COWA Privacy Policy
1. About Your Privacy and This Privacy Policy
COWA(“COWA”, “we”, “us” and “our”) is committed to protect and safeguard your private information that you provide when using this website in accordance with this privacy policy. We are devoted to ensuring the highest level of confidentiality of records. As an organization providing emotional and social support to people in need, privacy is extremely important to us.
This Privacy Policy describes the information we collect, how we use it, and the standards and procedures in place to safeguard your personal nonpublic information.
PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. When you submit your Personal Information to or through our services, you consent to the collection and processing of your Personal Information as described in this Privacy Policy. By using our services, you accept the terms of this Privacy Policy, and our Terms of Use.
It is our policy to comply with all federal and state laws and regulations relating to the privacy of our customers’ private information and private health information.
We may change this Privacy Policy from time to time at our discretion and when required by law. If we change our privacy policy we will post the changes on this page. If the change in our privacy policy affects the use of your personal information we will use our best endeavors to contact you by email to seek your consent to the use. Continued use of the service will signify that you agree to any such changes.
Information COWA Collects
We require certain Personal Information to provide our services to you. “Personal Information” may include contact information such as your first name, last name, birthday, email address, location, phone number, certain demographic information such as gender, race ethnicity, primary language spoken, sexual orientation, disabilities, and information about your health and medical history that you may input while using or communicating through the services, as well as the information you choose to share.
Depending on how you interact with our services, you may share your Personal Information with other Users, such as peers and other users who participate in group chat, forums or other non-private locations. Anything users post in the public forums, chats, or other features will be accessible to other users and may not be able to be deleted. Accordingly, COWA strongly discourages posting any Personal Information in these places and it is your responsibility not to share Personal Information in such non-private location.
How is the Information Used
We use this information
- To understand your needs and provide you with a better service,
- To communicate with you regarding our services,
- To provide customer support and respond to your inquires,
- For statistical purposes and analysis for management purposes in order to administer the website or improve our products and services.
- Internal record keeping, and administrative purposes, and to inform you about our events, services or products, or other related information that we think would be of interest to you, as explained above.
Security of Your Personal Information
The internet is not a secure medium. However we take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.
We protect nonpublic personal information by
- Restricting access to customer information to only those personnel for whom the information is necessary;
- Entering into written confidentiality/non-disclosure agreements with third party service providers for certain disclosures;
- Maintaining physical, electronic, and procedural safeguards that comply with the relevant laws and regulations; and
- Conducting a Security Training and Awareness training program to communicate and educate employees and volunteers about information security policies and procedures in order to make them aware of their roles and responsibilities in safeguarding information resources.
Owing to the global nature of the internet infrastructure, the information you provide may be transferred in transit to countries outside the North American that do not have similar protections in place regarding your data and its use as set out in this policy. However, we have taken the steps outlined above to try to improve the security of your information. By submitting your information you consent to these transfers.
Disclosure of Personal Information
We do not share nonpublic personal information about our customers (present, former and potential) with anyone, except as required by law, or as follows:
- To any person when you authorize such disclosure.
- To a Therapist. If you elect to consult with a licensed therapist through COWA, we may share your information with your therapist to enable and facilitate care.
- To computer services consultants and technicians or other security consultants, in order to ensure the confidentiality and security of customer & employee records.
- To independent auditors or consultants in order to carry out institutional risk control.
- To government or regulatory agencies, including self-regulatory organizations and to comply with a legal summons, court order, subpoena or a similar legal process, audit or investigation.
- We may disclose your Personal Information directly to law enforcement or local authorities in the event that it has been reasonably determined that your safety or the safety of others may be at risk.
Children’s Usage
COWA complies with the Children’s Online Privacy Act. Children between the ages of 13-17 years old may only participate in our services with parental consent and in the presence of at least one parent or guardian. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at ourcowa@gmail.com.
California Privacy Rights
Residents of the State of California who provide certain types of Personal Information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about certain types of Personal Information we shared, if any, with other businesses for their own direct marketing uses. It is our policy that we do not share your Personal Information with other businesses for marketing uses. Nevertheless, to make such a request, please contact us.
Nondiscrimination
COWA does not and shall not discriminate on the basis of race, color, religion (creed), gender, gender expression, age, national origin (ancestry), disability, marital status, sexual orientation, or military status, in any of its activities or operations.
Notices
We try to keep ourcowa.org safe, but you use it at your own risk. We are providing ourcowa.org “As Is” without any express or implied warranties. We do not guarantee that ourcowa.org will be safe or secure. Ourcowa.org is not responsible for the actions, content, information, or data of third parties, and you release us, our directors, officers, employees, and volunteers from any claims and damages, known and unknown, arising out of or in any way connected with any claim you have against any such third parties.
COWA reserves the right to amend this Privacy Statement at any time without notice, and only the current Privacy Statement may be deemed effective. Regardless of later updates or changes to our privacy notice, we will never use the information you submit under our current privacy notice in a new way without first providing you an opportunity to opt-out or otherwise prevent that use.
We welcome your views about our website and our privacy policy. If you would like to contact us with any queries or comments please send an email to ourcowa@gmail.com
3. Opting out of Marketing Communication
You can opt out of receiving email marketing by unsubscribing using the unsubscribe link provided in all of our marketing email communications.
4. Cookies and Web Beacons
Like many websites, we use “cookies” and “web beacons” (also known as pixels) to collect information. A “cookie” is a small data file that is transferred to your computer’s hard disk for record-keeping purposes. We collect cookies that are necessary for the Platform to function, cookies that enhance the Platform’s performance, and cookies used for third-party tracking. A “web beacon” is a tiny and sometimes invisible image or embedded code, placed on a Web page or email that can report your visit or use to a third party. Web beacons are typically used by third parties to monitor the activity of users at a website for the purpose of web analytics, advertising optimization, or page tagging. Additional information regarding web beacons is available on Wikipedia.
You can change your browser’s settings so it will stop accepting cookies or to prompt you before accepting a cookie. Opt-out options for cookies are located here.
Use of Cookies, Web Beacons, and Similar Technology for Analytics
We may use third party cookies for the purposes of web analytics, attribution, and error management. Our Platform may use vendor services that use cookies, web beacons, and similar technology to collect and store anonymous information about you, including when you pay for services, load a page, indicate that you heard about us on television, sign up for services, enter your payment information (but the payment details are not disclosed), start the intake questionnaire, and your response as to the referral source to the Platform.
Our Platform also uses analytics vendors to collect information (for example, Visitor Data and Onboarding Data) about user actions on our websites for purposes of analytics and analysis of certain Platform usage.
Use of Cookies, Web Beacons, and Similar Technology for Advertising Networks
You and others may see certain ads for our services or for the Platform on other websites because we participate in ad networks. Ad networks allow us to target our messaging to users through demographic, interest-based, and contextual means. These networks track individuals’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons. The networks use this information to show advertisements that may be tailored to an individual’s interests. The information our ad networks may collect includes information about your visits to websites that participate in the relevant ad networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts and assists other websites and advertising partners to find you or people like you on different platforms, including social media websites.
5. Social and General Information Tools
We use several publicly-available tools and information exchange resources, such as (but not limited to) a blog, a Facebook page, a Twitter account, and others (collectively “Social and General Information Tools”). Any information you provide or share while using Social and General Information Tools may be read, accessed, collected by that site and users of that site according to their Privacy Policy.
6. Phishing
Online identity theft and account hacking, including the practice currently known as “phishing”, are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).
7. Links
The Platform may contain links to other websites, services or offers which are owned, operated or maintained by third parties. If you click on a third party link, you will be directed to that third website or service. The fact that we link to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third party websites and services and we do not have control over their privacy policies and terms of use.
8. Security of Information
While using any Internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are all designed, built and maintained with your security and privacy in mind. We apply industry standards and best practices to prevent any unauthorized access, use, and disclosure. We comply with all applicable federal laws, state laws, and regulations regarding data privacy.
9. Service Providers
We may employ third party companies and individuals to facilitate our Platform, to perform certain tasks which are related to the Platform, or to provide audit, legal, operational or other services for us. These tasks include, but not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and only after entering into appropriate confidentiality agreements.
10. Children’s Privacy
We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to become our user. The Platform is not directed and not intended to be used by children under the age of 13. If you are aware that we have collected Personal Information from a child under age 13 please let us know by contacting us and we will delete that information.
11. Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Counselors may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment.
12. Changes to the Privacy Policy
We may update this privacy statement at our sole discretion. The date of the last revision of this policy appears at the end of this page. We encourage you to periodically review this page for the latest information on our Privacy Policy and practices. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to stop using the Platform.
13. Contacting us
If you have any questions or concerns about this Privacy Policy or our privacy-related practices, please contact us by clicking the “Contact” link at the bottom of any page in our website.
Privacy Notice for California Residents
This Privacy Notice for California Residents supplements and is expressly made part of the information contained in the BetterHelp 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”). Any terms defined in the CCPA have the same meaning when used in this Notice.
- Information We Collect
Through your use of our website, we collect 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 household (“personal information”). The description of the information that we collect is provided above, in the section titled “Categories of Information Collected.” In particular, our websites have collected the following categories of personal information from consumers within the last twelve (12) months. Additionally, we have disclosed the following categories of information for a business purpose in the past twelve (12) months:
| Category | Collected | Disclosed for a business purpose |
|---|---|---|
| A. Identifiers. | Yes | Yes |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Yes | Yes |
| C. Protected classification characteristics under California or federal law. | Yes | Yes |
| D. Commercial information. | Yes | Yes |
| E. Biometric information. | No | No |
| F. Internet or other similar network activity. | Yes | Yes |
| G. Geolocation data. | Yes | Yes |
| H. Sensory data. | No | No |
| I. Professional or employment-related information. | Yes | Yes |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | No | No |
| K. Inferences drawn from other personal information. | Yes | Yes |