The methods that may be used on the Services to collect Usage Information include:
- Log Information: Log information is data about your use of the Services, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
- Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, in-app tracking methods and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Services or e-mails, including information about your browsing and purchasing behavior.
A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Services and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Services, and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features and functionalities of the Services may not work. A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML5 cookies are locally stored on your device other than in the browser and browser settings won’t control them. To identify certain types of local shared objects on your device and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. The Services may associate some or all of these types of cookies with your devices.
Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Services, to monitor how users navigate the Services, and to count content views.
An embedded script is programming code designed to collect information about your interactions with the Services. It is temporarily downloaded onto your computer from MHM’s web server, or from a third party with which MHM works, and is active only while you are connected to the Services, and deleted or deactivated thereafter.
There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings.
MHM is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 11 so that your consent to encountering them is meaningfully informed.
C. Information MHM Collects From Other Sources.
2. HOW WE USE THE INFORMATION WE OBTAIN.
- Facilitate, manage, personalize, and improve your online or other Services experience;
- Allow you to participate in the features and service offerings we make available on or via the Services;
- To perform Professional Services for clients
- Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content, and send you notices;
- Our marketing (as permitted by applicable law) and other purposes;
- Improve the Services, and our other services, and for any other internal business purposes;
- Tailor our content and offers (as permitted by applicable law);
- Fulfill other purposes disclosed at the time you provide Personal Information, or at the time we receive Client-service PI or Client-Service PHI whether or not from you directly, or otherwise where we are legally permitted to do so and doing so is not inconsistent with an express privacy commitment we have made; and
- Prevent and address fraud, breach of policies or terms, and threats or harm and to comply with applicable law, and law enforcement or other legal processes, and government requests.
3. INFORMATION WE SHARE WITH THIRD PARTIES.
As permitted by applicable law, MHM may share non-Personal Information, and Personal Information that is not deemed MHM-Collected PI hereunder, or Client-service PI or Client-service PHI, provided that we are not aware of restrictions on our use or sharing, with third parties for any purpose. However, MHM’s sharing of MHM-Collected PI,Client-service PI, and Client-service PHI is subject to the following:
- Marketing: Subject to your communications choices explained in Section 11, and the rights of California residents explained here, we may use your Personal Information to send you marketing communications. MHM will not share your MHM-Collected PI with third parties, for their own direct marketing purposes, except with our Affiliates and in connection with Corporate Transactions (defined below), absent your consent (which may be by means of third party interaction described in the next bullet point). Your HIPAA PHI will be used or disclosed for marketing purposes only in accordance with the requirements of HIPAA and our Protected Health Information Notice of Privacy Practices and your non-public personal financial information that is governed by the federal Gramm-Leach-Bliley Act or state insurance or financial services privacy laws will be used or disclosed for marketing purposes only in accordance with the requirements of those laws and our Financial Services Privacy Statement.
- Your Disclosure or Consent: As more fully described in Section 5 (Information You Disclose Publicly or to Others) and Section 6 (Third-Party Content, Third-Party Services, Social Features, and Analytics), your activities on the Services may, by their nature, result in the sharing of your MHM-Collected Personal Information (as well as your other Personal Information and your non-Personal Information) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties. Such third party data receipt and collection is subject to the privacy and business practices of that third party, not MHM.
- Additional Privacy Notices: If governed by an applicable Additional Privacy Notice, then subject to the terms and conditions of that Additional Privacy Notice.
- Clients, in connection with our Services to them that you use or access or that relate to you;
- MHM’s agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to your information, including, without limitation, Personal Information, Demographic Information, and Usage Information, in connection with their work on MHM’s behalf, provided however, (i) your Client-service PHI will remain subject to any applicable requirements of HIPAA and state health information privacy laws; (ii) your non-public personal financial information that is governed by the federal Gramm-Leach-Bliley Act or state insurance or financial services privacy laws will remain subject to any applicable requirements of those laws; and (iii) MHM does not authorize its Service Providers to use MHM-Collected PI, Client-service PI or Client Service PHI provided by MHM to the Service Providers to send you direct marketing messages other than related to MHM absent your consent. For more information on choices Service Providers may offer you click here.
- To comply with the law, law enforcement or other legal process, and in response to a government request; and
MHM may share your Client-service PI, Client Service PHI and MHM-Collected Personal Information (as well as your other Personal Information and your non-Personal Information), in connection with or during negotiations of any proposed or actual merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of MHM assets, or transfer of all or a portion of MHM’s business to another company (“Corporate Transactions”).
In addition, in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity). Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information, to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.
4. PROTECTED HEALTH INFORMATION (“PHI”).
5. INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS.
6. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, AND ANALYTICS.
The Services may include hyperlinks to, or include on or in connection with, the Services (e.g., apps, software, and plug-ins), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personal Information from you.
For example, certain functionalities on the Services permit interactions that you initiate between the Services and certain Third-Party Services, such as third party social networks (“Social Features”). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Services (see Section 5) or by the Third-Party Service that you use. Similarly, if you post information on a third-party service that references the Services (e.g., by using a hashtag associated with MHM in a tweet or status update), your post may be used on or in connection with the Services or otherwise by MHM. Also, both MHM and the third party may have access to certain information about you and your use of the Services and any Third-Party Service.
7. DATA SECURITY AND MONITORING.
MHM takes reasonable measures to protect MHM-Collected PI (excluding public UGC), Client-service PI and Client-service PHI, from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet and online digital storage are not completely secure and MHM cannot guarantee the security of your information collected through the Services.
8. INTERNATIONAL TRANSFER.
9. CHILDREN'S PRIVACY.
The Services is intended for a general audience and not directed to children less than thirteen (13) years of age. MHM does not intend to collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.
Any California residents under the age of eighteen (18) who have registered to use the Services, and who posted content or information on the Online Services, can request removal by contacting MHM here, detailing where the content or information is posted and attesting that you posted it. MHM will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished or archived content by search engines and others that MHM does not control.
10. ACCESSING AND CHANGING INFORMATION.
MHM may provide web pages or other mechanisms allowing you to delete, correct, or update some of the MHM-Collected PI, and potentially certain other information about you (e.g., profile and account information). MHM will make good faith efforts to make requested changes in MHM’S then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from MHM’S databases (California minors see Section 9) and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
11. CHOICES: TRACKING AND COMMUNICATION OPTIONS.
A. Tracking Technologies Generally. Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies, some parts of the Services may not work and that when you revisit the Services your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Some app-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to Services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many Services, MHM currently does not alter its practices when MHM receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but MHM is not responsible for the completeness or accuracy of this third party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our Site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. MHM is not responsible for the completeness or accuracy of this tool or third party choice notices or mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section.
B. Analytics and Tracking Technologies.
You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use of a different device or web browsers or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. MHM supports the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising (http://www.iab.net/media/file/ven-principles-07-01-09.pdf) and expects that ad networks MHM directly engages to serve you Interest-based Advertising will do so as well, though MHM cannot guaranty their compliance. MHM is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
C. Mobile Apps.
With respect to MHM’s mobile apps (“apps”), you can stop all collection of data generated by use of the app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., push notifications, accessing phone, SMS, device id, data, photos/media/files, etc.), by adjusting the permissions in your mobile device and/or the app’s settings. Beware that if GPS precise location services are disabled, other means of establishing or estimating location (e.g., connecting to or proximity to wi-fi, Bluetooth, beacons, or our networks) may persist.
You can opt out of receiving certain promotional communications (emails or text messaging) from MHM at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the link to update your email communication preferences (or unsubscribe link if available); and (ii) for text messages, text back the word, “STOP” and (iii) for app push notifications, turn off push notifications on the settings of your device and/or the app, as applicable. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, MHM may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or MHM’s ongoing business relations.
12. YOUR CALIFORNIA PRIVACY RIGHTS.
We do not share personal information as defined by California Civil Code Section 1798.83 (“Shine The Light law”) with third parties, other that our Affiliates, for their direct marketing purposes absent your consent. “Affiliates” means any parent, subsidiary or affiliate in the MHM If you are a California resident, you may request information about our compliance with the Shine the Light law, and request information on our sharing of customer personal information with Affiliates for the recipient Affiliates’ own marketing purposes in the prior 12 months to the extent you are entitled by California law, by contacting us here or by sending a letter to Mayer Hoffman McCann P.C., 700 W. 47th Street, Suite 1100, Kansas City, MO 64112 (Attention: MHM Legal Counsel/Privacy). Any such request must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.
California minors should see “Children’s Privacy” at Section 9 regarding removal of certain content they have posted.
13. YOUR CONNECTICUT PRIVACY RIGHTS.
Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.
15. CONTACT US.
To see the full text, click on the links provided.
1. Information We Collect
(a) Information About You That You Provide
(b) Information Collected Automatically
(c) Information MHM Collects From Other Sources
2. How We Use The Information We Obtain
3. Information We Share With Third Parties
4. Protected Health Information (“PHI”)
5. Information You Disclose Publicly Or To Others
6. Third-Party Content, Third-Party Services, Social Features, and Analytics
7. Data Security and Monitoring
8. International Transfer
9. Children’s Privacy
10. Accessing and Changing Information
11. Choices: Tracking and Communications Options
(a) Tracking Technologies Generally
(b) Analytics and Tracking Technologies
(c) Mobile Apps
12. Your California Privacy Rights
13. Your Connecticut Privacy Rights
15. Contact Us