Road Recovery Privacy Policy

 

Last Updated: August 29, 2024

 

The Road Recovery Foundation, Inc. (“Road Recovery,” “we,” “our,”, and “us”) is committed to protecting the privacy of individuals who engage and interact with the Trax Program App and our website, www.roadrecovery.org (collectively, the “App”), or our meetings, events, videos and mentoring sessions (collectively, the “Services”). We provide this privacy policy (“Privacy Policy”) to describe and explain our information collection practices. This Privacy Policy applies to Personal Data that identifies, relates to, describes, is reasonably capable of being associated with a particular consumer or household, or as defined by applicable privacy laws (“Personal Data”) collected when you interact with the Services  (or any affiliated third-party website that may contain a link to this Privacy Policy).  

By accessing or using the Services , you agree to the terms of this Privacy Policy and consent to our privacy practices described in this Privacy Policy, including our use and disclosure of your Personal Data as described below. If you do not agree with our policies and practices, including our use and disclosure of your Personal Data, please do not register for or use the Services and do not provide us with any Personal Data.

OUR CONTENT CONTAINED ON AND WITHIN THE SERVICES (INCLUDING TEXT, IMAGES, LINKS, RESOURCES, AND MENTOR ADVICE) ARE SUGGESTED FOR INFORMATIONAL, MOTIVATIONAL, AND EDUCATIONAL PURPOSES ONLY. NOTHING ON THIS WEBSITE, APP OR SERVICES SHOULD BE CONSTRUED AS MEDICAL, THERAPEUTIC, LEGAL, FINANCIAL, TAX OR ANY OTHER KIND OF PROFESSIONAL ADVICE. THE CONTENT IS NOT INTENDED TO BE A SUBSTITUTE FOR PROFESSIONAL MEDICAL ADVICE, DIAGNOSIS, COUNSELING, OR TREATMENT. ALWAYS SEEK THE ADVICE OF YOUR PHYSICIAN, PSYCHIATRIST, OR OTHER QUALIFIED HEALTH PROVIDER WITH ANY QUESTIONS YOU MAY HAVE REGARDING A MEDICAL CONDITION AND YOUR ABILITY TO USE THE SERVICES OR CONTENT. NEVER DISREGARD PROFESSIONAL MEDICAL ADVICE OR DELAY IN SEEKING IT BECAUSE OF SOMETHING YOU HAVE READ ON THIS APP OR HEARD ON OR IN THE SERVICES OR APP.  WE DO NOT WARRANT THAT THE APP OR ITS CONTENTS WILL BE ERROR-FREE, ACCURATE, TIMELY, NONOFFESIVE, UNBIASED, OR RELIABLE, ALTHOUGH EFFORTS WILL BE MADE TO CORRECT ERRORS WHEN FOUND. RELIANCE ON ANY INFORMATION PROVIDED BY THE SERVICES IS SOLELY AT YOUR OWN RISK.  

IF YOU ARE HAVING A HEALTH EMERGENCY OR MENTAL HEALTH CRISIS YOU SHOULD IMMEDIATELY CALL 911 (HEALTH EMERGENCY) OR 988 (MENTAL HEALTH CRISIS). DO NOT USE OR RELY ON THE WEBSITE, APP OR SERVICES FOR ASSISTANCE.

REVISIONS AND UPDATES

From time to time, we may change this Privacy Policy to reflect changes to our privacy practices. We encourage you to periodically review our Privacy Policy for the latest information on our privacy practices. We will notify you of any changes to this Privacy Policy by posting the revised or updated Privacy Policy and its “Last Modified” date on the App. If the revision or modification is material, we will provide you notification via email. Your continued use of the App after the “Last Updated” date constitutes your acceptance of and agreement to the Privacy Policy and its revisions or updates.

 

COLLECTION OF PERSONAL DATA

During your use of the Services, we collect Personal Data, in various ways, including directly from you when you provide it to us and automatically when you use the App. 

1. Information Provided by You

We or our third party service providers may collect Personal Data and other information from you when you use the Services, such as when you engage with our Services, attend a mentoring session, provide profile attributes or contact us for customer support. We collect the following types of Personal Data based on your interactions with the Services:

 

• General Information: including your name, age, gender, photographic images and email address; and

 

• Customer Support Information: including name, address, and email address.

2. Information Automatically Collected

Like many other app providers, Road Recovery and its service providers may collect and store information that is generated automatically as you navigate through the App or engage with the Services. This information is primarily needed to maintain the security and operation of the App, and for our internal analytics so that we can improve the App; however, we may also use this information for marketing purposes. We may use the following technologies to collect certain types of information:

• Unique User Identification: we use automatically generated UIDs to identify/authenticate a user and associate their profile attributes and app data to them;

• Device Information: We collect phone model, phone operating system, IP address, search terms, and how you interact with the App;

 

• Customer Proprietary Network  Information: We collect information such as the time, date, and duration of App use;

 

3. Merged Information

 

Like many other app providers, Road Recovery and its service providers may merge stored information that is collected as noted above. This merged information is primarily needed to maintain the security and operation of the App, and for our internal analytics so that we can improve the App. We may use certain technology to merge the following types of information:

 

• Analytics/User journey data: we use this data for directing email communications specific to our Services and segment users during reporting; and

 

• Authentication of returning Users: we use Users log in email address data to access the User profile data.

PURPOSE OF COLLECTION

We may process your Personal Data for the following lawful business and commercial purposes, in accordance with the practices described in this Privacy Policy, and based upon the legal justification set forth in the parenthetical:

 

• Provide the Services . We may use your Personal Data to provide our Services and any other products or services you may request from us. [CONSENT; CONTRACT; LEGITIMATE INTEREST]

 

• Monitor the App. We collect your Personal Data for monitoring purposes to help us diagnose problems with our servers, administer and troubleshoot the App, calculate usage levels, analyze industry standards, and analyze transactions, trends, and statistics regarding the use of the App. [CONSENT; LEGITIMATE INTEREST]

 

• Respond to Inquiries and Fulfill Requests.  We may use your Personal Data to respond to your inquiries and to fulfill your requests for information.  [CONSENT]

 

• Communicate with You.  We may use your Personal Data to send you marketing and non-marketing information about our Services, new service offerings, events, and other items that may be of interest to you.  We may also contact you on behalf of our third-party mentoring, local resources, and/or research partners about a particular offering of theirs that may be of interest to you. [CONSENT; LEGITIMATE INTEREST]

 

• Improve the App.  We may use your Personal Data to make the App more stable and user-friendly, to analyze service issues, improve the design and content of the App, personalize your experience, analyze how the App is used, offer new products and services, and to develop new marketing programs relating to our products and services. [CONSENT; LEGITIMATE INTEREST]

 

• Customer Service. We may use your Personal Data when contacting you regarding customer service or in response when you provide feedback. We may also use your information to send administrative emails regarding the Services  or to inform you of any changes to this Privacy Policy, our Terms, or our third-party partner’s Terms. [CONSENT; LEGITIMATE INTEREST]

 

• Support Business Operations. We may use your Personal Data to support our internal and business operations, including marketing and security. [CONSENT; LEGITIMATE INTEREST]

 

• Enforce Agreements. We may use your Personal Data to enforce separate agreements between you and us, enforce this Privacy Policy, our Terms, or our third-party partner’s Terms of Use, or in connection with a transaction with a similar effect. [CONSENT; CONTRACT]

 

• Fulfill Other Purposes. We may use your Personal Data to fulfill: (a) any other purpose for which you provide it; (b) any legal, government or private grant reporting, or regulatory requirements, and any of our internal policies; (c) other purposes disclosed at the time of collection; (d) any other purpose with your consent; and (e) any other purposes set forth in this Privacy Policy. [CONSENT; LEGITIMATE INTEREST]

 

DISCLOSURE OF PERSONAL DATA

Except as otherwise described in this Privacy Policy, we will not sell, share, rent, or otherwise disclose Personal Data that we collect from the Services  to any third party for monetary or other valuable consideration, unless stated below or with your consent:

• Service Partners. We may share your Personal Data with our service partners to provide you with a service, such as an event, meeting or mentoring session with one of our mentors. We may also share your Personal Data to service partners with whom we jointly offer any services. 

• Service Providers & Contractors. To help us provide superior service, your Personal Data may be shared with our service providers, contractors, and other third parties we use to support our Service and who will safeguard it in accordance with this Privacy Policy. Such third parties may help us with providing customer service, maintaining and analyzing data, and sending customer communications on our behalf.

 

• In the Event of Merger, Sale, Divestitures, or Change of Control. Road Recovery reserves the right to transfer Personal Data to a successor in interest that acquires rights to that data as a result of a merger, divestiture, restructuring, reorganization, dissolution, or other transfer of Road Recovery or substantially all of its assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about you is among the assets transferred. 

 

• With Your Consent. We may share your data for other purposes pursuant to your consent or at your direction. 

 

• Other Disclosures. We may disclose your Personal Data if we have a good faith belief that disclosure of such data is helpful or reasonably necessary to: (a) conform to legal requirements and comply with any court order, law, or legal process, including responding to any government, law enforcement, or regulatory request, or fulfil requirements of government or private grant reporting; (b) enforce our Terms, other agreements, including between you and us, and any other documents included or referenced therein (all of which are incorporated into and made a part of this Privacy Policy by reference); (c) fulfill the purpose for which you provide it; (iv) detect, prevent, or otherwise address fraud or security issues; or (v) protect against harm to our, your, or third parties’ rights, property, or safety. 

 

We may share and disclose de-identified and/or aggregate analytics with third-party partners for the purposes described in this Privacy Policy or where it is collected, or any other legal purpose, including, when and where applicable, sharing and disclosing non-personally identifiable data combined with Personal Data.

CHOICES

Our ability to provide you with the Services through the App depends on the Personal Data and other information you provide to us through the App including your program  attendance, your mood, answers to survey questions relating to outcome measures and related communications, such as your achievements at skills building, social competency, and other related measures of the success of our Services. Please understand that if you choose not to disclose such data and information to us, it will affect your ability to use the App and the Services.  You must discontinue use of the App and our Service if you choose not to disclose the Personal Data.

THIRD PARTY LINKS AND WEBSITES

The App may contain links to third-party services, websites, mobile applications, that are not affiliates with us – and which may link to other websites, services, or applications. While we endeavor to work with third parties that share our respect for user privacy, we are not responsible for the privacy policies or privacy practices of such third parties. Any data collected by third parties are not covered by this Privacy Policy. You are responsible for knowing when you are leaving the App to visit a third-party website, service, or application and for reading and understanding the terms of use and privacy policy statements for each such third party. This Privacy Policy only governs data collected through the Services.

Social Networks

We maintain a presence on social media and other external platforms, such as Facebook, Instagram, LinkedIn and X (Twitter). We may occasionally incorporate third party social networking features into the Services. This Privacy Policy applies to our use of information you submit to us there, but it does not apply to what those third-party platforms do with your information.

The Services may allow you to share information with us that you have already provided to a third-party social networking platform. For example, you may be able to create an account on the Services or log in to the Services using your Facebook account or other third-party credentials. If you do so, Personal Information or other data that you have provided to the third party may be made available to us by that third party subject to its own privacy policy, terms, and conditions. Privacy policies of social networks and other external platforms explain how those third parties use, protect, and share your information, including any information you share on those platforms from the Services, and we encourage you to read them. The information we receive from these platforms may depend on your privacy settings.

We may also include tools in the Services that allow you to share or publicly post content from the Services to your profile on a third-party social network. You may choose to share information about your activities on the Services with such third-party platforms and its users, including publishing your information about what content you may have viewed on the Services. If you visit the Services while logged into certain social media platforms, the social media platform may be able to identify your browser and associate the technical information provided by your web browser with other information that they have already collected about you, which may result in their ability to identify you. In addition, when you choose to share information about your activities on the Services with certain social media platforms, Road Recovery may send technical information about you to that platform as well as information about what content you are viewing.

CHILDREN

The Services are not directed to persons under age 13. We do not knowingly collect Personal Data from children under  age13. Children between the ages of 13 and 17 must provide consent from a parent or legal guardian to access the App and Services. If you become aware that your child is accessing the Services  and providing Personal Data without your consent, please contact us by using the information provided in the Contact Information section below. We will take steps to remove Personal Data from our servers and terminate the account should we determine that a child under 13 has accessed the Services.

CONFIDENTIALITY AND SECURITY

We take the security of your Personal Data seriously and have implemented appropriate technical and organizational measures to protect it from unauthorized access, disclosure, or destruction. While we implement these measures, please note that 100% security is not possible, and we cannot guarantee that the security measures we have in place to safeguard Personal Data will never be defeated or fail, or that those measures will always be sufficient or effective.

UNITED STATES AND INTERNATIONAL CONSUMER RIGHTS

1. California Civil Code Section 1798.83

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact Road Recovery via email at  info@roadrecovery.org

2. Additional U.S. Laws. 

Additionally, there are other state privacy laws such as the California Consumer Privacy Act, as amended from time to time; the Colorado Privacy Act; the Connecticut Data Privacy Act; the Delaware Personal Data Privacy Act; the Indiana Consumer Data Protection Act; the Iowa Consumer Data Protection Act; the Kentucky Consumer Data Protection Act; the Maryland Online Data Privacy Act; the Minnesota Consumer Data Privacy Act; the Montana Consumer Data Privacy Act; the Nebraska Data Privacy Act ; the New Hampshire Expectation of Privacy Act; New Jersey (SB 332); the Oregon Consumer Privacy Act; the Tennessee Information Protection Act; the Texas Data Privacy and Security Act; the Utah Consumer Privacy Act; the Virginia Consumer Data Protection Act; and other state privacy laws as may be enacted upon their effective dates.  Due to the current number of users of Road Recovery, we may not be subject to these privacy laws.  However, customers of these states may reference the above sections of this Privacy Policy for transparency regarding the information we collect and our practices related to such information.  Additionally, customers may request further information relating access, deletion, correction, or limitation of our use of their Personal Information by contacting us as directed in the Contact Us section below.

INTERNATIONAL TRANSFER OF DATA 

The App is hosted in the United States.  If you do not reside in the United States and provide Personal Data to us, please note that your Personal Data will be transferred, processed, collected, used, accessed, and/or stored in the United States, a country and jurisdiction that may not have the same data protection laws or rights as the country in which you reside, and subject to U.S. laws. Please do not provide your Personal Data to us if you do not want this data to be transferred or processed outside of your country, or if the laws in your country restrict such transfers.

RETENTION

When may retain your Personal Data as required by law or for necessary business purposes. We are under no obligation to store such Personal Data indefinitely, and to the extent permitted by law, disclaim any liability arising out of, or related to the destruction of such Personal Data.

CONTACT INFORMATION

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us using the information below:

Email: info@roadrecovery.org