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Privacy Policy

Purpose

To explain how There Is No Hero in Heroin Foundation, Inc. (TiNHiH) collects, uses, discloses, retains, and protects personal information obtained through its website and other online services, and to provide individuals with clear choices and contact methods regarding that information.

Policy

TiNHiH respects the privacy of website visitors, clients, families, donors, volunteers, event participants, applicants, and community members. TiNHiH will collect and use online personal information for legitimate organizational, clinical, charitable, operational, safety, and legal purposes; limit access to persons with an appropriate need; and apply reasonable safeguards based on the nature and sensitivity of the information.

This Online Privacy Policy is separate from TiNHiH’s Notice of Privacy Practices. Protected health information (PHI) created, received, maintained, or transmitted by TiNHiH in its capacity as a health care provider is governed by the Notice of Privacy Practices and applicable health information law. If this policy conflicts with the Notice of Privacy Practices regarding PHI, the Notice of Privacy Practices controls.

Scope

This policy applies to https://tinhih.org and other websites, online forms, donation or payment pages, event-registration tools, memorial-submission features, communications, and online services controlled by or operated for TiNHiH (collectively, the Online Services). It does not control the independent privacy practices of third-party websites, social-media platforms, payment providers, patient portals, or other services reached through a link from the Online Services.

Definitions

  • Personal information means information that identifies, relates to, describes, or can reasonably be linked with an individual or household.
  • Protected health information (PHI) has the meaning assigned by the Health Insurance Portability and Accountability Act (HIPAA) and related regulations.
  • Tracking technologies include cookies, pixels, tags, scripts, software development kits, local storage, and similar technologies that collect information about use of an online service.
  • Service provider means an organization that processes information for TiNHiH to provide hosting, security, analytics, communications, payments, professional services, clinical systems, or another operational function.

Responsibility

The Chief Executive Officer or designee is responsible for approving this policy and designating a Privacy Officer or other responsible person to coordinate implementation, requests, incident response, vendor oversight, and annual review. Website, communications, information technology, clinical, fundraising, and program personnel must ensure that their online practices remain consistent with this policy and applicable law.

Procedures

  1. Information provided directly. Depending on how an individual interacts with TiNHiH, the Online Services may collect a name, mailing address, email address, telephone number, communication preferences, service inquiry, appointment or intake details, event registration, volunteer or employment information, donation or sponsorship details, memorial information and photographs, messages, survey responses, and other information the individual chooses to submit.

  2. Information collected automatically. When an individual uses the Online Services, TiNHiH and its service providers may automatically receive an Internet Protocol address, browser and device type, operating system, language, referring and exit pages, pages viewed, links selected, dates and times of access, approximate location derived from an IP address, and cookie, analytics, advertising, or device identifiers. TiNHiH uses this information to operate, secure, measure, and improve the Online
    Services and communications.

  3. Information received from others. TiNHiH may receive information from payment processors, event or fundraising platforms, referral sources, social-media services, website and analytics providers, clinical or patient-portal vendors, and other persons when permitted by law or directed by the individual. Information obtained from another source will be handled consistently with the purpose for which it was provided and any applicable agreement or legal requirement.

  4. Purposes of use. TiNHiH may use personal information to provide requested information, referrals, programs, or services; respond to inquiries; process and acknowledge donations, payments, registrations, purchases, or sponsorships; manage volunteers, applicants, events, memorials, and community programs; communicate service and organizational updates; operate, personalize, secure, troubleshoot, and improve the Online Services; maintain records; prevent fraud or misuse; protect individuals and TiNHiH; and comply with legal, regulatory, licensing, accreditation, funding, audit, and reporting obligations.

  5. Health information and secure communication. General website forms, ordinary email, text messages, and social-media messages may not be secure and should not be used to send detailed medical, treatment, diagnosis, insurance, or other sensitive information unless TiNHiH specifically directs the individual to an approved secure method. Information submitted through a TiNHiH patient portal, electronic health record, telehealth service, or secure intake process is governed by the Notice of Privacy Practices and applicable consent documents. A website privacy notice or cookie banner is not a HIPAA authorization.

  6. Cookies, analytics, and third-party tracking. The Online Services may use essential cookies, preferences, analytics, embedded content, social-media features, and advertising or campaign- measurement technologies. TiNHiH may use Google Tag Manager, Google Analytics, or comparable services. Depending on which tools are enabled, a third party may collect information about an individual’s online activities over time and across different websites or online services. TiNHiH will not permit a tracking technology to receive PHI unless the disclosure is permitted by HIPAA and any required business associate agreement or authorization is in place.

  7. Cookie and tracking choices. Individuals may use available cookie settings, browser controls, device settings, advertising-industry opt-out tools, or vendor controls to limit certain tracking. Disabling cookies may prevent some features from working correctly. Because there is no uniform standard for all legacy Do Not Track signals, the Online Services may not respond to every such signal. TiNHiH will honor legally required browser-based opt-out preference signals to the extent applicable and technically supported.

  8. Disclosures of information. TiNHiH may disclose personal information to service providers that support hosting, information technology, cybersecurity, analytics, communications, payments, fundraising, events, professional advice, records, clinical systems, and related operations; to government agencies, regulators, courts, law enforcement, funders, auditors, or licensing and accreditation bodies when authorized or required; to protect safety, rights, property, or the integrity of the Online Services; in connection with a lawful organizational transaction; or to another person at the individual’s direction or with appropriate consent. Service providers are expected to use information only for authorized purposes and to apply appropriate safeguards.

  9. Donations, payments, and purchases. Online donations and payments may be processed by card networks, PayPal, merchant processors, fundraising platforms, or other payment providers. Those providers receive payment and transaction information under their own privacy terms and security obligations. TiNHiH generally receives transaction details such as the donor’s name, contact information, amount, date, status, and limited payment information, but does not intentionally retain a complete payment-card number in its general website records.

  10. Memorials and other public submissions. Information, photographs, stories, names, dates, or other content submitted for a memorial, testimonial, event, social-media feature, or other public display may be published and viewed, copied, or shared by others. The person submitting content is responsible for having authority to provide it and for avoiding unnecessary sensitive information. TiNHiH may review, edit for length or safety, decline, or remove public content in its discretion and as permitted by law.

  11. Sale of personal information. TiNHiH does not sell covered information for monetary consideration as ‘sale’ is defined by Nevada law. A Nevada consumer may nevertheless submit a verified request directing TiNHiH not to make a future sale of covered information by emailing info@tinhih.org with the subject line ‘Nevada Privacy Request.’ TiNHiH will authenticate and respond to a verified request within the period required by applicable law.

  12. Individual choices and requests. An individual may request access to or correction of personal information collected through the Online Services, ask that TiNHiH stop certain communications, or request deletion where applicable by contacting TiNHiH as stated below. TiNHiH may need to verify identity and authority before acting and may retain information when required or permitted for treatment, legal compliance, security, fraud prevention, recordkeeping, or another legitimate purpose. Marketing emails may also be stopped by using the unsubscribe link in the message. Rights involving PHI must be exercised under the Notice of Privacy Practices.

  13. Security. TiNHiH maintains reasonable administrative, technical, and physical safeguards designed to protect personal information based on its sensitivity and the risks presented. Measures may include access controls, authentication, encryption where appropriate, vendor oversight, backups, monitoring, and workforce confidentiality requirements. No online transmission, service, or storage system can be guaranteed to be completely secure. Individuals should use secure channels and avoid sending sensitive information through unapproved methods.

  14. Retention. TiNHiH retains personal information only as long as reasonably necessary for the purposes described in this policy and to satisfy clinical, financial, contractual, donor, employment, licensing, accreditation, insurance, tax, litigation-hold, and legal requirements. Retention periods vary by record type. Information is deleted, destroyed, de-identified, or archived with appropriate protections when no longer required, subject to backup-system limitations and TiNHiH record-retention policies.

  15. Children’s privacy. The general Online Services are not directed to children under 13. TiNHiH does not knowingly collect personal information online directly from a child under 13 without verifiable parental consent or another lawful basis. A parent or legal guardian should submit inquiries concerning a child and use TiNHiH’s approved intake process. If TiNHiH learns that personal
    information was collected from a child under 13 contrary to this policy, it will take reasonable steps to delete or properly authorize the information.

  16. External services and links. The Online Services may link to or embed maps, videos, social-media pages, payment services, patient portals, event platforms, public resources, or other third-party services. Those services are governed by their own privacy policies and terms. A link or integration does not mean that TiNHiH controls the third party’s privacy or security practices.

  17. Policy changes. TiNHiH may revise this policy to reflect changes in the Online Services, organizational practices, vendors, or legal requirements. The updated policy will be posted in a reasonably accessible location with a revised effective or review date. When required by law, TiNHiH will provide additional notice or obtain consent before applying a material change to information previously collected.

  18. Contact and requests. Questions, requests, corrections, complaints, or Nevada verified requests may be directed to: Privacy Officer, There Is No Hero in Heroin Foundation, Inc., 3441 W. Sahara Ave, Suite C-1, Las Vegas, NV 89102; email: info@tinhih.org; telephone: (702) 445-7318. To protect privacy, individuals should not include detailed health or financial information in an initial email.

References

  • Health Insurance Portability and Accountability Act and implementing regulations, including 45 C.F.R. Parts 160 and 164.
  •  Nevada Revised Statutes Chapter 603A, including NRS 603A.300 through 603A.360.
  • Children’s Online Privacy Protection Act and 16 C.F.R. Part 312, when applicable.
  • Controlling the Assault of Non-Solicited Pornography and Marketing Act (CAN-SPAM Act), when applicable.