BRIGHTWAY Q&A PRIVACY POLICY

Last updated June 25, 2021.

Welcome to Brightway Health, an online community website (“Site”), and thank you for reviewing this Privacy Statement (the “Statement”). This Site is operated by Brightway Health, which may operate other websites. The Site is designed to connect persons (such as those with brain injury, caregivers and professionals) who are interested in sharing and receiving information about and adjacent to brain injury (the “Service).

 

In connection with the use of this Site and the Service, users may be asked to provide personal information relating to health conditions, demographics, contact information, and other information. This Statement informs you of our practices with respect to the online collection, use, and disclosure of personal information by means of the Service. We reserve the right to change, modify, add, or remove provisions of this Statement, and any changes to this Statement will be posted here.

 

Please refer back to this Statement regularly because your use of this Site signifies that you agree to be bound by this Statement, as might be amended from time to time.

 

What Information About You Do We Collect?

 

You may view some content on this Site without becoming a member of Brightway Health (a "Member"). However, you must register in order to create a profile, submit questions, vote on questions, write comments to the questions, or communicate with others via the Service.

 

At the registration page, you are asked to provide certain personal information such as a functioning e-mail address (which we may use to contact you) as well as your state of residence and user type (if you are a brain injury Survivor, Caregiver, Medical Professional, or another type of user). Upon registering, you become a Community Member.

 

You have the option, but are not required, to provide additional personal information.  Some information may be added no matter which user type you selected.  You may choose to provide your name (your name will never be shared with other users or outside of Brightway unless you choose to share it, for example, by associating a question you posted with a social media account that identifies you, and will be used only to personalize emails and other communications Brightway may send to you) and your city of residence regardless of user type.

 

Other optional information depends on the user type you selected.  If you selected the Survivor user type, additional optional information includes your date of birth, date of injury, type of injury, injury status, employment status and which topics you are  interested in.  If you selected the Friend user type, you may provide the same information about the survivor you are friends with.  If you selected the Caregiver or Family user types, you may provide the same information about your survivor, as well as your relationship to the survivor.  If you selected the Medical Professional or Other Professional user types, you may provide your title, a short bio, a prefix and suffix to your name, an avatar image, the organization you work for, and your professional specialties.  If you select the Other user type, you are not given the option to provide additional optional information beyond your name and city of residence.  If you provide any optional information, you consent to us sharing such information with other Members (except for your name) to find your profile and connect with you based on shared location, condition or interests. You also consent to us using it in order to recommend relevant posts to you. We rely on your consent to process this type of data for these purposes. You may withdraw your consent at any time by removing this information from your profile.

 

We also collect "clickstream" data, including your IP address and what pages you visit on the Site, in order to improve the performance of the Site and Service and to learn how different aspects of the Site and Service are used.

 

We 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 in 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 treat the combined data as personal data which will be used in accordance with this privacy policy.

How we use your personal information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • We use your email to confirm your membership and send you notifications such as when another user answers your question, comments on one of your answers, sends you a message, reacts to something you posted, or posts a question you may be interested in. We may also use it to send you information about your account, Brightway and its products.

  • We may use your name in emails we send to you if you provide us with your name.

  • We may use your city, state, date of birth, date of injury, type of injury, your employment status or your interests - if you provide this information to us - to present you with participation opportunities, such as additional Brightway services.

  • To provide or improve Brightway’s products and services, such as product performance, features and customer service.

  • To aggregate data for reporting or anonymized data for marketing purposes.

How we disclose your personal information

  • When you post information on our Site, by creating or replying to questions or messages, that information is considered to have been publicly disclosed by you.

  • If you sign up for Brightway Health using a third-party website or choose to share your question on a third-party website, such as Google or Facebook you must remember that we do not control these third party websites and are not responsible for their privacy policies. When you leave our Site, we encourage you to read the privacy policy of every website you visit. Their use of your personal information will be governed by their privacy policies and terms.

  • We use Fathom Analytics to, among other things, analyze and track users’ use on the Site, determine the popularity of certain content and better understand online activity. For example, Fathom may collect data about how much time you spend on our website, what pages you visit and how much time you spend on each page.

 

You can view Fathom Analytics’ Privacy Policy by visiting https://usefathom.com/privacy

 

Otherwise, we do not share, sell, or otherwise disclose individually identifiable personal information to any entity that we do not control, without your prior consent, except as required by law. 

 

You should be aware that Brightway Health may be required to disclose your personal information to the government or other entities in connection with a legal process, such as in response to a valid subpoena, court order in judicial or regulatory proceedings, or pursuant to a valid law enforcement investigative demand.

 

 

Information from Integrated Services like Facebook or Google

 

If you decide to register through or otherwise grant access to a third-party social networking or integrated service such as Facebook Connect or Google, we may also collect personal information that is already associated with your integrated service account.  You may also have the option of sharing additional information with Brightway Health through an integrated service.  If you choose to provide such information during registration or otherwise, you are giving Brightway Health the permission to use, share, and store it in a manner consistent with this Privacy Policy.

Minimum age requirement

 

You must be at least 18 years old to join Brightway Health. 

 

 

Deactivating Your Membership

 

If at any time you decide that you want us to stop processing your information, you should deactivate your membership. Upon termination of your membership your profile and posts will no longer be visible by others; however, we may retain this information internally, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

You can deactivate your membership by going to Settings and clicking “Delete my Account”.

 

You can request for your account to be permanently deleted. To request an account be permanently deleted expresses your intention to fully remove both your user account and any existing information relevant to your user account. This cannot be undone, and we won’t be able to recover any of your data in the future. You may submit a request for your user account to be permanently deleted by emailing us at privacy@brightwayhealth.org. Please provide us with your username and email address you used during your sign up. It may take up to 90 days to complete the deletion process after it begins. 

 

 

Access

 

You may access and change personal information on your profile at any time. This can be done by logging into your account.

 

 

Protecting Your Data

 

Stewardship of your personal information is critical to us and a responsibility we embrace. Our team is dedicated to keeping your information secure including testing for vulnerabilities. We also have established internal policies and procedures to limit access to Members' personal information to only those employees who need the information to perform a specific job.

 

Brightway Health employs commercially reasonable security measures consistent with standard industry practice and the HIPAA Privacy Rule, to safeguard personal and other information collected through this Site. We believe these practices provide adequate security to protect against the loss, misuse, or alteration of the information we collect on our Site. We have implemented measures and procedures that protect the privacy of individuals and we ensure that data protection is integral to all processing activities. This includes implementing measures such as:

  • Anonymization;

  • Pseudonymization;

  • Cyber security;

  • An information security policy.

 

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Cookies

 

We use a standard technology called "cookies" to help us administer the Site. Cookies are small data files stored on your computer that contain the address of the website and codes that your browser sends back to the website every time you visit it.  Some cookies reside on your computer persistently and help our Site to recognize your computer's browser as a previous visitor. We also use "session cookies" which expire when you close your browser and do not retain any information about you after they expire. This information allows us to customize delivery of information. For example, our Site may use cookies to save and remember registration information or preferences that you may have set while browsing the Site, to ensure you don't see the same content repeatedly, and to deliver content specific to your interests. We use cookies only to gather information as indicated in this Statement.

 

 

Your privacy rights

 

  • Accessing your data. Upon request, we shall provide any information relating to your data and our processing of your data. The information shall be provided in writing or by other means, including, where appropriate, by electronic means within 30 days of a written request.

  • Correcting your data. You have the right to ask us to rectify any inaccurate or incomplete personal information on our platform. If we have given your personal information to any third parties, we will notify those third parties that we have received a request to rectify your personal information, unless doing so proves impossible or involves disproportionate effort. Those third parties should also rectify the personal information they hold - however, we are not in a position to audit those third parties to ensure that the rectification has occurred.

  • Erasing your data. You can ask us to erase your personal information stored on our platform. If we receive a request to erase your data, we will ask you if you want your personal information to be removed entirely or if you want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). If we have given your personal information to any third parties, we will tell those third parties that Brightway Health has received a request to erase your personal information, unless this proves impossible or involves a disproportionate effort. Those third parties should also rectify the personal information they hold - however, Brightway Health will not be in a position to audit those third parties to ensure that the rectification has occurred.

  • Restricting the use of your data. We only process your personal information where we have the legal basis for doing so. 

  • Withdrawing your consent. Where we are relying on consent to process your personal information (for example consent to receive information about Brightway Health updates) you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

What are the Levels of Privacy Settings?

 

All information shared on the platform is public except for your name and email address, including questions and answers posted within our community.  Only members of the community will be able to contact you, unless you make your name or contact information publicly available or you turn off Messaging within the platform. 

 

 

California Online Privacy Protection Act.

 

As required by the California Online Privacy Protection Act ("California Act") and the California Business and Professions Code, this Privacy Statement identifies the categories of Personally Identifiable Information (as that term is defined above and in the California Act) that we collect through our website about individual consumers who use or visit our website and the categories of third-party persons or entities with whom such personally identifiable information may be shared. See more about the California Act at http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

 

 

Governing Law

 

Any dispute which may arise over privacy will be subject to this Statement and the provisions of law of the State of Maryland.

 

 

Contacting the Service

 

If you have any questions about this Statement, the practices of this Site, or your dealings with this Site, you can contact us at privacy@brightwayhealth.org.