Privacy Policy

Last Updated April 19, 2023

Easter Seals, Inc. (d/b/a "Easterseals") ("we," "our," or "us") understands that data privacy and the protection of personal information is important to you. This Privacy Notice explains how we collect, use and share your personal information, and your rights and choices regarding the personal information we collect about you.

Please read this Notice carefully to understand our policies and practices regarding your personal information and how we will process it. You can also click on the links below to navigate to a specific section.

  1. Scope of Notice
  2. Personal Information Collection
  3. How We Use Personal Information
  4. How We Disclose Personal Information
  5. Easterseals Affiliate Members
  6. Links to Other Sites
  7. Security of Personal Information
  8. Transmission of Health-Related Information
  9. Retention of Personal Information
  10. Your Rights and Choices Regarding your Personal Information
  11. Cookies
  12. International Transfers of Personal Information
  13. Information from Children
  14. Changes to this Notice
  15. Contact Us

1. Scope of Notice

This Privacy Notice applies to all donors, members, website visitors, business partners, employees, job applicants, and individuals who otherwise interact with Easterseals whom we collect personal information from. We often refer to your interactions with us as using our "services" throughout this Notice.

2. Personal Information Collection

We collect a variety of information as part of our operations, including personal information and other information. "Personal information" is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual.

a. How We Collect Personal Information

Easterseals collects information, including personal information, from and about its donors, event attendees and program participants, individuals who interact with our affiliate members, employees and job applicants, individuals who visit our website and other individuals who choose to interact with us. We collect information from or about you in the following ways:

  • Directly from you. We collect information directly from you when you make a donation, create a user profile on our website, attend an event or program we are offering, apply for employment or gain employment with us, when you visit our website, and when you otherwise voluntarily submit or provide information to us.
  • Automatically. When you visit and interact with our website, we collect information automatically through cookies. For more information about cookies on our website, please visit the section below titled "Cookies."
  • From our Affiliate Members. We rely on our affiliate members to provide us with information about the individuals they provide services to and interact with so that we can understand the impact of our and our affiliate members' programs and services, yield actionable insights, and drive future-forward decision making to ensure that our services and programs make the most impact in the communities we serve.
  • From Other Sources. We may collect information about you from other sources and we may combine information from other sources with information we collect through our services or interactions with you. Examples of the other sources we most frequently collect information from includes national donor data bases and registries, and companies that compile mailing lists about individuals.

b. Types of Personal Information We Collect

The types of personal information we collect depends on how you interact with us, including whether the interaction is through one of our affiliate members or directly with us. In many cases, the personal information we collect will be apparent from the context in which you provide the information.

We collect the following types of personal information from you depending on how you interact with us (i.e., donor, employee, etc.).

Categories of Personal InformationCategories of individuals
Contact Information. This includes your name, mailing address, email address, social media handle, or other similar identifiers.
  • Donors
  • Employees and job applicants
  • Website visitors
  • Event attendees
  • Program participants
  • Individuals who interact with our affiliate members
  • Easterseals affiliate member users
Identification Information. This includes your SSN, driver's license number, passport number, or similar legal identification information.
  • Employees and job applicants
Profile Information. This includes information about your activity and interactions with us, including your donor tendencies and donation history, information you voluntarily provide to us or that we collect from other sources regarding your interests, preferences, and characteristics. We compile this information we collect about you to better understand you.
  • Donors
  • Website visitors
  • Event attendees
  • Program participants
  • Individuals who interact with our affiliate members
  • Easterseals affiliate member users
Health Information. This is information about your health, disability, or medical condition which may include "Protected Health Information" (PHI).
  • Event attendees
  • Program participants
  • Individuals who interact with our affiliate members
  • Employees and job applicants (if you choose to participate in our group health plan)
Financial Information. This includes information about your wealth and financial status, income, credit card, bank account, or payment information.
  • Donors
  • Employees and job applicants
  • Individuals who interact with our affiliate members
Location Information. This includes information about your location.
  • Donors
  • Website visitors
  • Easterseals affiliate member users
Professional or Employment-Related Information. Current or past job history or performance evaluations.
  • Employees and job applicants
  • Affiliate clinical and non-clinical service providers
Internet or other similar network activity. Browsing history, search history, information on your interaction with a website, application, or advertisement.
  • Website visitors
  • Donors
  • Easterseals affiliate member users
Interaction Information. This includes information about your attendance at events we host or programs we sponsor, as well as information about correspondence with us and other ways you interact with us.
  • Donors
  • Event attendees
  • Program participants
  • Website visitors
  • Individuals who interact with our affiliate members
  • Easterseals affiliate member users
Sensitive Personal Information. We may collect certain sensitive personal information including race, gender, and age information. This information is collected in aggregate form.
  • Employees and job applicants
  • Individuals who interact with our affiliate members
  • Easterseals affiliate member users

We may not collect all of the above categories of information from each category of individual who interacts with us. Please note that if you voluntarily provide us with additional information when you interact with us that does not fit one of these categories of information or individuals set forth above, we will collect the information and use it for the purposes you direct or that we disclose to you.

As noted above, in certain circumstances, we may also collect "Protected Health Information." "Protected Health Information" ("PHI") is individually identifiable health information. We sometimes collect PHI when we gather information about the effectiveness of our programs in order to understand whether a program that we or our affiliate members offered resulted in improved outcomes for the individuals or communities our programs are designed to serve.

3. How We Use Personal Information

We use personal information for our legitimate business purposes to further our mission and for other purposes disclosed to you at the time data is collected. More specifically, we use personal information in the following ways:

  • Provide our services, programs, and events to the communities and individuals we serve.
  • Send you confirmations about event or program registration, or donations.
  • Process donations and gifts made to Easterseals or our affiliate members.
  • Understand our donor base and potential donors.
  • Measure the effectiveness of our services, programs, and events, including services, programs, and events offered by our affiliate members.
  • Communicate with you about our services, programs, events, happenings, and news.
  • Respond to your comments, inquiries, and customer service requests.
  • Market our events, services, programs, and potential donor opportunities to you. You may opt-out of marketing communications at any time.
  • Provide you with employment, or consider you for employment with Easterseals.
  • Process payroll and other benefits afforded to our employees.
  • Improve and personalize our content and services.
  • Monitor and analyze trends regarding our services, programs, and events, including services, programs, and events offered by our affiliate members.
  • Protect against and prevent fraud, unauthorized transactions, and manage risk exposure.
  • Enforce our legal rights and agreements.
  • Comply with applicable legal requirements.
  • Carry out any other purpose you consent to, that we disclose to you at the time your data is collected, or that you direct us to.

We may aggregate and de-identify personal information we collect from you to understand the effectiveness of our programs, services, and offerings, as well as to understand our donor base and donor trends. When we aggregate or de-identify information, it is no longer personally identifiable.

4. How We Disclose Personal Information

Easterseals may share your personal information in the following circumstances, and as otherwise described in this Notice:

  • Affiliate Members. We share information with our affiliate members in order to understand and improve the impact of our and our affiliate members' programs, services, and offerings. Please see the section below titled "Easterseals Affiliate Members" for more information.
  • Service Providers, Vendors, and Consultants. We rely on third parties to perform functions on our behalf. Some of these service providers include marketing service providers, payment service providers who help us process donations and pay our employees, cloud storage providers, website hosting platforms, client relationship management providers, HR or employee benefits providers, and content providers. We endeavor to ensure written agreements are in place with all service providers, vendors, and consultants where feasible and appropriate. All service providers, vendors, and consultants are required to use the information we disclose to them at our direction and only for the purpose(s) for which it was disclosed to them, and they are required to adhere to security and confidentiality measures.
  • List Rental and Exchange Program. We may share certain information about our donors with national donor registration and list service providers in order to grow our donor base and more effectively reach current and prospective donors. If you do not wish for your information to be shared with these third parties, you may opt-out by contacting us via a method set forth in the "Contact Us" section below or by visiting our website and contacting us through a means listed on our website. If you would like to know which third parties participate in the list rental and exchange program, you may also contact us via one of the methods listed below.
  • Law Enforcement Agencies, Courts, Regulators, Government Authorities, or Other Third Parties. We may disclose your information: 1) to apply with a legal obligation or court order; 2) when we believe in good faith that the law requires it; 3) at the request of governmental authorities conducting an investigation; 4) to verify or enforce our policies, procedures, terms of service, and other agreements, or to protect the rights, property, safety, and security of Easterseals, our members, vendors, business partners, service providers, affiliate members, website visitors, or the public; 5) to respond to an emergency; or 6) when we believe it is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity.
  • Successor Entities, Buyers, Transfers and Mergers and Acquisitions. We may disclose your information to a buyer, potential buyer, successor in interest, or to an organization in connection with a bankruptcy, transfer, merger or acquisition, or other transfer of some or all of Easterseals' or an affiliate's assets, which may include your information. If this occurs, we will endeavor to ensure that the successor entity uses your personal information in accordance with this Privacy Notice, or provides you with notice and a choice about future use of your personal information.

5. Easterseals Affiliate Members

Easterseals has a number of affiliate members throughout the United States who interact directly with the populations we serve by bringing Easterseals' mission and work directly into the community in which the affiliate member operates. While our affiliate member organizations are associated with and use Easterseals branding, they may have their own practices regarding how they collect, use, share, and retain information when you interact with them.

As described above, affiliate members share information with us, and we share information with our affiliate members. This information sharing occurs so that we can understand the impact of our and our affiliate members' programs and services, yield actionable insights, and drive future-forward decision making so that we can continue to further the Easterseals' mission of equity, inclusion, and access for individuals with disabilities.

Easterseals' website may contain links to other sites, including to our affiliate members, as well as links to non-affiliated third parties, such as social networks or business partners. These linked sites may have personal information collection, use, and disclosure practices that differ from Easterseals' practices. We encourage you to review the privacy policies of websites that you visit before sharing your personal information with them. Please also be aware that if you disclose personal information, PHI, or other sensitive information through public forums, at an event, or on online message boards, this information may be used by others. We take no responsibility for the content, security, or confidentiality of any information posted on or conveyed in these public spaces.

7. Security of Personal Information

Easterseals knows that information security is of the utmost important to our donors, affiliate members, website visitors, and individuals whose information we collect. We maintain reasonable technical, administrative, physical, and organizational safeguards in proportion to the sensitivity of information we collect that are designed to prevent unauthorized access, use, and disclosure of personal information.

However, no electronic data transmission or processing of personal information is completely secure, so we cannot guarantee the security of personal information. We encourage you to assist us with securing your personal information by using a strong password and not disclosing your login credentials, where applicable, to anyone. If we become aware of an incident that affects your personal information, we will investigate and comply with all reporting obligations.

8. Transmission of Health-Related Information

Easterseals understands the sensitivity of collecting and using health-related data. It is not Easterseals' intent to collect personally identifiable health-related information or PHI. If we do collect personally identifiable health-related information or PHI, it will not be used by or shared with entities other than Easterseals or our affiliate members, unless the information is de-identified. Any transfer of personally identifiable health-related data between Easterseals organizations will take place in a secure environment with access allowed only to certain qualified employees of Easterseals. Easterseals will comply with all regulations set forward by the Health Insurance Portability and Accountability Act (HIPAA). To learn more about HIPAA, visit the U.S. Department of Health and Human Services Office for Civil Rights.

9. Retention of Personal Information

We will retain your information only for as long as necessary to achieve the purpose for which it was collected. This may mean that we will continue to retain certain information even after we stop providing our services directly or indirectly to you, after you delete your user profile, or cease interacting with us, as required by law or for our legitimate business purposes. We may also retain de-identified, aggregated, or anonymous information that does not identify a particular individual. In all cases where we retain data, we do so in accordance with limitation periods and record retention obligations that are imposed by applicable law.

10. Your Rights and Choices Regarding your Personal Information

Easterseals offers various rights that are consistent with state consumer privacy laws. Easterseals offers the option to access, correct, and delete your personal information. If you are a registered user of our website, you can access your Easterseals profile and update your contact information and user preferences by clicking here. Upon your request, we will delete, aggregate, or de-identify personal information related to you that is retained in our organizational databases, unless we are required to continue to retain the information in an identifiable format. To exercise your right to deletion, or to modify or correct your information other than through the link above, please contact us via a method set forth in the below "Contact Us" section.

You can also change your communication preferences and opt-in or opt-out of marketing communications from Easterseals. To opt-out of receiving email communications, postal mail or from participating in the list rental and exchange program, or to request a disclosure of list rental and exchange information, please follow the directions below.

We will endeavor to fulfill all requests within a reasonable timeframe.

11. Cookies

Our website uses or may use cookies, web beacons, pixel tags, and similar technologies (collectively, "cookies"). Cookies are small text files stored directly on a website visitor's computer or mobile device that automatically collect certain information from users such as browser type, IP address, time spent online, pages visited, referring URL, and additional aggregated website traffic data. We also rely on partners to provide features of our services, which may involve using cookies.

We use cookies for the following purposes:

  • Functionality. These cookies are necessary for us to ensure that the website functions properly.
  • Security. These cookies are necessary for us to mitigate the risk of data breaches and similar attacks by ensuring that requests are submitted to our website from proper domains.
  • Authentication. These cookies allow us to authenticate user requests and to maintain session information related to users.
  • Preference. These cookies allow our website to remember which events you have signed up or registered for, the products you place in your shopping cart, and to recognize your device.
  • Advertising. These cookies allow us to provide you with more relevant advertisements.
  • Analytics. These cookies enable us to learn more about how users and visitors interact with our website, including pages visited, how much time is spent on each pages, and similar information. We use this information in aggregate.
  • Third-Party. These cookies are placed by third parties such as Google and social media networks. These cookies track and monitor how you interact with our services and other websites, provide us insight into how you interact with our website (such as analytics), facilitate account registration and login, and also enable the sharing of content from our services to these third parties. We do not control the data use or sharing practices of these third parties. If you do not wish to accept third party cookies, we encourage you to update your browser settings accordingly.

The use of cookies has become standard among website operators. Most browsers are initially set to accept cookies. You can usually set your browser to refuse cookies that are not necessary or to indicate when a cookie is being set. To understand your options regarding cookies, you can visit the help section of your web browser, or take a look at the links below:

If you refuse cookies, you may not be able to use certain functions on our website and our website may not function as smoothly as it does when cookies are enabled.

12. International Transfers of Personal Information

Easterseals and all of its affiliate members are located in the United States, and all programming offered by Easterseals and its affiliate members occurs in the United States. Because of the global nature of the internet, the Easterseals website may be accessible from jurisdictions other than the United States, even though Easterseals does not operate, provide, or market its services outside of the United States. If you access the Easterseals website outside of the United States, your information will be transferred to and processed in the United States. Since the data protection laws of various countries differ, information transferred to the United States may not be subject to the same level of protection as the jurisdiction in which you reside. If you choose to access our website from a jurisdiction outside the United States, we rely on your consent to transfer the data to the United States. To the extent you do not consent to data transfers to the United States, please do not provide us with your personal information or visit our website.

13. Information from Children

Our website is not directed towards children under the age of 13. We do not knowingly collect personal information from anyone under the age of 13 through our website without parental consent. If you become aware that we have collected personal information from an individual under the age of 13 through our website without parental consent, please let us know so that we can take appropriate action.

14. Changes to this Notice

We may update this Privacy Notice from time to time. If we make material updates to this Notice, we will endeavor to provide you notice by placing a prominent notice on this website and/or sending an email notification of the change. We will also update the "last updated" date at the top of this policy. Any changes will be effective immediately on posting unless otherwise indicated. Continued use of our services after updates to our Notice will be deemed consent to the changes.

15. Contact Us

If you have any questions about this Notice or our information practices, please contact us by emailing us through this link or directly at info@easterseals.com, calling us toll-free at 800-221-6827, or writing to us at:

Easter Seals, Inc.
Attn: Privacy Manager
141 W. Jackson Blvd
Suite 1400A
Chicago, IL 60604

Easter Seals of Mahoning, Trumbull and Columbiana Counties

Notice of Privacy Practices

 

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

 

I.  Our duty to Safeguard Your Protected Health Information.

Individually identifiable information about your past, present, or future health or condition, the provision of health care to you, or payment for the health care is considered "Protected Health Information" (PHI). We are required to extend certain protections to your PHI, and to give you this Notice about our privacy practices that explains how, when and why we may use or disclose your PHI. Except in specified circumstances, we must use or disclose only the minimum necessary PHI to accomplish the intended purpose of the use or disclosure.

 

We are required to follow the privacy practices described in this Notice, though we reserve the right to change our privacy practices and the terms of this Notice at any time. If we do so, we will post a new Notice at each service office. You may request a copy of the new notice from Easter Seals, 299 Edwards St, Youngstown, Oh 44502, and it will also be posted on our website at http://www.mtc.easterseals.com./

 

II.  How We May Use and Disclose Your Protected Health Information.

We use and disclose PHI for a variety of reasons. We have a limited right to use and/or disclose your PHI for purposes of treatment, payment or our health care operations. For uses beyond that, we must have your written authorization unless the law permits or requires us to make the use or disclosure without your authorization. If we disclose your PHI to an outside entity in order for that entity to perform a function on our behalf, we must have in place an agreement from the outside entity that it will extend the same degree of privacy protection to your information that we must apply to your PHI. However, the law provides that we are permitted to make some uses/disclosures without your consent or authorization. The following offers more description and some examples of our potential uses/disclosures of your PHI.

  • Uses and Disclosures Relating to Treatment, Payment, or Health Care Operations: Generally, we may use or disclose your PHI as follows:
    • For Treatment: We may disclose your PHI to health care personnel who are involved in providing your health care. For example, your PHI will be shared among members of your health care team, or with outside services for consultation, referral, or coordination of your care.
    • To obtain payment: We may use/disclose your PHI in order to bill and collect payment for your health care services. For example, we may contact a private insurer to get paid for services that we delivered to you or release portions of your PHI to the Medicaid program, county board of MR/DD, or other payer source.
    • For health care operations: We may use/disclose your PHI in the course of operating Easter Seals. For example, we may use your PHI in evaluating the quality of services provided, or disclose your PHI to our accountant or attorney for audit purposes. Since we are an integrated system, we may disclose your PHI to designated staff in our regional office. Since many of our services are accredited, we may disclose your PHI to these accrediting bodies. 
  • Uses and Disclosures that We May Make Unless You Object:     
    • Family or friends involved in care: Unless you object, health professionals, using their best judgment, may disclose to a family member, other relative, close personal friend or any other person you identify, health information relevant to that person's involvement in your care or payment related to your care. 
    • Marketing and Fundraising:  We may use or disclose your health  information in connection with limited marketing or fund-raising communications permitted under the Federal Privacy Rules.  If you do not want to receive fundraising materials, please contact our privacy officer (See section V.) and request that these materials not be sent to you.
  • Uses and Disclosures Requiring Authorization: For uses and disclosures beyond treatment, payment and operations purposes we are required to have your written authorization, unless the use or disclosure falls within one of the exceptions described below. Authorizations can be revoked at any time to stop future uses/disclosures except to the extent that we have already undertaken an action in reliance upon your authorization.
  • Uses and Disclosures of PHI Not Requiring Consent or Authorization: The law provides that we may use/disclose your PHI without consent or authorization in the following circumstances:
    • When required by state or federal law.
    • To state and federal public health authorities, including state medical officers, the Food and Drug Administration (FDA), and other agencies charged with preventing or controlling disease.
    • To government authorities, including protective service agencies, authorized to receive reports of abuse, neglect, or domestic violence.
    • To government health oversight agencies, such as the state and federal Departments of Health and Human Services, Medicare/Medicaid Peer Review Organizations (PRO's), state Boards and other licensing authorities.
    • When required by court order in a judicial or administrative proceeding.
    • To law enforcement officials for certain law enforcement purposes, including the reporting of certain types of wounds or injuries, or pursuant to a warrant, subpoena, or other legal process, or for the purpose of identifying or locating a subject, fugitive, material witness, missing person, or victim, provided that the conditions in the rule are met.
    • To coroners, medical examiners, or funeral directors for purposes of identifying a deceased person or carrying out their duties as required by law.
    • For research approved by an Institutional Review Board (IRB) or Privacy Board that has reviewed the research proposal and established protocols to ensure the privacy of your health information.
    • When required to avert a serious threat to health or safety.
    • When requested for certain specialized government functions authorized by law, including military and similar situations.
    • As authorized by law in connection with workers compensation programs.

III.  Your Rights Regarding Your Protected Health Information.

You have the following rights relating to your protected health information:

 

To request restrictions on uses/disclosures: You have a right to ask that we limit how we use or disclose your PHI. We will consider your request, but are not legally bound to agree to the restriction. To the extent that we do agree to any restrictions on our use/disclosure of your PHI, we will put the agreement in writing and abide by it except in emergency situations. We cannot agree to limit uses/disclosures that are required by law.

 

To choose how we contact you: You have the right to ask that we send you information at an alternative address or by an alternative means. We must agree to your request as long as it is reasonably easy for us to do so.

 

To inspect and copy your PHI: Unless your access is restricted for clear and documented treatment reasons, you have a right to see your protected health information upon your written request. We will respond to your request within 30 days. If we deny you access, we will give you written reasons for the denial and explain any right to have the denial reviewed. If you want copies of your PHI, a charge for copying may be imposed, depending on your circumstances. You have a right to choose what portions of your information you want copied and to prior information on the cost of copying.

 

To request amendment of your PHI: If you believe that there is a mistake or missing information in our record of your PHI, you may request, in writing, that we correct or add to the record. We will respond within 60 days of receiving your request. We may deny the request if we determine that the PHI is: correct and complete; not created by us and/or not part of our records; or, not permitted to be disclosed. Any denial will state the reasons for denial and explain your rights to have the request and denial, along with any statement in response that you provide, appended to your PHI. If we approve the request for amendment, we will change the PHI and so inform you, and tell others that need to know about the change in PHI.

 

To find out what disclosures have been made: You have a right to get a list of when, to whom, for what purpose, and what content of your PHI has been released other than instances of disclosure for treatment, payment, and operations; to you or your family; or pursuant to your written authorization. The list will also not include any disclosures made for national security purposes, to law enforcement officials or correctional facilities, or disclosures made before April, 2003.  We will respond to your written request for such a list within 60 days of receiving it. Your request can relate to disclosures going as far back as six years. There will be no charge for up to one such list a year. There may be a charge for more frequent requests.

To receive this Notice: You have a right to receive a paper copy of this Notice and/or an electronic copy by email upon request.

 

IV.   How to Complain about our Privacy Practices:

If you think we may have violated your privacy rights, or you disagree with a decision we made about access to your PHI, you may file a complaint with the person listed in Section V below. You also may file a written complaint with the Secretary of the U.S. Department of Health and Human Services at 200 Independence Avenue SW, Washington, D.C. 20201 or call 1-877-696-6775. We will take no retaliatory action against you, if you make such complaints.

V.  Contact Person for Information, or to Submit a Complaint:

If you have questions about this Notice or any complaints about our privacy practices, please contact: Susan Mauro, Privacy Officer, Easter Seals, 299 Edwards St., Youngstown, OH 44502, (330) 743-1168, or smauro@mtc.easterseals.com.

 

VI. Effective Date:

This notice was effective on April 1, 2003

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