Privacy Policy Pertaining to the Use of SmartStartModoc.org

 

OVERVIEW

First 5 Modoc (Modoc County Children and Families Commission) respects your privacy and is committed to protecting your personal information. Persons may search our resource website (smartstartmodoc.org) to learn about local resources available to Modoc County residents who are pregnant or who have children birth through age 5, without entering or sharing any personal information.  

 

SmartStartModoc.org s an electronic referral system, online site designed to match interested persons with service providers by collecting needed data to determine eligibility and, depending upon the provider, provide the opportunity for site Users to self-refer and share their eligibility data with outside providers.

 

In this Privacy Policy Statement (“Policy”), we describe the information that we collect from visitors to our Site (SmartStartModoc.org). This Policy governs the use of our Site, as well as services offered through this Site (collectively, “Services”). Your use of our Site or the Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. This Policy is incorporated by reference to the Terms of Service of our Site. This Website and the Services are designed for persons in the United States, specifically for residents of Modoc County, California.

 

What Information Do We Collect from You and How Do We Use Your Information? 

Service Providers across Modoc County who participate in the Smart Start Modoc Collective shared their intake forms and eligibility criteria with First 5 Modoc in order to create the data fields listed on our Site for parents/expectant parents and their dependents. Below are listed the personal data fields for parents/expectant parents which are collected and the reason for collecting each.

 

Name

To deduplicate data entries in the site

Date of Birth

To determine eligibility for services that are age related

Email Address

To provide a way for service providers to contact Users if they opt-in to their program, and to provide First 5 Modoc a way to contact Users for feedback on Site experience

Zip Code

To determine eligibility for services that require Modoc County residency.

Race/Ethnicity

To determine eligibility for services that may be limited to a specific race/ethnicity, e.g. Tribal Home Visiting 

Gender

To determine eligibility for services that may be for specific genders, e.g. Moms-only or Dads-only

Disability Status

To determine eligibility for services that may be specifically available to the disabled.

Number of People Living in Household

To be used in conjunction with income to determine income eligibility for programs/services.

Pregnancy Status

To determine eligibility for services available to those who are pregnant.

Employment Status

To determine eligibility for services available to those who are unemployed or are students. 

Monthly Household Income

To be used in conjunction with number of people living in household to determine income eligibility for programs/services.

Housing Status

To determine eligibility for services available to those who are homeless or housing insecure.

Medi-Cal Enrollment Status

To determine eligibility for services available to those enrolled in Medi-Cal

TANF/CALWorks Enrollment Status

To determine eligibility for services available to those enrolled in TANF/CALWorks

CALFresh/Food Stamp Enrollment Status

To determine eligibility for services available to those enrolled in CALFresh

Request for Information about Quitting Smoking

To provide relevant information and service information to those answering yes.

Request for Information About Health Effects of Second/Third-Hand Smoke and Vaping

To provide relevant information and service information to those answering yes.

 

Below are listed the personal data fields for dependents which are collected and the reason for collecting each.

 

Name

To deduplicate data entries in the site

Date of Birth

To determine eligibility for services that are age related

Child’s Age

To determine eligibility for programs and services that are age-based (Preschool, for example)

Race/Ethnicity

To determine eligibility for services that may be limited to a specific race/ethnicity, e.g. Tribal Home Visiting 

Disability Status

To determine eligibility for services that may be specifically available to the disabled.

Need for Medical Appointments Out of County 

To determine eligibility for medical transportation services and funding.

Need for Child Care

To provide relevant information and service information to those answering yes.

Preschool Enrollment

To provide relevant information and service information to those answering no. 

 

Information We Collect Through Your Use of Our Website

We use cookies and other tracking technologies to automatically collect information about you when you visit our Website or use our Services. Specifically, we may collect the following information: your IP address, browser type, domain name, operating system, date, and time of visit, referring website, time spent on and/or logged in to the Website, and pages viewed. Please see the section below entitled “Cookies & Other Tracking Technologies” for additional information.

 

Use of Your Information

We use your information primarily to determine eligibility for available programs and services benefitting children prenatally through age five and their families. We also may use your information to assist us in maintaining our Website, such as for troubleshooting and technical support purposes, and to improve our Website and Services and to better understand how users access and use our Website and Services, on an aggregated and individualized basis.

We also may use aggregate information to assist us in determining services needed to add to our Website.

 

Sharing Your Information

We share your information at your direction; with the limited exceptions discussed below, we do not share your information with third parties unless you agree in advance. We will not share your personal information under any circumstance with any third parties for their direct marketing purposes. In this section, we describe the potential uses of your information in greater detail:

 

With Third Parties That Provide Benefits:  As stated above, we primarily share your information, including your personal information, with the third parties that provide the Services that you would like to receive. Specifically, at your direction, we will submit your data to the appropriate third parties. The third party, not First 5 Modoc County, will evaluate your eligibility to obtain service from its program. The third party’s use of your personal information will be governed by the third party’s privacy policy. First 5 Modoc County does not have any control over your information once it is submitted to a third party for receipt of Services. ALTHOUGH WE SHARE INFORMATION WITH THIRD PARTIES AT YOUR DIRECTION, WE ARE NOT RESPONSIBLE FOR THE ACTS AND OMISSIONS OF THIRD PARTIES.

 

To Perform Services on Our Behalf: We may hire vendor companies to provide limited services on our behalf, such as website hosting, program evaluation, and providing technical support. We only provide those service providers with the information necessary to perform the requested service.

 

Consolidation of Company: If we are acquired by or merged with another organization, if substantially all of our assets are transferred to another organization, we may transfer the information we have collected from you to the other organization.

 

To Protect Ourselves/For Legal Purposes: We also may disclose your information to protect our rights and property, to prevent against fraud and abuse, and to protect other users of our services. For example, if we believe that you are misusing our Website or taking an action that is harming our Website (e.g., uploading a virus to our Website), we may share your information with law enforcement to protect our Services. We also may disclose your information as permitted or required by law, for example, in response to court orders, subpoenas, or other requests from government agencies.

 

Cookies & Other Tracking Technologies

We and our third party service providers use cookies and other tracking mechanisms to track information about your use of our Website or Services. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf).

 

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).

  • When you come to the Website, our web server sends a cookie to your computer. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. There are two types of cookies: session-based and persistent-based cookies. We also may permit certain third party cookies to be placed on our Website.  

  • Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you while you are logged into the Website. This allows us to process your online requests as you move through our Website.

  • Persistent cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We may use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information.

 

Third Party Analytics. We may use automated devices and applications, such as Google Analytics, to evaluate usage of our Website. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties. We do not have access to or control over these third party cookies nor does this Privacy Policy cover such third parties’ use of data.  You may be able to opt-out or restrict the collection or use of information by some commonly used tracking pixels and services. The following links are provided for your convenience:

  • Google Analytics – https://tools.google.com/dlpage/gaoptout/

  • Facebook Pixel – https://www.facebook.com/settings?tab=ads

  • Bing Pixel – https://choice.microsoft.com/en-US/opt-out

 

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Website visitors who disable their web browsers’ ability to accept cookies will be able to browse the Website; however, you must enable cookies to use most of our Services.

 

Opting Out of Communications

Email. We may send you email about topics and opportunities that we believe may be of interest to you. At any time, you may unsubscribe from our emails by responding to any email from First 5 Modoc with a request to unsubscribe. 

Phone. If you no longer wish to receive information from us, please email info@first5modoc.org

We want the information that you submit to us to be secure. We use industry-standard techniques to safeguard the information that you provide to us through our Website. Notwithstanding our commitment to your information, please be aware that there is a risk that others could find a way to thwart our security systems or the security systems of the third parties that host our server. As a result, we cannot ensure or warrant the security or privacy of any information that you choose to submit to us. 

You should take steps to protect against unauthorized access to your phone and computer by, among other things, signing off after using a shared computer, choosing robust passwords that nobody else knows or can easily guess, and keeping your log-ins and passwords private.

 

Children’s Privacy

Our Website is not intended for persons under the age of 13, and we do not knowingly collect information from persons under the age of 13. If we learn that a person under the age of 13 has created an account or directly applied for programs through our Website, then we will remove that information from our systems. Please be advised, however, that certain programs offered by third parties may be applicable to persons under the age of 13 or may require us to provide information about the children in your household. In those situations, we only collect information about persons under the age of 13 directly from the registered user, which must be a person over the age of 13.

 

Your California Privacy Rights

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. 

We have collected and shared the following categories of personal information under the CCPA within the past 12 months, as more fully described above;

  • A. Identifiers;

  • B. Personal information categories listed in the California Customer records statute;

  • C. Protected classification characteristics under California or federal law;

  • D. Commercial information;

  • F.  Internet or other similar network activity.

You also have the right to request that we disclose certain information to you or take other actions concerning your personal information, including:

  • The right to know the personal information collected about you, including the right to receive it in a data portable format;

  • The right to opt-out of the sale of your personal information, although we currently do not sell your personal information and thus do not offer the right to opt-out;

  • The right of deletion of your personal information, subject to certain limitations under applicable law;

  • The right not to be discriminated against for individuals who choose to exercise any of their rights under the CCPA.

To exercise these rights, please submit a request by emailing info@first5modoc.org, including your email address and phone number. Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. If we need additional information to verify your identity, we will let you know. We will respond to your request within 45 days of receipt, or notify you if we require additional time.

 

If you would prefer, you may designate an authorized agent to make a request on your behalf.

 If you are a California resident under the age of 18, and a registered user of any website where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an e-mail with a detailed description of the specific content or information to info@first5modoc.org. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

 

Changes to this Privacy Policy

We will post changes to this Policy to this Website. Changes will become effective upon posting. If we make a material change to this Policy, we will endeavor to notify our Users by highlighting the change upon posting and sending an email to our account holders at the most current email address.

 

Contact Us

Please contact us at info@first5modoc.org if you have any questions regarding this Policy.
Last Revised: Sept 21. 2022

 

General Information from First 5 Modoc’s Adopted Data Confidentiality and Sharing Policies and Procedures

 

First 5 Modoc owns and oversees the platform and data for the Smart Start Modoc Collective’s SmartStartModoc.org website. Data is collected by First 5 Modoc for the following purposes: (1) to meet the annual statewide reporting requirements of First 5 California; (2) to meet the legislative requirements for evaluation of programs funded with tobacco tax funds; (3) to meet specific funder requirements; and (4) to guide contract management and future local granting decisions.

 

The following procedures shall be followed regarding data collection, reporting, input, and storage.

  1. DATA COLLECTION

When data is collected from Site users by First 5 Modoc: 

  • Users will be made aware of the purpose of the data collection and its intended use either in the Terms & Conditions of the Site.

  • Users will have the option to opt-in to share their data with specific Community Based Organizations (CBOs) for whose services/programs they qualify. To be made aware of the data confidentiality policy or policies adopted by the agencies who will receive the data, Users will have to contact those CBOs directly. 

User permission for First 5 Modoc to collect data according to these policies is given implicitly by the User’s decision to enter the data into the SmartStartModoc.org Site.

 

  1. PERSONALLY IDENTIFIABLE DATA 

 

The First 5 Modoc Commission wishes to ensure that all local data that are linked to personal identifiers are handled using the most stringent confidentiality standards.  

  • No data collected by First 5 Modoc may ever be sold for any reason.

  • First 5 Modoc shall be required to store all data with identifying information in a secure location. The number of staff with access to this data shall be limited to the minimum number necessary. 

  • First 5 Modoc staff, and/or the First 5 Modoc evaluation consultant may input collected data into password protected evaluation tools or internal databases for purposes of aggregating data and reporting.  The following procedures shall be followed: 

    • Names will be replaced with ID numbers or codes before submitting data for local analysis but shall only be reported out on an aggregate basis.  The purpose for client level data shall be to enhance the level of analysis that may be done, especially for data that is comparable across fiscal years or over the life of a Site.  

    • No service or outcome data shall be reported linked to particular agencies when the demographics show less than 10 individuals served.  

    • The local First 5 Modoc Evaluator shall sign a confidentiality agreement. 

    • First 5 Modoc staff and the First 5 Modoc Evaluator shall input shared data into evaluation tools or secure internal databases within 60 days of receipt using ID numbers instead of names. After the data transfer is complete, any paper forms that may exist shall be shredded.

    • First 5 Modoc staff and the First 5 Modoc Evaluator shall not share any identifiable information regarding participants with anyone.  All reports generated from the individual User data shall include only aggregated data.