STEP ONE SERVICE PRIVACY STATEMENT
This Privacy Statement applies to the https://steponeservice.com website (“Website”), which is owned and operated by Evergreen Health Partners and/or its affiliates and related companies (“Evergreen Health Partners”, “us” or “we”).
Step One Service™ cares about your personal integrity. Therefore, this Privacy Statement is provided to equip you with information about how Step One Service™ collects, uses, discloses and processes personal data gathered through your use of this Website or any of the other services that we may make available to you.
Our Privacy Statement also explains your privacy rights, and how you can manage the privacy of your Personal Information. Please note that this Privacy Statement does not govern the practices of third parties, including our partners, third party service providers, and/or advertisers, even when those services are branded as, or provided on behalf of, Step One Service™. Information collected from you by others, such as third party websites that you access through links on the Website, are governed by those entities’ privacy policies.
By using our Website, you acknowledge that you have read this Privacy Statement, and agree to be bound by it. If you do not agree to any of the terms contained in this Privacy Statement, your remedy is not to use the Website. Privacy Statement last updated: January 1, 2020.
Definitions
- Personal Information (also referred to as “Personal Data”): Personal Information means data about a particular individual or household that identifies, relates to, describes, could be reasonably linked with, or could be used to identify that person or household (or from those and other information either in our possession or likely to come into our possession). It also includes other information that may be associated with your Personal Information, such as your Usage Data (defined below), location, preferences or interests, if that information can be used to identify you or your household.
- Services: As noted above, our Services include the https://www.avalonhealthcare.com/ Website owned and operated by Step One Service™ as well as any services provided.
- Cookies: Cookies are small files stored on your device (computer or mobile device).
- Data Controller: The natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Information are, or are to be, processed. For the purpose of this Privacy Statement, we are a Data Controller of your Personal Information.
- Data Processors: Any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
- User (also referred to as “Data Subject”): Any individual who uses our Services and is the subject of Personal Information collected and/or processed.
Information We Collect
We use your information to provide the Services that you request, and to improve the Services we offer to you. By using our Services, you agree to the collection and use of information in accordance with this Privacy Statement.
Included below is a list of several different types of information used for various purposes to provide and improve our Service to you.
- Personal Information. In the course of visiting the Website and using our Services, we may ask you to provide us with or otherwise obtain certain personally identifiable information that can be used to contact or identify you (“Personal Information,” as defined above). Such Personal Information may include, but is not limited to, your name, address, email address, and any other information that may identify you. You may choose whether to disclose Personal Information, but you may not be able to use certain aspects of the Website without disclosing it. We may collect information you send us and combine it with information from other users and/or de-personalize it to make it non-personal Information.
- Generic Information. Generic Information is information that does not directly reveal the identity of an Step One Service™ client, or visitor to the Website. This information may include Usage Data and other aggregate usage metrics such as total number of Website visitors, pages viewed, and usage patterns within the Website, etc. This may also include information about your device. We may automatically gather some Generic Information from our members, customers, and Website visitors. In particular, we employ Google Analytics to collect user demographics, which helps inform us about our users’ ages, genders, and general interests an affinities. At times, the combination of various types of data, including Generic Information and Usage Data, may enable you to be identified, and may therefore qualify as Personal Information.
- Usage Data. We may also collect information on how you access and use our Services (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), your operating system version, browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, the site from which you linked to ours, search terms you used in search engines which resulted in you linking to our Website, unique device identifiers and other diagnostic data.
- Tracking & Cookies Data. We use cookies and similar tracking technologies to track the activity on our Website, and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Services. Examples of Cookies and other technologies we may use include, but are not limited to:
- Session Cookies. We use session cookies to remember your selections and/or changes you make when you interact with our Website. Session cookies are temporary, and are automatically deleted once you close your Internet browser.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings. Preference cookies are first party cookies that remain on your computer or device until you delete them or they are otherwise removed upon expiration.
- Third Party Cookies. We permit third-party service providers, advertisers and other companies to use cookies or other similar technologies on our Website. These companies may collect your information, track your behavior on our Website, and gather information about your use of our Website or services and other online services over time and across different services. Additionally, some companies may use information collected to deliver targeted ads on behalf of us or other companies, including on other websites or online services. We are not responsible for the functioning of cookies and other technologies used and placed by third parties on your device.
- Web Beacons. Web Beacons are small bits of code embedded in web pages or emails that assist in delivering cookies. Web beacons help us determine whether a page on this Website has been viewed and, if so, how many times. Although you cannot decline to receive web beacons when visiting a web page, you can choose not to receive web beacons by email if you disable HTML images or refuse HTML email messages, but you may not be able to experience all portions of the Website or service.
- Log Files. The Website server automatically recognizes the Internet URL from which you access this Website. We may also log your Internet protocol (“IP”) address for system administration and troubleshooting purposes. (An IP address indicates the location of your computer on the Internet.
Your Cookie Choices
When it comes to how you want to use or allow cookies to be used on your devices, you are in control. Most internet browsers are initially set to accept cookies. You may set your browser to block or otherwise control what cookies your browser or mobile device accepts via your browser or mobile device settings. Additionally, you can choose to modify your settings and delete those cookies that are otherwise stored on your device. Please consult the instructions provided by your browser or your mobile device’s manufacturer to determine how you can limit the placement of and/or remove cookies or other technologies. Please note, however, that limiting or disabling the use of cookies and other technologies may impact or adversely affect your ability to perform certain transactions on, use certain functionalities of, and access certain content on our Website.
Additional Data
We have collected the Personal Information listed above within the last 12 months.
How We Collect Your Information.
We collect and obtain your information in a few ways: there is information that you provide voluntarily, information that is technologically gathered through your use of our Services – including our Website – and information we obtain from third parties.
- Voluntarily Provided: We collect information that you decide to share with us. At times, we may require you to provide certain information – including Personal Information – in order to use certain parts of our Website, fulfill your requests with us, or provide you with certain Services. For instance, we may require you to provide your name, email address or other contact information when you contact us with a question or comment. Additionally, you may be required to provide Personal Information when applying for a job.
- Technologically Gathered: As noted above, we collect certain information from you through your use of our Services, such as Usage Data. For instance, in using our Website, we may collect information about the device you use to log into, access, and use the Website. We may collect other Generic Information in relation to how you use our Website or other Services (for example, aggregate metrics on how often certain pages on our Website are accessed and viewed). We also may collect information through the use of cookie, pixel tags, or other technologies, as described above.
- Information We Obtain from Third Parties: We may also obtain information about you from our third party service providers who help us provide our Services to you.
- The categories of third parties we receive Personal Information from include employment search companies, social media outlets, other health care providers, and health care insurance carriers.
How We Use Your Information
Generally, we use information provided through the Website to enhance and personalize the Website, to communicate with you via email, to contact you about our Services or relevant third parties’ services, to improve, administer, customize, and/or maintain the Website, for billing purposes, to understand our users’ preferences and patterns, and to carry out our obligations and enforce our rights.
We may use your information to provide you with news, special offers, marketing or promotional materials, and general information about other services, products, and events which we offer which we believe may be of interest to you, unless you have opted not to receive such information. You may opt out of receiving any, or all, of these communications from us by contacting us at the contact information listed below, or by following the “unsubscribe” links in such emails.
We may use non-personal Information to conduct market research and analysis for ourselves and for others or disclose information about demographics or use of our Website in a way that does not personally identify you. We may combine information about your use with information about others’ use to generate aggregated non-personal Information about visitors as a group. As noted above, we employ Google Analytics to collect user demographics, which helps inform us about our users’ ages, genders, and general interests and affinities. We may review this information and use it to view and create reports to assist us with analyzing our users’ preferences and patterns. We may combine this with your Personal Information or with other non-personal Information. When non-personal Information is combined in a way that it identifies you, it will be treated like Personal Information.
We may use your information to facilitate our business purposes in relation to the Services that we provide to you. These operational purposes may include but are not limited to:
- Undertaking tasks related to the operations of our Website, including the placement of ads and/or providing customized content to our users;
- Maintenance and improvement of our services, including the Website;
- Detecting security incidents; and
- Debugging our services.
How We Disclose or Share Your Information
We do not sell your information to any third party without your permission, and will not sell the Personal Information of anyone under the age of 16 without applicable consent. We will only provide your personal data if it is necessary in order to provide you with the information you have requested. However, we may disclose your information in a number of ways in order to provide our Services to you.
We may also provide your Personal Information to third party service providers who assist us in facilitating or providing certain services in relation to Step One Service™ business and therefore process Personal Information on Step One Service’s behalf. These include:
- IT service companies that host our Website or assist us in developing our Website;
- IT support service providers; and
- Other third party service providers, such as software providers.
These third party service providers are authorized to use your personal data only as necessary to provide their services to us.
We also may disclose your Personal Information in response to a subpoena or other court order, if otherwise required by law, or in an effort to cooperate with law enforcement. We may disclose your Personal Information when we believe that doing so is necessary or desirable for the following:
- To enforce our rights or defend against legal claims.
- To investigate, prevent, or take action regarding illegal activities suspected fraud, situations involving personal threats to physical safety, allegations of intellectual property infringement or violations of privacy rights.
- As otherwise required by law.
We may disclose your Personal Information in the event of a sale of substantially all of the assets, the merger, dissolution, or reorganization, or in connection with the transfer of a discrete portfolio of assets or information of Step One Service™, Inc., or one of its affiliates that operates this Website. If that happens, the new company’s privacy policy may govern the further protection, use, and disclosure of your Personal Information.
Categories of Third Parties that Receive Personal Information: We share or otherwise disclose individuals’ Personal Information to the following categories of third parties:
- Service Providers: We employ third party service providers, companies, individuals, and agents to facilitate and help us provide our Services to you. Such Service Providers perform tasks or functions on our behalf, provide Services-related services, or assist us in analyzing how our Services are used or delivered. These third parties are granted access to your information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
- Other Step One Service™ entities: We may share or disclose your information to our subsidiaries or affiliated companies.
- Marketing and social media entities: We may share your reviews and assessment of our Services to companies, such a Google, for marketing purposes and postings on social media outlets.
Categories of Personal Information Disclosed for Business Purposes: We may share certain Personal Information related to our business purposes outlined above.
Categories of Personal Information Sold: Except as otherwise stated in this Privacy Statement, we do not currently, but may in the future, share, sell, or rent your Personal Information with non-affiliated third parties so that they may offer, market and advertise products and services directly to you. If and when we decide to share your Personal Information with non-affiliated third parties other than as described in this Privacy Statement, we will provide you with advance notice and the choice to opt out of such information sharing.
Data Retention
We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Statement. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. Transfer of Data While our Website is available for anyone who is interested in Step One Service™, we do not sell or make available any products, goods, or other services to individuals outside of the United States, including the European Union. Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to United States and process it there. If you are located in the European Union, you should be aware that U.S. data protection laws are not deemed to be as adequate as those in the European Union. Your submission of such information represents your agreement to that transfer.
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. We take all reasonable technical, organizational, and otherwise, measures to protect Personal Information collected on our Website and elsewhere from being subject to accidental or unlawful destruction, accidental loss or alteration, disclosure without authorization, and any other unlawful actions taken against otherwise protected information. Moreover, we take all judicious legal, technical, and organizational measures to ensure that all Personal Information is handled with a sufficient level of security. Furthermore, we take all reasonable measures to protect Personal Information during transfers of said information to a third party.
Despite the security measures taken, we cannot guarantee the protection of the data you provide us. By using our Website and Services, you acknowledge that there are data security and privacy limitations inherent to the use of the Internet, and that the security, integrity, and privacy of any and all information exchanged between you and Step One Service™, or between you and other related entities, cannot be guaranteed. We cannot ensure or warrant the security of any information you transmit to us or that we store, and you do so at your own risk.
We use third-party payment processors to process any transactions you make with us, including via our Website. The processing of those transactions is governed by the payment processors’ privacy policy and security practices. We are not responsible for the third-party payment processors’ data security practices.
Our Policy on “Do Not Track” Signals under the California Online Protection Act (“CalOPPA”)
The Website does not respond to do-not-track signals from browsers or other similar mechanisms. While we (with the assistance of our service providers) do collect information about your use of the Website for our own use, we do not permit third party advertisers to collect personally identifiable information about your online activities for their use when you use the Website. Except as described above, we do not permit third-party data collection through the Website.
We do not track consumers’ online activities over time and across third-party sites or online services.
Third parties may collect data that relates to you. We cannot control third parties’ responses to do-not-track signals or other such mechanisms. Third parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.
Your California Privacy Rights
California residents are afforded certain rights related to their information under state law. We aim to take reasonable steps to allow California residents to correct, amend, delete or limit the use of your Personal Information, and exercise other rights available under applicable law. Step One Service™ informs you that, where applicable under relevant law, individuals may be entitled to the following:
- Right to Access / Disclosure: The right to have access to your Personal Information upon simple request – that is, you may receive a copy of such data upon receipt of a verifiable request, along with other information related to the collection or processing.
- Disclosure of Direct Marketers: The right to have access upon simple request, and free of charge, the categories and names of addresses of third parties that have received Personal Information for direct marketing purposes.
- Collecting, Selling, Sharing, or Disclosing Personal Information: Upon receipt of a verifiable request, to obtain a list of:
- The specific pieces of your Personal Information Step One Service™ holds;
- The categories of Personal Information collected about you, sold to third parties, or disclosed to third parties for business purposes;
- The categories of Personal Information sold within the last 12 months;
- The categories of sources from which Personal Information is collected;
- The business or commercial purpose for collecting or selling Personal Information; and
- The categories of third parties with whom Personal Information is shared, sold, or disclosed for a business purpose.
- Right to Opt-Out of the Sale of Personal Information: California residents have the right under the California Consumer Privacy Act (“CCPA”) to opt-out of the sale of their Personal Information under certain circumstances. As noted elsewhere, however, Step One Service™ does not sell individuals’ Personal Information at this time.
- Right to Correction: The right to correct your Personal Information if you find it is inaccurate, incomplete or obsolete.
- Right to Deletion / “Right to be Forgotten”: The right to obtain the deletion of your Personal Information in the situations set forth by applicable data protection law and upon receipt of a verifiable request.
- Withdraw of Consent to Processing: The right to withdraw your consent to the data processing without affecting the lawfulness of processing, where your Personal Information has been collected and processed based on your consent and not any other basis.
- Right to Object: The right to object to the processing of your Personal Information under certain circumstances, in which case we may ask you to justify your request by explaining to us your particular situation.
- Right to Restrict Processing: The right to request limits to the processing of your data, when allowed by and in circumstances set forth under applicable law.
- Right to Data Portability: The right to have your Personal Information directly transferred by us to a third-party processor of your choice (where technically feasible; may be limited to situations when processing is based on your consent).
- Right to Non-Discrimination: As defined under relevant law, you have a right to nondiscrimination in the Services or quality of Services you receive from us for exercising your rights.
Please note, however, these rights do not apply to protected health information that we may have been collected about you.
Please contact us at the information in “Contact Us” Section below in relation to exercising these rights. Note that we may ask you to verify your identity before responding to such requests.
More Information About Your Rights as a California Resident
Request Access to Specified Information
If you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of Personal Information with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address listed below to receive:
- the categories of information we disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year;
- the names and addresses of the third parties that received the information; and
- if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.
To make such a request, please provide sufficient information for us to determine if this applies to you, and attest to the fact that you are a California resident. Please also provide a current California address for our response. You may make this request in writing to us at the below address. Any such request must include “California Privacy Rights Request” in the first line of the description, and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the address provided for this purpose below.
Note that responsive information may be provided in a standardized format that is not specific to you.
Deletion Right Request
You have the right to request that any of your Personal Information that we collected from you and retained be deleted, provided certain exceptions do not apply. If we receive and confirm a verifiable consumer request, we will delete your Personal Information from our records, unless an exception applies, and direct our service providers to do the same.
Please note that we may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide the goods or service that your requested, take actions reasonably anticipated within the context of our business relationship, or fulfill our contractual obligations with you;
- Detect security incidents, protect against malicious activity, and prosecute those involved;
- Debug products to identify and repair errors that may impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise free speech rights, or another right as guaranteed by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the requested deletion might seriously damage the chance of that research’s achievement, if informed consent was previously provided;
- Enable solely internal uses that are reasonably aligned with consumer expectations based upon our existing relationship;
- Comply with a legal obligation; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Employee Exception
Please note that we are not required to provide or delete any of the above information to employees, agents, or contractors. Links to Other Sites Our Privacy Statement is designed to advise you about how we collect, use, protect, and disclose the information that we collect and/or receive about you. However, our Website may also contain links that lead to websites neither owned nor operated by us. As such, this Privacy Statement does not govern the practices of third parties, including partners, third-party service providers, and/or advertisers, even when those services are provided on our behalf or in partnership with us. Information gathered about you by others are governed by those distinct entities’ privacy policies. Therefore, we strongly recommend that you review the privacy policy of every website you visit. We exercise no control over and assume no responsibility for the content, privacy policies or practices of any third party site or services.
Children’s Privacy
All of our Services, including our Website, are intended for adult audiences, and are not meant to address anyone under the age of 18 (“Children”). As such, Children under 18 may not use our Website. If you are under 18, do not attempt to register for or use any of our services, including our Website, and do not provide us any Personal Information about yourself.
We do not knowingly collect Personal Information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has violated this Privacy Statement and provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we will take steps to remove that information from our servers.
Updates to this Privacy Statement
From time to time, Step One Service™ may modify this Privacy Statement. We will notify you of any material changes to its Privacy Statement by posting those changes on this page and updating the Privacy Statement modification date above. We encourage you periodically to check back to this page for any updates.
Submitting a Verifiable Request to Step One Service™
As mentioned above, California residents have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Step One Service™ will respond to an individual’s “verifiable request” to exercise his or her rights under such laws – that is, where we have received a request purporting to be from a particular individual, and we have been able to verify the individual’s identity. The need to verify an individual’s identity is critical to protecting your information, and ensuring that your information is not shared with anyone pretending to be you or someone who is not authorized to act as your agent on your behalf.
You may submit a verifiable request via our email address or mailing address, listed in the “Contact Us” section below, or as otherwise provided on our Website (if such means are available). We will ask you to provide information about yourself so that we can verify your identity as part of this process. This information may include your name, your address, your account information, and any other information deemed necessary by Step One Service™ to reasonably verify your identity, to ensure that your information is not shared with anyone impersonating you.
We may ask for additional information if we have difficulty confirming your identity. We will not share your information or honor other requests in those situations in which we are unable to confirm a request for your information is a “verifiable request.”
Under California law, a consumer can appoint an “authorized agent” to make certain verifiable requests upon their behalf, such as the right to know what information we collect about the consumer or to request deletion of the consumer’s information. Because the security and privacy of your information is paramount, we will ask that you identify and provide permission in writing for such persons to act as your authorized agent and exercise your applicable rights under California law in such situations. This may require us to contact you directly and alert you that an individual has claimed to be your agent and is attempting to access or delete your information. We will also independently verify your identity to ensure that an unauthorized person is not attempting to impersonate you and exercise your rights without authorization. We will not share your information or honor any other requests in those situations where you cannot or do not grant permission in writing for an identified authorized agent to act on your behalf, or where we cannot independently verify your identity.
How to Contact Us
If you have questions about this privacy statement, the practices of this site or your dealings with this site, please contact Step One Service™:
- By email: info@steponeservice.com
- By mail: Step One Service™, Inc. Attn: Legal Privacy Request 14136 Clayton Road, Town & Country, MO 63017
Difficulty Accessing Our Privacy Statement?
Individuals with disabilities who are unable to usefully access our Privacy Statement online may contact us at the above-listed contact information to inquire how they can obtain a copy of our policy in another, more easily readable format.