Privacy Policy

Overview

New England Collaborative Health Network (“NECHN”, “us”, “we” or “our”) is committed to respecting your privacy, and we follow a general policy of openness regarding our privacy practices. We have created website privacy policy (the “Privacy Policy” or the “Policy”) to inform you about (i) the types of information we collect from you, or that you may provide to us, when you access and use the website, https://www.nechnetwork.com,  (the “Website”), and the services, communications, and information provided on the Website (the “Services”), (ii) our practices for collecting, using, processing, and disclosing that information, and (iii) the choices you can make about how we collect, use, process, and disclose your personal information. This Privacy Policy applies to personal information collected on our Website, through our Website, and anywhere else this Privacy Policy is posted.

“Personal Information” is any Information that relates to, describes, references, is reasonably capable of being associated with, is linked to, or could reasonably be linked to, a particular individual, household or device, such as an individual’s name, postal address, email address, telephone number, or other online identifier. When anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information.

The Website is only directed to and intended for residents of the United States. If you reside in or are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), Canada, or anywhere else other than in the United States, our Website and Services are not directed to you and not intended for your use. If we learn we have collected or received personal information from a non-U.S. resident, we will delete that information. Additionally, we reserve the right to take all actions consistent with our Terms of Use.

Please read this Policy carefully and, if you have any questions, comments, or concerns, please contact us using the information provided in the Contact Us section at the end of this Privacy Policy.

Table of Contents

Overview
Children Under the Age of 18
This Website Privacy Policy
What Categories of Personal Information Does NECHN Collect?
Sources of Personal Information Collected
Purpose for Collecting Personal Information
Use of Personal Information
Categories of Personal Information We May Sell to or Share with Third Parties
To Whom Your Personal Information May be Disclosed
Cookies and Similar Technologies
Cookie Policy
Your Choices in Relation to Tracking and Online Advertising
Accessing and Correcting Your Information
Your State Privacy Rights
Your Nevada Privacy Rights
California “Shine the Light”
Exercising Your Privacy Rights
Choices About How We Use and Disclose Your Information
To Exercise Your Right to Opt-In
To Exercise Your Right to Opt-Out
Opting-Out of Non-Essential Email or Text Communications
Response Timing and Format
Requests Submitted by Authorized Agents
Appeal Process
Non-Discrimination
“Do-Not-Track” Signals
Data Security
Changes to Our Privacy Policy
Contact Us

Children Under the Age of 18

Neither the Website nor the Services are directed to or intended for persons under 18 years of age (or the age of majority in your state of residence) unless such person has obtained the consent of such person’s parent or guardian. We do not knowingly collect personal information from persons under 18. If you are under 18, do not use or provide any information on this Website or through any of its features or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.

If we receive any information from a visitor under the age of 18 without the consent of the visitor’s parent or guardian, we will delete all information about that visitor from our system as quickly as possible. No information collected from users under the age of 18 is used for any marketing or promotional purposes whatsoever. If you believe we might have any information from or about a child under 18, please contact using the information provided in the Contact Us section.

If you are under the age of 18 and would like to use our Website and/or Services, have your parent or guardian contact us using the information provided in the Contact Us section so that we may obtain the affirmative consent of your parent or guardian to the collection and use of your personal information as set out herein.

This Website Privacy Policy

This Policy applies to information we collect:

• On and through this Website;
• In email, text, and other electronic messages;
• Through our digital properties and Services; and
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Website.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by NECHN or any third party (including our affiliates, partners, and sponsors);
• Any third party (including our affiliates, partners, and sponsors), including through any application or content (including advertising) that may link to or be accessible from or through the Website;
• When you may choose to interact with features from third parties that operate independently from NECHN, such as links to third-party websites. NECHN has no control over and is not responsible for the privacy practices of such third parties. For example, if you click on a link to the website of one of our partners or sponsors, and you are directed out of our site, we are not responsible for the content or privacy practices of the website to which you are directed;
• To information publicly available from government records; or
• To de-identified or aggregated consumer information.

By using the Website or Services, you agree to us collecting, using, storing, disclosing, and otherwise processing your personal information in accordance with this Privacy Policy. If you do not consent to the collection, use, storage, disclosure or other processing of your personal information as described in this Policy, you should discontinue using our Website and not affirmatively provide your personal information.

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. Please check the Policy periodically for updates.

What Categories of Personal Information Does NECHN Collect About You?

Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, is linked, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device, which is considered personal information. When you access and use the Website and its Services, you may be asked to or may have the opportunity to provide your personal information to us.

Personal Information Collected Directly From You

We collect certain information from users accessing the Website, and we collect additional information from particular categories of users.

Categories of personal information that you may provide to us directly includes:

• Contact Information, such as your name, mailing address, telephone number, and email address;
• Payment Information, such as credit or debit card numbers;
• Demographic Information, such as date of birth and professional and employment information, including company name, and
• Any other identifier by which you may be identified online or offline.

You are responsible for ensuring the accuracy of personal information you provide to us. Inaccurate information may affect your ability to use the Website or Services, including the information you receive when using the Services and our ability to contact you and/or provide the Services to you. While you are not required to provide the personal information that we request, if you chose not to do so, we may not be able to provide you with our Services or respond to questions you may have.

We do not collect biometric information or sensory data. We do not collect non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)). We do not intentionally collect any sensitive data. We will not process your sensitive personal information or personal information collected from a known child without obtaining your consent.

If you provide any personal information about another individual to us, you are solely responsible for making sure that you have the authority to do so. By providing a third party’s personal information to us, you are affirmatively representing to us that you have and are exercising the right and authority to (i) provide such personal information to us on or through the Website and (ii) to allow us to use such personal information in accordance with this Privacy Policy. You acknowledge and agree that you will be solely liable for any claims of any nature resulting from your actions in providing a third party’s personal information to us.

Personal Information Collected Indirectly From You

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns.

We automatically collect and store certain types of information about your equipment, browsing actions, and patterns, as well as your use of the Website and Services, such as through the use of “cookies,” pixels and other tracking technologies. Examples of the categories of information we may collect automatically and indirectly includes:

• Internet or other electronic network activity information, such as:
  • your IP address;
  • Device ID;
  • Location of your device;
  • Browser type;
  • Operating system;
  • Internet service provider;
  • Content interaction information, such as pages visited, files or content viewed, time spent viewing content, download information, and dates and times associated with the same.
• Information from Cookies, including personal information.
• Profile information, such as information relating to your personal preferences, interests, and behavior.

The information we collect automatically may not personally identify you, but we may maintain or associate it with personal information we collect in other ways or receive from third parties.

We use the automatically collected information, including information from cookies and Internet or other electronic network activity information, to help us to improve our Website and Services and deliver better and more personalized experiences with the Website and our Services, including by enabling us to:

• Develop a user-friendly experience on the Website;
• Make the Website more useful for you and other visitors;
• Identify popular features or content on the Website;
• Estimate our audience size and usage patterns;
• Provide information and marketing that may be of interest to you;
• Store information about your preferences, allowing us to customize our Website and Services according to your individual interests;
• Speed up your searches; and
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include cookies. See Cookies and Similar Technologies and our Cookie Policy for more detail about cookies and information we collect automatically.

Sources of Personal Information Collected

We may collect personal information in the following ways:

• Directly from you when you provide it to us;
• When you visit our Website or download information from our site;
• When you participate in an online survey;
• If you ask a question, make a request, or otherwise contact us through this Website, including through a contact form, we may collect your first and last name, company, email address, phone number, and information in your message;
• If you send us an email, we may collect your name, email address, and any information that you provide in the email;
• Automatically as you navigate through the Website; and
• From third parties, for example, our service providers and affiliates.

We may also collect information from other sources, such as through social media, third-party platforms and forums, contacts, business partners, sponsors, and affiliates. Examples of the types of information we may receive from other sources are:

• Personal information, such as your name, personal and professional mailing address, email address, and phone number;
• Profile information, comments, and similar information provided to or on social networks and other forums that connect to us;
• Demographic information, interests, and purchasing behavior; and
• Information collected from you offline or through other channels. For example, information you provide over the phone, such as when we discuss our Services with you.

Some of the information we collect may, when combined with other information, be personal information that could be used to identify you. Such information is treated as personal information.

Purpose for Collecting Personal Information

We use, store, and otherwise process the information for purposes that include the following:

• To respond to your inquiries and provide support;
• To present our Website and its contents to you;
• To improve our Website and Services;
• To provide you with information or services that you request from us email alerts and updates, newsletters, or other marketing information or opportunities;
• To provide information about products or services in which you may be interested;
• To provide you with information about us, our Services, and our business activities;
• To support our business functions;
• To comply with any applicable COVID-19 tracing efforts;
• For customer service and customer support purposes;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
• To fulfill legal obligations we may have to you or others;
• To facilitate payment or delivery of services requested;
• To personalize, provide, measure, and improve our advertising and marketing;
• To help prevent transactional fraud;
• To provide you with support and respond to your inquiries, such as to investigate and address your concerns, and monitor and improve our responses;
• To provide you with notices regarding the Services;
• To deliver content, product, and service offerings based on your advertising customization preferences;
• To help maintain and improve the safety, security, and integrity of our Website and Services;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website or Services is among the assets to be transferred;
• For testing, research, analysis, and product development, such as to develop and improve our Website, Services, databases, other technology assets, and other offerings;
• To respond to law enforcement requests as required by applicable law, court order or governmental regulation;
• To notify you about changes to our Website, Services, Terms Of Use, or this Privacy Policy;
• As described to you when we collect your personal information;
• To fulfill any other purpose for which you provide your personal information;
• For any other purpose with your consent; and
• For any other lawful purpose.

Use of Personal Information

The following are ways in which we use certain categories of your personal information.

Personal Information We Collect About You	Why We Use Your Personal Information
Contact information, such as your name, mailing address, telephone number, and email address	Providing customer service; Responding to your comments, questions, and messages; Notifying you regarding the Website and Services; Updating you about our services; Offering new services and opportunities to you; Advertising; Marketing; Analytics; Research
Demographic information, such as date of birth and professional and employment information	Improving our Website and Services; Personalizing your user experience; Offering new services and opportunities to you; Advertising; Marketing; Analytics; Research.
Internet or other electronic network activity information, such as your IP address; Device ID; Location of your device; Browser type; Operating system; Internet service provider; Content interaction information; and information from cookies	Improving our Website and Services; Personalizing your user experience; Providing the Website and Services to you; Offering new services and opportunities to you; Advertising; Marketing; Analytics; Research; Website security.
Commercial information	Advertising; Marketing; Analytics; Research.
Profile information, such as information relating to your personal preferences, interests, and behavior	Improving our Website and Services; Improving and personalizing your user experience; Offering new services and opportunities to you; Advertising; Marketing; Analytics; Research.

We may also use your personal information to contact you about our own or third-parties’ goods and services that may be of interest to you or to enable us to display advertisements to our advertisers’ target audiences. If you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. For more information about how third-parties might collect your information or make assumptions about, such as that you meet a third-party’s target criteria, please see our Cookie Policy. If you are a resident of Colorado and you do not want us to use your personal information in this way, please see the Exercising Your Privacy Policy and associated sections. For more information about exercising rights you may have under applicable state law, please see Your State Privacy Policy.

Categories of Personal Information We May Sell to or Share with Third Parties

We do not intentionally sell personal information about visitors to the Website.

However, some exchanges of your personal information to third parties may be considered a “sale” under certain state privacy laws. We may share or sell (if considered a sale under certain state privacy laws) the following categories of personal information for the following purposes:

Personal Information We Collect About You	Why We Sell or Share Your Personal Information
Contact information	Advertising; Marketing; Analytics; Research.
Demographic information	Advertising; Marketing; Analytics; Research.
Internet or other electronic network activity information	Advertising; Marketing; Analytics; Research.
Information from Cookies	Advertising; Marketing; Analytics; Research.
Commercial information	Advertising; Marketing; Analytics; Research.
Profile information	Advertising; Marketing; Analytics; Research.

To Whom Your Personal Information May be Disclosed

NECHN is committed to the communities it serves and strives to collect only the personal information that we need. We do not sell your personal information in exchange for money. We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may sell (if considered a sale under applicable data privacy laws, e.g., the use of analytics) or share your personal information by disclosing it to a third party for a business purpose. We make these disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. We make these disclosures where it is required in order for us to perform our obligations under our contract with you, where it is required to provide the Services you requested, where it is required by law, or where we have another legitimate interest in doing so, including, but not limited to, as follows:

• To our affiliates (such as companies that we own, that own us, or companies that share common ownership with us);
• To consultants, service providers, and other third parties that perform services on our behalf, such as data management and storage providers, marketers and advertisers, analytics and research companies, and professional advisors, including Data Analytics (such as Google Analytics, Google Tag Manager, and Google Ads), Hosting Services, Sales and Marketing Tools, Ninja Forms, and ClickDimensions;
• To law enforcement agencies, regulators, and courts in response to a court order, subpoena, regulatory requirements or similar legal process, to report any activities we reasonably believe to be unlawful, or as otherwise required by law;
• To another entity in connection with a merger, transfer of data assets, reorganization, divestiture, financing, dissolution, or similar corporate event involving all or part of our business, in which personal information held by us about our Website users is among the assets transferred; and
• As otherwise discussed in this Privacy Policy.

Cookies and Similar Technologies

We, as well as third parties that provide content or other functionality for our Website, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Website. These technologies allow us to understand who has interacted with us and also help us to operate our Website and Services more efficiently. These technologies also help us deliver online advertising to you.

• Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. For more information on cookies, please see our Cookie Policy.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Website that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page.
• Marketing. We may use ClickDimensions or other marketing cookies for marketing automation in order to improve user experience and provide the Website and Services to users. For more information on how ClickDimensions uses your information, please see ClickDimensions’ Privacy Policy, at https://clickdimensions.com/about/privacy-policy/.
• Analytics. We also may use Google Analytics and Google Tag Manager to collect information regarding visitor behavior and visitor demographics for our Website and to develop content. For more information on how Google uses your information, please see Google’s Privacy Policy, at https://policies.google.com/privacy?hl=en-US, and Google’s Advertising Policy, at https://policies.google.com/technologies/ads?hl=en-US.

Cookie Policy

Overview
Cookies help make your browsing experience with our Website more personal. Different cookies serve different purposes, such as recognizing your devices, storing information about your preferences, identifying the geographic location of a user, tracking browsing habits and preferences to deliver personalized advertising, recalling information entered on forms, login pages, shopping carts or other features of the Website, helping us understand how the Website is being used, and generally improving your browsing experience on the Website.

Categories of Cookies:
There are different ways to classify cookies, including based on when they expire or whether they are managed by us or a third party.

Type of Cookie	Description
Persistent Cookies	Persistent Cookies stay on your computer or mobile device until you delete them.
First Party Cookies	First Party Cookies are those that may be managed by NECHN and originate from our Website.
Third Party Cookies	Third Party Cookies originate with service providers or business partners providing services on or through our Website; and can be used by these third parties to recognize your device when it visits other websites. Third Party Cookies may also be used for other purposes, such as analytics, advertising, and social media features.

Why do we use cookies?
We use cookies to learn how you interact with our Website and to improve your experience and provide you additional functionality on the Website. Certain things we do using cookies include subjects such as remembering your language preference, remembering Services you may have requested, and providing you with content and advertisements consistent with your interests.

What type of cookies do we use?

Strictly Necessary	These cookies are necessary for the Website to function and cannot be switched off in our systems. Strictly necessary cookies are typically set in response to actions or services that you request, such as setting your privacy preferences, logging in, filling out a form, or putting items in a shopping basket. Strictly necessary cookies can also be used to manage sessions on load balanced servers or to ensure user requests are routed consistently to the correct server. You can set your browser to block these cookies or to alert you about these cookies, but some parts of the Website will not work if you select such settings.
Performance Cookies	Performance cookies are sometimes called analytics cookies. We use these cookies to count visits and traffic sources so we can measure and improve the performance of our Website, including determining whether or not a user is new or returning, distinguishing users from one another, calculating new and returning visitor statistics. These cookies help us to know which pages are the most and least popular on the Website and to see how visitors move around the Website. For example, we use Google Analytics to help us understand how frequently the same people revisit the Website, how the Website is found (from advertising or referring websites), and which pages are most frequently viewed. All information collected through these performance cookies is aggregated and anonymous. This information is combined with data from a large number of other users to create an overall picture of Website use, and is never identified individually or personally and is not linked to any other information we store about you. For more information about Google Analytics, or how to opt-out of Google Analytics cookies, please visit Google’s Privacy Policy and Opt-out page. If you do not allow these cookies we will not know when you have visited our Website, and will not be able to monitor the Website’s performance.
Tracking, Marketing and Advertising Cookies	We may partner with third party advertisers who may use tracking pixels that set cookies to assist with delivering online advertising relevant to your interests. We or our advertising partners may build a profile of your interests and show you targeted advertisements on other sites. You can opt-out of almost all advertising cookies by updating your preferences on www.aboutads.info. These cookies do not directly store personal information about you, but they are based on uniquely identifying your browser and internet device. If you do not allow advertising cookies, you will not stop seeing advertisements—they just will not be tailored specifically to you.

How Do Third Parties Use Cookies on our Website?:
We work with third parties to provide certain services on the Website. These third parties include: Data Analytics (including Google Analytics and Google Tag Manager), Hosting Services, ClickDimensions, and Ninja Forms.

Third parties may use their own cookies to collect information about your actions on our Website and/or the advertisements you click on. They may use this information to deliver advertisements they believe are most likely of interest to you based on content you have already viewed. Third parties may also use this information to measure the effectiveness of certain advertisements. NECHN does not control such third party cookies. To disable or reject the third parties cookies, you should refer to their own websites and policies.

For more information on how some of our third party service providers collect and use information please refer to their privacy policies:

• Google: https://policies.google.com/privacy?hl=en-US
• ClickDimensions: https://clickdimensions.com/about/privacy-policy/
• Ninja Forms: https://ninjaforms.com/privacy-policy/

How do I Control Cookies?:
If you choose, you can set your browser to reject cookies or you can manually delete individual or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, this may alter your access and use of some of the pages and features on our Website.

You may also reject or block all or specific types of cookies from our Website by setting your preferences on our Website. You can change those preference at any time.

You may also visit https://allaboutcookies.org/ or https://www.aboutcookies.org/ for details on how to delete, reject, or block cookies and for further information on cookies generally.

Your Choices in Relation to Tracking and Online Advertising

• Users can visit Ad Settings (google.com), https://adssettings.google.com, for more information about its settings.
• Users can visit Google Analytics Opt-out Browser Add-on Download Page, https://tools.google.com/dlpage/gaoptout, for information on how to opt-out of Google Analytics
• To opt-out of third-party interest-based advertising from advertisers and third parties that participate in certain self-regulatory programs, please visit the Network Advertising Initiative, at https://thenai.org/opt-out/, and the Digital Advertising Alliance, at https://digitaladvertisingalliance.org/. Opt-outs are generally device and browser specific, meaning that you will need to opt-out on each device and browser you use. Please note, even if you opt-out of interest-based advertising, you will continue to receive ads, but they will not be targeted to your interests. Users of mobile applications may opt-out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoice mobile app, https://apps.apple.com/us/app/appchoices/, and selecting the user’s choices.
• You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly

Accessing and Correcting Your Information

• You may send us an email to the email address specified in the Contact Us section of this Privacy Policy to request access to, correct, obtain, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement, cause the information to be incorrect, or the request is otherwise subject to a legal exception.
• Please see Your State Privacy Policy for more information.

Your State Privacy Rights

State consumer privacy laws may provide their residents with certain rights regarding our use of their personal information. As of the date on which this Privacy Policy was last updated, California, Colorado, Connecticut, Indiana, Iowa, Montana, Oregon, Nevada, Tennessee, Texas, Utah, and Virginia have each passed their own consumer privacy laws. Some of these laws may not take effect until a later date. However, please note that, at this time, only the consumer privacy laws of Colorado, Indiana, and Oregon apply to non-profit entities and, as of the date on which this Privacy Policy was last updated, only the consumer privacy law of Colorado is in effect (see below). Should these privacy laws apply in the future, we will let you know in an updated version of this Privacy Policy.

• The Colorado Privacy Act (CPA) (Colo. Rev. Stat. Ann. § 6-1-1306) (effective July 1, 2023)
• The Indiana Consumer Data Protection Act (SB 00005) (effective January 1, 2026)
• The Oregon Consumer Privacy Act (S.B. 619) (effective January 1, 2026)

Colorado, Indiana, and Oregon each provide their residents with rights to:

• Confirm whether we are processing your personal information;
• Access your personal information;
• Delete personal information concerning you;
• Correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information; and
• Obtain your personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. Some states’ privacy laws may limit the number of times per year that you are allowed to exercise this right. For Indiana residents, we have the discretion to instead send you a representative summary of your personal information.
• Opt-out of the processing of your personal information, or authorize another person to opt-out on your behalf, for:
  • profiling in furtherance of decisions that produce legal or similarly significant effects; or
  • the sale of personal information.
• Appeal our refusal to honor your exercise of these rights within a reasonable time.
• Not to be discriminated against for exercising any of your state privacy rights.

See Non-Discrimination for more information.

The parents or guardians of residents of Indiana and Oregon, and the parents or guardians of Colorado residents under the age of thirteen (13), may exercise the above rights on behalf of the resident.

If you are a resident of Colorado you may exercise your privacy rights by following the procedures set forth in Exercising Your Privacy Rights, To Exercise Your Right to Opt-Out, and Appeal Process.

Your Nevada Privacy Rights

Under NRS 603A.340, Nevada provides its residents with a limited right to opt-out of certain personal information sales, including personal information such as your first and last name, postal address, email address, telephone number, SSN, an identifier that allows you to be contacted either physically or online, or any other information about you that, in combination with an identifier, makes the information personally identifiable. Nevada residents who wish to exercise this sale opt-out right may submit a request by using the information provided in the Contact Us section below. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

California “Shine the Light”

In addition to the rights described above, California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please contact us as set out in the Contact Us section, Attn: California Shine the Light Inquiry. This request may be made no more than once per calendar year.

Exercising Your Privacy Rights

As of the date of this Privacy Policy, only Colorado residents have the rights set out in this section, Exercising Your Privacy Rights.

Verification: Only you, or someone legally authorized to act on your behalf, may make a request to exercise your privacy rights. We will need to verify your identity before processing your request. In order to verify your identity, we must be able to match certain information you provide us to the information we maintain about you. Your request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such person; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Certain requests may require us to obtain additional personal information from you. 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. We will only use personal information provided in the request to verify the requestor’s identity or authority to make the request.

Authorized Agents: You can empower an “authorized agent” to submit requests on your behalf. We will require the authorized agent to have a written authorization confirming their authority pursuant to the relevant legal regulations.

Method: To exercise any of your privacy rights, including the rights to know, access, correct, delete, or obtain your personal information, please email or write to us as provided in the Contact Us section below.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by contacting us using the formation in the Contact Us.
• Promotional Offers from NECHN. If you do not wish to have your email address or other contact information used by NECHN to promote our own or third parties’ products or services, you can opt-out by Contact Us. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to NECHN as a result of a purchase of the Services.

Residents of certain states, such as Colorado, Indiana, and Oregon may have additional personal information rights and choices with respect to our use of their personal information. Please see Your States Privacy Rights for more information.

To Exercise Your Right to Opt-In

You can opt-in to the selling or sharing of your personal information by clicking:

OPT-IN TO SELLING OR SHARING MY PERSONAL INFORMATION

or by contacting us via the information in the Contact Us section of this Privacy Policy.

To Exercise Your Right to Opt-Out

You can opt-out of the selling or sharing of your personal information by clicking:

DO NOT SELL, SHARE, OR PROCESS MY PERSONAL INFORMATION

As stated previously, NECHN does not sell your personal information for monetary consideration.

In addition to, or in lieu of, the link DO NOT SELL, SHARE, OR PROCESS MY PERSONAL INFORMATION, you may contact us via the information in the Contact Us section of this Privacy Policy. You may also exercise your opt-out rights by managing your preferences, as set out in the Cookie Policy. Please note that there are some categories of personal information that are required and that may not be subject to the opt-out rights, such as personal information needed to complete a transaction you requested.

Opting-Out of Non-Essential Email or Text Communications

If you do not wish to receive email or text communications from us, you may opt-out of receiving such communications by emailing or writing to us as provided in the <> section below. You may also reply to the email or text in question and request that you receive no further correspondence from us. You may follow this same procedure to change or update information you have previously provided to us.

Your election not to receive promotional and marketing correspondence from us will not (a) preclude us from corresponding with you, by email, text or otherwise, regarding your existing or past relationship with us, nor (b) preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing your personal information while maintaining and improving the Website.

Response Timing and Format

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days (or the applicable timeframe provided by law) of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing prior to the expiration of the original 45 days.

We will deliver our written response electronically to the email address we have on file for you, regardless of the email address from which you submitted the request.

Any disclosures we provide will only cover the twelve- (12) month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests (if applicable), 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.

You can request information free of charge once per year. For a second or subsequent request within a 12-month period, we may charge an amount that is the same for the provision of a public record, which is $0.25 per standard page, or a fee not to exceed the actual cost of providing a copy, printout, or photograph of the record in a format other than a standard page.

Requests Submitted by Authorized Agents

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where you provide sufficient evidence that the requestor is an authorized agent with written permission to act on your behalf and you successfully verify your own identity with us. An Authorized Agent can make a request on the subject consumer’s behalf by:

• For requests to know and delete: (1) providing a valid power of attorney under the laws of the subject individual’s state of residence; or (2) providing sufficient evidence to show that the subject consumer has (i) provided the Authorized Agent signed permission to act on their behalf, (ii) verified their own identity directly with us, and (iii) directly confirmed with us that they have provided the Authorized Agent permission to submit the request on their behalf; and
• For requests to opt-out: submitting a signed permission demonstrating that the Authorized Agent has been authorized by the subject consumer to act on their behalf.

Appeal Process

If we refuse to take action upon your request to exercise any of your state privacy rights, we will notify you without undue delay, but within forty-five (45) days (or the applicable timeframe provided by law) of the receipt of the notice. You may appeal our decision within a reasonable period after you receive notice of our decision.

To initiate an appeal, please contact us using the information in the <> section and inform us that you would like to appeal our decision. Within forty-five (45) days (or the applicable timeframe provided by law) after we receive your appeal, we will inform you of any action taken or not taken in response to your appeal, and we will provide you with a written explanation of the reasons in support of our response.

If your appeal is denied, we will also provide you with an online mechanism, if available, or other method through which you may contact your state attorney general to submit a complaint, should you wish to do so.

Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. Unless permitted by the applicable privacy law(s), we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

“Do-Not-Track” Signals

Some web browsers may transmit “do-not-track” signals to Website with which the user communicates. The Website does not monitor or identify “do not track signals” from your computer, and such signals will not impact the operation of this Website. If you wish to ensure that you are not being tracked while you use the Website, please see the Choices About How We Use and Disclose Your Information and To Exercise Your Right To Opt-Out sections of this Privacy Policy.

Data Security

We care about the privacy of your personal information and have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. As a result, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

Contact Us

To ask questions, provide comments, or express concerns regarding this Privacy Policy or are privacy practices, or to exercise any of your state privacy rights, contact us at:

Compliance Officer
1573 Mallory Lane, Suite 200
Suite 200
Brentwood, TN 37027
Phone: 615-371-7979
Email: info@ovationhc.com