PRIVACY POLICY 

Last Updated: January 1, 2021

Effective Date: January 1, 2021

 

Introduction

 

The Armenian Mental Health Initiative ("Company" or "We" or “Us”) respects your privacy and is committed to protecting it through our compliance with this policy.

 

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.amhi.org (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

 

This policy applies to information we collect

  • On this Website.

  • In email, text, and other electronic messages between you and this Website.

  • Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.

  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

 

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Company or any third party, including our affiliates and subsidiaries, as applicable; or

  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

 

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, please immediately terminate your use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

 

Company Background

The Armenian Mental Health Initiative is a not-for-profit enterprise that provide interested persons with tele-health support services, evidence-based medical information, training, peer-to-peer consultations, and other resources through the Website and via third party telephonic and electronic services (e.g. Zoom). We neither receive nor grant financial incentives relating to the provision of mental health services through this Website. Our tele-health services should not be construed as a therapy service.

 

Jurisdiction

 

This Policy is intended to comply with all applicable United States and, European Union, and Armenian privacy laws, including, but not limited to, the EU General Data Protection Regulation (GDPR), the Health Insurance Portability and Accountability Act (HIPAA), and the Children’s Online Privacy Protection Action (COPAA).

 

In accordance with these and other regulations, we endeavor to comply with the following governing principles concerning personal data processing: (1) lawful, fair, and transparent collection and use of your personal information; (2) collection and processing of your personal information reasonably limited to the purpose for which you have provided it to us; (3) collecting only that information that is adequate, relevant, and limited to what is necessary; (4) keeping personal data accurate, and timely correcting inaccuracies; (5) maintaining your data only as long as is necessary; and (6) securing your personal data against unlawful processing, loss, destruction, or damage.

 

Children Under the Age of 13

 

Our Website is not intended for children under 13 years of age. No one under the age of 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at armenianmentalhealth@gmail.com.

 

Information We Collect About You and How We Collect It

 

We collect several types of information from and about users of our Website, including information:  

  • By which you may be personally identified, such as name, postal address, e-mail address, telephone number, and any other identifier by which you may be contacted online or offline ("personal information");

  • That is about you but individually does not identify you; and/or

  • About your internet connection, the equipment you use to access our Website, and usage details.

 

We collect this information:

  • Directly from you when you provide it to us (during account creation or otherwise).

  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

  • From third parties, for example, our business partners or service providers, which services may be subject to that third party’s privacy policies.

 

Information You Provide to Us

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.

  • Records and copies of your correspondence (including email addresses), if you contact us.

  • Your responses to surveys that we might ask you to complete for research purposes.

  • Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

  • Your search queries on the Website.

 

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website 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.

 

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website (e.g. Company’s use of Google Analytics or other web traffic monitoring systems).

  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

 

The information we collect automatically is only statistical data and does not include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. This information helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.

  • Store information about your preferences, allowing us to customize our Website according to your individual interests.

  • Speed up your searches.

  • Recognize you when you return to our Website.

 

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. For more information on cookies and how to disable them, please visit http:// www.allaboutcookies.org.

 

  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

 

  • Web Beacons. Pages of our the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

 

Although we do not collect personal information automatically, we may tie the non-personal information we collect to personal information about you that we collect from other sources or you provide to us.

 

Third-Party Use of Cookies and Other Tracking Technologies

 

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

 

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. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

 

How We Use Your Information

 

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

  • To present our Website and its contents to you.

  • To provide you with information, products, or services that you request from us (when aligned with the communication and marketing preferences you have set).

  • To fulfill any orders placed through the Website (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations).

  • To communicate to you with respect to your order (or otherwise as requested).

  • To screen our orders for potential risk or fraud.

  • To fulfill any other purpose for which you provide it.

  • To provide you with notices about your account, including account balance, expiration, and renewal notices.

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

  • To notify you about changes to our Website or any products or services we offer or provide though it.

  • To allow you to participate in interactive features on our Website.

  • In any other way we may describe when you provide the information.

  • For any other purpose with your consent.

 

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

 

Sharing Your Personal Information

 

We share your personal information with third parties to assist in the performance of the services you request from us, and only when reasonably necessary. We do not share or sell your personal information for any other reason.

 

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

 

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • 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 it to them.

  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.

  • To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.

  • To fulfill the purpose for which you provide it.

  • For any other purpose disclosed by us when you provide the information

  • With your consent.

 

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

  • To enforce or apply our Terms of Use and other agreements between you and us, including for purchasing, billing, and collection purposes.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

 

HIPAA and Telesupport Compliance

 

We might employ remote and electronic communication platforms over which sensitive medical information is transmitted. We endeavor to comply with HIPAA for all United States residents who disclose protected health information (PHI) through the Website.

 

We might make use of the services of third party business associates (BA) who perform certain functions or activities that involve creating, receiving, maintaining, or transmitting PHI on our behalf, including, but not limited to, electronic communication and data storage, claims processing or administration, data analysis, quality assurance, and billing services. We disclose PHI only to those third parties with a need for such information, and only to the extend disclosure is necessary in the performance of their services for us.

 

We will disclose your PHI to BA’s only as permitted under a business associate agreement or other relationship in which the BA is subject to restrictions on the disclosure of PHI compliant with HIPAA.

 

We may disclose your PHI without your consent for treatment, payment, and health care operations reasons as permitted under HIPAA, or as otherwise limited by applicable law.

 

Our designated privacy and security officer is Heghineh Galstian, MD. You may contact him/her at the following email address with any questions you might have about our HIPAA compliance policy, or to request that certain restrictions apply to the use and disclosure of your PHI: armenianmentalhealth@gmail.com.

 

Choices About How We Use and Disclose Your Information

 

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

 

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data (e.g. the order or registration form(s)). You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile, checking or unchecking the relevant boxes, or by sending us an email with your request to armenianmentalhealth@gmail.com

 

  • Promotional Offers from the Company. If you do not wish to have your email address or other contact information used by the Company to promote our own or third parties' products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time by logging into the Website and adjusting your user preferences in your account profile, by checking or unchecking the relevant boxes, or by sending  us an email stating your request to armenianmentalhealth@gmail.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

 

  • Targeted Advertising. We may use your personal information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by contacting us at armenianmentalhealth@gmail.com. For this opt-out to function, you must have your browser set to accept all browser cookies.

 

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.

 

Do Not Track

 

Please note that we do not alter our Website’s data collection and use practices when we see a Do Not Track signal from your browser.

 

Accessing and Correcting Your Information

 

You can review and change your personal information by logging into the Website and visiting your account profile page.

 

You may also send us an email at armenianmentalhealth@gmail.com. to request access to, correct or delete any personal information that you have provided to us. In many cases, we cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

 

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use as applicable.

 

Rights of European Visitors

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

 

Additionally, if you are a European resident, we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Website), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, which may include to Canada and the United States.

 

Data Security

 

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

 

Changes to Our Privacy Policy

 

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website home page. The date the privacy 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 for you, and for periodically visiting our Website and this privacy policy to check for any changes.

 

California and other United States Residents

 

Specific U.S. states, including California and Nevada, might have other privacy and data protection laws that apply to their residents’ participation on the Website. In some cases, such laws apply only while we engage in certain activities, store a certain volume of personal data, or engage in a certain minimal amount of commerce. For more information on how we comply with the California Consumer Privacy Act, Nevada’s Senate Bill 220, or other relevant state laws, please contact us at the email address found below.

 

Contact Information

 

To ask questions or comment about this privacy policy and our privacy practices, contact us at: armenianmentalhealth@gmail.com