About this Privacy Notice
This Privacy Notice explains how we, SPG Therapy & Education (The Speech Pathology Group, Inc. doing business as SPG Therapy & Education) (herein “Company”), handle your information that is collected in connection with our website, therapy services or other services the Company offers, and the employment relationship with our employees (collectively “Services”). It applies generally to the following groups:
- Consumers and the general public
- Clients (including prospective clients)
- Employees (including prospective employees)
- Third party business partners
- Other individuals who interact with us or whose personal information we maintain
By participating in any of the Company’s Services, you consent to the data practices described in this statement.
About Us
SPG Therapy & Education is a provider of multidisciplinary therapy services. We are a highly regarded team of SLPs/SLPAs, BCBAs/RBTs, OTs, PTs, Mental Health Therapists, Psychologists, Education Technicians, and Teachers working in schools and clinics throughout California since 1989.
Information Collection
By participating in any of the Company’s Services, you may intentionally or unintentionally be providing information to the Company. The types of information that may be collected, how that information is handled, and your rights pertaining to that information, are described throughout this Notice.
Personal Information Provided by You
We collect personal information that you voluntarily provide to us when you participate in our Services, or when you otherwise contact us. The personal information that we collect depends on the context of your interactions with us and the types of Services you participate in. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Categories of Personal Information We Collect
In general, we have collected the following categories of personal information in the past twelve (12) months:
Sensitive Information
As a provider of health and therapy services, the information we collect that you voluntarily provide to us may be considered Personally Identifiable Information (PII) or Protected Health Information (PHI). More information can be found here: https://www.cdc.gov/phlp/php/resources/health-insurance-portability-and-accountability-act-of-1996-hipaa.html
We only collect sensitive personal information with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.
Automatically Collected Information
Certain information may be collected without you intentionally providing it to us, such as, but not limited to, the types outlined below.
Social Media Profile Information
If you interact with us on a social media platform using your social media account (e.g., Facebook, Instagram, LinkedIn), we receive personal information about you from such platforms. Any personal information that we collect from your social media account depends on your social media account’s privacy settings. The information we receive may vary depending on the social media provider, but will often include your name, email address, profile picture, and connections list, as well as other information you choose to make public on said platform.
Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.
Cookies
We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our website or systems. A “cookie” is a text file that is placed on your hard disk by a web page server. The purpose of a cookie is to tell the web server that you have returned to a specific page. A cookie helps the website to recall your specific information on subsequent visits.
Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer.
Google Analytics
We may receive derivative information from Google Analytics, which is used to track and analyze the usage of our website. Information about the type of data Google Analytics collects can be found here: https://support.google.com/analytics/answer/11593727
To opt out of being tracked by Google Analytics, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.
Internet or other similar network activity
The Company may automatically collect information about your computer hardware and software when you interact with our website or systems. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our website, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
How We Use and Share Your Information
We will use your information primarily for, but not limited to, the following purposes:
For Treatment
Your information may be used or disclosed by us to facilitate your treatment and for the coordination and management of your health care, as well as to communicate with you in relation to Services you have requested or are receiving from us.
For Payment
Your information may be used and disclosed by us to let billing administrators or your insurance provider know what anticipated Services will be, for example, to make coverage determinations, administer claims, and coordinate benefits with other coverage you may have. Your information may also be used and disclosed to pay for Services you have received.
For Business Operations
Your information may be used or disclosed for a variety of operations-related purposes, for example, statistical analysis, business planning, conducting of care quality assessments improvement activities, or for the purpose of health care fraud or abuse detection or compliance.
For Employment Opportunities
We may use your information to communicate with you about interest you have expressed in employment opportunities.
Internal Information Sharing
SPG Therapy & Education is part of the Unison Therapy Services family of companies, and as such may use your information internally across our affiliates for the purposes outlined in this Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us. This is not considered to be “selling” of your personal information.
Compliance with the law
We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights. Any such use or disclosure will be made in compliance with the law and will be limited to what is required by the law.
Information Sharing with Third Parties
The Company may share your data with third-party business partners that support our business, such as our system and content providers, vendors, contractors, analytics providers, advertising and marketing agencies, government agencies, and other third parties with whom we engage (collectively “Third Parties”). Your information is only shared with Third Parties who perform services for us or on our behalf, and require access to such information to provide the needed services.
The categories of Third Parties we share personal information with may include:
- Cloud computing services
- Data storage service providers
- Data analytics services
- Testing tools
- Finance & accounting tools
- Government entities
- Payment processors
- Website hosting service providers
- Postal or delivery services
We have contracts in place with our Third Parties, which are designed to help safeguard your personal information. All Third Parties are prohibited from using your personal information except to provide services to the Company, and are required to maintain the confidentiality of your information. They will also not share your personal information with any organization apart from us. They commit to protect the data they hold on our behalf and to retain it for the period we instruct.
The Company does not sell, rent, or lease customer lists or customer data to Third Parties.
Phone numbers collected with SMS consent will not be sold, rented, or shared with third parties or affiliates for marketing purposes under any circumstances.
How do we keep your information safe?
We have implemented appropriate and reasonable physical, technical, and organizational safeguards designed to protect your Personal Data from accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access.
However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat security measures and improperly collect, access, steal, or modify your information.
As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet and computer systems that are beyond our control; and (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed.
How long do we keep your information?
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (e.g. HIPAA, accounting, tax, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
These rights include:
- Right to know whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request the deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to non-discrimination for exercising your rights
- Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)
Depending upon the state where you live, you may also have the following rights:
- Right to obtain a list of the categories of Third Parties to which we have disclosed personal data (as permitted by applicable law, including California’s and Delaware’s privacy law)
- Right to obtain a list of specific Third Parties to which we have disclosed personal data (as permitted by applicable law, including Oregon’s privacy law)
- Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
- Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)
How to Exercise Your Rights
To exercise these rights, you can contact us by email, phone, or postal mail. Refer to the contact details at the bottom of this document.
Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
Right to Deletion
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
- Delete your personal information from our records; and
- Direct any service providers to delete your personal information from their records.
Please note that we may not be able to comply with requests to delete your personal information if it is necessary to:
- Complete the transaction for which the personal information was collected, fulfill the terms of a written agreement in accordance with federal law, and provide a service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act;
- 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
- Comply with an existing legal obligation; or
- Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
California privacy rights
As it specifically pertains to the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA), the Company may have collected, used, and shared personal data about you as described in this Privacy Notice for business purposes during the last 12 months. Categories of data the Company may have collected, used, or shared with Third Parties are outlined in this Privacy Notice.
California consumers have a right to: (1) request access, correction, and deletion of their personal data, (2) opt out of the sale or sharing of their personal data, and (3) not be discriminated against for exercising one of their California privacy rights.
All individuals have the right to request access to and deletion of information the Company holds about them. To exercise these rights, you can contact us by email, phone, or postal mail. Refer to the contact details at the bottom of this document.
SPG Therapy & Education does not sell the Personal Data of California consumers.
SPG Therapy & Education does not discriminate against individuals for exercising their privacy rights.
Exemptions
This Privacy Notice does not apply to any website, application, product, or service that links to its own privacy statement or that is offered by Third Parties, in which clicking on Third-Party links or enabling those connections may allow the Third Party to collect, use, or share data about you. Please be aware that we are not responsible for the content or privacy practices of Third Parties. We encourage you to read their respective privacy statements.
Changes to This Statement
The Company reserves the right to change this Notice from time to time. For example, when there are changes in our Services, changes in our data protection practices, or changes in the law. When changes to this Notice are significant, we will inform you. You may receive a notice by receiving an email from us sent to an email address we have on file for you, or by us posting an updated notice on our website. Your continued use of the website and/or Services available after such modifications will constitute your: (a) acknowledgment of the modified Notice; and (b) agreement to abide and be bound by that Notice.
Contact Information
The Company welcomes your questions or comments regarding this Notice. We can be contacted through the following methods:
Postal Mail
SPG Therapy & Education
2021 Ygnacio Valley Road, Suite C103
Walnut Creek, California 94598
info@spgtherapy.com