mySoberLife Privacy Policy
I. General
This Privacy Policy applies to the mySoberLife.com web site (mySoberLife.com) owned and operated by mySoberLife, LLC including the mySoberLife.com parent company, Axion Group, Inc. The terms “mySoberLife” and “we” in this Privacy Policy include (1) the mySoberLife.com website; (2) mySoberLife, LLC; (3) and Axion Group, Inc . MySoberLife may share information among its subsidiaries and parent company, but it is always protected under the terms of this Privacy Policy.
The mySoberLife.com web site contains links to other sites. Once you enter another Web site (whether through an advertisement, service, or content link), mySoberLife is not responsible for the privacy practices of these other sites. We encourage you to look for and review the privacy statements of each and every Web site that you visit through a link or advertisement on mySoberLife.com.
While you may use some of the functionality of mySoberLife.com without registration, many of the specific services on our website require registration. If you use our Web site without registering, the only information we collect will be Non-Personal Information through the use of Cookies or Web Beacons. If you choose to register with our Web site for our services, we require you to submit Personally Identifiable Information. Depending on the service you have selected, we may also collect Personal Health Information. You are responsible for ensuring the accuracy of the Personally Identifiable Information and Personal Health Information you submit to mySoberLife.com. Inaccurate information may affect the information you receive when using our site and tools and our ability to contact you as described in this Privacy Policy.
II. Non-Personal Information
Even if you do not register with mySoberLife.com, we collect Non-Personal Information about your use of our Web site.
A. Cookies
We collect Non-Personal Information about your use of our Web site and your use of the Web sites of selected sponsors and advertisers through the use of Cookies. Every computer that accesses mySoberLife.com is assigned a different Cookie by mySoberLife. The information collected by Cookies (i) helps us generate advertising and content on Web pages; (ii) allows us to statistically monitor how many people are using our Web site and selected sponsors’ and advertisers’ sites; (iii) how many people open our emails; and (iv) for what purposes these actions are being taken. We may use Cookie information to target certain advertisements to your browser or to determine the popularity of certain content or advertisements. Cookies are also used to facilitate a user’s log-in, as navigation aides and as session timers. If you reject our Cookies, certain functions and conveniences of our Web site may not work properly but you do not have to accept our Cookies in order to productively use our site. We do not link Non-Personal Information from Cookies to Personally Identifiable Information without your permission and do not use Cookies to collect or store Personal Health Information about you.
B. Web Beacons
We also may use Web Beacons to collect Non-Personal Information about your use of our Web site and the Web sites of selected sponsors and advertisers. The information collected by Web Beacons (i) allows us to statistically monitor how many people are using our website and selected sponsors’ and advertisers’ sites; (ii) how many people open our emails; and (iii) for what purposes these actions are being taken. Our Web Beacons are not used to track your activity outside of our Web sites or those of our sponsors’. We do not link Non-Personal Information from Web Beacons to Personally Identifiable Information without your permission and do not use Web Beacons to collect or store Personal Health Information about you.
C. Third Parties
Third parties under contract with mySoberLife may use Cookies or Web Beacons to collect Non-Personal Information about your usage of MySoberLife’s sites, and this information may be used by mySoberLife to tailor the advertising you may see on sites within the networks of these third parties. This Non-Personal Information is anonymous and does not contain any personal information about you. These third parties may collect this information, on our behalf, to help MySoberLife target our advertising on these third party sites. These third parties have agreed not to use this non-personal cookie or web beacon information except to help us target our advertising on these sites and have agreed to not link any non-personal cookie or web beacon information collected by them on our sites to Personally Identifiable Information they or others collect from other sites. If you browser is set to reject cookies, this Non-Personal Information will not be sent to these third parties.
III. Personally Identifiable Information We Collect About You
We collect Personally Identifiable Information that you provide to us when you register as a member of MySoberLife and/or when you update your member profile. We use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific services you select, send you emails about Web site maintenance and updates, and inform you of significant changes to this Privacy Policy.
A. Newsletters & Emails to You
At registration and at various times as you use MySoberLife.com, you will be given the option of receiving recurring informational newsletters via email from MySoberLife.com. These emails will not contain Personal Health Information. At the time you sign up for our email newsletters or any time thereafter, you can choose to Opt-In to receiving additional promotional emails from MySoberLife.com. In order to subscribe to MySoberLife newsletters via email, we need your contact information, such as name and email address. You can unsubscribe from the newsletters by simply clicking on the “unsubscribe” link at the bottom of any email newsletter.
B. SupportBuddy
When you use MySoberLife “SupportBuddy”, MySoberLife emails the content you designate to your buddy’s email address and identifies your email address as the sender. MySoberLife uses the buddy’s email address to send your friend the particular email you requested.
C. Emails You Send to MySoberLife.com
This Privacy Policy does not apply to content, business information, ideas, concepts or inventions that you send to MySoberLife by email. If you want to keep content or business information, ideas, concepts or inventions private or proprietary, do not send them in an email to MySoberLife.
D. Blogs, Message Boards, and other Public Forums
As a service to our users, MySoberLife.com features blogs, message boards, chat rooms and other public forums where users with similar interests, addictions, or medical conditions can share information and support one another or where users can post questions for experts to answer. We also offer online discussions moderated by medical or healthcare experts. Any information shared (including Personally Identifiable and Personal Health Information) that you reveal in a blog, chat room, message board, Ask Our Expert posting, or online discussion is by design open to the public and is not a private, secure service. You should think carefully before disclosing any Personally Identifiable or Personal Health Information in any public forum. What you have written may be seen, disclosed to or collected by third parties and may be used by others in ways we are unable to control or predict, including to contact you for unauthorized purposes. As with any public forum on any site, this information may also appear in third-party search engines like Google, Yahoo, MSN etc.
E. Website Registration and Interactive Tools on MySoberLife.com
After you have registered as a member of MySoberLife.com, you may choose to use certain MySoberLife interactive content, tools, and services that may ask you to voluntarily provide other types of information about yourself including Personal Health Information. Some of the tools do not retain your Personal Health Information, while others store your Personal Health Information in accordance with the authorization you provide at the time you use the tool.
F. Subscription Services
From time to time, MySoberLife.com offers users the opportunity to register for paid subscription services. Each subscription service has its own Service Agreement that governs your use of the service and the information we collect to provide the service, including your credit card information. The Service Agreement will be disclosed to you at the time of registration for that subscription service.
G. Children/Minors
We are committed to protecting the privacy of children. Neither MySoberLife nor any of its services are designed or intended to attract children under the age of 13. We do not collect Personally Identifiable Information from any person that claims is under the age of 13. A parent or guardian, however, may use MySoberLife to establish a personal health record and a MySoberLife profile for a minor. The parent or guardian is solely responsible for providing supervision of the minor’s use of MySoberLife.com. The parent or guardian assumes full responsibility for ensuring that the registration information is kept secure and that the information submitted is accurate. The parent or guardian also assumes full responsibility for the interpretation and use of any information or suggestions provided through MySoberLife.com for the minor.
H. Research
From time to time the MySoberLife’s research department, or its operations contractors acting on its behalf, conducts online research surveys in order to gather feedback about our site, recovery, addiction, our sponsors and opinions on important healthcare issues, through email invitations, pop-up surveys and online focus groups. When participating in a survey, we may ask you to submit Personally Identifiable Information. This Personally Identifiable Information is used for research and educational purposes, and is not used for sales solicitations. When a survey is sponsored by a third party, Aggregate Information of the survey results is reported to the sponsor. Personally Identifiable Information collected through research will be used only by MySoberLife, its service providers, and contractors and will not be given or sold to a third party without your consent or as otherwise permitted by this Privacy Policy. For research surveys we will not knowingly accept survey responses from or conduct interviews with any person under the age of 13. In addition to collecting survey responses from our members, Cookies may be used to authenticate respondents or to help you pick up where you left off in a survey. If you have Cookies disabled you may not be able to participate in some studies. Cookies may be used to connect survey data with MySoberLife.com usage characteristics. You will be notified when we would like to use Cookies in this way and your consent will be requested for these Cookies.
IV. MySoberLife.com - Registration, Use and Tools
MySoberLife.com allows you a secure place to store your personal recovery/addiction information and provides services in order to better manage your health and the health of your support group. Regardless of how you access the MySoberLife.com the following apply:
A. MySoberLife.com Profile
Personal Health Information that you enter into one of the MySoberLife.com services is used to provide you personalized and clinically relevant information on your personalized profile and throughout your recovery process. MySoberLife.com creates a personal home page specifically for you. You control and authorize who can gain access to this page.
B. Aggregate Data
MySoberLife.com may combine, in a non-identifiable format, the Personal Health Information you provide with information from other users to create Aggregate Data that may be disclosed to third parties. Aggregate data does not contain any information that could be used to contact or identify you. For example, MySoberLife may use information gathered to create a composite profile of all the users of a particular third party. These third parties may use this information to understand community needs and to design appropriate programs and activities. MySoberLife will not disclose your Personal Health Information to any third party without your prior permission, except as otherwise permitted by this Privacy Policy and the Terms of Use & Services Agreement.
C. Secure Message Center
MySoberLife.com has the ability to use Personally Identifiable Information that you provide to send you personalized emails or secure electronic messages. During registration for the MySoberLife services, you have the option of choosing whether you receive emails pertaining to you, including news, announcements, reminders and opportunities.
If your health care provider has implemented the MySoberLife services on your behalf, you will receive email at your provider-related email address, or email address provided to your health care provider, that has been authorized by your health care provider but to which you have not specifically Opted-in. These emails will be sent in accordance with instructions from your health care provider and you will not be able to Opt-out of receiving such emails.
D. Interactive Tools on MySoberLife.com
Interactive tools within the MySoberLife web site, gather self-reported Personal Health Information. In addition, certain of these tools can store Personal Health Information coming from third party data interchange agreements between your health care provider, recovery organization, and other third parties that provide data interchange services. We maintain and limit the use of that information to the Opt-in permission you have provided at the time you use the tool.
MySoberLife Health does not knowingly engage in business with a company that uses Spyware nor does MySoberLife provide Users with downloadable software that collects or uses any PII without full disclosure and Opt-in consent.
E. Data Warehouse Analysis
Upon authorization by your health plan, healthcare provider or recovery organization, MySoberLife may send your Personal Health Information in a form that cannot be used to personally identify or contact you to a data warehouse for analysis of health trends and effectiveness of health programs. We require these data warehouses to agree that they will not attempt to make this information personally identifiable, such as by combining it with other databases.
V. Information Collected by Third Parties Not Acting on MySoberLife Health’s Behalf
Sponsors or advertisers on MySoberLife Health may use their own Cookies, Web Beacons or other online tracking technologies in the banner advertisements served on MySoberLife.com and in emails, special promotions or newsletters we send you. Some advertisers use companies other than MySoberLife to serve their ads and to monitor users’ responses to ads, and these companies (”Ad Servers”) may also collect Non-Personal Information through the use of Cookies or Web Beacons on our Web site. In certain situations, information collection may be facilitated by momentarily directing your browser to the Web site of an Ad Server or other third party acting on behalf of the sponsor, partner, or advertiser before re-directing your browser to its selected destination; this re-direction process will not be apparent to you.
We do not control these third parties’ use of cookies or Web Beacons, or how they manage the non-personal information they gather through them. However, we do require sponsors, advertisers and Ad Servers who collect cookie or web beacon information through our Web site to agree that they will not collect any Personally Identifiable Information from our site without your consent. They have promised us they will not link any non-personal cookie or web beacon information collected by them on our site to Personally Identifiable Information they or others collect in other ways or from other sites except as may be described in connection with a particular program.
VI. Disclosure of Your Information
Except as set forth in this Privacy Policy or as specifically agreed to by you, MySoberLife will not disclose any Personally Identifiable or Personal Health Information it gathers from you on our website. We may only release Personally Identifiable or Personal Health Information to third parties: (1) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (2) in special cases, such as in response to a physical threat to you or others, to protect property or defend or assert legal rights. In the event that we are legally compelled to disclose your Personally Identifiable or Personal Health Information to a third party, we will attempt to notify you unless doing so would violate the law or court order. In addition, we may disclose Personal Information as described below.
A. Disclosure to MySoberLife Health Operations and Maintenance Contractors
MySoberLife Health operations and maintenance contractors sometimes have limited access to your Personally Identifiable Information in the course of providing products or services to MySoberLife Health. These contractors include vendors, suppliers, educational institutions, health care providers, research groups, and recovery organizations that provide us with technology, services, and/or content for the operation and maintenance of our Web site. Unless you have Opted-out of receiving emails and newsletters from MySoberLife.com, these contractors also may have access to your email address to send newsletters or special promotions to you on our behalf or to send emails to you for purposes such as conducting research on our behalf. Access to your Personally Identifiable Information by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for MySoberLife. We also contractually require that our operations and maintenance contractors (1) protect the privacy of your Personally Identifiable Information consistent with this Privacy Policy, and (2) not use or disclose your Personally Identifiable Information for any purpose other than providing us with products and services as required by law.
B. Disclosure of Aggregate Information
MySoberLife may provide Aggregate Information to third parties. For example, we might inform third parties regarding the number of users of our website and the activities they conduct while on our site. Depending on the circumstances, we may or may not charge third parties for this Aggregate Information. We require parties with whom we share Aggregate Information to agree that they will not attempt to make this information personally identifiable, such as by combining it with other databases.
VII. How MySoberLife Health Handles Privacy and Security Internally
Listed below are some of the security procedures that MySoberLife Health uses to protect your privacy:
* Requires both a personal username (log-in name) and a password in order for users to access their Personally Identifiable Information or Personal Health Information.
* Requires a public ‘nickname’ different from the username and password, used for any public forums like message boards.
* Uses firewalls to protect information held in our servers.
* Utilizes Secure Socket Layer (SSL) encryption in transmitting Personally Identifiable Information to our servers. In order to take advantage of encryption technology, you must have an Internet browser which supports 128-bit encryption.
* Closely monitors the limited number of MySoberLife employees who have potential access to your Personally Identifiable Information.
* Requires all MySoberLife employees to abide by our Privacy Policy and to be subject to disciplinary action if they violate it.
* Backs-up our systems to protect the integrity of your Personally Identifiable and Personal Health Information.
MySoberLife provides additional protection for your Personal Health Information as follows:
* Provides secure messaging within the MySoberLife services so that information related to your personal health related characteristics is sent through a secure, encrypted connection.
* Provides geographic redundancy of MySoberLife servers, which enhances your ability to access your information by storing identical information at two separate, secure locations. Both sites maintain physical security through pass code locked door access and pass code authority.
* Limits access to Personally Identifiable Information to authorized users. MySoberLife enables you to have full control over who has access to your Personal Health Information. For example, you may decide to permit your physician or other health care providers access to the personal health information you maintain within our services. Only the person who creates a record can grant access to other users.
Despite MySoberLife’s efforts to protect your Personally Identifiable Information and Personal Health Information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted.
VIII. Updating Your Information and Contacting MySoberLife Health
A. Updating Your Personally Identifiable Information
MySoberLife services that collect and store self-reported data allow you to correct, update or review information you have submitted by going back to the specific service, logging-in and making the desired changes. MySoberLife may store user submitted data (PII and/or PHI) in an active database for a period of six (6) months. After six (6) months, user submitted data, including PII and/or PHI will be held in an active database or on an inactive back-up medium for a period of not less than six (6) years.
B. Removing your Personal Information
If you have a complaint or problem, please email our customer support staff. Our customer service department will forward your complaint to the appropriate internal MySoberLife department for a response or resolution. We try to answer every email within 48 business hours, but may not always able to do so. If you want to (1) delete your Personally Identifiable Information from our systems, (2) update the Personally Identifiable Information that you have provided to us, or (3) change your preferences with respect to marketing contacts or other activities, select the privacy option on our Contact Us form.
If you do not receive adequate resolution of a privacy related problem, you may write to MySoberLife’s Privacy Help Desk at:
MySoberLife, LLC.
Attn: Customer Support
1309 114th Ave SE
Suite 104
Bellevue, WA 98004
Or Call: 206-453-3556
C. Updating Your Personal Health Information in MySoberLife Profile Editor
Self-Reported Information - Please log-in to the MySoberLife Profile Editor, access your “settings” tab, and the functions will show you how to correct, update or review your information. We remove Personal Health Information only at the request of the authorized user. In order to verify that it is the authorized user requesting removal of his/her Personal Health Information, we require you to send a signed statement, including your name, address, email address and birth date, to the address below authorizing MySoberLife to remove your Personal Health Information from our active databases and other readily searchable media. Upon receiving your request, your personal health identifiers stored in active databases and other readily searchable media will be removed so that you cannot be identified or associated with any Personal Health Information you previously provided. Mail your requests to:
MySoberLife, LLC.
Attn: Customer Support
1309 114th Ave SE
Suite 104
Bellevue, WA 98004
We will notify you after your personal health identifiers have been removed.
Professionally Sourced Health Information - For Personal Health Information at MySoberLife, your ability to correct, update or remove previously provided Personally Identifiable or Personal Health Information only covers information within the reasonable control of MySoberLife. We place certain restrictions on your ability to correct, update or remove professionally sourced health information that you have authorized to be entered into your MySoberLife record. You may potentially authorize physicians, other health care providers, health plans, hospital systems, pharmacists or laboratories (or their respective Web sites) to provide data into your MySoberLife record. While you can remove this professionally sourced information from your record for the purpose of controlling the viewing or sharing of that information, MySoberLife will maintain an audit log, a notice of that transaction and a copy of the information deleted.
D. Limitations on Removing or Changing Information
Upon your request, we will delete your Personally Identifiable or Personal Health Information from our active databases and where feasible from our back-up media. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to MySoberLife from our servers.
IX: Changes to this Privacy Policy
Personally Identifiable Information - We will inform you if a material change to the Privacy Policy, which means a change that expands the permissible uses or disclosures of Personally Identifiable Information allowed by the prior version of the Privacy Policy. Your continued use of the MySoberLife.com will indicate acceptance of the changes. You may of course choose to Opt-out of continuing to use of MySoberLife.com. Please exit the site immediately if you do not agree to the terms of this Privacy Policy or any revised policy.
Personal Health Information - We will inform you if a material change in the Privacy Policy is made that involves the use of your Personal Health Information. If you choose to not accept the new privacy policy, then the current privacy policy conditions will remain in effect, so long as MySoberLife continues to make the functionality available. MySoberLife reserves the right to discontinue or limit functionality in all its services including MySoberLife.com and SupportBuddy.
Non-Significant Changes – MySoberLife may make non-significant changes to the Privacy Policy that do no affect Personally Identifiable Information or Personal Health Information. For these instances, MySoberLife may not notify you of such non-significant changes.