Last updated 11/9/2023
Wilton Cross, Inc. (Wilton Cross, "we" or "us") is committed to protecting your privacy. This Privacy Policy (“Policy”) describes how we collect, use, disclose and protect your Personal Information (defined below). It applies to all Personal Information processed by us in connection with or as part of providing our Services or engaging in written or electronic communications with you.
This Policy does not:
Describe how we collect or use your Protected Health Information (as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”)), which is covered by our Notice of HIPAA Privacy Practices; or
Describe how we collect or use Personal Information provided to us or collected by us about a person in the course of the person acting as a job applicant or employee with us.
By using or interacting with our website, app, and other products or services (“Services”), you accept the privacy practices described in this Policy. If you disagree with any part of this Policy, you must not use or access our Services.
We may modify this Policy from time to time. The date of change will be shown next to “Last Updated” at the top of this page. We encourage you to read this Policy periodically to ensure you have up-to-date knowledge of our privacy practices. When we make material changes to this Policy, we will provide you with notice before the modifications are effective by sending a message to the email address associated with your account. By continuing to access or use the Services after changes to this Policy become effective, you accept the revised Policy. If any changes are unacceptable to you, you may stop using our Services at any time.
Categories and Sources of Personal Information We Collect
We collect Personal Information when you use our Services, create an account with us or provide Personal Information to us. “Personal Information” is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular individual, including, but not limited to, a first and last name, unique identifier, email address, a home, postal or other physical address, and phone number. The categories of Personal Information that we may collect about you are:
Information You Provide to Us
We collect information you give us when you register with us for an account, when you use our Services, when you participate in surveys or promotional activities, give us feedback, or when you otherwise choose to provide your information to us.
When you sign up for an account we may collect your name, address, phone number, email address, race, ethnicity, title, birth date, sex, gender identification, credit card information, together with other information such as occupation and personal interests. We may also ask you about income or other financial information to determine if you qualify for a waiver of any fees.
When you use our Services, such as logging into your account or speaking with our administrative staff, we may collect your name, address, email address, phone number, birth date, credit card information, audio (with your permission), photos and videos (with your permission), or other files in media storage or other shared storage directories (with your permission), and/or request access to your microphone or camera in order to verify your identity and provide Services to you.
From time-to-time, we invite users to volunteer to participate in surveys or promotional activities or give us feedback. When a user participates, we request certain Personal Information such as name and email address. We may use this information to follow-up with the participants, or, if applicable, to notify contest winners and award prizes
Communications from You
When you use our Services (for example on our website), complete electronic forms, or contact us by online chat, email, phone, or text, we may automatically collect and store certain information about you and the activity you engaged in, for example: your name and contact information; information that you voluntarily provide to us; the nature of your communication; the purpose of the interaction, and the action we took in response to your inquiry or request
Information Related to Your Use of the Services
We may automatically collect information about your use of the Services (we refer to this information as "Usage Data"), including information sent by your device. For example, we may collect:
Device information, such as your hardware model, IP address (the Internet address of your computer), unique device identifiers, and other information such as your browser type and operating system.
Website usage information regarding customer traffic patterns and website usage. This may include the web page that you were visiting before accessing our website or mobile application, the pages or features of our website or mobile application you browsed to inform us which part of our website, app and Services you visit and how much time you spend there.
Information about your preferences to make your use of the website more productive through the use of cookies.
Additional information about our use of cookies and other data trackers can be found below.
Information Sent by Your Mobile Devices
We collect certain information that your mobile devices send when you use our Services, such as the unique identifier, user settings and the operating system of your device, as well as information about your use of our services on your mobile device.
Location Information
When you use our online Services, we may collect and store information about your general location by converting your IP address into a rough geo-location, so we can, for example, provide you with information about services available in your geographic market. We may also access your mobile device’s GPS coordinates or course location, but only if you have previously agreed that we can collect this information by allowing the sharing of your location information. If you do not want us to have your location information, you may disable the location sharing feature on your device or browser.
Information from Our Clients and Partners
We may receive your Personal Information from our business clients and partners, such as your employer, in connection with one or more business purposes, including to make our Services available to you.
Mobile Applications
Depending on your permissions, we may receive your Personal Information from your internet service and mobile device providers. Users of mobile devices who do not want to receive interest-based advertising may opt-out in several ways. Learn more about your choices for mobile devices by visiting Your Ad Choices. To end all targeting on a mobile device immediately, turn on “Limit Ad Tracking” in the device settings.
Social Media
Depending on your permissions, we may receive your Personal Information from your social media accounts. You can edit or remove Personal Information usage permissions by using privacy settings on your social media account.
II. Purpose for Collecting Your Personal Information
We will only use your Personal Information as described in this Policy or otherwise through your informed consent.
We will use your Personal Information to provide information or perform Services that you request. We may use general location information to improve and personalize Services to you, such as providing location-relevant information and Services to you. Your information may be available or provided to third-party service providers in order to provide you with the information or to support the Services you request. These third-party service providers are contractually obligated to protect your information as disclosed in this Policy.
We will use your Personal Information for the purposes of furthering our business and the business of our affiliated companies, including creating, operating, delivering, maintaining, and improving our content, products, and Services. We may monitor how our users use our Services including without limitation time spent using our Services, pages visited, and content viewed. Aggregated forms of this data may also be used for research and development purposes in order to offer new features, functionalities, content, products and services.
We analyze, and may engage third parties to analyze, your Personal Information and Usage Data to determine the usefulness of our website, mobile app, and other elements of the Services. Analytics help us determine how effective our navigational structure is in helping users reach the information they seek, completing the task they wish to complete, etc., and to tailor features and functionalities to our users’ needs and preferences.
Marketing lets us grow our community and update you about new products and services, including those offered together with our affiliated companies. We process your contact information or information about your interactions on our Services to: send you marketing communications and keep you updated about our products and services; provide you with informational content; and deliver targeted marketing to you.
We may periodically send you free newsletters and emails that directly promote our Services, and that we believe may be of interest to you. In some instances you will be asked to opt-in to certain SMS text marketing and other electronic communications. If you choose to opt-in to receive SMS texts from us, that choice will not be shared with third parties except as necessary to fulfill your choice. When you receive such promotional communications from us, you will have the opportunity to "opt-out" (either through your account or by following the unsubscribe instructions provided in the email or text you receive).
We do need to send you certain administrative and transactional communications regarding the Services and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms, this Policy, or information about billing, among others.
We collect information that you provide to us when you contact us, such as with questions, concerns, feedback, disputes or issues, so we can address your needs and support your use and enjoyment of the Services.
We care about keeping you secure and safe while using our Services. Keeping you safe requires us to process your Personal Information, such as your device information, log-in information, activity information and other relevant information to proactively manage privacy and security risks. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity to prevent unauthorized users from gaining access to your information.
Our Services are subject to certain laws and regulations which may require us to process your Personal Information. For example, we process your Personal Information to comply with privacy laws, comply with employment laws, or as necessary to manage risk as required under applicable law. We will ask for information to verify your identity and residence status in order to fulfill your requests related to your rights under certain state laws (described below).
When you access or use our Services, you are bound to our Membership Terms and this Policy. To ensure you comply with them, we process your Personal Information to actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on our Services. We also process your Personal Information to investigate, prevent or mitigate violations of our terms, agreements or policies.
Uses and Disclosures
Uses and disclosures of your PHI may be permitted, required, or authorized. The following categories describe various ways that we use and disclose PHI.
Among Stepwell Care Personnel
We may use or disclose information between or among personnel having a need for the information in connection with their duties that arise out of the provision of diagnosis, treatment, or referral for treatment of alcohol or drug abuse, provided such communication is: (i) Within the treatment center; or (ii) Between the treatment center and other Stepwell Care facilities. For example, our staff, including doctors, nurses, and clinicians, will use your PHI to provide your treatment care. Your PHI may be used in connection with billing statements we send you and in connection with tracking charges and credits to your account. Your PHI will be used to check for eligibility for insurance coverage and prepare claims for your insurance company where appropriate. We may use and disclose your PHI in order to conduct our healthcare business and to perform functions associated with our business activities, including accreditation and licensing.
Secretary of Health and Human Services
We are required to disclose PHI to the Secretary of the U.S. Department of Health and Human Services when the Secretary is investigating or determining our compliance with the HIPAA Privacy Rules.
Business Associates
We may disclose your PHI to Business Associates that are contracted by us to perform services on our behalf which may involve receipt, use or disclosure of your PHI. All of our Business Associates must agree to: (i) Protect the privacy of your PHI; (ii) Use and disclose the information only for the purposes for which the Business Associate was engaged; (iii) Be bound by 42 CFR Part 2; and (iv) if necessary, resist in judicial proceedings any efforts to obtain access to patient records except as permitted by law.
Crimes on Premises
We may disclose to law enforcement officers information that is directly related to the commission of a crime on the premises or against our personnel or to a threat to commit such a crime.
Reporting as Required by State Law
We may disclose information we are required to report under state law. However, we may not disclose the original patient records without consent or a court order.
Court Order
We may disclose information required by a court order, provided certain regulatory requirements are met.
Emergency Situations
We may disclose information to medical personnel for the purpose of treating you in an emergency.
Research
We may use and disclose your information for research if certain requirements are met, such as approval by an Institutional Review Board.
Audit and Evaluation Activities
We may disclose your information to persons conducting certain audit and evaluation activities, provided the person agrees to certain restrictions on disclosure of information.
Reporting of Death
We may disclose your information related to cause of death to a public health authority that is authorized to receive such information.
III. Personal Information Sharing and Disclosure
Your Personal Information is not shared with third parties without your permission, except as described in this Policy.
a. Information Shared with Our Employees and Service Providers
We engage employees and third-party services providers to work with us to administer and provide the Services or to promote our Services. These employees and third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf and are expressly obligated not to disclose or use your Personal Information for any other purpose.
b. Information Disclosed in Connection with Business Transactions
If we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale, or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Information, may be disclosed or transferred to a third-party acquirer in connection with the transaction. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Policy. Any information you submit or that is collected after a transfer, however, will be subject to a new privacy policy adopted by the successor entity.
c. Information Shared with Our Affiliates
We work with our subsidiaries and affiliates (“Affiliates”) to make certain services available to consumers. We may share your Personal Information with our Affiliates in order for us and our Affiliates to provide services to you or to respond to your requests and inquiries.
d. Information Disclosed for Our Protection and the Protection of Others
We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information about you to government or law enforcement officials as we, in our sole discretion, believe necessary or appropriate: (i) to enforce our Membership Terms, (ii) to respond to claims and legal process (including subpoenas); (iii) to protect the property, rights and safety of a third party, our users, or the public in general; (iv) to protect our property, rights and safety; (v) to stop any activity that we consider fraudulent, illegal, unethical or legally actionable; and (vi) as required by applicable local, state or federal laws.
IV. Cookies and Other Tracking Technologies
a. Cookies
i. General Information
A "cookie" is a small data file that certain websites write to your computer or smart device when you visit them. A cookie can't read data off your hard disk or read cookie files created by other websites. We use session cookies that are deleted when you leave our website and close your browser, and persistent cookies that can remain even after you leave. A cookie file can contain information such as a user ID that the website uses to track the pages you've visited. The cookies that are configured by our website do not contain directly identifying information, such as your name or sensitive information, such as your credit card number. Cookies are used:
to make our Services function properly;
to provide a secure browsing experience during your use of our Services;
to collect passive information about your use of our Services;
to support our marketing campaigns, including to measure how you interact with our marketing campaigns;
to help us improve our Services; and
to remember your preferences for your convenience.
ii. Types of Cookies on Our Services
We use the following types of cookies on our Services:
Strictly Necessary Cookies - These cookies are essential because they enable you to use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, Services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work and they cannot be disabled.
Functional Cookies - We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name and location. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.
Performance or Analytics Cookies - These cookies collect passive information about how you use our Services, including webpages you visit and links you click. We use the information collected by such cookies to understand our users better and to improve and optimize our Services. We do not use these cookies to target you with online marketing.
Third-Party Cookies - These are cookies that are provided by third-party service providers and belong in one of the cookie categories described above. These third-party providers process your Personal Information on our behalf pursuant to our instructions and obligations consistent with this Policy.
iii. How to Manage Cookies
Depending on whether you would like to manage a first-party or third-party cookie, you will need to take the following steps:
First-Party Cookies - If you prefer not to receive cookies while browsing our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by changing the settings in your browser. You do not need to have cookies turned on to use and navigate through many parts of our website, although if you block or disable the cookie functions, you may not be able to access all portions or features of the website and the Services. Please follow instructions provided by your browser (usually located within the "Help", "Tools" or "Edit" settings) to disable first-party cookies. You can find more information about how to change your browser cookie settings here.
Third-Party Cookies - Some third-party services providers that we engage (including third-party advertisers) may also place their own cookies on your device. Note that this Policy covers only our use of cookies and does not include use of cookies by such third parties. Modern browsers also allow you to block third-party cookies, please see section above to learn how to do that.
b. Web Beacons
Web Beacons, also known as web bugs, pixel tags or clear GIFs, are tiny graphics with a unique identifier that may be included on our website to deliver or communicate with cookies, in order to track and measure the performance of our website and Services, monitor how many web visitors we have, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s device, Web Beacons are typically embedded invisibly on web pages (or in an email).
c. Analytics Technologies
Users of our Services who have JavaScript enabled may be tracked using analytics technologies, including Google Analytics. Unless the Analytics feature is blocked, it collects the following types of information from the user: type of user agent (web browser) used, software manufacture and version number; type of operating system; network location and IP address; country, city, state, region, county, or any other geographic data; hostname; bandwidth (internet connection speed); time of visit; pages visited; time spent on each page of the website; referring site statistics; the website (URL) the user came through in order to arrive at our website; search engine query used (example: typing in a phrase into a search engine, and clicking on a link from that search engine). The data collected by the analytics technology is primarily used to optimize the Service experience for our users. We also use this data for our own business purposes, for example, to analyze how many users we have, where visitors come from, and understand how they interact with us.
The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies.
d. Interest-Based Advertising
We may use information collected about a user’s use of our Services to arrange for advertisements about our Services to be served to the user on third party’s websites. To do so, our advertising service providers place or recognize a unique cookie on the user’s browser and use other techniques, such as pixel tags. Please visit the Network Advertising Initiative for more information about this practice and to learn about your choices. Users may opt-out of receiving interest-based advertising. The opt-out may be provided through specific opt-out cookies. Please visit Your Ad Choices and the Network Advertising Initiative to learn more.
V. Mobile App Account Deletion
At any time you may request removal of your mobile app account and deletion of your data, however, doing so may impact our ability to provide you with care. Requests can be made to contact@stepwellcare.com or through a discussion with your primary therapist. Deletion of your account does not in any way affect the retention of data in your medical record which is governed separately under our HIPAA policy.
At any time you may request removal of your mobile app account and deletion of your data, however, doing so may impact our ability to provide you with care. Requests can be made to contact@stepwellcare.com or through a discussion with your primary therapist. Deletion of your account does not in any way affect the retention of data in your medical record which is governed separately under our HIPAA policy.
VI. Links to Third Party Sites
We may contain links to other sites that are owned or operated by third parties. We are not responsible for the content, privacy or security practices of any third parties. To protect your information, we encourage you to learn about the privacy policies of those third parties.
VII. Our Social Media Usage
We have accounts on social media platforms through which we may post information or conduct promotional activities. If you use social media to follow us or interact with us, we may collect Personal Information you choose to share with us. Please understand your use of the social media services may result in the collection or sharing of information about you by those social media services. We have no control over, and decline all responsibility for, the use of your personal data by these third parties. Your use of social media, including your interactions with us on social media, are at your discretion. We encourage you to review the privacy policies and settings on the social media services with which you interact to make sure you understand how your information may be collected, used, and shared by those social media services.
VIII. International Transfer
Your information is stored on controlled servers with limited access and may be stored and processed in the United States or another country where our service providers are located. We offer our Services only to individuals located in the United States, and we do not advertise our Services outside the United States. If you are located outside the United States and choose to provide your Personal Information to us, please note that we may transfer your Personal Information to the United States or another country where our service providers are located, and such countries may not provide the same data protection. Those who choose to access and use the Services from outside the United States do so on their own initiative, at their own risk, with this understanding.
IX. Data Security
We safeguard the security of the information you provide to us with physical, electronic, and administrative procedures. For certain features of our Services we use industry-standard SSL-encryption to enhance the security of data transmissions. Your account information is password-protected for your privacy and security. While we strive to protect your information, we cannot guarantee the security of the Internet, and cannot ensure the security of the information that is transmitted through the Internet.
Please recognize that protecting your Personal Information is also your responsibility. We urge you to take every precaution to protect your information when you are on the Internet, or when you communicate with us and with others through the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account might have been compromised), or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the “How to Contact Us” section. If your payment information, username, or password is lost, stolen, or used without permission, please promptly update your account or notify us and we will assist you in updating your account details.
Some portions of the Services (for example our presence on social media) allow users to submit comments, reviews, ratings and other information that may be displayed on the Services and viewed by others. We recommend that you do not post on or through the Services any information that you do not want to make available to other users or the public generally. You assume all responsibility for any loss of privacy or other harm resulting from information you post publicly.
X. Contact Us
If you have questions or concerns about our collection, use, or disclosure of your Personal Information, please email us at contact@stepwellcare.com. Or write to us at: Privacy Officer, 10770 N 46th St, Suite A1200, Tampa, FL 33617.