Connect-a-Voice Privacy Policy

Last updated January 27, 2023

PLEASE READ CAREFULLY BEFORE YOU START TO USE THE PLATFORM (DEFINED BELOW). THIS PRIVACY POLICY (“Policy“) CONSTITUTES A LEGALLY BINDING AGREEMENT BETWEEN THE CUSTOMER (“Customer“, “You“, or “Your“) AND NORTHWOODS CONSULTING PARTNERS, INC. (“Northwoods“, “we“, “us“, or “our“) GOVERNING THE INFORMATION WE COLLECT FROM YOU AND OUR PRACTICES FOR COLLECTING, USING, MAINTAINING, PROTECTING, AND DISCLOSING SUCH INFORMATION. BY USING THE PLATFORM YOU ACCEPT AND AGREE TO BE BOUND AND ABIDE BY THIS POLICY AND OUR TERMS OF SERVICE, FOUND AT https://connectavoice.com/terms-of-service/ (“Terms“), INCORPORATED HEREIN BY REFERENCE. IF YOU DO NOT WANT TO AGREE TO THIS POLICY OR THE TERMS OF USE, YOU MUST NOT ACCESS OR USE THE PLATFORM. IF YOU ARE ACCEPTING ON BEHALF OF CUSTOMER, YOU REPRESENT AND WARRANT THAT: (I) YOU HAVE FULL LEGAL AUTHORITY TO BIND CUSTOMER TO THIS POLICY; (II) YOU HAVE READ AND UNDERSTAND THIS POLICY AND INTEND FOR CUSTOMER TO BE BOUND BY THIS POLICY; AND (III) YOU AGREE, ON BEHALF OF CUSTOMER TO ALL OF THE TERMS, CONDITIONS, AND OTHER PROVISIONS OF THIS POLICY.

Introduction

Northwoods respects your privacy and are committed to protecting it through our compliance with this policy (“Policy“). This Policy describes:

the types of information we may collect or that you may provide when you download, install, register with, access, or use our proprietary web-and mobile-app known as “Connect a Voice”, including all services, modules, functions, features, updates, releases, improvements, and corrections (collectively, the “Platform”); and
our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies only to information we collect on our Platform, and in email, text, and other electronic communications sent through or in connection with this Platform. This Policy does not apply to any data otherwise regulated (for example, any Protected Health Information as regulated by the Health Information Portability and Accountability Act (HIPAA)).

This Policy DOES NOT apply to information that:

we collect offline or on any other Northwoods apps or websites, including websites you may access through this Platform.
you provide to or is collected by any third party (see Third-Party Information Collection)

Our app, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this Platform. By downloading, registering with, or using this Platform, you agree to this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Platform after we revise this Policy means you accept those changes, so please check the Policy periodically for updates.

Children Under the Age of 18

The Platform is not intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at cavinfo@teamnorthwoods.com.

Information We Collect and How We Collect It

We collect information from and about users of our Platform:

Directly from you when you provide it to us; and
Automatically when you use the Platform.

Information You Provide to Us

When you download, register with, or use this Platform, we may ask you to provide information:

By which you may be personally identified, such as electronic visit verification information, name, postal address, email address, telephone number, billing information, Medicaid number, medical information, social security number, employee number, and location information (“personal information”); and/or
That is about you but individually does not identify you.

This information includes:

Information that you provide by filling in forms in the Platform. This includes information provided at the time of registering to use the Platform, subscribing to our service, and requesting further services. We may also ask you for information when you report a problem with the Platform.
Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.

You may also provide information for publication or display (“Posted”) on public areas of the app or websites you access through the Platform (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatic Information Collection

When you download, access, and use the Platform, we may use technology via the Platform to automatically collect:

Usage Details. When you access and use the Platform, we may automatically collect certain details of your access to and use of the Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Platform.
Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser, mobile network information, and the device’s telephone number.
Stored Information and Files. The Platform also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

If you do not want us to collect this information do not download the Platform or delete it from our device. Note, however, that opting out of the Platform’s collection of location information will disable its location-based features.

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our Platform.

Third-Party Information Collection

When you use the Platform or its content, certain third parties may use automatic information collection technologies to collect information about your device. These third parties may include:

Analytics companies
Your mobile device manufacturers

Your mobile service provider

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information to:

Provide you with the Platform and its contents, and any other information, products or services that you request from us.
Fulfill any other purpose for which you provide it.

Give you notices about your account.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
Notify you when Platform updates are available, and of changes to any products or services we offer or provide through it.

The usage information we collect helps us to improve our Platform and to deliver a better and more personalized experience by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Platform according to your individual interests.
Speed up your searches.
Recognize you when you use the Platform.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we collect or you provide:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of all of Northwoods’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Northwoods about our Platform users is among the assets transferred.

To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Northwoods, our customers, or others.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.

Tracking Technologies. You can set opt to refuse all or some cookies, or alert you when cookies are being sent through your mobile device. You can choose whether or not to allow the Platform to collect information through other tracking technologies. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Platform may then be inaccessible or not function properly.
Location Information. Use of the Platform is heavily reliant on geolocation data. A choice to not allow the Platform to collect and use real-time information about your device’s location will result in an inability to use the Platform effectively.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

California Privacy Rights and Choices

This section is our Privacy Notice for California Residents (“Notice”) and applies to visitors, users, and others who reside in the State of California (“consumers” or “you”/”your”) and use our Services, as contemplated under the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”).

If you wish to exercise your rights under the CCPA/CPRA, please contact us using any of the methods provided in the Contact Us section below. We will consider and process your request within a reasonable period of time. Please be aware that under certain circumstances, the CCPA/CPRA may limit your exercise of these rights.

We collect different types of information from users, and we use and/or disclose this information for different business purposes. The chart below identifies the Personal Information we may collect and lists the parties with whom we may share this information and for what business purpose.

Category of Personal Information	Specific Personal Information that may be collected	Collected?	Purpose of Collecting the personal information	Categories of sources from which the Personal Information is collected	Is this category of Personal Information shared with third parties?	Categories of third parties with which the Personal Information may be shared	Purpose of disclosing or sharing Personal Information
Identifiers	Name, mailing address, email address, telephone number, IP address, and account information	Yes	To uniquely identify an individual in support of business activities	Active Consumers and DSPs	No	N/A	N/A
Personal Information categories listed in the California Customer Records Statute (Cal. Civ. Code 1798.80(e))	Name, signature, Social Security number, address, telephone number, driver’s license or state identification card number, education, employment, employment history, bank account number or any other financial information. Some personal information included in this category may overlap with other categories	Yes	To uniquely identify an individual in support of business activities	Active Consumers and DSPs	No	N/A	N/A
Protected classification characteristic under CA or federal law	Age (40 years or older), national origin, citizenship, marital status, sex, veteran or military status.	Yes	To uniquely identify an individual in support of business activities	Active Consumers and DSPs	No	N/A	N/A
Commercial Information	Contact information and transaction/order history	Yes	To support business transactions	Active Consumers and DSPs	No	N/A	N/A
Biometric information	Physiological, biological, or behavioral characteristics	Yes	To uniquely identify an individual in support of business activities	Active Consumers and DSPs	No	N/A	N/A
Internet or other similar network activity	IP address, browser type and version, Browsing history, information on a consumer’s interaction with a website, or advertisement	Yes	To allow access to and optimize our Platform	Active Consumers and DSPs	No	N/A	N/A
Geolocation data	Information that can identify an individual’s precise location	Yes	To uniquely identify an individual in support of business activities	Active Consumers and DSPs	Yes	State of Ohio, third party aggregator	Necessary to support of the operation of the platform and for performance of the Platform’s services
Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information.	No	N/A	N/A	N/A	N/A	N/A
Professional or employment-related information	Current or past job history or performance evaluations.	No	N/A	N/A	N/A	N/A	N/A
Non-public education information (per the Family Educational Rights & Privacy Act)	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	N/A	N/A	N/A	N/A	N/A
Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes	To uniquely identify an individual in support of business activities	Active Consumers and DSPs	No	N/A	N/A

Use of Personal Information

We do not sell your personal information. We may use or disclose the personal information we collect for one of the purposes listed in the chart. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without first providing you notice.

Sharing Personal Information

We may disclose and have disclosed in the past twelve (12) months personal information to third parties for business purposes as set forth in the above chart in this Policy. In the preceding twelve (12 months), we have not sold personal information.

We do not share your personal information as defined under Cal. Civ. Cd. 1798.140(ah).

Data Retention

We will retain your personal information for no longer than is necessary for the purposes stated in this privacy policy, unless otherwise extending the retention period is required or permitted by law or subject to our retention policies as may be in place from time to time. The data storage period may vary depending on the scenario, product, and service. The standards we use to determine the retention period are as follows:

The time required to retain personal data to fulfill business purposes, including providing products/services

Maintaining corresponding transaction/business records
Controlling and improving the performance and quality of the Platform
Handling possible user queries or complaints and locating problems
Whether the user agrees to a longer retention period
Whether the law, contracts, and other equivalencies have special requirements for data retention

Your California Rights and Choices

The CCPA/CPRA provides California residents with specific rights regarding their personal information. This section describes your CCPA/CPRA rights and explains how to exercise those rights.

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 12 months. Once we receive and confirm your verifiable consumer 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 share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we disclosed your personal information for a business purpose, a list of the disclosures made identifying the personal information categories that each category of recipient obtained.

Correct/Rectify Personal Information

You have the right to rectify (correct, update, or modify) the personal information we collect about you. After making such a request, we will take commercially reasonable efforts to correct inaccurate personal information within 45 days of receiving the request. In the event an extension is needed, we may take an additional 45 days when reasonably necessary. In this case, we will provide you a notice of extension within the first 45-day period.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records unless an exception applies.

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

Complete the transaction for which we collected the personal information, provide 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 contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, specifically if you previously provided informed consent and deleting that information may seriously impair or render impossible the research’s achievement.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of personal information that are compatible with the context in which you provided it.

Exercising Access, Rectification, Data Portability, and Deletion Rights

To exercise access, rectification, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:

Emailing us at cavinfo@teamnorthwoods.com

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

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

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or 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 request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We will try our best to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures will only cover the 12-month period preceding the receipt of the verifiable consumer request’s receipt. The response we provide will also explain the reasons 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 and should allow you to further transmit information if you desire.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or 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 of your CCPA/CPRA rights. Based solely on the exercise of your CCPA/CPRA rights, 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
Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services

Changes to Our Privacy Policy, including our CCPA/CPRA Policy

We may update our Policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page and notify you by email to the primary email address specified in your account.

The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address or phone number for you and for periodically visiting the Policy to check for any changes.

Contact Information

To ask questions or comment about this Policy and our privacy practices, contact us at:

cavinfo@teamnorthwoods.com