Privacy Policy – Karen Egan Cuan
1. About Your Privacy and This Privacy Policy
Your privacy is extremely important to Cuan Safe Harbour. This document is our "Privacy Policy" and sets forth the details related to your privacy and personal data when using our Services and/or using our website, www.karenegancuan.com (hereafter, the “Website”). This Privacy Policy applies to visitors of our Website, as well as to anyone who uses Karen Egan Cuan’s Services. It is intended to inform you of our policies, procedures and practices regarding the collection, use and disclosure of any information that you provide to Karen Egan Cuan through the Website and/or while receiving Karen Egan Cuan’s Services.
European Union residents should read the information available in the Privacy Notice for European Union Residents below about the categories of personal information to be collected from them and the purposes for which the personal information and/or data will be used and/or stored.
The Privacy Policy is part of our Website Terms and Conditions. The terms in the Privacy Policy (such as, but not limited to, "we", "our", "us", "Website", and "Services") have the same meaning as in our Website Terms and Conditions as applicable. When you use our Website and/or avail yourself of our Services, you accept and agree to the terms and conditions of this Privacy Policy. If you do not agree to be bound to the Privacy Policy you should stop using the Website immediately or cease using the Services, as applicable. By accessing and using our Website or using the Services, as applicable, you affirm your receipt of this Privacy Policy and you understand, agree to and acknowledge all the terms and conditions of this Privacy Policy.
2. Information Collection, Use, and Disclosure
Categories of Information Collected
To enable us operate the Website effectively and to let you use the Website, including the Services (if and as applicable), we may collect, use, and store the information described below. We may also disclose certain information to third parties, as described further below. The information we collect is received directly or indirectly from you and generated in the course of your use of the Website and/or receipt of the Services. The data we collect is not used for marketing or any other purposes except as specified in this Privacy Policy and shall be limited to enable Cuan Safe Harbour to provide its Services to you and/or improve performance of this Website.
Visitor Data: Karen Egan Cuan collects, uses, and stores data regarding user visits to this Website ("Visitor Data"), including the particular pages visited or viewed by the user, the amount of time the user spent on the website or application, website errors experienced by the user, visits to the "FAQ" page, and information about the browser or device used to access the website and application, such as the user’s mobile device ID and IP address.
Onboarding Data: In addition to the questionnaire responses provided by users in the process of initial registration, Karen Egan Cuan collects, uses, and stores certain additional data from users during the onboarding process ("Onboarding Data"), as precursor to receiving our Services. This data includes the pages viewed by the user, whether the user clicks the link to begin completing the questionnaire, and whether the user responds to any of the questionnaire prompts.
Account Registration Data: If applicable, Karen Egan Cuan may collect, use, and store certain information in connection with the account registration process, such as whether users registered using their Facebook or Google profiles, and whether a user verifies their reported email address or phone number ("Account Registration Data").
Financial Transaction Data: Karen Egan Cuan may use a trusted third party provider (such as a designated third party payment processor) to collect, use, and store certain information regarding payment for its Services by users and related transactions on its Website, such as whether a user completed payment for Karen Egan Cuan’s Services, signed up for Karen Egan Cuan’s Services using a trial offer, and/or cancelled or otherwise ended an appointment ("Financial Transaction Data").
Appointments for Services: Karen Egan Cuan collects, uses, and stores certain general data regarding user sessions such as whether an appointment for Karen Egan Cuan’s Services have been scheduled by the user, when an appointment session has begun and ended, and whether a given appointment for Services was cancelled or re-scheduled.
Customer Data: Karen Egan Cuan collects, uses, and stores certain data from users that have signed up for Karen Egan Cuan’s Services such as a user’s self-reported name or nickname, age, e-mail address, phone number, and emergency contact information ("Customer Data").
Protecting all of the above information is important to us. Other than in the ways detailed in this Privacy Policy, Karen Egan Cuan will never use or disclose any information unless you requested or approved us to do so.
Purposes for Which Information is Used
We may use the information we collect for one or more of the following purposes:
Communication with you
· To contact you or provide you with information, alerts and suggestions that are related to the Website.
· To verify your identity.
· To complete an activity you requested, such as register for the Website and/or Services or obtain more information.
· To reach out to you, either ourselves or using the appropriate authorities, if we have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.
Delivery of Services to you
· To create your account on our Website and let you log in to your account and use the Website. (if and as applicable)
· To manage your account, provide you with support, and ensure you are receiving quality Services.
· For billing and transaction processing purposes (whether directly by Karen Egan Cuan or via one of its approved designated third-party payment processors).
· To provide, support, personalize, and develop our Website and the Services.
Administration and improvement of Services
· To supervise, administer and monitor the Website.
· To measure and improve the quality, effectiveness and delivery of our Services.
Customization and marketing
· To advertise and market the Website and Services to potential users.
· To personalize Website experience and to deliver content and Service offerings relevant to individual interests, including targeted offers and ads through our Websites, third-party sites, and via email or text message.
Compliance with law
· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
· To comply with applicable state, federal, and international laws, regulations, and/or EU Directives including, but not limited to laws related to protecting client and public health and safety.
Other uses with consent
· Any other purpose that you have given your explicit consent.
Purposes for Which Information is Disclosed to Third Parties
Information about you may be disclosed to third parties for one or more of the following purposes:
For business purposes, advertising, and processing Financial Transaction Data: We may share a user’s information with a designated third party only as necessary for facilitating the Services. We may also share your information with vendors and service providers, including our data hosting and data storage partners, analytics and advertising providers, and vendors providing technology services and support, payment processing, and data security. We also may share information with professional advisers, such as auditors, law firms, and accounting firms.
Compliance with law: We may share your information with a court, a regulatory entity, law enforcement personnel, or pursuant to a subpoena, to comply with applicable law or any obligations thereunder.
For other business reasons: We may share your information to enforce any applicable Terms and Conditions and Terms of Use, and to ensure the safety and security of the Website and our users.
Note that if you make any information publicly available on the Website, anyone may see and use such information.
3. Opting out of Marketing Communication
You can opt out of receiving email marketing by unsubscribing using the unsubscribe link provided in all of our marketing email communications.
4. Cookies and Web Beacons
Karen Egan Cuan, may, from time-to-time use certain cookies and/or web beacons. The policy for which can be found here and is hereby incorporated into the terms and conditions of this Privacy Policy.
5. Phishing
Online identity theft and account hacking, including the practice currently known as "phishing" are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. Karen Egan Cuan will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).
6. Links
The Website may contain links to other websites, services or offers which are owned, operated or maintained by third parties. If you click on a third party link, you will be directed to that third website or service (such as, by way of some non-limiting examples, a third party payment processor). The fact that we link to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third party websites and services and we do not have control over their privacy policies and terms of use.
7. Security of Information
While using any Internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are all designed, built and maintained with your security and privacy in mind. We apply industry standards and best practices to prevent any unauthorized access, use, and disclosure. We comply with all applicable federal laws, state laws, EU Directives and regulations regarding data privacy, specifically including without limitation the GDPR.
8. Service Providers
We may employ third party companies and individuals to facilitate our Website, to perform certain tasks which are related to the Website, or to provide audit, legal, operational or other services for us. These tasks include, but not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and only after entering into appropriate confidentiality agreements, and always anonymizing user data to the extent possible.
9. Children's Privacy
We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to become a user. The Website is not directed and not intended to be used by children under the age of 13. If you are aware that we have collected Personal Information from a child under age 13 please let us know by contacting us and we will delete that information.
10. Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Karen Egan Cuan may be obliged to disclose information to law enforcement, certifying bodies, and/or other authorities to conform to Karen Egan Cuan’s professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment.
11. Changes to the Privacy Policy
Karen Egan Cuan may update this Privacy Policy at its sole discretion. The date of the last revision of this Privacy Policy appears at the end of this page. We encourage you to periodically review this page for the latest information on our Privacy Policy and practices. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to stop using the Website and/or Services.
12. Contacting us
If you have any questions or concerns about this Privacy Policy or our privacy-related practices, please contact us by clicking this link.
13. Additional terms and conditions for the General Data Protection Regulation (GDPR) Notice
This section provides additional information about our Privacy Policy relevant to users from the European Union (EU) and Switzerland. It supplements and should be read in conjunction with the rest of the Privacy Policy. Under the GDPR, Karen Egan Cuan is the Controller with respect to your Personal Data (as defined in the GDPR).
Karen Egan Cuan may use your personal information:
· When it is necessary to do so to perform our obligations in accordance with any contract that we may have with you, for example to manage your account, and to respond to enquiries about your use of the Website.
· When it is in our legitimate interests or a third party's legitimate interests to use personal information in such a way to ensure that we provide the Website in the best way that we can. In particular, we have a legitimate interest in using your personal information for Services improvement and internal analytics purposes, and otherwise to improve the safety, security, and performance of the Website. We only rely on our or a third party's legitimate interests to process your personal information when these interests are not overridden by your rights and interests.
· When it is necessary to do so in order to comply with any legal obligations imposed upon us, for example under applicable law or to adhere to certain obligations required by applicable certifying bodies.
· When you have consented to the use of your personal information, for example for marketing purposes or to track your online activities via Cookies and similar technologies.
EU and Swiss residents have specific rights regarding their personal information. This section describes your rights if you are resident in the EU or Switzerland, and explains how to exercise those rights.
Right of access: You may be entitled to ask us for a copy of any personal information which we hold. This right is known as a ‘Subject Access Request.’ We will normally send you a copy of the personal information within one month of your request. However, that period may be extended by two further months where necessary, taking into account the complexity of the request or the difficulty in accessing the personal information that you request. There is usually no charge; but in exceptional circumstances we may charge but will discuss this with you if those circumstances apply.
Right to rectification: If the personal information we hold about you is inaccurate, you may request rectification. The personal information will be checked, and, where appropriate, inaccuracies will be rectified.
Right to erasure: In certain circumstances, you may be entitled to ask us to erase your personal information.
Right to data portability: In certain circumstances, you may wish to move, copy, or transfer the electronic personal information that we hold about you to another organization.
Right to object: You may object to your personal information being used for direct marketing. You may object to the continued use of your personal information in any circumstances where we rely upon consent as the legal basis for processing it. Where we rely upon legitimate interests as the legal basis for processing your personal information, you may object to us continuing to process your personal information, but you must give us specific reasons for objecting. We will consider the reasons you provide, but if we consider that there are compelling legitimate grounds for us to continue to process your personal information, we may continue to do so. In that event, we will let you know the reasons for our decision.
Rights related to automated decision-making including profiling: We use limited personal information to operate the Website and to carry out certain profiling activities to support and grow our business. When doing so, we rely upon our legitimate interests as the lawful basis for processing your personal information and you may exercise the above rights if you do not wish us to process your personal information in this way.
To exercise the rights in relation to your Personal Information set out in this section, please contact us by clicking here.
Whilst we will always work with you to resolve any concerns you have about the use of your personal information, under GDPR you have the right to lodge a complaint with the supervisory authority in your country of residence if you have any concerns about our use of your personal information.