Protecting your private information is our priority. This Statement of Privacy applies to all Platinum Teletherapy websites and governs data collection and usage. By using any Platinum Teletherapy website, you consent to the data practices described in this statement.
Platinum Teletherapy (“Platinum”) may collect personally identifiable information, such as your e-mail address, name, home or work address, or telephone number. If you purchase Platinum products and services, we collect and store billing and credit card information. Platinum may also collect anonymous demographic information, which is not unique to you, such as your Postal Code, age, gender, preferences, interests, and favorites. Platinum will not delete customer information for paying members. Information about your computer hardware and software also may be automatically collected by Platinum. This information can include: your IP address, browser type, domain names, access times, and referring website addresses. This information, obtained through Google Analytics, is used by Platinum for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the website.
Should you desire to access or delete the information collected by Google, you can do so via My Google Activity. Platinum encourages you to review the privacy statements of websites you choose to link to from any Platinum website so that you can understand how those websites collect, use, and share your information. Platinum is not responsible for the privacy statements or other content on websites outside of the Platinum family of websites.
Platinum collects and uses your personal information to operate the website and deliver the services you have requested. We will periodically send service updates to registered users.
Platinum may also use your personally identifiable information to inform you of other products or services available from Platinum and its affiliates. Platinum may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered. Platinum does not sell, rent, or lease its customer lists to third parties. Platinum may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party without your explicit consent. In addition, Platinum may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries.
Platinum may share your information with third parties who perform tasks required to complete a purchase transaction. All such third parties are prohibited from using your personal information except to provide these services to Platinum, and they are required to maintain the confidentiality of your information. Platinum does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent. Platinum keeps track of the websites and pages that our customers visit, in order to determine what services are the most popular. This data is used to deliver customized content to customers whose behavior indicates that they are interested in a particular subject area. Platinum websites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Platinum; (b) protect and defend the rights or property of Platinum; and, (c) act under exigent circumstances to protect the personal safety of users of Platinum, or the public. Parents or children under 13 have the option to agree to the collection and use of the child’s information without consenting to the disclosure of the information to third parties. Children under 13 will not be asked to disclose more information than is reasonably necessary to participate in an activity as a condition of participation. If a parent of child under 13, wishes to review the child’s personal information, ask to have it deleted, or refuse to allow any further collection or use of the child’s information, that parent must contact Platinum.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties
Platinum may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Platinum pages, or register with Platinum, a cookie helps Platinum to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Platinum website, the information you previously provided can be retrieved, so you can easily use the Platinum features that you customized. You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Platinum services or websites you visit.
You are responsible for safeguarding and preventing unauthorized access to the user information and password that you use to access Platinum. You agree not to disclose your password to any third party and you are responsible for any activity using your account, whether or not you authorized that activity. You must immediately notify Platinum of any unauthorized use of your account. Platinum secures your personal information from unauthorized access, use, or disclosure. Platinum secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL)
protocol.
Platinum is a vendor to educational agencies and institutions (EAs) and receives personally identifiable information (PII) contained in student records from the EAs. Only information that is needed for Platinum and its employees and contractors to perform services is disclosed to Platinum by the EA. These disclosures are authorized under the Family Educational Rights and Privacy Act (FERPA). Platinum, as a contractor to the EA, receives the disclosures on the same basis as school officials employed by the EA, consistent with FERPA regulations, 34 CFR §99.31(a)(1)(i)(B). Consistent with those regulations, Platinum has a legitimate educational interest in the information to which it is given access because the information is needed to perform the outsourced service, and Platinum is under the direct control of the EA in using and maintaining the disclosed education records, consistent with the terms of its contract.
Platinum is subject to the same conditions on use and redisclosure of education records that govern all school officials, as provided in 34 CFR §99.33. In particular, Platinum must ensure that only individuals that it employs, contracts with, or that are employed by its contractor, with legitimate educational interests – consistent with the purposes for which Platinum obtained the information — obtain access to PII from education records it maintains on behalf of the district or institution. Further, in accordance with 34 CFR §99.33(a) and (b), Platinum may not redisclose PII without consent of a parent or an eligible student (meaning a student who is 18 years old or above or is enrolled in postsecondary education) unless the agency or institution has authorized the redisclosure under a FERPA exception and the agency or institution records the subsequent disclosure. An example of such a disclosure is when Platinum is requested by a school district to assist the district in the transfer of the student records from our system to another system.
Platinum will not sell or otherwise use or redisclose education records for targeted advertising or marketing purposes. Platinum does not allow advertising within its products or services, and therefore there is no behavioral or targeted advertising. Platinum uses data within its products and services only to deliver the services contracted by the educational institution. Platinum may use anonymized, non-PII data internally to improve the products and services it delivers to EAs.
Platinum employs extensive technological and operational measures to ensure data security and privacy, including advanced security systems technology, physical access controls, and security and privacy training for employees regarding compliance with FERPA, HIPAA, and other applicable privacy laws.
Platinum does not own any of the student data or district-created data within its products. These data within the products are property of, and under the control of, the EA.
In the event any third party seeks to access education records, Platinum will immediately inform the EA of such request in writing. Platinum shall not provide access to such data or information or respond to such requests unless compelled to do so by due process, court order or lawfully issued subpoena from any court of competent jurisdiction or directed to do so by the EA. Should Platinum receive a court order or lawfully issued subpoena seeking the release of such data or information, Platinum shall provide immediate notification, along with a copy thereof, to the EA prior to releasing the requested data or information, unless such notification is prohibited by law or judicial and/or administrative order or subpoena.
If the EA is unable to fulfill a request of an eligible student or parent/guardian to review the student’s records, Platinum can assist at the direction and expense of the EA. In such an event where a parent, legal guardian, or eligible student seeks to make changes to the data within our products, parents, legal guardians, or eligible students shall follow the procedures established by the EA in accordance with FERPA. Generally, these procedures establish the right to request an amendment of the student’s education records that the parent or eligible student believes is inaccurate, misleading, or otherwise in violation of the student’s privacy rights under FERPA.
Parents or eligible students who wish to ask the EA to amend their child’s or their education record should write an EA official (often a Principal or Superintendent), clearly identify the part of the record they want changed, and specify why it should be changed. If the EA decides not to amend the record as requested by the parent or eligible student, the EA will notify the parent or eligible student of the decision and of their right to a hearing regarding the request for amendment. Additional information regarding the hearing procedures would be provided to the parent or eligible student when notified of the right to a hearing.
In the event Platinum becomes aware of a data breach or inadvertent disclosure of PII, Platinum shall take immediate steps to limit and mitigate such security breach to the extent possible.
Platinum will notify a senior member of the affected EAs leadership team, ideally the Superintendent or similar chief executive. This typically will occur within 48 hours of confirmation of the event and would include the known relevant details. The EA and Platinum will work cooperatively in determining an action plan, including any required notification of affected persons.
In the event of termination to use our services or products, and at the written request of the EA or in accordance of the terms of the EAs contract, Platinum will make commercially reasonable efforts to destroy all student records contained in our systems. Furthermore, Platinum shall ensure that it disposes of any and all data or information received from the EA in a commercially reasonable manner that maintains the confidentiality of the contents of such records (e.g. shredding paper records, erasing and reformatting hard drives, erasing and/or physically destroying any portable electronic devices). At the written request of the EA, Platinum will provide a written certification of destruction.
If the EA does not make a written request, Platinum retains student data for a period 6 years.
To the extent parents, guardians or students have questions regarding the content of, or privacy associated with, any applications used by the educational institution, please contact that agency or institution.
Student records that are disclosed to Platinum by EA and maintained within Platinum products are by definition “education records” under FERPA and not “protected health information” under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Because student health information in education records is protected by FERPA, the HIPAA Privacy Rule excludes such information from its coverage. See the exception at paragraph (2)(i) to the definition of “protected health information” in the HIPAA Privacy Rule at 45 CFR § 160.103.
See, also, Joint Guidance on the Application of the Family Educational Rights and Privacy Act (FERPA) and the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to Student Health Records, USED and U.S. Department of Health and Human Services (November 2008).
However, Platinum strives to comply with all privacy laws and therefore has taken measures to ensure that we are HIPAA compliant.
Platinum will occasionally update this Statement of Privacy to reflect company and customer feedback, and to be in compliance with evolving state and federal laws and regulations. A message will be posted on Platinum websites to notify you of the changes. Platinum encourages you to periodically review this Statement to be informed of how Platinum is protecting your information.
Platinum welcomes your comments regarding this Statement of Privacy. If you believe that Platinum has not adhered to this Statement, please contact us.
info@platinumteletherapy.com
(888) 270-1148
Last Updated: May 20, 2020
