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Privacy Policy and Practices

Privacy Policy and Practices

PRIVACY POLICY

Centre for Neuro Skills and its affiliated entities (collectively “CNS”) take your privacy very seriously.  Please read this Privacy Policy (“Policy”) carefully as it contains important information on who we are, how and why we collect, store, use and share your personal information when you visit any of our websites (collectively “Website”) or transact with us (collectively, the Website and our services are referred to as the “Services”).  It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

By accessing the Website and/or using the Services, you agree to this Policy, and if you are under age 16, you have parent or legal guardian’s permission to use our Services and your parent/guardian has agreed to this Policy.

CNS has the right to revise this Policy at any time.  Your continued use of the Website and/or Services constitutes your acceptance of this Policy as it exists at the time of such use.

Personal Information We Collect About You

CNS may collect and use certain information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or household (collectively “Personal Information”).  This Policy applies to Personal Information we collect: (i) Directly from you when you visit our Website or communicate with our representatives (whether electronically, by telephone or paper forms); and, (ii) Automatically from you as you browse the Website.  This Policy does not apply to any Protected Health Information (“PHI”) as defined in the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and all PHI collected by CNS, either directly or indirectly, is subject to our HIPAA Notice of Privacy Practices, a copy of which is also posted on the Website.  This Website contains links to other websites, within and outside of CNS.  Please be aware that this Policy does not apply to those websites. We encourage you to read the privacy policy on any other websites before providing them with Personal Information.  

We use different methods to collect Personal Information from you including direct interactions and automated interactions.

Direct interactions include you giving CNS your Personal Information by filling in forms or corresponding with us by mail, phone, email or otherwise, including Personal Information you provide when you use our Services, request marketing materials to be sent to you, fill out a form or contact a representative, or give us feedback or report a problem with our Services. If you submit to CNS any Personal Information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Policy. By submitting Personal Information, you grant CNS the right to transmit, monitor, retrieve, store and use your information in connection with the operation of the website.

Automated technologies or interactions include the automatic collection of Personal Information about your equipment, browsing actions, and patterns, which may also include usage details, IP addresses and information collected through cookies.  The Website works with third-party products or services (“Service Providers”). These include Google, Facebook, and other Service Providers who help us track and analyze visitor activity on the Website, measure the effectiveness of our advertising efforts, and support the optimization of CNS digital marketing campaigns. The website uses “cookies,” tracking pixels and related technologies. These can be set by CNS or by our Service Providers.  Cookies are small data files that online services can store on, and retrieve from, a user’s computer or mobile device through the user’s web browser. The information is stored and retrievable either for the duration of a website visit (known as “session cookies”), or until some later point in time set by the website setting the cookie (known as “persistent cookies”).  Examples of information CNS and our Service Providers collect include how often someone visits this website and what they do while on the website. CNS and our Service Providers use this information in the aggregate to understand how our visitors as a group use different resources and to help us improve our website. CNS and our Service Providers also collect information about the activity of individual website users.  Most internet browsers accept cookies by default, but you can modify your browser preferences to block or restrict cookies if you do not want your web browsing activity tracked. There are a variety of tools publicly available to manage cookies and similar technologies that collect information related to your use of the Website.  CNS is not responsible for the effectiveness or compliance of third party opt-out mechanisms or programs. Please note that if you delete your cookies or upgrade your browser after having opted out, you will need to opt out again.  Further, if you use multiple browsers or devices you will need to opt out on each browser or device.  You can access the information on this Website without enabling cookies in your browser but disabling cookies may result in a diminished ability to take advantage of the Services and related informational content on the Website.  CNS uses web analytics and tag management services and tools provided by Google and other third parties to collect certain information relating to your use of this website. You can find out more about how Google uses data when you visit our website by visiting “How Google uses data when you use our partners' sites or apps.”  Service Providers may acquire additional information about your activity on our website, including pages you visit, access times, visit duration, how you arrived at the Website and your IP address. An IP address is a number that identifies a device connected to the Internet. For most devices, the IP address changes on at least a weekly basis. CNS Service Providers may also acquire device identifiers and specific information about the browser you use. In some cases, this information may be unique to you.

How We Use Personal Information

CNS may use Personal Information for the following purposes: (i) fulfill online requests, (ii) as described to you when collecting your Personal Information, (iii) respond to customer service inquiries, (iv) help us improve the services we offer; (v) personalize your experience and inform you about the treatments/services in which you have indicated an interest (vi) tailor digital advertisements on third-party websites based on your interactions on our website; (vii) improve our Website offerings and send you information and updates; (viii) respond to your questions and requests and improve customer service (ix) administer a promotion, survey, or other site feature; (x) communicate changes to this Policy or terms of use; or (xi) or in other ways as required by law.

Who We Share Your Personal Information With

We routinely share personal information with: (i) Our affiliates, including companies within the CNS group; (ii) Service Providers we use to help deliver our services to you; (iii) other third parties we use to help us run our business, such as marketing agencies or website hosts; and, (iv) third parties approved by you, including social media sites you choose to link your account to or third-party payment providers. We only allow our Service Providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on Service Providers relating to ensure they can only use your personal information to provide services to us and to you.  We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

Promotional Communications and Email

CNS may use your Personal Information to send you updates (by email, text message, telephone or mail) about our services.  CNS has a legitimate interest in processing your Personal Information for promotional purposes. This means CNS does not usually need your consent to send you promotional communications. However, where consent is needed, CNS will ask for this consent separately and clearly.  CNS will always treat your personal information with the utmost respect and never sell or share it with other organizations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by using the “unsubscribe” link in emails or “STOP” number in texts.

CNS may ask you to confirm or update your marketing preferences if you instruct CNS to provide further Services in the future, or if there are changes in the law, regulation, or the structure of our business.  Please do not provide Personal Information via email to us unless it is through a secure channel (these will be marked, as secure online forms, for example). Remember that email messages, unless encrypted while in transit, can be viewed by other Internet users. If you have Personal Information to communicate, please use the appropriate secure online form or contact the necessary party using traditional means such as phone or mail.  If you receive an email that looks like it is from CNS and asks for your Personal Information, do not respond. This may be a scam or “Phishing” email intended to steal your information. CNS will never request your password, username, credit card information or other personal information through email.

Data Retention

CNS may maintain one or more databases to store your Personal Information and may keep such Personal Information indefinitely in order to fulfill the purposes for which it was collected, including for purposes of satisfying any legal, accounting or reporting requirements.  In some circumstances CNS may deidentify your Personal Information so that it can no longer be associated with you for research or statistical purposes, in which case CNS may use this information indefinitely without further notice to you.

Data Security

CNS has appropriate security measures in place to prevent Personal Information from being accidentally lost or used or accessed in an unauthorized way. CNS limits access to your Personal Information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. CNS also has procedures in place to deal with any suspected data security breach.  CNS will notify you and any applicable regulator of a suspected data security breach where legally required to do so.

International Transfer

If you are located in a province, country or other governmental jurisdiction outside of the United States, and if you choose to provide your Personal Information to the Company through our Services, please be aware that your Personal Information will be transferred to any maintained on computers located in the United States and the applicable United States privacy laws may not be as protective as those in your jurisdiction.

Your Rights Under the CCPA [California Residents].  If you are a resident of the state of California, you have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

For Personal Information disclosed by CNS, you have the right to know:

Please note that we are not required to: (i) retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; (ii) reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or, (iii) provide the Personal Information to you more than twice in a 12-month period.

For Personal Information sold or disclosed by CNS to a third party for a business purpose, you have the right to know:

You have the right under to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, see “How to Exercise Your Rights” below.

You have the right to deletion of Personal Information.  Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

Please note that we may not delete your personal information if it is necessary to:

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

•    Deny goods or services to you;
•    Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
•    Provide a different level or quality of goods or services to you; or
•    Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

How to Exercise Your Rights.

If you would like to exercise any of your rights as described in this Policy, please call us, toll-free, or email/write to us at:

Centre for Neuro Skills
5215 Ashe Road
Bakersfield, California 93313
Attn: General Counsel
Phone: 661.872-3408
Fax: 661.872.5150
Email: nashley@neuroskills.com

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.  If you choose to contact directly, you will need to provide us with:

CNS is not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected Personal Information or is someone authorized to act on such person’s behalf.  Any personal information collected from you to verify your identity in connection with you request will be used solely for the purposes of verification.


NOTICE OF PRIVACY PRACTICES

THIS NOTICE OF PRIVACY PRACTICES (“NOTICE”) DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. CENTRE FOR NEURO SKILLS AND ITS AFFILIATED COMPANIES (COLLECTIVELY “CNS”) COMPLIES FULLY WITH STATE AND FEDERAL PRIVACY LAW INCLUDING THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (“HIPAA”).  PLEASE REVIEW IT CAREFULLY.

Our Pledge Regarding Medical Information.

CNS is committed to protecting medical information about you.  This Notice describes our privacy practices and that of all our employees and staff.  This Notice will tell you about the ways in which we may use and disclose medical information about you.  It also describes your rights and certain obligations we have regarding the use and disclosure of medical information.  CNS is required by law to:

How We May Use and Disclose Medical Information About You

The following categories describe different ways we use and disclose medical information.  For each category we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed.  However, all of the ways we are permitted to use and disclose information will fall within one of the categories.

Treatment.  We may use and disclose medical information about you to provide you with medical treatment or services.  For example, a specialist we may refer you to may need to know about a treatment you received at our office to coordinate other treatments you are receiving.  We may use the telephone number you provide us to contact you about testing results or other follow-up to your treatment.
Payment.  We may use and disclose medical information about you so that the treatment and services you receive at our office may be billed and payment may be collected from you, an insurance company or a third party.  For example, we may need to give your health plan information about services you received at our office so your health plan will pay us or reimburse you for the services.  We may contact the guarantor that you list for billing purposes.
Health Care Operations.  We may use and disclose medical information about you for our office operations including notifying you of a breach of your medical information.  For example, we may use medical information to review our treatment and services and to evaluate the performance of our staff in caring for you.
Appointment Reminders.  We may use and disclose medical information to contact you as a reminder that you have an appointment for treatment or medical care at our office.
Treatment Alternatives.  We may use and disclose medical information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.
Health-Related Benefits and Services.  We may use and disclose medical information to tell you about health-related benefits or services that may be of interest to you.
Individuals Involved in Your Care or Payment for Your Care.  We may release medical information about you to a close personal friend or family member who is involved in your medical care or payment for your care, so long as you have not objected and it is reasonable for us to infer that such disclosure is in your best interest.
Special Purposes When Permitted or Required by Law.  We may disclose medical information about you for special purposes when permitted or required by law, including the following:

State and Other Federal Laws.  We will comply with all applicable State and Federal laws. For example, under State law, there are more limits on the disclosure of HIV and AIDS information. We will continue to abide by all applicable state and federal laws.

Other Uses of Medical Information Require an Authorization. Other uses and disclosures of medical information not covered by this Notice or the laws that apply to us will be made only with your written authorization.  Specifically, these uses require your written authorization:

If you provide us an authorization to use or disclose medical information about you, you may revoke that authorization, in writing, at any time.  If you revoke your authorization, we will no longer use or disclose medical information about you for the reasons covered by the written authorization.  You understand that we are unable to take back any disclosures we have already made with your authorization, and that we are required to retain our records of the care that we provide to you.

Your Rights Regarding Medical Information About You.  You have many rights with regard to your medical information.  If you wish to exercise any of these rights, you must submit your request in writing, unless otherwise noted.

Your Right to Inspect and Copy.  You have the right to inspect and copy medical information that may be used to make decisions about your care.  We may charge a reasonable fee for the costs of copying, mailing or other supplies associated with your request.

Your Right to Amend.  If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information.  You have the right to add a statement.  You must provide a reason that supports your request for an amendment. We may deny your request if the medical information  (i) was not created by CNS; (ii) not part of the medical and billing records kept by or on behalf of CNS; (iii) is not part of the information which you would be permitted to inspect and copy; or (iv) is determined by us to be accurate and complete.

Your Right to an Accounting of Disclosures. You have the right to request an “accounting of disclosures.”  This is a list of certain disclosures we made of medical information about you. Your request must state a time period.  We may limit the time period to 6 years prior to the date on which the accounting is requested.  The first list you request within a 12-month period is free.  For additional lists, we may charge you for the costs of providing the list.

Your Right to Request Restrictions.  You have the right to request a restriction or limitation on the medical information we use or disclose about you.  For any services for which you paid out-of-pocket in full, we will honor any request you make to restrict information about those services from your health plan, provided that such release is not necessary for your treatment.  In all other circumstances, we are not required by law to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you emergency treatment.

Your Right to Request Confidential Communications.  You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail.  If we maintain medical information about you in electronic format, you also have the right to obtain a copy of such information in electronic format and to direct us to transmit such information directly to an entity or person clearly, conspicuously, and specifically designated by you. We will not ask you the reason for your request. You may make this request in writing or verbally.

Right to be Notified in the Event of Breach.  We will notify you if your medical information has been “breached”, which means that your medical information has been used or disclosed in a way that is inconsistent with law and results in it being compromised. 

Right to Paper Copy of this Notice.  You have the right to a paper copy of this Notice.  You may ask us to give you a copy of this Notice at any time.

Right to File a Complaint.  If you believe your privacy rights have been violated, you may file a complaint with us. You may also file a complaint directly with the Secretary of the Department of Health and Human Services.  You will not be penalized in any way for filing a complaint.

Future Changes To This Notice.  The effective date of this Notice is January 1, 2022.  We reserve the right to change this Notice. We reserve the right to make, revise or change this Notice effective for medical information we already have about you as well as any information we receive in the future.  Should our privacy practices change, we will post the amended Notice on our website. You may request a copy by contacting our Privacy Officer.

Use of Email.  If you choose to communicate with us via email, we may respond to you in the same manner in which the communication was received and to the same email address from which you sent your email. Before using email to communicate with us, you should understand that there are certain risks associated with the use of email, such as misaddressed/misdirected messages, email accounts that are shared with others, messages that can be forwarded on to others, or messages stored on portable electronic messages that have no security. Additionally, you should understand that the use of email is not intended to be a substitute for professional medical advice, diagnosis or treatment. Email communications should never be used in a medical emergency. 

Questions or Complaints.  If you believe that your privacy rights have not been followed as directed by applicable law or as explained in this notice, you may file a complaint with us. Please send any complaint to the CNS Privacy Officer at the address provided below. You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services. You will not be penalized for filing a complaint. 

Privacy Notice Contact Information.  For questions about this Notice, or for further information, please contact:

Centre for Neuro Skills
5215 Ashe Road
Bakersfield, California 93313
Attn: Privacy Officer
Phone: 661.872-3408
Fax: 661.872.5150
Email: nashley@neuroskills.com

Application to CNS Affiliates.  This Notice applies to the following entities:

Centre for Neuro Skills, a California corporation
Centre for Neuro Skills - LA, a California corporation
Centre for Neuro Skills - S.F., a California corporation
Centre for Neuro Skills, Inc. - Texas, a Texas corporation
CNS - F.W., LLC, a Texas limited liability company
CNS - Houston, LLC, a Texas limited liability company
CNS - Austin, LLC, a Texas limited liability company