Privacy Policy

    Effective October 2020

    Peer Health Exchange (“PHE,” “we” or “us”) is committed to respecting the privacy of all users (“users,” “you” or “your”) of our website at (the “Website”) and of users of all PHE’s other websites, mobile applications, platforms and other Internet-related, text-based or in-person services provided by us (collectively with the Website, the “Services”). We have established and implemented this Privacy Policy to inform you of the information we collect from you in connection with the Services, how we collect and use your information, with whom and for what purposes we may share your information, and the choices you can make about our use of your information. By using the Services, you consent to the privacy practices described in this Privacy Policy. If you do not consent to these practices, do not use any of the Services.

    Types of Personal Information We Collect

    The phrase “Personal Information” in this Privacy Policy means contact information (e.g., name, address, email address, mailing address, telephone number) and any other information that personally identifies an individual. In general, we collect Personal Information about you in connection with the provision of the Services, including by collecting Personal Information that you submit to us voluntarily when you correspond with us or use the Services. You can always decline to provide Personal Information to us—it is your choice, and you are under no obligation to provide Personal Information to us. However, if you decide not to provide such information, then you may not be able to access or use certain Services, or request or access certain information or materials from PHE.

    In general, we use the information collected to operate, maintain, enhance and provide all features of the Services, to help us understand who uses the Services, for internal operations such as operating and improving the Services, and to contact you for survey and follow-up purposes. We may also collect Personal Information that you submit to us voluntarily when you correspond with us or interact with the Services. We may combine your Personal Information with information we receive offline, such as when you interact with PHE personnel. Please be aware that any Personal Information you provide to other users during your use of the Services can be collected, used, maintained, shared, or disclosed by those users, and we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such users.

    Types of Anonymous Information We Collect

    We may also collect and store certain information that does not identify you, such as your Internet protocol address, browser type, domain names and access times (“Anonymous Information”). As you navigate, use, or otherwise interact with the Services, we may use automatic data collection technologies to collect certain information about your equipment and browsing actions, including without limitation: (i) information about your computer or mobile device and internet connection; (ii) details about your visit to the Services, including resources you use on the Services

    and other traffic, navigational, or communication data; and (iii) your geolocation information. We may also use Cookies (as defined below) and other tracking technologies to collect information about your online activities. “Cookies” are small pieces of information that a website sends to your browser while you are viewing a website. You can instruct your browser, by changing its options, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. We do not track users across third party websites and therefore do not respond to Do Not Track signals.  We may use your Anonymous Information to analyze usage patterns so that we may enhance the Services and improve our internal operations. We may combine such data with certain of your Personal Information.

    How We Collect Personal Information

    Active Information Collection. We may collect Personal Information from you at various places and through various mechanisms on the Website or through your use of the Services. This is Personal Information that you voluntarily enter including, without limitation, when you register for e-mail communications and when you submit a survey response, question or request to the Website using a form or the e-mail address links on the Website or Services, or when you post to any interactive forum or other feature that we may make available on the Website or Services. You should exercise caution when deciding to disclose Personal Information in connection with any of these features.

    Passive Information Collection. When you visit, or download information from or upload information to, the Services, we automatically collect certain information about your activities (“Website Usage Information“). Website Usage Information includes information about how users use and navigate the Services, such as, for example, the number and frequency of users to each website page, the length of their stays, the type of browser each user is using to view the Services, the type of operating system each user is using, the domain name of each user’s Internet service provider, the user’s internet protocol address, the uniform resource locator (or URL) address of the website that the user navigated from before visiting the Services, which pages were visited on the Services, what was clicked on, and certain other available information. When you request pages from the Services, our servers log your IP address as well as information about your activities on those pages.

    How We Use Personal Information

    In general, we may use your Personal Information to:

    • Administer your account and verify your identity;
    • Provide you with the Services and customer support;
    • Tailor the features, performance, and support of the Services to you;
    • Market the Services to you;
    • Respond to your requests, resolve disputes, and/or troubleshoot problems;
    • Improve the quality of the Services;
    • Detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
    • Comply with U.S., state, local and non-U.S. laws, rules and regulations
    • Communicate with you about the Services; and
    • To fulfill any other purpose for which you provide it.

    PHE uses email to contact users of its Services. If you voluntarily submit your email address to receive information, we may subsequently send information to you via email about Services and other products and services, including emails about promotions and product or service updates (“Promotional Emails”); however, we respect your right to opt out of receiving such Promotional Emails from us. If, at any time after registering, you change your mind about receiving Promotional Emails, you can opt out of receiving such information by sending your request to In addition, you can choose to opt out of the Promotional Emails via the “opt out” link included in each email.

    With Whom We Share Personal Information

    We may disclose your Personal Information: (i) to third party vendors who help us provide the Services, including vendors that help us verify your identity and vendors that process payments for us; (ii) to third parties to whom you ask or authorize us to send Personal Information (including other users) by opting in; (iii) to any subsidiary organizations, joint ventures, or other organizations under our control (collectively, “Affiliates“), in which case we will require our Affiliates to honor this Privacy Policy; (iv) to a company that merges with us, acquires us, or purchases substantially all of our assets, in which case such company may continue to process your Personal Information as set forth in this Privacy Policy; or (v) if we believe in good faith that such disclosure is necessary to: (1) resolve disputes, investigate problems, or enforce our Terms of Service; (2) comply with relevant laws or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity, in which case we can (and you authorize us to) disclose Personal Information without subpoenas or warrants served on us; or (3) protect and defend our rights or property or the rights and property of you or third parties. Except as otherwise stated in this Privacy Policy, we do not trade, rent, or share the Personal Information that we collect with unaffiliated third parties.

    Third Party Links

    The Services may contain links to third parties’ websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on third party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting Personal Information.

    Other Information

    We exercise reasonable security measures to help protect against the loss, misuse, and alteration of your Personal Information. PHE hosts its Services (as applicable) and the collected data in a secure environment that uses reasonable technology to help prevent interference or access from unauthorized persons. Despite such efforts, however, please note that no company, including PHE, can fully eliminate risks or guarantee the security of your Personal Information; unauthorized entry or use, hardware or software failure, and other factors may compromise the security of information about you at any time. Consequently, we do not guarantee the security of any information you provide to PHE through the Services.

    This Privacy Policy is subject to revision from time to time on a going-forward basis. Please revisit this page periodically to remain aware of any changes to this Privacy Policy. We will post any revised version of this Privacy Policy on this page. If we make any material changes to it, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Services for the first time after such material changes are made. Continued use of the Services following notice of such changes will indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

    The Services are operated in the State of California in the United States. If you are located in Canada, the European Union, or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the Website or Services or providing us with your information, you consent to this transfer.

    How to Update Your Information

    You may request to update, or ask that we delete, any Personal Information that we have collected from you or that you have provided to us by contacting us using any of the methods set forth in the Contact Information section below.

    California Residents: Your rights under the California Consumer Privacy Act (“CCPA”)

    Deletion Rights. You have the right to request that we delete any of your Personal Information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

    Disclosure and Access Rights. You have the right to request that we disclose to you certain information regarding our collection and use of Personal Information specific to you over the last twelve (12) months. Such information includes:

    • the categories of Personal Information we collected about you;
    • the categories of sources from which the Personal Information is collected;
    • our business or commercial purpose for collecting such Personal Information;
    • the categories of third parties with whom we share the Personal Information;
    • the specific pieces of Personal Information we have collected about you; and
    • whether we disclosed your Personal Information to a third party, and, if yes, the categories of Personal Information that each recipient obtained.

    No Discrimination. We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

    How to Exercise Your Rights. To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact Information section below.

    Contact Information

    For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.

    Call our National Office at the following number: (415) 684-1240

    Submit a request online using the following online form:

    We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request.  We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information in order to verify your request or use third-party verification services.  You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.

    Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request, but in certain cases, additional time might be required.

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