Privacy Policy (Platform)
Last Updated: 10/26/2023
We take your privacy very seriously. Please read this privacy policy carefully, as it contains important information on who we are and how and why we collect, store, use, and share your personal information. It also explains your rights concerning your personal information and how to contact us or supervisory authorities if you have a complaint.
The AACN provides an alliance of many different community organizations (collectively, the “Community” and each, a “Partner”) in and around San Antonio, Texas working to provide community care coordination and limited health and educational support services (“Services”) to individuals. The AACN utilizes a cloud-based platform (the “Community Network”) to store and share your personal information amongst the Community to aid in the provision of the Services. The AACN respects your privacy and is committed to protecting it through our compliance with this privacy policy.
We collect, use, and are responsible for certain personal information about you. When we do so, we are subject to various laws in the United States. Please note, the use of the Community is only intended for those currently residing in Texas, and we only intend information to collect information of those currently residing in Texas.
As a reminder, this Privacy Policy supplements our permission to use and disclose protected information form, and, in the form and this privacy policy, we make it clear that the services are only intended for individuals currently residing in texas.
1. Key Terms.
It would be helpful to start by explaining some key terms used in this policy:
| We, us, our, Company, AACN | Alamo Area Community Network |
| Contact details for our data protection officer | privacy@ouraacn.com |
2. Personal Information We Collect About You.
We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
| Category | Categories of Personal Information | Specific Types of Personal Information Collected |
| A | Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) | Real name; email address; social security number; date of birth; postal address; Internet Protocol (IP) address. |
| B | Information that identifies, relates to, describes, or is capable of being associated with a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | Real name; email address; social security number; date of birth; postal address; date of birth; phone number; physical characteristics; health insurance information; financial information; medical information including medical history; medical treatments; medical diagnoses; and/or medical needs. |
| C | Characteristics of protected classifications under federal law. | Information related to personal titles, e.g., Mr., Mrs., and Ms.; race; ethnicity; gender; sexual preference. |
| D | Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) | None |
| E | Biometric information | None |
| F | Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement) | IP address(es) of your computer(s). |
| G | Geolocation data | None |
| H | Audio, electronic, visual, thermal, olfactory, or similar information | None |
| I | Professional or employment-related information | Employment status; employer information. |
| J | Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA) | Education records; directory information. |
| K | Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | None |
This personal information is required to provide you with products and/or services. If you do not provide the personal information asked for, it may delay or prevent us from providing you with products and/or services.
3. How Your Personal Information is Collected.
We and/or the relevant Partner collect most of this personal information directly from you—in person, by telephone, by email and/or online communication. However, we may also collect information:
- From publicly accessible sources;
- Directly from a third party;
- Via our IT systems.
4. How and Why Your Personal Information is Used.
Partners of the Community only use your personal information if there is a proper or legitimate reason for doing so. When your personal information needs to be shared on the Community Network for limited reasons described in this Section 4, your personal information is shared (as necessary) as specified in Section 5.
Some examples of how we use your personal information are as follows:
- To provide the Services;
- To comply with our legal and regulatory obligations;
- For the performance of our obligations to you under any agreements that we have with you or to take steps at your request before entering into an agreement with you;
- For our legitimate interests (explained below); or
- Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
| What we use your personal information for | Our reasons |
| To provide products and/or services to you | For the performance of our obligations to you under any agreements we have with you, to take steps at your request before entering into an agreement with you, or to provide the Services to you. |
| To prevent and detect fraud against you or Company | For our legitimate interests, i.e., to minimize fraud that could damage us and you. |
| Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety regulations or rules issued by our professional regulator | To comply with our legal and regulatory obligations. |
| Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies | To comply with our legal and regulatory obligations. |
| Ensuring business policies are adhered to, e.g., policies covering security and internet use | For our legitimate interests, i.e., to ensure we follow our own internal procedures to deliver the best service to you. |
| Operational reasons, such as improving efficiency, training, and quality control | For our legitimate interests, i.e., to be as efficient as we can so we can deliver the best service for you. |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests, i.e., to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations. |
| Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range, or other efficiency measures | For our legitimate interests, i.e., to be as efficient as we can so we can deliver the best service for you. |
| Preventing unauthorized access and modifications to systems | For our legitimate interests, i.e., to prevent and detect criminal activity that could damage us and you. To comply with our legal and regulatory obligations. |
| Updating and enhancing customer records | For the performance of our obligations to you under any agreements that we have with you or to take steps at your request before entering into an agreement with you To comply with our legal and regulatory obligations For our legitimate interests, e.g., making sure that we can keep in touch with our customers about existing orders and new products |
Marketing our services to:
| For our legitimate interests, i.e., to promote our business to existing and former customers as far as legally permitted. Otherwise, we only process your data if we have your consent. |
| External audits and quality checks | For our legitimate interests, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations |
5. Who We Share Your Personal Information With.
We routinely share personal information with the following third parties:
- Service providers we use to help provide the Services to you; and
- Partners of the Community to help provide the Services to you.
We will generally only disclose your personal information to the aforementioned third parties in accordance with the applicable data protection laws and inform you of the disclosure in accordance with legal requirements.
We will always try to have our service providers process and/or store your personal information in the United States.
We only allow our service providers to handle and process your personal information if we are satisfied they take appropriate measures to protect it. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you and only in accordance with applicable federal and state laws and regulations. Accordingly, processing is only permitted to the extent necessary to perform the services on our behalf or to comply with legal requirements.
We may also share personal information with external auditors.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. We will typically de-identify the personal information, but this may only sometimes be possible. The recipient of the personal information will be bound by confidentiality obligations.
We will not share your personal information with any third party unless you consent.
6. Personal Information We Sold or Disclosed for a Business Purpose.
We have not sold any of your personal information (as defined above), and we will not sell any of your personal information.
We do not process personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you or other consumers. We do not sell personal information for money.
7. Where Your Personal Information is Held.
Information may be held at our offices and those of our service providers, representatives, agents as described above, and/or Partners (see above: “Who We Share Your Personal Information with”). We will always try to store your personal information in the United States.
8. How Long Your Personal Information Will Be Kept.
After you consent to sharing your information, we may keep your personal information described above. After you stop receiving the Services, we may keep your personal information for as long as is necessary:
- To respond to any questions, complaints, or claims made by you or on your behalf;
- To show that we treated you fairly;
- To keep records required by applicable federal and/or state laws and/or regulations; or
- To improve the Services.
We will only retain your personal information for as long as necessary for the purposes set out in this policy. Different retention periods may apply for different types of personal information.
When retaining your personal information is no longer necessary, we will delete, de-identify, otherwise anonymize it, or restrict its processing.
9. Keeping Your Personal Information Secure.
We and our service providers have appropriate physical, technical, and administrative security measures in place to prevent personal information from being accidentally lost, altered, used, or accessed in an unauthorized way.
10. Changes to This Privacy Notice.
We may change this privacy notice from time to time–when we do, we will inform you via the Website or other means of contact such as email.
11. How to Contact Us.
Please contact us by postal mail, email, or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:
| Contact address | 112 E. Pecan Street, Suite 830 San Antonio, Texas 78205 |
| Contact email address | privacy@ouraacn.com |
| Contact telephone number | (210) 390-6993 |
Any guest or registered user of the Website may contact us regarding all questions or suggestions concerning data privacy.
12. You Need Extra Help?
If you would like this notice in another format (e.g., audio, large print, braille), please get in touch with us (see “How to contact us” above).
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