Last Updated: August 22, 2023

This PRIVACY NOTICE IS FOR CONNECTICUT RESIDENTS and applies solely to visitors, users, and others who reside in the State of Connecticut (“consumers” or “you”). We adopt this notice to comply with the Connecticut Personal Data Privacy and Online Monitoring Act (“CTDPA”). In this Privacy Notice, we explain how we collect and use personal information relating to your use of our services, including our website, https://finhealthnetwork.org/ (the “Website”).  When you interact with our Website, you agree that your personal information will be handled as described in this Policy and our general Privacy Policy.  To fully understand our collection and use of personal information, and your rights, please review both this notice and our Privacy Policy. Any terms defined in the CTDPA have the same meaning when used in this notice.

Pursuant to the CTDPA, below are the following additional details regarding the collection, use, and disclosure of personal information about Connecticut residents.

• Categories of Personal Information Collected: in the preceding 12 months, the Company has collected the following categories of personal information:

Identifiers	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.
Personal information categories	A 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. Some personal information included in this category may overlap with other categories
Sensitive Data, as defined in Conn. Gen. Stat. Ann. § 42-515(27)	Personal data revealing racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship or immigration status. Genetic or biometric data processed to uniquely identify an individual. Personal data collected from a known child. Precise geolocation data.
Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

• Categories of Sources of Personal Information: The Company may have collected the above categories of personal information from:
  • Directly from clients or their agents. For example, from documents that clients provide to the Company related to the services for which they engage us.
  • Indirectly from clients or their agents. For example, through information we collect from our clients in the court of providing services to them.
  • Directly or indirectly from activity on the Website. For example, from submissions through the Website portal or Website usage detailed collected automatically.
  • From third parties that interact with the Company in connection with the services the Company performs.
• Business or Commercial Purpose for Collecting and Using Data: The Company has collected the above categories of personal information for the following business purposes:
  • To fulfill or meet the reason for which the information is provided. For example, if you share your name and contact information to request pricing information or ask a question about our products or services, we will use that personal information to respond to your inquiry.
  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To improve the Website and present its contents to you.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CTDPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
• Categories of Personal Information Disclosed: In the preceding 12 months, the Company has disclosed the following categories of personal information for business or commercial purposes:
  • Identifiers.
  • Personal information categories.
  • Protected classification characteristics under Connecticut or federal law.
• Categories of Third Parties with Whom We Share Personal Information:
  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agent authorize us to disclose your personal information in connection with products or services we provide to you.
• Sale of Personal Information: In the preceding 12 months, we have not sold any personal information.

Your Rights as a Connecticut Resident. The CTDPA provides Connecticut residents with specific rights regarding personal information. Those privacy rights include the following:

• Right to Access. You have the right to request that we disclose certain information to you about our collection and use of your personal information. The right does not apply if the confirmation or access requires the Company to reveal a trade secret. Those rights include:
  • Confirming whether we process your personal data.
  • Accessing your personal data.
• Right to Correct. You have the right to correct inaccuracies in your personal data, considering the personal data’s nature and the processing purposes.
• Right to Delete. You have the right to request that we correct inaccuracies in or delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
  • Comply with legal obligations
  • Provide a product or service that you specifically requested, perform a contract with you, including fulfilling the terms of a written warranty, and to take steps at your request before entering into a contract.
  • Protect an interest essential for the consumer or another individual’s life or physical safety when the entity cannot clearly rely on another legal processing basis and to process personal data for the public interest in the area of public health, community health, or population health, subject to suitable safeguard measures and under a professional subject to confidentiality obligations.
  • Prevent, detect, protect against, respond to security incidents, identify theft, fraud, harassment, malicious or deceptive activities, or any illegal activity, preserve the integrity of security systems, and to investigate, report, or prosecute any parties responsible for those actions.
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • For any other reason permitted by the CTDPA
• Right to Data Portability. You have the right to request a copy of your data in a format that is portable and readily usable so that you may transmit the data to another controller without hinderance, to the extent technically feasible, whenever the processing is carried out by automated means.
• Right to Confirm. You have the right to confirm whether we are processing your personal data unless the confirmation would require us to reveal a trade secret.
• Right to Opt-out. You have the right to opt out of the processing of personal data for the purposes of targeted advertising, the sale of personal data, or profiling in further of decisions that produce legal or similarly significant effects concerning the consumer.
• Non-Discrimination. The right to be free from discriminatory treatment relating to the exercise of any of your privacy rights conferred by the CTDPA. Unless permitted by the CTDPA, we will not:
  • Deny you goods or service.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services of a different level or quality of goods or services.

Exercising Your Rights. Connecticut residents, and their authorized agents on their behalf, may exercise their rights by contacting us at:

Financial Health Network
135 S. LaSalle Street, Suite 2125
Chicago, IL 60603
312.881.5856

Submitting a Request. Only you may make a verifiable consumer request related to your personal information. If you are the parent or legal guardian of a child, you may make a verifiable consumer request related to the personal information of that child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

Response Timing and Format. We will confirm receipt of your request within 10 business days. We endeavor to substantively respond to a verifiable consumer request with 45 days of its receipt. If we require more time (up to 45 more days), we will inform you of the reason and extension period in writing.

• If you have an account with us, we will deliver our response to you via that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
• Disclosures will only cover the 12-month period preceding our receipt of your request. The response provided will also explain the reason we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Changes to Our Privacy Notice. We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on the Website homepage. If this policy is revised, we will update the date at the top of this notice to reflect when such update occurred.

Contact Information. If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under Connecticut law, please do not hesitate to contact us at:

Financial Health Network
135 S. LaSalle Street, Suite 2125
Chicago, IL 60603
312.881.5856