InReach Solutions’ Privacy Policy

 

Last updated March 1, 2019

Welcome to the Privacy Policy of InReach Solutions, LLC (“InReach”/“we”/“our”/“us”) (the “Policy”). By using SAM or any products or services by InReach Solutions, you are agreeing to the following terms and conditions.

InReach Solutions, LLC takes your privacy very seriously. This Policy describes how we collect, use, share, and protect the information obtained by the inreachsolutions.com, mysamdb.com, qasamdb.com websites (the “Sites”) as well as from our Clients and other individuals that use our products and services or communicate with us. Please understand that this Policy only applies to us but not to any third-party websites, including Client websites, that may process your Personal Information or other data. In this Policy, “Personal Information” means any information that identifies or could be used to identify an individual person.

1) Definitions

“We”, “Our”, “InReach”, or “InReach Solutions” means InReach Solutions, LLC.

“You”, “Your”, or “Client”, means the person or agency that is party to a SAM Agreement to use SAM or other services of InReach Solutions.

“Client User” means the member of a Client organization that has purchased a subscription to access SAM for case management purposes, and who has been granted access to SAM by that Client.

“End User” means a person who has been granted access to SAM by a Client in order to participate in the case management process; usually, this person is the adopting parent who has been granted access by an adoption or foster care agency so that they can provide personal information to be used in the adoption process. Access granted for any purpose will be governed by the terms of this Privacy Policy.

“SAM Admin” or “SAM Administrator” means the User with Full Admin permissions.

“Public Form” means a fillable form, provided by InReach Solutions and hosted on SAM, or created by the Client and hosted by SAM. Public Forms are provided as an efficient means for End Users to provide data and artifacts to be maintained in the SAM database for use by the Client in providing client services. InReach Solutions disclaims responsibility for the content and presentation of Public Forms created by the Client.

“SAM”, “SAM service”, “SAM System” or “SAM Site” is the software application owned by InReach Solutions which is hosted by InReach Solutions and makes available certain of the Services.

“SAM Agreement” means that particular SAM Proposal & Agreement that has been delivered to and executed by an authorized representative of the Client, further specifying the Services that Client is agreeing to purchase from InReach Solutions.

“Services” means products or services provided by InReach Solutions to facilitate the Client’s case management process.

2) CLIENT DATA

InReach Solutions may receive and process Personal Information of Clients in order to provide our Services (the “Client Data”). InReach will only process Client Data on behalf of and under the instructions of our Clients, as set out in our client agreements, or where otherwise required by applicable laws. In these cases, our Clients are the data controllers of their respective Client Data, and we are the data processor for such data. Subject to our client agreements, we may use aggregate data and anonymized information in order to improve our Services and for research, analytics and other purposes, provided such information does not identify a particular individual.

3) INFORMATION WE COLLECT

We may collect Personal Information about the Client or Client Users directly from you or third parties, and automatically through the use of our Site. You do not have to provide us with your Personal Information to access public areas of our Site. However, if you choose not to disclose certain information, you may be unable to access certain options, offers, and services that require our interaction with you.

InReach Solutions does not collect Personal Information from End Users directly. Personal information of End Users may only be entered into the Sites by the following authorized methods: when the Client enters End User information directly into SAM portal through their Client login; and when the Client sends a Public Form to the End User, and the End User fills in data fields and/or adds artifacts to the Public Form and posts it to their folder in SAM for retrieval by the Client. Any other communication of Personal Information, any transmission of Personal Information other than via the SAM portal, or any collection or transmission of Personal Information other than for the performance of case management Services, is a violation of InReach Solutions’ Terms of Service, and may result in termination of Client or Client Users’ access to the Service.

Information collected directly. We may collect Personal Information (including the categories of information listed below), about you directly from you or from your company. For example, when you fill out a ‘Contact Us’ form, register for an account, signup for our mailing lists, register for events we host or sponsor, post comments on our Sites, or otherwise provide us information through the Sites.

• name, company name, and title/position

• payment and billing information

• email address, phone number, mailing address and contact details

• login credentials

• job title, other company or agency information

• employment, leadership, and licensure information

• preferences and interests

• business affiliations

• other information related to your request or inquiry

Automatically-collected information. We use cookies, log files, pixel tags, local storage objects, and other tracking technologies to automatically collect information when Users access or use the Services or visit our Site, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider (“ISP”), referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked, features used, size of files uploaded, streamed or deleted, and similar device and usage information. For more information, see the “Information we collect automatically” section below.

4) HOW WE USE YOUR INFORMATION

We use your information, including your Personal Information, primarily to provide our services to you and to communicate with you (including for marketing purposes). In particular, we may use your information as follows:

• Providing Support and Services: to provide and operate our Site and Services, communicate with you about your use of the Site and our Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you, and for similar service and support purposes.

• Responding to Your Requests: for the purpose for which you provided the information to us, such as to respond to your inquiries and to provide information in response to your request.

• Analytics and Improvement: To better understand how Site visitors access and use our Services, both on an aggregated and individualized basis, to administer, monitor, and improve our Services, for our internal purposes, and for other research and analytical purposes.

• Personalization: to tailor the content and information that we may send or display to you, to offer location customization (where permitted by applicable law), and to otherwise personalize your experiences while using our website.

• Marketing and Promotional Purposes: for example, where permitted by law, we may use your information, such as your email address, phone number, or mailing address to contact you about Services or information we think may interest you. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages or calls, we will only contact you for direct marketing if you have opted-in.

• Advertising: to advertise our Services on third party sites and social media services.

• Protect Our Legal Rights and Prevent Misuse: to protect our customers, employees or property; for instance, to prevent, detect and investigate fraud, misuse, harassment or other types of unlawful activities, where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of this policy and our applicable terms of service and agreements.

• Comply with Legal Obligations: To comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.

• General Business Operations: Where necessary to the administration of our general business, accounting, recordkeeping and legal functions.

We also create and use anonymous and de-identified information to assess, improve and develop our business, products and Services, and for similar research and analytics purposes. This information is not generally subject to the restrictions in this Policy, provided it does not identify and could not be used to identify a particular individual.

5) WHEN WE DISCLOSE YOUR INFORMATION

We do not sell your Personal Information to third parties. In general, we disclose the Personal Information we collect as follows:

• Affiliates. We may disclose the information we collect from you to our affiliates (companies related by common ownership or control), whose handling of your Personal Information is subject to this Policy.

• Service Providers. We may disclose the information we collect from you to third party service providers who perform functions on our behalf. Third party service providers will only process your personal data in accordance with our instructions and will implement adequate security measures to protect your personal data.

• In Response to Legal Process. We may disclose the information we collect from you in order to comply with the law, judicial proceedings, a court order, or other legal process, such as in response to a subpoena.

• To Protect Us and Others. We may disclose the information we collect from you where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this policy, to respond to claims asserted against us or, or as evidence in litigation in which we are involved.

• Business Transfers. We may disclose or transfer information, including Personal Information, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, including related to due diligence conducted prior to such event where permitted by law.

We may share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

6) INFORMATION WE TRACK AUTOMATICALLY

We also collect information automatically by using cookies, pixel tags, log files, and similar tracking technologies when you visit our Site.

Cookies. Cookies are identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes and make it easier for us to provide a better experience for you when using the Site during future visits. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most browsers allow you to control cookies, including whether or not to accept them, and how to remove them. Please note that disabling cookies will affect the functionality of the website, and may prevent you from being able to access certain features on the website.

Clear GIFs, pixel tags. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies but are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities users of our Services, help us manage content, and compile statistics about usage of our Services. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Log Files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. Such information is gathered automatically and stored in log files.

Do-Not-Track Signals. Our Site does not respond to so-called ‘do-not-track’ signals. For more information about do-not-track signals, please click here. You may, however, disable certain tracking as discussed above (e.g., by disabling cookies).

Third-Party Analytics. We use automated tools, such as Google Analytics and GA Audiences (more info here) to evaluate use of our Services. We use these tools to gather non-personal data about users to help us improve our Services and user experiences. These analytics providers may use cookies and other technologies to perform their services, and may combine the information they collect about you on our Sites with other information they have collected for their own purposes. This Policy does not cover such uses of data by third parties.

7) INTEREST-BASED ADVERTISING

InReach works with different third party ad networks, analytics companies, and measurement services. We and these third parties may use automatic web-tracking tools to collect activity information on our Services (as well as on third party sites and services), as well as IP address, device ID, cookie and advertising IDs, and other identifiers, general location information, and, with your consent, your device’s geolocation information; we and these third parties use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.

For more information about third party ad networks and to opt-out of interest based ads from many ad networks please click:

Canada: www.youradchoices.ca

EU: www.youronlinechoices.eu

U.S.: www.aboutads.info

8) DIRECT MARKETING

We may send you promotional emails from time to time, but we will obtain your consent where required by law to do so. If you wish, you may opt-out of such communications by following the opt-out instructions contained in the respective email. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or Services you have requested or received from us.

9) HOW YOUR INFORMATION IS STORED OR TRANSFERRED/STATEMENT ON GDPR

InReach Solutions, LLC is headquartered in the United States, and has no operations, entities or service providers in other jurisdictions. InReach Solutions acts only as a processor of Personal Information, and does not directly collect, transfer, or control the Personal Information of European Economic Area (“EEA”) citizens. While InReach may store the Personal Information of EEA citizens, such data is received by InReach only after it has been transferred from the EEA by a Client organization in the EEA to a Client affiliate in the United States. Therefore, any such collection, transfer, or control, were it to occur, would be subject to the privacy policy of the collecting and transferring Client that acts as a controller as that term is defined in the General Data Protection Regulation 2016/679 (“GDPR”). While InReach Solutions is therefore not subject to GDPR, we do respect the privacy rights of citizens in all jurisdictions, and make all commercially reasonable efforts to protect the Personal Information that we process in performing the Services.

10) YOUR PREFERENCES AND CHOICES

Access, Amend and Correct. If you wish to access Personal Information that you have submitted to us, to request the correction of any inaccurate information you have submitted to us, or to request deletion of your information. If you are a SAM Admin User of the Site, you may review and update most of your Personal Information by accessing your organization’s Client Portal. You may also send your request to privacy@inreachsolutions.com. We will review your request and make reasonable efforts to respond to it as soon as practicable. We may ask you for additional information so that we can confirm your identity.

Direct Marketing. You can let us know if you do not want us to send you information by clicking the unsubscribe link at the bottom of the email; you may also let us know about your communication preferences (email, phone, and postal mail), by sending an email to privacy@inreachsolutions.com. Please identify all the email addresses, postal address information, and phone numbers that you would like to unsubscribe.

Complaints. We will take steps to try to resolve any complaint you raise regarding our treatment of your Personal Information. You also have the right to raise a complaint with the privacy regulator in your jurisdiction.

11) SECURITY

The security of your Personal Information is very important to us. We employ security measures to protect your information both online and offline from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage. Unfortunately, the Internet is not and will likely never be completely secure, and you acknowledge that we cannot guarantee the complete security of the information you provide us.

12) RETENTION

We will retain your Personal Information as long as necessary for purposes for which the personal data was collected by us, as explained in this Policy or as required to comply with legal obligations or resolve claims and disputes. In general, we will retain relevant Personal Information of clients and Site visitors for at least three years from the date of our last interaction with you and in compliance with our obligations under applicable laws. Our clients instruct us on how long to retain Client Data, which we handle as a data processor. We may retain personal data for longer periods where required by our regulatory obligations, professional indemnity obligations, or where we believe necessary to establish, defend, or protect our legal rights and interests or those of others.

13) CHILDREN

We do not knowingly collect or solicit Personal Information from anyone under the age of sixteen (16) or knowingly allow such persons to register. If we become aware that we have collected Personal Information from a child under the relevant age without parental consent, we will take steps to delete that information.

14) CHANGES TO THIS POLICY

InReach may update this Privacy Policy from time to time. Any changes to this Privacy Policy in the future will be posted to our Site. If the changes will materially affect the way we use or disclose your Personal Information, we will endeavor to notify you in advance of the change, such as by sending a notice to the primary email address associated with your account or by posting a notice on our Site; however, your continued use of the Services and/or accessing the Sites constitutes your acceptance of changes to this Policy. We encourage you to review this Policy periodically for the latest information on our privacy practices.

15) CALIFORNIA PRIVACY RIGHTS

California law permits Users who are California residents to request and obtain from us no more than twice a year, free of charge, a list of their Personal Information we have collected, a list of the third parties to whom we have disclosed their Personal Information (if any) in the prior calendar year, as well as the types of Personal Information disclosed to those parties and the categories of those third parties, and the business purpose of collecting such Personal Information. If you are a California resident and would like to request this information, please submit your request in an email to privacy@inreachsolutions.com.

16) CONTACT US

We want to hear from you! If you are a Client or Client User, you may reach us by [insert contact method via SAM portal or Zendesk support method]. If you are not currently a Client or Client User, please contact us at privacy@inreachsolutions.com.