Privacy Policy

This Online Privacy Notice applies to the information that we collect when you visit Baton Health's main website (www.batonhealth.us) and other websites that we own or control and link or refer to this Privacy Notice (together, the “Sites”). This Notice describes how this information is processed, as well as the choices that are available to you regarding the use of the information you provide.

Unless otherwise indicated on a specific Site, Baton Health (Baton) is the data controller for all information collected under this Notice. Contact information for Baton is listed at the end of this Notice.

This Notice does not apply to information collected from or about current or former employees, contractors, volunteers, clients, and other workers of Baton Health as part of their employment or working relationship with Baton.

Personal Information we collect and process:

When you access or use the Sites, we may collect and process the following types of information from you:

“Personal Information” is any information that we can reasonably use to identify you. If you are located in the European Economic Area (EEA), Personal Information includes all Personal Data as defined under EEA laws.

“Sensitive Personal Information” includes special categories of Personal Information (e.g., racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health, and data concerning a natural person’s sex life or sexual orientation) for which applicable law provides enhanced protections.

The information below describes the Personal Information and Sensitive Personal Information that we collect, why we collect it, and our legal basis for processing it.

Categories of Personal Information

Legal Basis

As part of the student and client process, we collect applicant Personal Information to evaluate applications for readiness. We also may obtain Personal Information from third parties, such as other schools, references, family or community members, and education partners as part of an application package.

Name, address, contact details, race/ethnicity, demographic information, educational history, reference letters, and other relevant information as part of the application package.

Legitimate Interest: Personal Information collected through the student enrollment or client consulting inquiry is necessary to evaluate readiness of participants, students, or clients for certain courses, consulting supports, and for our internal statistical and analytics purposes.

Consent: Processing of Sensitive Personal Information for purposes stated above to evaluate and determine whether financial aid opportunities or need for sponsorship are available to an applicant.

Name, address, contact details, demographic information, salary history, tax forms and other relevant information to evaluate financial aid eligibility and opportunities.

Legitimate Interest: Personal Information collected through the financial aid application is necessary to evaluate whether the applicant (individual student, group, or school) is eligible to receive financial aid and for our internal statistical and analytics purposes.

Consent: Processing of Sensitive Personal Information for purposes stated above to support course registration

Name, Baton Unique ID, contact information

Legitimate Interest: Personal Information collected for students, staff, faculty and members of the public, as appropriate for the course, to register in courses or classes to process requests for special services

Name, Baton Unique ID, contact information

Legitimate Interest: To provide online/hybrid training, online/hybrid academic courses, and other online/hybrid educational programs

Name, Baton unique ID, contact information, demographic information, platform usage and interaction, student-provided data and content

Legitimate Interest: To facilitate provision, administration, instruction, and quality improvement of platform use, courses, learning, and teaching/instruction to matriculated students, staff, faculty, and members of the public, as appropriate for the course. To enroll interested individuals in educational opportunities Name, contact information

Legitimate Interest: Upon request from the individual, inform registrants about research opportunities

To enroll in wellness programs

Name, Baton Unique ID

Legitimate Interest: For eligible individuals interested in participating in a variety of wellness programs, courses, activities, facilitate enrollment and communications about the programs

Contract: If there is a contract for participation in wellness programs, Personal Information is processed pursuant to that contract to process employment applications 

Name, Baton Unique ID (if available), demographic information, resumes

Legitimate Interest: For individuals interested in employment opportunities, processing applications to process visa applications

Name, demographic information, financial information, passport number

Legal Requirements to request and receive donations, and assess donor and prospective donor giving activities

Name, contact information, demographic and biographic information, affiliation to Baton Health, giving history, payment information

Legitimate Interest: To collect and process donations/gifts and donor and prospective donor information to receive brochures or other information

Name, contact information

Legitimate Interest: To send brochures or other requested information to purchase tickets to events

Name, Baton Unique ID (if available), contact information

Contract: To process ticket payment for a variety of events for event registration

Name, Baton Unique ID (if available), contact information

Legitimate Interest: To process registration for sports, cultural, educational and other Baton Health events

Name, Baton Unique ID, contact information

Contract: To submit requests for services (e.g., IT, help desk, help line, etc.)

Name, Baton Unique ID, contact information

Legitimate Interest: To process service requests from students, staff and faculty

Contract: If there is a contract that governs your use of such services, Personal Information is processed pursuant to that contract

Website account registration

Name, contact information, alumni or Baton Health Certified status

Legitimate Interest: For websites that require registration for access, to facilitate the registration

Travel sites

Name, Baton Unique ID, contact information, passport number, loyalty membership information, emergency contacts

Legitimate Interest: To facilitate travel arrangements and coordination for students and affiliated travelers through Baton Health programs

Contract: If there is a contract that governs your use of travel sites, Personal Information is processed pursuant to that contract

Cookie Policy

This Cookie Policy applies to the cookies we use when you visit Baton Health’s main website (batonhealth.us) and other websites that we own or control and link or refer to this Cookie Policy (together, the “Sites”).

This cookie policy provides you with more information about cookies, what types of cookies we use and how we use them. Our Sites use cookies with the intention of providing you with a user experience that best suits your needs, while concurrently allowing us to improve the design and functionality of our Sites. Cookies can be adjusted or disabled, and this policy provides you with instructions to do so.

Cookies

A cookie is a file designed to contain a small amount of user and website information stored on a user’s computer. The file interacts with the user and the website to provide a webpage tailored to the user through its awareness of information held within the file. Cookies also have the ability to carry all or parts of the information stored within the file to other websites that the user may visit or to third parties.

Types of Cookies

A third-party cookie is placed by a domain other than that of the website the user is visiting.

A session cookie is temporary, linking the actions of a user during the any given browser session. When the browser is closed, the cookie is deleted.

A permanent cookie, also known as a persistent cookie, is stored for a specific period of time and activates each time the user visits the website that created the cookie.

Our Use of Cookies

We may use third-party, session and persistent cookies and similar technology to collect aggregate (non-personal) information about Sites usage by all of our visitors and to help us remember you and your preferences when you revisit the Sites. These cookies may stay on your browser into the future until they expire or you delete them. We also use technology to remember you the next time you log in. Some of these cookies are erased when you close your browser window and some persist for a period of time. Further general information about cookies and how they work is available at www.allaboutcookies.org.

We may allow selected third parties to place cookies through the Sites to provide us with better insights into the use of the Sites or user demographics or to provide relevant advertising to you. These third parties may collect information about a user’s online activities over time and across different websites when he or she uses our Sites.

The cookies used on our Sites may include, but are not limited to, the following:

Description

Cookie Name Category

These cookies expire when the browser is closed. The purpose of these cookies is to temporarily retain information related to the user’s visit to a Site, such as the number of visits, average time spent on the Site, and what pages have been loaded._atrfs _lorid __lotl _lo_u AWSELBBIGipServerab15web-app_https cas_user cas_cookie_test2 CMDD CMPS CMRUM3 CMSCCMST gig_hasGmid gsbBaton Health_1_init pgn_new_browser pgn_rta2 remote_sidrequests rlas3 su-homesite-show-alert symfony TS0115db8a TS01e902afTS01fc008b TS01ba2ef2 TS015271e5 lo_session_in nextId ma_hashUserMatchHistory xtc YSC

Session

These cookies remain in operation, even when the browser is closed. The purpose of these cookies is to retain information to help the user avoid retyping data.cas_perm2 pgn_user2 webauth_atWMDsecureLogin

Permanent Third parties install these cookies to collect certain information for statistical purposes and conducting research into behavior, demographics, and similar topics about our users.__atuvc __atuvs__cfduid __gads _gig_llp _gig_llu APISID AWSALB Blaze DSID DVFormSpringFormSession21642262 FormSpringFormView214262 fr gmid hasGmid HSIDlang LOGIN_INFO metrics_token PHPSESSID PREF SAPISID SID SSID tfw_exp ucid uvcVISITOR_INFO1_LIVE

Third-party

These cookies help us understand how our visitors engage with our Sites. These cookies collect information and report website usage statistics. Some of these cookies are used to see how people use our Sites, which helps us improve it.__adroll __ar_v4 __gat_Destiny _A_time _ceg.s _ceg.u _ceir _gat_gat_exec _gat_rollUpTracker _gat_UA-17324310-1 _gat_UA-5950986-19_gd_svisitor _gd_visitor _gid _ivu _litra_id.dc12 _unam _utma _utmc _utmt_utmv _utmz _uuid AMCV_ bcookie buid_1038693605 buid_1830491566buid_2015930208 buid_692015568 buid_741299734 C3UID C3UID-312 cto_lwiddemdex dextp dpm DST DSTJS gpv_pn JSESSIONID mbox MentAdUserID s_cc s_fids_invisit s_lv s_lv_s s_nr s_ppv s_ppvl s_vnum sess t_gid uuid2

Analytics

These cookies allow our Sites to remember information that changes the way the site behaves or looks for you, such as your preferred language or the region you are in. For instance, by remembering your region, a website may be able to provide you with local weather reports or traffic news. These cookies can also assist you in changing text size, font, and other parts of web pages that you can personalize. Loss of the information stored in a preference cookie may make the website experience less functional but should not prevent it from working.has_js khaos put_2760 put_3644 rpb tuuid tuuid_last_updateDrupal.tableDrag.showWeight

Preferences

We use security cookies to authenticate users, prevent fraudulent use of login credentials, and protect user data from unauthorized parties. Some of these cookies may collect the request made by your browser to the server hosting the website which includes the IP address, the date and time of connection and the page you ask for. We use this information to ensure the security of our Sites.

Some of these cookies help make the Sites work and deliver services that the website visitor expects, like navigating around web pages or accessing secure areas of the website. Without these cookies, the Sites cannot function properly.

ajs_group_id ajs_user_id atlassian.xsrf.token cloud.session.tokenHTML_VisitCountCookie SimpleSAMLAuthToken SimpleSAMLSessionID

Security

We use cookies to make advertising more engaging to users and more valuable to publishers and advertisers. Some common applications of these cookies are to select advertising based on what’s relevant to a user; to improve reporting on campaign performance; and, to avoid showing ads the user has already seen.

We use cookies like NID and SID to help customize ads on Google websites and other online properties, like Google Search. Some uses include remembering your most recent searches, your previous interactions with an advertiser’s ads or search results, and your visits to an advertiser’s website. This helps us to show you customized ads.

_#sess _#srchist _#uid _#vdf __atuvc __gads __sonar _ct_rmm _ga 1P_JAR anjAPID BizoID bku c Doubleclick (IDE) IDE IDSYNC KRTBCOOKIE_10 lidc loc musna_id na_tc NID pgn_eventId pgn_tparty pgnData PUBMDCID PugT rpx ssc ssh sshstaboola_usg uid uvccas_perm Advertising

Adjusting Cookie Settings

You can change your cookie settings by reviewing your internet browser’s cookie options. The links below to popular browsers may help you understand your cookie options better. Typically, such information can be found under the browser’s ‘Help’, ‘Preferences’ or ‘Options’ menus.

·  Cookie settings in Chrome

·  Cookie settings in Firefox

·  Cookie settings in Internet Explorer

·  Cookie settings in Safari – iOS

·  Cookie settings in Safari – macOS

Blocking Cookies

Should you choose to decline or block cookies by adjusting your browser settings, including cookies essential to the Sites.  Please note that all or parts of our Sites may not be functional or accessible to you. Our Sites will issue cookies as soon you visit the Sites, unless your browser cookie settings are adjusted to prevent such an occurrence. Please review the information provided in this cookie policy on adjusting cookie settings for the browser of your choice.

Google Analytics

In the future, we may use Google Analytics to help operate our Sites more efficiently, to gather demographic information, and to monitor the level of activity of our Sites. For information on how Google uses data from sites that share information with Google, see https://www.google.com/policies/privacy/partners/ (or other relevant URL that Google may provide from time to time). You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing the browser plugin available at this link: https://tools.google.com/dlpage/gaoptout?hl=en.

Sharing your Personal Information

Baton Health  will not share or sell any personal information to third parties for their use in direct marketing, advertising, or promotion of their products or services.

International Transfer of Personal Information

Personal information provided to us by users outside of the United States may be transferred to other countries such as the United States, where data protection laws may differ from those of your home country. By providing us with your information you acknowledge that your information will be transferred to the U.S. and processed on servers in the U.S. However, all reasonable steps will be taken to protect your privacy in accordance with the applicable data protection laws.

Non-personally identifiable information we collect and process

Standard, non-personally identifiable internet log information such as browser type and navigation to various parts of the Sites, in an aggregated form, is collected for analytical purposes to improve the browsing experience of our Sites, update relevant content and improve the overall design.

Information security

Baton Health takes the security of your personal information seriously. 

Marketing

Personal Information you submit through our Sites, such as your name, address and other contact information, may be collected by Baton Health for internal marketing and development purposes as well as to respond to your inquiry, complete a transaction for you, or fulfill other forms of customer service. You can choose not to receive marketing from us by “unsubscribing” using the instructions in any marketing email you receive from us.

EEA Data Subject Rights

If you are an individual located in the EEA only, you will have the following rights with regard to your Personal Data:

1.  Right of access You may request details of your Personal Information that we hold. We will confirm whether we are processing your Personal Information and we will disclose supplementary information including the categories of Personal Information, the sources from which it originated, the purpose and legal basis for the processing, the expected retention period, and the safeguards regarding Personal Information transfers to non-EEA countries, subject to the limitations set out in applicable statutes, regulations and other laws.

2.  Right of correction We will comply with your request to edit and update incorrect Personal Information promptly.

3.  Right to be forgotten At your request, we will delete your Personal Information promptly if:

o  it is no longer necessary to retain your Personal Information;

o  you withdraw the consent which formed the basis of your Personal Information processing;

o  you object to the processing of your Personal Information and there are no overriding legitimate grounds for such processing;

o  the Personal Information was processed illegally; or

o  the Personal Information must be deleted for us to comply with our legal obligations.

o  We will inform any third parties we might have shared your Personal Information with of your deletion request. We will decline your request for deletion if processing of your Personal Information is necessary: 

o  to comply with our legal obligations;

o  in pursuit of a legal action;

o  to detect and monitor fraud; or

o  for the performance of a task in the public interest.

1.  Right to restrict processing of your Personal Information At your request, we will limit the processing of your Personal Information if:

o  you dispute the accuracy of your Personal Information;

o  your Personal Information was processed unlawfully and you request a limitation on processing, rather than the deletion of your Personal Information;

o  we no longer need to process your Personal Information, but you require your Personal Information in connection with a legal claim; or

o  you object to the processing pending verification as to whether an overriding legitimate ground for such processing exists.

1.  Right to notice related to correction, deletion, and limitation on processing In so far as it is practicable, we will notify you of any correction, deletion, and/or limitation on processing of your Personal Information.

2.  Right to data portability At your request, we will provide you free of charge with your Personal Information in a structured, commonly used and machine readable format, if: (i) you provided us with Personal Information; (ii) the processing of your Personal Information is based on your consent or required for the performance of a contract; or (iii) the processing is carried out by automated means.

3.  Right to object Where we process your Personal Information based upon our legitimate interest then you have the right to object to this processing.

4.  Right not to be subject to decisions based solely on automated processing You will not be subject to decisions with a legal or similarly significant effect (including profiling) that are based solely on the automated processing of your Personal Information, unless you have given us your explicit consent or where they are necessary for a contract with us.

5.  Right to withdraw consent You have the right to withdraw any consent you may have previously given us at any time. If you withdraw your consent, this will not affect the lawfulness of our collecting, using and sharing of your Personal Information up to the point in time that you withdraw your consent. Even if you withdraw your consent, we may still use your information that has been fully anonymized and does not personally identify you.

If you wish to contact us in connection with the exercise of your rights listed above, please email us at info@batonhealth.us.  We will respond to your written request without unreasonable delay. 

Access and Choice

You can choose not to receive emails from us by “unsubscribing” using the instructions in any email you receive from us. This will not stop us from sending emails about your account or your transactions with us.

Document Retention

We keep your Personal Information for as long as needed to fulfill the particular purpose for which it was collected. We may also retain your records if legally required or to fulfill a legitimate interest.

Updates to Privacy Policy

Baton Health reserves the right to modify this Privacy Notice at any time. Prior to changes to the Privacy Notice, we will provide you notice, which shall be available at Batonhealth.us/privacy, prior to the effective date of any notice. Your continued use of the Sites after any change in this Privacy Policy will constitute your acceptance of such change.

Contact Information

For more information on how we collect and process your Personal Information, or if you have any complaints please contact info@batonhealth.us. 

Effective Date

The effective date of this policy is January 25, 2022.

Privacy Policy adopted from Stanford University