exercising Access, Data Portability, and
Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data
portability request).
- If we disclosed your personal information for a business purpose, a list identifying the
personal information categories that each category of recipient obtained.
2. Right to request deletion
You have the right to request that we delete any of your personal information that we collected
from you and retained, subject to certain exceptions. Once we receive and confirm your
verifiable consumer request (see Exercising Access, Data Portability, and
Deletion Rights ), we will delete (and direct our service providers to delete) your
personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service
provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or
service that you requested, take actions reasonably anticipated within the context of our
ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal
activity, or prosecute those responsible for such activities.
- Comply with a legal obligation.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech
rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546
et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the
public interest that adheres to all other applicable ethics and privacy laws, when the
information's deletion may likely render impossible or seriously impair the research's
achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on
your relationship with us.
- Make other internal and lawful uses of that information that are compatible with the context
in which you provided it.
3. Exercising your access, data portability, and deletion rights
To exercise the access, data portability, and deletion rights described above, please submit a
verifiable consumer request to us by either:
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer
request related to your personal information. You may also make a verifiable consumer request on
behalf of your minor child. You may only make a verifiable consumer request for access or data
portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about
whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand,
evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify
your identity or authority to make the request and confirm the personal information relates to
you. Making a verifiable consumer request does not require you to create an account with us.
4. Response timing and format rights
We attempt to respond to a verifiable consumer request within forty-five (45) days of its
receipt. If we require more time, we will inform you of the reason and extension period in
writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable
consumer request's receipt. The response we provide will also explain the reasons we cannot
comply with a request, if applicable. For data portability requests, we will provide your
personal information in a format that is readily useable and allows you to transmit the
information from one entity to another entity. We do not charge a fee to process or respond to
your verifiable consumer request unless it is excessive, repetitive, or noticeably unfounded. If
we determine that the request warrants a fee, we will tell you why we made that decision and
provide you with a cost estimate before completing your request.
5. Personal information sales opt-out and opt-In rights
We do not sell your personal information to third parties.
6. Non-discrimination rights
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by
the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting
discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different
level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can
result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive
we offer will reasonably relate to your personal information's value and contain written terms
that describe the program's material aspects. Participation in a financial incentive program
requires your prior opt in consent, which you may revoke at any time.
Changes to our privacy notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make
changes to this privacy notice, we will post the updated notice on the website and update the
notice's "Last Modified" date. You are responsible for regularly reviewing the privacy notice(s)
to stay informed of changes or modifications of the privacy notice(s).
Contact Information
If you have any questions about this notice or wish to exercise your rights under California law,
please contact us at:
Online Rights Request: Click California
Resident Data Rights Request
Email: privacy@ntst.com
Phone: (800) 842-1973 and select the Privacy Office option.
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