Privacy Policy

Privacy Policy

This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally identifiable information’ (PII) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

What personal information do we collect from the people that visit our blog, website, social media channels or app?

When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address or other details to help you with your experience.

When do we collect information?

We collect information from you when you subscribe to a newsletter, fill out a form, enter information on our site, make a phone call, view pages on our site or engage with our ads on facebook or google. 

How do we use your information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

  • To improve our website in order to better serve you.
  • To allow us to better service you in responding to your customer service requests.
  • To send periodic emails regarding your order or other products and services.
  • To tailor our marketing efforts to those who engage best with our outreach. 

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How do we protect visitor information?

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.

We use regular Malware Scanning.

We use an SSL certificate.

In an effort to protect your privacy and the security of any transmissions through the site we use an SSL certificate provided through Really Simple SSL

Do we use ‘cookies’?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

  • Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.

If you disable cookies off, some features will be disabled. It won’t affect the users experience that make your site experience more efficient and some of our services will not function properly. 

Third Party Disclosure

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Third party links

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Google 

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en

We currently use Google Ads on our site, and so we track behavior on our site when coming to the site from any Google Ads. This information includes page visits, phone calls and form submissions. 

Google Analytics

We have integrated the component Google Analytics (with anonymisation function) on this website.

Google Analytics is a web analytics service. Web analysis is the gathering, collection and analysis of data about the behavior of visitors to websites. Among other things, a web analysis service collects data on which website a data subject has come to a website from (so-called referrers), which subpages of the website were accessed or how often and for which period of time a subpage was viewed. A web analysis is mainly used to optimize a website and for the cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

Google Analytics uses cookies. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. Google might transfer the personal information collected via this technical procedure to third parties.

 As IP anonymization is activated on our website, your IP address will be shortened by Google within Member States of the European Union or other states in agreement with the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by a Google server in the USA. On behalf of the operator of the website, Google will use this information to evaluate your use of the website, compile reports on website activity and to provide further services related to website and internet use to us. The IP address transferred through your browser to Google Analytics will not be combined with other data held by Google.

In addition, this website uses the Analytics feature UserID to track interaction data. This User ID will be additionally anonymized and encrypted and will not be linked with other data.

You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of this website to the fullest extent possible.

In addition, you may prevent the collection of the data generated by the cookie and related to your use of the website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en

This browser add-on informs Google Analytics via JavaScript that no data and information about website visits may be transmitted to Google Analytics.

In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Further information and Google‘s applicable privacy regulations can be found at https://policies.google.com/privacy?hl=en and https://marketingplatform.google.com/about/ The following link provides a further explanation of Google Analytics https://marketingplatform.google.com/about/.

Google Tag Manager

This website uses Google Tag Manager. Through this service so-called website tags can be managed centrally via a user interface. Google Tag Manager only implements tags.No cookies are used and no personal information is collected.

For each third-party data collection, Google will provide a respective privacy policy: https://www.google.com/analytics/tag-manager/use-policy/

However, Google Tag Manager will not access these data. If deactivation has been implemented for certain domains / websites or cookies, it will remain in effect for all tracking tags as far as they are implemented with the Google Tag Manager.

Call Rail- Call Tracking

We use Callrail.com for our dynamic number insertion to determine the effectiveness of our digital marketing. This means that numbers shown on our website, Google My Business and other marketing materials are generated by callrail. You can read the specific data storage policy below. The information collected through these call tracking 

services are not stored long term with third parties and is only shared with us. 

“Collection of Personal Information

CallRail collects the information on the callers that call our business customers through the dedicated phone numbers that our business customers have purchased through CallRail (or numbers our business customers have requested be ported into CallRail from another provider). This information includes: (1) the caller’s phone number, (2) the name displayed on the Caller ID (when available), and other data that may be correlated through your business customer’s data sources (for example, customer data from CRM systems), personal data sources (social contacts, email inboxes, etc, when such express consent is granted through the use of pop up dialogue boxes to prompt for approvals to access to relevant third party data), and third party data services (for example, White Pages, Contactive, FullContact). The data is collected in order to display relevant caller information related to an incoming phone call. With respect to our use of data collected from third party data services, the transmission of such data is encrypted using TLS encryption and all data cached is deleted and is not stored by CallRail for any longer than necessary for business purposes. We do not share this data outside of the application. We may use this data to increase the accuracy of caller information and provide more specific information to our customers regarding the call location, to describe the types of businesses that engage with our clients and to determine call histories for analytics purposes.

We also collect information on client website visitors via our JavaScript. This information includes IP address, User Agent, URLs visited on our client’s website, and other data that may be accessible through the JavaScript code installed on the client’s website. We use various in-house and third-party analytics tools to analyze the activity of our own clients as they use our website and our Products and Services.”

Note that we do not record the content of any calls transferred to our phone lines and so the contents of those calls remain private. We can only tell:

1. That you called 

2. From what number

3. How long the call was

4. Potentially what keywords/searches led you to our site

More information can be found here: https://www.callrail.com/privacy/

Facebook

We follow Facebook’s privacy guidelines which you can read more about here: https://www.facebook.com/policies/ads/

We currently limit our remarketing to Facebook, in that we remarket to Facebook users who visit our site after engaging with our facebook content and following the link included. If you want to avoid this practice, you can directly navigate to our website after seeing our ads. 

We also remarket our Facebook ads to you based on your previous interaction with other ads. If you watch most of one video we may send you a related one. 

In accordance with Facebook’s guidelines we do not discriminate with our ads. “Ads must not discriminate or encourage discrimination against people based on personal attributes such as race, ethnicity, color, national origin, religion, age, sex, sexual orientation, gender identity, family status, disability, medical or genetic condition.” And so we reveal no sensitive medical conditions or personal attributes in our ad text. 

Nor do we use personal attributes in our ad text. “Ads must not contain content that asserts or implies personal attributes. This includes direct or indirect assertions or implications about a person’s race, ethnic origin, religion, beliefs, age, sexual orientation or practices, gender identity, disability, medical condition (including physical or mental health), financial status, membership in a trade union, criminal record, or name.”

Facebook – Facebook Tracking Pixel

With your consent, we will use Facebook’s “tracking pixel”. This pixel can be used to track user behavior after they have been redirected to our website by clicking on a Facebook and / or Instagram ad. This allows us to record the effectiveness of Facebook and Instagram advertisements for statistical and market research purposes and, if necessary, to take optimization measures. The tracking of users who have landed on our website after clicking on one of our Facebook and Instagram ads can remain active up to 180 days.

The data collected in this way is anonymous for us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, about which we will inform you to the best of our knowledge.

Facebook may connect this data to the Facebook account and also use it for its own advertising purposes, according to its data usage policy.

If you want to disable cookie storage for Facebook, you can do so via your browser settings.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA we agree to the following:

  • Users can visit our site anonymously

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Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website.

Our Privacy Policy link includes the word ‘Privacy’, and can be easily be found on the page specified above.

Users will be notified of any privacy policy changes:

      • On our Privacy Policy Page

Users are able to change their personal information:

      • By emailing us

How does our site handle do not track signals?

We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third party behavioral tracking?

It’s also important to note that we allow third party behavioral tracking. That is we do not track or use information found on our website or through third parties based on interests, demographics, remarketing or DCM integrations.

The only exception may be that if you come to our website from one of our facebook ads, we track whether you visited the website, but take no action based on what you viewed, clicked or submitted. 

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under 13.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

  • We will notify the users via email within 7 business days

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

To be in accordance with CANSPAM we agree to the following:

  • If at any time you would like to unsubscribe from receiving future emails, you can email us at and we will promptly remove you from ALL correspondence.

Contacting Us

If there are any questions regarding this privacy policy you may contact us using the information below:

Email us at ben@twincitiesmft.com

Twin Cities Marriage and Family Therapy

250 Prairie Center Drive Suite 202 Eden Prairie MN 55344