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Western Reserve Area Agency on Aging Internet Privacy Policy
Last modified: March, 2022
Owner and Data Controller:
Western Reserve Area Agency on Aging
1700 East 13th Street, Suite 114
Cleveland, Ohio 44114
Owner Contact Email:
Megan Nelson
Senior Compliance and Privacy Officer
Western Reserve Area Agency on Aging
1700 East 13th Street, Suite 114
Cleveland, Ohio 44114
TermsOfUse@areaagingsolutions.org
Owner Phone Number:
216-621-0303
TABLE OF CONTENTS
Introduction
The Western Reserve Area Agency on Aging (WRAAA) is a private nonprofit corporation. We were organized and designated by the State of Ohio to be the planning, coordinating, and administrative agency for federal and state aging programs in Cuyahoga, Geauga, Lake, Lorain and Medina counties. Building upon four decades of experience in providing services and support to individuals in need, WRAAA continues to expand our service portfolio in the long-term and healthcare delivery systems. We look forward to the opportunity to serve you.
Our Mission Statement
We provide choices for people to live independently in the place they want to call home.
Our Vision Statement
We aim to create a community that provides aging individuals and people with disabilities the opportunity to have their needs met with optimum choice, dignity, and maximum independence.
To learn more about the support we provide contact us, read our Agency newsletter, or view our Directory of local resources in our Publications section.
Your trust matters to us. WRAAA and WRAAA Foundation (collectively, “WRAAA”) respect your privacy, and are committed to protecting the security of your personal data and other personally identifiable information (“PII”) and using it responsibly. This Privacy Policy describes how WRAAA collects, processes, uses and discloses your personal data. This Privacy Policy describes the categories of personal data that we collect, how we secure your personal data, and when we may disclose your personal data to third parties. We will process your personal data in accordance with this Privacy Policy, your consent, or as otherwise required by applicable law. This Privacy Policy applies in the United States.
It is important that you read this Privacy Policy, together with any other privacy notice or policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.
Please read this 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 this Website, you agree to this Privacy Policy and our Terms of Use.
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 our Privacy Policy periodically for updates.
PLEASE NOTE: Our Website is not intended for use by children under 18 years of age. We do not seek to collect or knowingly collect personal information of persons who are below the age of 18. We do not want a person under the age of 18 ever to access this Website or provide any information about himself or herself to us, including his or her name, address, telephone number, email address or any screen name or username. If we unintentionally collect the personal information of a person between the age of 13 and 16, we will not transfer or sell their data.
We encourage parents to talk with their children about using the Internet safely and the dangers of communicating with strangers and disclosing personal information online. If we learn we have unintentionally collected or received personal information from a child under 18 we will delete it upon learning of its existence. If you would like to request that we delete any information from or about a child under 18, please contact us through the Contact Information earlier provided in this policy.
By accessing and viewing this Website you represent, promise, and agree you are not under the age of 18.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data under the law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be treated in accordance with this Privacy Policy.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you, including through:
HOW WE WILL USE YOUR PERSONAL DATA
We may process your personal data for the following purposes as well as for the purposes of performing any service contracts we may have with you:
We may also process your personal data:
Use of Information We Collect Through Automatic Data Collection Technologies.
We may use third-party service providers, such as Google, to collect anonymous information about your visit and interaction with us. They may also use information about you to target services that may be of interest to you. They may place or recognize a unique cookie on your browser to enable you to receive customized information from us. Demographic or other interest data may be associated with your browser or device in a non-personally identifiable manner. We also may use automated data collection technologies to collect information about your online activities over time.
The information we collect automatically is statistical data and may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
The technologies we use for this automatic data collection may include:
Opting Out
To the extent our sharing or disclosure of PII with or to our related and affiliated entities, and others, constitutes a “transfer” or “sale” of PII, you have the right to ask us, subject to certain exceptions, to “opt-out” or not to share or disclose PII by contacting us through the Contact Information provided elsewhere in this Privacy Policy or by clicking here: https://form.jotform.com/221095729538161 “Do Not Sell My Personal Data.”
You can also request to opt-out of receiving fundraising or other promotional/ marketing emails by clicking “Unsubscribe” at the bottom of any email that you receive from us, or by contacting us through the Contact Information elsewhere provided in this Privacy Policy.
Opting out will not affect any services or benefits we are providing or arranging for you.
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. For example, you may easily opt out of Google’s services by visiting Google's Ad Settings.
THIRD-PARTY SOURCES
Our Website or other materials may contain links to websites controlled, owned and operated by third parties (“Linked Sites”). Those third parties may collect personal information about you. Once you navigate away from WRAAA webpages, this Privacy Policy no longer applies, and WRAAA disclaims any responsibility for the privacy practices of such third parties, the content provided through any Linked Site, or webcasting or any other form of transmission received from any Linked Sites. Further, WRAAA disclaims responsibility for information that is collected by a third party not affiliated with WRAAA, and subsequently provided to WRAAA with or without your consent. You should always protect your privacy by reviewing the privacy policies of each third-party with whom you interact.
HOW WE MAY SHARE YOUR PERSONAL DATA
We may need or have to share your personal data with internal/external third parties set out below for the purposes set out above:
We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:
YOUR CALIFORNIA PRIVACY RIGHTS AND PRIVACY NOTICE
Effective Date: January, 2020
This Privacy Notice for California Residents supplements the information contained in WRAAA’s 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.
This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.
Information We Collect
Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:
In particular, our Website has collected the following categories of personal information from or about its consumers, vendors or others who support WRAAA’s mission within the last twelve (12) months:
Cal. Info. Category |
Examples |
Collected |
§ 1798.80(e)). |
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
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). |
NO |
D. Commercial information.
E. Biometric information. |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
YES |
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. |
NO
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. |
NO |
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)). |
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. |
NO |
K. Inferences drawn from other personal information. |
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
NO |
Our Website obtains the categories of personal information listed above from the following categories of sources:
Use of Personal Information
We may use, transfer, sell or disclose the personal information we collect for one or more of the following purposes:
We 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 an associated or affiliated entity or a third party for a purpose consistent with our mission subject to your right to opt-out of those transfers or sales (see Personal Information Sales Opt-Out Rights). If we ever 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. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
We share or may your personal information with the following categories of third parties:
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the following categories of personal information [by applicable California Information Category] for a business purpose:
[Category A: Identifiers];
[Category B: Consumer records personal information];
[Category D: Commercial information];
We disclose, transfer or sell, or may disclose, transfer or sell your personal information for a business purpose to the following categories of parties and:
Sales of Personal Information
In the preceding twelve (12) months, we have not disclosed, transferred or sold the following categories of personal information [by applicable California Information Category]:
[Category C: Protected classification characteristics under California or federal law];
[Category E: Biometric information];
[Category F: Internet or other similar network activity];
[Category G: Geo location data];
[Category H: Sensory data];
[Category I: Professional or employment-related information];
[Category J: Non-public education information]; and
[Category K: Inferences drawn from other personal information].
Your 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.
Access to Specific Information and Data Portability Rights
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), generally, we will disclose to you:
Deletion Request Rights
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:
Exercising 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:
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. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out Rights.
Response Timing and Format
We endeavor 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 receipt of a verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly 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.
Personal Information Sales Opt-Out Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not intentionally collect, sell or maintain the personal information of consumers we actually know are less than 18 years of age.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:
[https://areaagingsolutions.org/] "Do Not Sell My Personal Information"
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to us at our email address or write us at our mailing address.
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 our Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us.
HOW DO WE ENSURE THE SECURITY OF YOUR DATA?
WRAAA has put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, vendors and other third parties who have a need to know.
In the event that the security of any personal consumer information stored by us is compromised, we will provide the affected consumers with notice of such breach in the most expedient time possible and without unreasonable delay. This notice shall be posted on our Website, and, depending upon the extent of the breach and the nature of the information compromised, we may also provide affected consumers with personalized notice in writing, by e-mail, or by telephone.
Please note: the safety and security of your information also depends on you.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk.
CHANGES TO OUR PRIVACY POLICY
The date this privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.
LIABILITY DISCLAIMERS
The information, software, benefits and services included in this website or available through WRAAA may include inaccuracies or typographical errors. changes are periodically added to the information herein, and WRAAA may make improvements and/or changes in its website at any time. advice or information received via this website or wraaa should not be relied upon for medical, legal or financial decisions and you should consult an appropriate professional for specific advice tailored to your situation. WRAAA AND/OR ITS VENDORS MAKE NO REPRESENTATIONS ABOUT THE SUITABILITY, RELIABILITY, AVAILABILITY, TIMELINESS, OR ACCURACY OF THE INFORMATION, SOFTWARE, SERVICES AND RELATED GRAPHICS CONTAINED ON THE WRAAA WEBSITE FOR ANY PURPOSE. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, ALL SUCH INFORMATION, SOFTWARE, BENEFITS AND SERVICES AND RELATED GRAPHICS ARE PROVIDED “AS IS” without warranty or condition of any kind. WRAAA and/or its suppliers hereby disclaim all such warranties, including all implied warranties or conditions of merchantability, fitness for a particular purpose, title and non-infringement.
to the maximum extent permitted by applicable law, in no event shall WRAAA and/or its suppliers be liable for any direct, indirect, punitive, incidental, special, consequential damages or any damages whatsoever including, without limitation, damages arising out of or in any way connected with the use or performance of the wraaa website. because some states/jurisdictions do not allow the exclusion or limitation of liability for consequential or incidental damages, the above limitation may not apply to you. if you are dissatisfied with any portion of the WRAAA website, or with WRAAA’s internet privacy policy or terms of use, your sole and exclusive remedy is to discontinuing using the WRAAA website.
TERMS OF USE
WRAAA’S Terms of Use are incorporated by reference in WRAAA’s Internet Privacy Policy.
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