Privacy Policy Citizens Disability - SSDI & Benefit Advocates

Mindset Care Privacy Policy

 

Last updated 10/12/2024

Thank you for visitingthe Mindset Care website located at https://mindset.care (the Site”).The Site is the property of Mindset Care Inc. (“Mindset Care”, “we”, “our” or “us”). This Mindset Care privacy policy ("Privacy Policy") including, without limitation, our [SMS/MMS Mobile Message Marketing][1][Program Terms and Conditions][2]covers our treatmentof personal information and other information that we collect when an end-uservisitor to the Site (“User”, “you” or “your”): (a) accesses or uses the Site; (b) accesses and/or views any of the: (i) links to resources and/or information on the Site, as well as related products and/or services (“Third Party Websites”); and/or (ii) text, video and/or other information on the Site, as well as related products and/or services, made available on the Site (the “Informational Content” and together with the Third Party Websites,the “Content”); (c) accesses links to Mindset Care's social media pages/accounts featured on third-party social media websites (collectively, “Social Media Pages”); and/or (d) utilizes the various contact forms and/or contact information made available on the Site as a means to contact directly, or request to be contacted by, Mindset Care and/or other related productand/or third party service providers (the “Third Party Service Providers”, and collectively, the “Contact Services”). Please note that if you are a resident of, or physically located in, a country other than the United States, you are not permitted to use either the Site or any Content or Social Media Pages (collectively, the “Site Offerings”).

Capitalized terms not defined herein shall have the meanings set forth in the Mindset Care Terms of Use (“Terms of Use”).

Users with disabilities who wish to access this Privacy Policy in an alternate format may contact us by emailing us at: allison@mindset.care; calling us at: 888-502-3799; or writing to us via mail to: Mindset Care, Attention: Privacy, 80 Broad St Fl 5 Suite 1085, New York, NY 10004.

IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICYIN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE SITE OFFERINGS.

When you register on our Site, you hereby agree and acknowledge that your personal information will be placed into a Mindset Care database, that such personal information may be shared with third parties for marketing purposes, and that you agree with the terms of this Privacy Policy in their entirety.

1. YOUR CALIFORNIA PRIVACY RIGHTS


Shine the Light. If you are a residentof the State of California and would like tolearn how your "personal information" (as defined in the Shine the Light Law, Cal. Civ. Code 798.83) is shared with third parties, what categories of personal information we share with third parties, as well as the names and addresses of those third parties, please email us at: allison@mindset.care; call us at: 888-502-3799; or write us via mail to: Mindset Care, Attention: Privacy, 80 Broad St Fl 5 Suite 1085, New York, NY 10004.

Further, if youare a resident of the State ofCalifornia and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please email us at: allison@mindset.care; call us at: 888-502-3799; or write us via mail to: Mindset Care, Attention: Privacy, 80 Broad St Fl 5 Suite 1085, New York, NY 10004. Please be advised thatwhere California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law. When you request the information, use the phrase “California Shine the Light Request” to help us appropriately identify your question, and include your mailing address, state of residence and email address so we can provide a response.

California ConsumerPrivacy Act of 2018 (“CCPA”). In addition to the foregoing, if you are a resident of the State of California, certain other privacy-related rights may apply to you in accordance with the CCPA, including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Pleasesee our Privacy Provisions for California Residents Section fora more complete description of your rights under the CCPA as a California State resident.

TheCalifornia PrivacyRights Act (“CPRA”). Inaddition to the foregoing,if you are a resident ofthe State of California,certain other privacy-related rights may apply to you in accordance with the CPRA,including the right to opt-out of our use/sharing of your sensitive personal information, the rightto know how long we retain your sensitive and non-sensitive personal information, the right to know what sensitive personal information about you we have collected, whether your sensitive personalinformation was shared withthird parties in the preceding year and, if so, what categories of sensitive personal information were shared, as well as the categories of third parties with whom we shared that sensitive personal information. Please see our Privacy Provisions for California Residents Section for a more complete description ofyour rights under the CPRA as a California State resident.

 

Browser“Do Not Track”Signals. Most browsers have built-in options allowing users to enable do-not-track settings. In general,when a "do-not-track"setting is active,the User's browser notifies other websites that the User does not want her/his personal information and online behavior to be tracked and used, for example, for interest-based advertising.As required by CaliforniaOnline Privacy Protection Act (“CalOPPA”), we are required to inform you that,as is the case with most websites,we do not honor or alter our behavior when a Site User has activated the "do-not-track" setting on her/his browser.

 

2. YOUR NEVADAPRIVACY RIGHTS

Nevada State residents have the right to submit opt-out requests to website operators instructing those website operators not to sell any “covered information” that the website operators have collected about the Nevada State residents to any third-party data broker(s). Covered information includes a customer’s name, postal and email address, telephone number and social security number, and includes the information described below in the Personal Information That We Collect Section.

If you are a Nevada State resident and you wish to exercise your right to request that we stop the sale of your Information to third-party data brokers, please email us at: allison@mindset.care; call us at: 888-502-3799; or write us via mail to: Mindset Care, Attention: Privacy, 80 Broad St Fl 5 Suite 1085, New York, NY 10004.In your request, please specify that you want to exercise your rights to opt-out from the sale of covered information under the Nevada Privacy Law and specify the website that you visited and the email address you registered with.Please allow thirty (30) days for a response.

 

3. Personal Information That We Collect

Pleasesee our Privacy Provisions for California Residents Section foradditional details regarding the categories of personal information collected.

We collect your personally identifiable information when you access and/or utilize the Site Offerings. We may also collect your personally identifiable information when you otherwise agree to the terms of this Privacy Policy, but do not complete the applicable registration process in full. The types of personally identifiable information that we collect on the Site include, without limitation, the following:

Where a User attempts to utilize the Contact Services, Mindset Care may collect,some or all of the following information: (i) the User's full name; (ii) the User's email address; (iii) the User's telephone number; (iv) the User's mailing address (v) User’s social security number; (vi) User’s date of birth; (vii) the User’s work history; (viii) the User’s education; (ix) whether the User is being treated bya medical professional; () whether the User already receives social security benefits; (xi) whether the User has already retained a social security disability benefits advocate; (xii) the User’s ages range; and (xiii) any other information requested on the applicable form.

Where a User attempts to update their medical condition-related information, that User may be required to submit, and Mindset Care may collect, some or all of the following information: (A) the name of the User’s doctor; (B) the telephone number of the User’s doctor; (C) the address of the User’s doctor; (D) the date of the User’s last visit to their doctor; (E) the reason for the User’s last visit to their doctor; and (F) any other information requested on the applicable form.

For purposes of this Privacy Policy, items (viii), (A), (B), (C), (D) and (E) above shall be treated as sensitive information (“Sensitive Information”).

4. Use and Sharing of Personal Information

Pleasesee our Privacy Provisions for California Residents Section for details regarding our use and sharing of personal information.

Bysubmitting your personal information by and through the Site Offerings, you agree that we may share,sell, rent, lease or otherwise provide that personal information (other than Sensitive Information) to any third-party for any purpose permitted by law, and we may work with other businesses to bring selected retail opportunities to our Users. These businesses and third parties may include but are not limited to:(a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) online,email and mobile marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers.The above excludes text messaging originator opt-in data and consent. This information will not be shared with any third parties.Wewill also useyour personal information to send you promotional messages regarding various Mindset Care products and/or services, as well as third-party products and/or services that we think may be of interest to you.

Without limiting the foregoing, upon entering personal information and clicking on the applicable submission button on the Site, Mindset Care may pass your personal information (including Sensitive Information) along to one (1) or more of Mindset Care's Third Party Service Providers to complete your request for assistance with filing for benefits.

We may also employ third parties and individuals to perform certain functions on our behalf, including helping us operate the Site Offerings and/or to administer related activities on our behalf.Examples include sending direct and electronic mail, removing duplicate information from User Lists, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to our Users' personal information as needed to perform their functions for us, but we do not permit them to use Userpersonal information for other purposes.

We will also use your personal information for customer service, to provide you with information that you may request, to customize your experience on the Site and/or to contact you when necessary in connection with transactions entered into by you through the Site Offerings. We may also use your personal information for internal business purposes, such as analyzing and managing our business. We may also combine the information we have gathered about you with information from other sources.

By registering at the Site, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.

Where you provide “prior express consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive telephone calls from Mindset Care and any specified Third Party Service Provider(s), including artificial voice calls, pre-recorded messages and/or calls (including SMS text messages) delivered via automated technology, to the telephone number(s) that you provided. Please note that you are not required to provide this consent in order to obtain access to the Site Offerings, and your consent simply allows Mindset Care and any specified Third Party Service Provider(s) to contact you via these means. Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes. Without limiting the foregoing, if you: (a) have your telephone number reassigned to another person or entity; (b) give up your telephone number so that it is no longer used by you; (c) port your telephone number to a landline or vice versa; or (d) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify Mindset Care of the Phone Number Change via email at: allison@mindset.care, or by using one of the methods set forth in the Contact Us Section below.

We also reserve the right to release current or past Users’ information (including Sensitive Information) in the event that we believe that the User is using, or has used, the Site Offerings: (i) in violation of the Terms of Use, this Privacy Policy or any other of our operating rules, policies, and other supplemental terms and conditions or documents that may be published by us from time to time; (ii) to commit unlawful acts; (iii) if such information is subpoenaed; provided, however, that, where permitted by applicable law, we shall provide you with email notice, and opportunity to challenge the subpoena, prior to disclosure of any personal information pursuant to a subpoena; (iv) if we are sold, merge with a third-party or are acquired by a third-party (collectively, “M&A Transactions”) (including where we share your personal information, including Sensitive Information, in connection with the due diligence process associated with a potential M&A Transaction); (v) if we are the subject of bankruptcy proceedings; provided, however, that if Mindset Care is involved in a bankruptcy proceeding and/or M&A Transaction, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information; and/or (vi) when we deem it necessary or appropriate including, without limitation, sharing your email address with other third parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time, and Federal Trade Commission implementing regulations.

5. Non-Personally Identifiable Information Collection and Use


Please see our Privacy Provisions for California Residents Section for more details regarding the categories and types of non-personal information collected.

Computer IP Addresses/Browser Type

We may collect certain non-personally identifiable information about you and your desktop computer when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and Content of the Site Offerings and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze usage of the Site Offerings.

Cookies
When a User visits the Site and/or interacts with one of our commercial email messages, we send one (1) or more cookies and/or gif files (collectively, “Cookies”) to assign an anonymous, unique identifier to the applicable User’s computer and/or mobile device, as applicable. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience on the Site, as applicable. To find out more about Cookies, please visit 
www.cookiecentral.com. We use Cookies to improve the quality of the Site Offerings, including for storing User preferences and tracking Site usage (such as pages opened and length of stay at the Site, as applicable).

Most internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your internet browser. Even in the case where a User rejects a Cookie, he or she may still use the Site Offerings; provided, however, that certain functions of the Site Offerings may be impaired or rendered inoperable if the use of Cookies is disabled. We reserve the right to retain Cookie data indefinitely.

 

Behavioral Tracking

An action tag or a web-beacon (also known as a clear gif or a pixel tag) is a method used to track Mindset Care and its third-party partners, such as Google®, use Cookies, pixels and other tracking technology (collectively, “Tracking Technology”) to analyze trends, administer the Site, track Users’ movements around the Site and to gather demographic information about our user base as a whole. In addition, we partner with third parties to use Tracking Technology in connection with the display of advertising on our Site, and to manage the serving of our advertising to you on other websites when you exit the Site. Our third-party partners may use Tracking Technology to gather information about your activities on the Site and other websites in order to provide you with certain Mindset Care advertising based upon your browsing activities and interests. To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third parties in connection with the Site.

Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers. To learn more about how you can opt out of targeted advertising on the Site, please visit the “Ad Choices” website located at https://youradchoices.ca. Users can opt-out of certain Google®-related tracking technology, and customize the Google® Display Network ads that they receive, by visiting the Google® Ads Settings at: http://www.google.com/settings/ads. Google® also recommends installing the Google® Analytics Opt-out Browser Add-on for your web browser, which is available here: https://tools.google.com/dlpage/gaoptout.

If you wish to opt-out of having this information used for the purpose of serving you interest-based ads, you may opt-out by emailing us at allison@mindset.care. Further, Users may be able to opt-out of this form of tracking utilizing the options made available by the Network Advertising Initiative or Digital Advertising Alliance. Please note that opting out of this tracking activity does not opt you out of being served advertising. Even if you opt out of this tracking activity, you will continue to receive generic ads.

To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third parties in connection with the Site.

 

Cross Device Tracking

Mindset Care tracks Users’ use of the Site Offerings across various devices, including your personal computer and mobile device, in order to optimize and personalize your Site Offerings experience. Mindset Care may collect certain of your personal information across various devices. Please be advised that where you opt-out of having your use of the Site Offerings tracked across devices, you may need to upload certain information multiple times and/or input your log-in information multiple times.

Aggregate Data

Mindset Care reserves the right to transfer and/or sell aggregate or group data about Users of the Site Offerings for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of Users as a group, without disclosing personally identifiable information.

6. Other Websites

The Site Offerings may contain links to other third-party owned and/or operated websites including, without limitation, Social Media Websites, the websites of Third Party Service Providers, as well as the websites of other third parties. Mindset Care is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of their third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Mindset Care has no responsibility or liability relating to them.

7. Security of Your Personal Information

The privacy of your personal information is very important to us. As such, we endeavor to safeguard and protect our Users’ personal information. When Users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). Where our registration/application process prompts Users to enter Sensitive Information (such as medical information, health insurance information and social security number), and when we store and transmit such Sensitive Information, that information is encrypted with advanced TLS (Transport Layer Security).

Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. The servers that we store personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control. Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the internet can be guaranteed to be 100% secure.

Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software constitutes a crime punishable by law. For the reasons mentioned above, we cannot guarantee that your personal information will be absolutely secure. Any transmission of data by or through the Site Offerings is at your own risk.

Only employees or third-party agents who need personal information to perform a specific job function are granted access to personal information. Our employees are dedicated to ensuring the security and privacy of all User personal information. Employees not adhering to our firm policies are subject to disciplinary action. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies if we learn of an information security breach with respect to your personal information. You will be notified via email in the event of such a breach. Please be advised that notice may be delayed to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

8. AGE RESTRICTION

Please see our Privacy Provisions for California Residents Section for more details regarding the personal information of minors.

You may not use the Site or the Services if you are under eighteen (18) years of age. By using the Site, (a) you acknowledge and agree that you are not under the age of eighteen (18) years, or are of adult age in your jurisdiction, (b) that you are permitted by your jurisdiction’s applicable law to use the Site and the Services, and (c) you are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations and warranties set forthin this Privacy Policy, and to abide by and comply with this Privacy Policy, and all applicable laws. We assume no responsibility or liability for any misrepresentation of your age.

9. Removal, Amending and/or Updating Your Information

Please see our Privacy Provisions for California Residents Section for instructions on how California Residents can access and/or delete personal information that we have collected.

At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected. You may do so by contacting us via email at: allison@mindset.care; provided, however, that we ask individuals to identify themselves and the information requested to be accessed, amended or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

10. Opt-Out; Unsubscribe

Please see our Privacy Provisions for California Residents Section for instructions on how California Residents can opt-out of the sale of their personal information to third parties.

We provide Users with the ability to opt-out from receiving information sent via electronic mailings on our own behalf and that of our third-party advertisers. Users may unsubscribe from receiving email at any time by following the instructions contained at the end of every email. Unsubscribe requests can only be processed by us if you have registered with us in the first instance. If you have not registered with us and wish to opt out of receiving email from a particular sender, please consult that sender’s opt out policies or contact that sender.

To opt-out from email marketing, please email us at: allison@mindset.care.

Information sent on behalf of third-party advertisers is prepared several days in advance, so Users may continue to receive email from us for up to ten (10) days following our receipt of unsubscribe requests. If, after that point, a User is still receiving email from us, the User should contact us at: allison@mindset.care.

Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Site Offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving Site Offerings-related and/or inquiry response-related messages from us, you must cease requesting Site Offerings and cease submitting inquiries to us, as applicable.

11. Transfer of Personal Information Internationally

If you are visiting the Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of information across international boundaries. By visiting the Site and/or otherwise communicating electronically with us, you consent to such transfers. Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information with the same level of protection as set out in this Privacy Policy.

12. Changes to this Privacy Policy

We reserve the right, at our discretion, to change, modify, add and/or remove portions of this Privacy Policy at any time. If the way we use personally identifiable information changes, we will notify Users by: (a) sending the modified policy to our Users via email; and/or (b) any other reasonable means acceptable under applicable state and federal law. Your continued use of the Site and the Mindset Care products and services following the posting of changes to this Privacy Policy will mean you accept those changes.  If you do not agree with the changes, you should cease using the Site and the Mindset Care products and services.

13. Contact Us

If you have any questions about this Privacy Policy, the practices of Mindset Care or your dealings with Mindset Care, please email us at: allison@mindset.care; call us at: 888-502-3799; or write us via mail to: Mindset Care, Attention: Privacy, 80 Broad St Fl 5 Suite 1085, New York, NY 10004.

14. Privacy Provisions for California Residents

These Privacy Provisions for California Residents (“Privacy Provisions”) supplement, and do not limit in any way, the Privacy Policy set forth above. These Privacy Provisions apply solely to residents of the State of California (“CA Users”). We adopt these Privacy Provisions in compliance with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”). Any terms defined in the CCPA and/or CPRA have the same meaning when used in these Privacy Provisions. Users with disabilities who wish to access these Privacy Provisions in an alternate format can contact us by emailing us at: allison@mindset.care; call us at: 888-502-3799; or write us via mail to: Mindset Care, Attention: Privacy, 80 Broad St Fl 5 Suite 1085, New York, NY 10004.

Categories of Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CA User or device (“personal information”). We have collected the following categories of personal information from CA Users within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, telephone number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, social security number, physical characteristics or description, postal address, telephone number, passport number, driver’s license or State identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a CA User’s interaction with a website, application or advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

L. Sensitive Personal Information (Cal. Civ. Code §1798.140(ae)).

A social security number, driver’s license number, state identification card number, or passport number. Account log-in information, financial account, or debit or credit card number used in combination with any required security code, access code, password, or log-in credentials necessary to access an account. Precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership. The contents of a consumer’s U.S. mail, electronic mail, or text messages unless the business is the intended recipient, and a consumer’s genetic data.

YES

Personal information does not include:

·Publicly available information from government records.

·Information that we believe has been lawfully made public by the consumer or from widely distributed media or from disclosure to a third-party by the consumer where the consumer did not limit disclosure to a specific audience.

·De-identified or aggregated CA User information.

·Information excluded from the CCPA’s scope, such as:

o    Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and

o    Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above (including the information set forth in the Personal Information That We Collect Section) from the following categories of sources (with the specific categories of personal information indicated in parenthesis):

·Directly from our CA Users. For example, from online Surveys and/or registration forms that our CA Users submit to us in connection with the products and/or services that we offer by and through the Site. (Categories A, B, C and L)

·Indirectly from our CA Users. For example, through information we collect from our CA Users in the course of providing our products and/or services to them. (Categories A, B, C and F)

·Directly and indirectly from activity on the Site. This includes the type of browser that the CA User uses (e.g., Safari, Chrome, Internet Explorer), CA User IP address, the type of operating system used by the CA User (e.g., Windows or iOS) and the domain name of the CA User’s Internet Service Provider. In addition, we obtain certain Site usage details and analytics as same are collected automatically by us and our third-party partners. (Category F)

·From third parties that interact with us in connection with the products and/or services that we offer to our CA Users. For example, third-party entities that assist us in sending direct and electronic mail, removing duplicate information from CA User lists, analyzing data and providing marketing analysis. (Categories A, B, C and F)

Retention of Personal Information and Sensitive Personal Information

We retain all categories of your personal information and sensitive personal information (including the information set forth in the Personal Information That We Collect Section that we collect for the maximum period permitted by applicable law. We may also use certain criteria to determine whether and when to delete certain categories of collected personal and sensitive personal information including:

·Date of collection.

·Frequency of consumer interaction with us.

·Last interaction the consumer had with us.

·Whether the purpose of collection has been completed.

 

Use of Personal Information

We may use the personal information that we collect (including the information set forth in the Personal Information That We Collect Section for one or more of the following business purposes (with the specific categories of personal information indicated in parenthesis):

·To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with your purchase of products and/or services, we will use that information to process your order. (Categories A, B, C, F and L)

·To provide you with information, products or services that you request from us. (Categories A, B, C, F and L)

·To create, maintain, customize and secure your account with us. (Categories A, B, C and F)

·To provide you with email, direct mail and telemarketing messages concerning certain Mindset Care products and/or services, as well as third-party products and/or services, that we believe may be of interest to you. (Categories A, B, C and F)

·To deliver relevant Site Content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (Categories A, B, C and F)

·To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Site’s Terms of Use. (Categories A, B, C, F and L)

·To improve the Site and better present its Contents to you. (Categories A, B, C and F)

·For customer service purposes and to respond to inquiries from you. (Categories A, B and C)

·For testing, research, analysis and product development. (Categories A, B, C and F)

·As necessary or appropriate to protect our rights, property or safety, and that of our clients and/or others. (Categories A, B, C, F and L)

·To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Categories A, B, C, F and L)

·As described to you when collecting your personal information or as otherwise set forth in the CCPA and/or CPRA. (Categories A, B, C, F and L)

·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 is among the assets transferred. (Categories A, B, C, F and L)

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you with notice.

 

Sharing Personal Information

Subject to your right to opt-out of such sharing/sale, we may share, rent and/or sell your personal information from Categories A, B, C and F (but not Sensitive Information from Category L) ((including the information set forth in the Personal Information That We Collect Section)): (i) with/to third parties for marketing purposes; and (ii) for the other business purposes set forth above.

When we disclose personal information to a Third Party Service Provider or other entity, we enter into a contractual relationship that describes the purpose for which such third-party may use the personal information and requires that third-party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from CA Users that we know are less than eighteen (18) years of age and we do not share or sell the personal information of CA Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of CA Users that we actually know are less than eighteen (18) years of age in the preceding twelve (12) months.

In the preceding twelve (12) months, we have disclosed the following categories of personal information ((including the information set forth in the Personal Information That We Collect Section)) for a business purpose:

Category A Identifiers.
Category B California Customer Records personal information categories.
Category C Protected classification characteristics under California or federal law.
Category F Internet or other similar network activity.
Category L Sensitive Personal Information (disclosed solely as required in connection with facilitating your request for SSDI benefit-related products and/or services).

We disclose your personal information (including the information set forth in the Personal Information That We Collect Section) for a business purpose to the following categories of third parties (with the specific categories of personal information indicated in parenthesis):

·Our affiliates. (Categories A, B, C and F)

·Service providers. (Categories A, B, C, F and L)

·Third parties who provide the products and/or services featured on the Site. (Categories A, B, C and F)

·Third parties who purchase and/or license your personal information for marketing purposes, including: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) email marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers. If a third-party purchaser of your personal information wants to resell it, that purchaser is required by law to provide you with explicit notice and an opportunity to opt-out of further sales, unless the right to resell it was secured by us at the point of collection. (Categories A, B, C and F); provided, however, that we do not share Sensitive Information with third parties for this purpose.

·Third parties to whom you authorize us to disclose your personal information in connection with the products and/or services that we provide to you. (Categories A, B, C, F and L)

In the preceding twelve (12) months, we have sold the following categories of personal information (including the information set forth in the Personal Information That We Collect Section, but not the Sensitive Information, other than as required in connection with facilitating your application for social security disability insurance benefits) to third parties:

Category A Identifiers.
Category B California Customer Records personal information categories.
Category C Protected classification characteristics under California or federal law.
Category F Internet or other similar network activity.

In the preceding twelve (12) months, we have sold the above referenced categories of personal information (including the information set forth in the Personal Information That We Collect Section, but not the Sensitive Information) to the third parties who purchase and/or license your personal information for marketing purposes, as well as the third parties who provide the products and/or services featured on the Site.

 

Your Rights and Choices

The CCPA and CPRA provide CA Users (California residents) with specific rights regarding their personal information. This section describes your CCPA and CPRA rights and explains how to exercise those rights.

Opt-Out from the Sale or Sharing of Your Personal Information

You have the right: (a) to opt-out of our sale of your personal information (including Sensitive Information) to third parties; and/or (b) to opt-out of our sharing your personal information (including Sensitive Information) with third parties. To exercise any or all of these rights to limit our use of your personal information, please submit a verifiable User request to us by either:

·Calling us at: 888-502-3799;

·Emailing us at: allison@mindset.care; or

·Writing to us via mail to: Mindset Care, Attention: Privacy, 80 Broad St Fl 5 Suite 1085, New York, NY 10004.

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.

 

Opt-Out from the Sharing of Your Personal Information

You have the right to opt-out of our sharing your personal information with third parties. To exercise your right to opt-out of our sharing your personal information with third parties, please submit a verifiable CA User request to us by either:

·Calling us at: 888-502-3799;

·Emailing us at: allison@mindset.care; or

·Writing to us via mail to: Mindset Care, Attention: Privacy, 80 Broad St Fl 5 Suite 1085, New York, NY 10004.

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.

 

Opt-Out from the Sale of Your Personal Information

You have the right to limit our use of your sensitive personal information, including any Sensitive Information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law) and/or Category L (Sensitive Personal Information), to those uses which: (i) are necessary to perform the services or provide the goods requested by you; (ii) help us to ensure security and integrity of your personal information to the extent the use of your sensitive personal information is reasonably necessary and proportionate for these purposes; (iii) are short-term, transient uses including, but not limited to, non-personalized advertising shown as part of your then-current interaction with the Site, provided that your personal information is not disclosed to another third-party and is not used to build a profile about you or otherwise alter your experience outside the then-current interaction with the Site; (iv) involve performing services on behalf of Mindset Care, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of Mindset Care; and (v) include activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by, Mindset Care, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by, Mindset Care.

You also have the right opt-out of our sharing your sensitive personal information with third parties, including any Sensitive Information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law) and/or Category L (Sensitive Personal Information).

To exercise your right to limit our use of your sensitive personal information and/or opt-out of our sharing your sensitive personal information with third parties, please submit a verifiable CA User request to us by either:

·Calling us at: 888-502-3799;

·Emailing us at: allison@mindset.care; or

·Writing to us via mail to: Mindset Care, Attention: Privacy, 80 Broad St Fl 5 Suite 1085, New York, NY 10004.

We endeavor to act on all such requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.

 

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you:

·The categories of personal information we collected about you.

·The categories of sources for the personal information we collected about you.

·Our business or commercial purpose for collecting or selling that personal information.

·The categories of third parties with whom we have shared that personal information.

·The specific pieces of personal information we collected about you (also called a data portability request).

·If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

o    sales, identifying the personal information categories that each category of recipient purchased; and

o    disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

 

Right to Request Correction of Inaccurate Personal or Sensitive Personal Information

You have the right to request correction of inaccurate personal and/or sensitive personal information that we collect. Upon receiving a verifiable consumer request for correction, we will make commercially reasonable efforts to correct information identified as inaccurate.

 

Right to Request Deletion of Personal and/or Sensitive Personal Information

You have the right to request that we delete any of your personal information and/or Sensitive Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1.      Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract with you.

2.      Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.

3.      Debug products to identify and repair errors that impair existing intended functionality.

4.      Exercise free speech rights, ensure the right of another CA User to exercise her/his free speech rights or exercise another right provided by law.

5.      Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

6.      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 information’s deletion may likely render impossible or seriously impair the research’s achievement, but only if you previously provided informed consent.

7.      Enable solely internal uses that are reasonably aligned with CA User expectations based on your relationship with us.

8.      Comply with a legal obligation.

9.      Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Exercising Access, Data Portability and Deletion Rights

To exercise your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by either:

·Calling us at: 888-502-3799;

·Emailing us at: allison@mindset.care; or

·Writing to us via mail to: Mindset Care, Attention: Privacy, 80 Broad St Fl 5 Suite 1085, New York, NY 10004.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information.

You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must:

·Provide sufficient information that allows us to reasonably verify that you are: (1) the person about whom we collected personal information; or (2) an authorized representative.

·Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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 that the personal information relates to you. Making a verifiable CA User request does not require that you create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor’s identity or authority to make the request.

 

Response Timing and Format

We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures that we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response that we provide will also explain the reasons that we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable CA User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA and/or CPRA rights. Unless permitted by the CCPA and/or CPRA, 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; and/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.

 

Changes to these Privacy Provisions

We reserve the right to amend these Privacy Provisions in our discretion and at any time. When we make changes to these Privacy Provisions, we will notify you by email or through a notice on the Site’s homepage.

 

Contact Information

If you have any questions or comments about these Privacy Provisions, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either:

·Calling us at: 888-502-3799;

·Emailing us at: allison@mindset.care; or

·Writing to us via mail to: Mindset Care, Attention: Privacy, 80 Broad St Fl 5 Suite 1085, New York, NY 10004.

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