Most Recent Update: June 12, 2023

This PRIVACY NOTICE FOR VIRGINIA RESIDENTS and applies solely to visitors, users, and others who reside in the Commonwealth of Virginia (“consumers” or “you”). We adopt this notice to comply with the Virginia Consumer Data Protection Act (“VCDPA”) and other Virginia privacy laws. 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 VCDPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
A. 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.	YES
B. 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.	YES
C. Sensitive Data, as defined in Va. Code Ann. § 59.1-575	“1. Personal data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status; 2. The processing of genetic or biometric data for the purpose of uniquely identifying a natural person; 3. The personal data collected from a known child; or 4. Precise geolocation data.” Va. Code Ann. § 59.1-575	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

 

 Personal information does not include:

• • Publicly available information from government records.

• • De-identified or aggregated consumer information.

• • Information excluded from the VCDPA’s scope, like:

• • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and other relevant federal and state laws, or clinical trial data; and

• • personal information covered by certain federal and state sector-specific privacy laws, including but not limited to, the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• • Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.

• • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.

• • Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically.

• • From third parties that interact with us in connection with the services we perform.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of 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 our 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.

• • 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.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information internally in furtherance of the purposes described above. 

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: Personal information categories.

Category C: Sensitive Data as defined under Virginia law and protected classification characteristics under Virginia or federal law.

We disclose your personal information for a business purpose to the following categories of third parties:

• • Our affiliates.

• • Service providers.

• • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information. You have the right to opt-out of the sale of your personal information. You can learn more about exercising this right below. 

Your Rights and Choices

The VCDPA provides Virginia residents with specific rights regarding their personal information. This section describes your VCDPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• • Whether we are processing personal data about you.
  • The categories of personal information we collected about you.

• • The categories of sources for the personal information we collected about you.

• • Our business or commercial purpose for collecting or selling that personal information.

• • The categories of third parties with whom we share that personal information.

• • The specific pieces of personal information we collected about you (also called a data portability request).

Correction and Deletion Request Rights

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:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. 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.
6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
7. Comply with a legal obligation.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

The above list is not exhaustive, and we may deny your request for any reason permitted by the VCDPA. 

Opt-out Rights

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. 

Exercising Access, Data Portability, Correction, Deletion, and Opt-out Rights

To exercise the access, portability, correction, deletion, or opt-out rights described above, please submit a verifiable consumer request to us by email at privacy@finhealthnetwork.org or by mail to the following address:

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

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 or an authorized representative of the person we collected personal information on.

• • 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 endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days total from day of receipt), we will inform you of the reason and extension period in writing within the initial 45 day period.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons 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.  In addition, we do not charge for a customer’s first two data requests, unless excessive, repetitive, or manifestly unfounded, in any given year, but VCDPA allows us to charge for responding to more than two data requests per year per customer.  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.

Appeal Rights 

To appeal our response to your consumer request, please email info@finhealthnetwork.org. 

Non-Discrimination

We will not discriminate against you for exercising any of your VCDPA rights. Unless permitted by the VCDPA, we will not:

• • Deny you goods or services.

• • 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 or a different level or quality of goods or services.

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 our website homepage.

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 Virginia law, please do not hesitate to contact us at:

Financial Health Network
135 S. LaSalle Street, Suite 2125
Chicago, IL 60603
312.881.5856
info@finhealthnetwork.org