INTRODUCTION
Kyo Autism Therapy, LLC (“Kyo”) provides a website and a mobile app:
The Website and the App are referred to collectively in this Privacy Policy as the “Site.”
The Site allows the parents / guardians of our clients and other users to view service-related information, communicate with our staff, and arrange for services.
This Privacy Policy applies to the Site, which is owned and operated by Kyo. This Privacy Policy describes how Kyo collects and uses the personal information you provide on, and other information that is collected from, your use of the Site. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.
Personal information means information that is individually identifiable. Information that has been de-identified by Kyo or others is no longer personal information and is not covered by the terms of this Privacy Policy.
All of your or your children’s protected health information maintained by Kyo, including information you provide on the Site, is also subject to the Notices of Privacy Practices issued by Kyo under the Health Insurance Portability and Accountability Act (“HIPAA”). The Notices of Privacy Practices may contain additional provisions relating to the use and disclosure of such information that go beyond the terms of this Privacy Policy.
Kyo is committed to protecting the privacy of the users of the Site. We will use and disclose your personal information as stated in this Privacy Policy.
The Site is hosted and operated in the United States. If you use the Site from outside the United States, please be aware that the information you provide to us is transmitted to, processed, and stored in the United States. Data will be collected, processed, maintained, and used subject to this Privacy Policy and applicable privacy laws in the United States. These laws may be different from the privacy laws in your country. However, this does not change our commitments to safeguard your privacy.
SITE PRIVACY POLICY
Use and disclosure of health information includes using the information to provide treatment to the individual, to make payments for such treatment, and to conduct ongoing quality improvement activities. Our use and disclosure of an individual’s personal information (including health information) is limited as required by state and federal law. We do not sell or rent personal information about visitors to the Site.
SECURITY
The Site has security measures in place that are intended to help protect against the loss, misuse, unauthorized access or alteration of information under our control both during transmission and once the information is received. These measures include encryption of data using the Secure Socket Layer (SSL) system, and using a secured messaging service when we send your personal information electronically to the Site. Despite these measures, the confidentiality of any communication or material transmitted to or from us via the Site by Internet, text message or email cannot be guaranteed. At your discretion, you may contact us at the mailing address or telephone number listed in the “Questions, complaints, and contacts” section at the end of this Privacy Policy.
REVISIONS TO THE PRIVACY POLICY
We may revise this Privacy Policy from time to time as we add new features or modify the way in which we manage information, or as laws change that may affect our services. If we make material changes to our Privacy Policy, we will post notice of this on our Site prior to the changes becoming effective. Any revised Privacy Policy will apply both to information we already have about you at the time of the change, and any personal information created or received after the change takes effect. We include a version number on this Privacy Policy consisting of the date (year, month, and day) it was last revised. We encourage you to periodically reread this Privacy Policy, to see if there have been any changes to our policies that may affect you.
SITE VISITOR DATA
In addition to web logs, described below, Kyo routinely gathers data on Site activity, such as how many people visit the Site, the web pages or mobile screens they visit, where they come from, how long they stay, etc. The data is collected on an aggregate basis, which means that no personally identifiable information is associated with the data. This data helps us improve our content and overall usage. The information is not shared with other organizations for their independent use.
The Site does not honor a browser’s signal or header request not to track the user’s activity.
COLLECTING AND USING AND DISCLOSING PERSONAL INFORMATION
Except as disclosed in this Privacy Policy, we do not collect any personally identifiable information about visitors to the Site. The policies, sources, uses and disclosures of information are outlined in Sections 1 through 13 that follow:
1) Information collection use
We may collect the following personal information from you about you or your child:
We use and disclose this information to:
2) Web logs
As is true of most websites, we gather certain information automatically. We maintain standard Web logs that record data about all visitors and customers who use the Site and we store this information for no longer than reasonably useful to carry out its legitimate business purpose, or as legally required. These logs may contain the Internet domain from which you access the Site (such as xfinity.com, att.com, etc.); the IP address which is automatically assigned to your computer when you get on the Internet (a static IP address may be identifiable as being connected to you, while a dynamic address is usually not identifiable); the type of browser and operating system you use; the date and time you visited; the pages or mobile screens you viewed; and the address of the website you linked from, if any. If you sign on to the Site to use secured features, our logs may also contain an individual identifier and show the services you have accessed.
All logs are stored securely, and may only be accessed by Kyo employees or designees on a need-to-know basis for a specific purpose. Kyo uses log information to help us design our Site, to identify popular features, to resolve user, hardware, and software problems, to make the Site more useful to visitors and for security purposes.
3) Internet cookies
We and our service providers may place Internet “cookies” or similar technologies (JavaScript, HTML5, ETag) on the computer hard drives of visitors to the Site. Information we obtain helps us to tailor our Site to be more helpful and efficient for our visitors. For example, we are able to see the navigation path taken by users, and that information allows us to understand user success or challenges with the web experience. The cookie consists of a unique identifier that does not contain information about your health history. We use two types of cookies, “session” cookies and “persistent” cookies, along with other similar technologies.
A session cookie is temporary, and expires after you end a session and close your web or app browser. We use session cookies to help customize your experience on our Site, maintain your signed-on status as you navigate through our features, and to track your “click path” through our web pages or mobile screens.
Persistent cookies remain on your hard drive after you’ve exited from our Site, and we use them for several reasons. For instance, if you’ve given us permission to email you with information about your Kyo benefits, or for other reasons, we may place a persistent cookie on your hard drive that will let us know when you come back to visit our Site. We sometimes use this type of persistent cookie with a “Web beacon” (see below). Persistent cookies will not contain any personal health information about you.
You may have software on your computer that will allow you to decline or deactivate Internet cookies, but if you do so, some features of the Site may not work properly for you. For instructions on how to remove cookies from your hard drive, go to your browser’s website for detailed instructions. In addition, further information regarding cookies may be available on other websites or from your Internet service provider. Safari, Chrome, Firefox, Internet Explorer and iOS browsers are commonly used browsers.
4) Web beacons
We may also occasionally use “Web beacons” (also known as “clear gifs,” “Web bugs,” “1-pixel gifs,” etc.) that allow us to collect non-personal information about your response to our email communications, and for other purposes. Web beacons are tiny images, placed on a Web page or email, that can tell us if you’ve gone to a particular area on our Site. For example, if you’ve given us permission to send you emails, we may send you an email urging you to use a certain feature on our Site. If you do respond to that email and use that feature, the Web beacon will tell us that our email communication with you has been successful. We do not collect any personal health information with a Web beacon, and do not link Web beacons with any other personal health information you’ve given us.
Since Web beacons are used in conjunction with persistent cookies (described above), if you set your browser to decline or deactivate cookies, Web beacons cannot function.
Our Site contains software development kits (SDKs) that may collect and transmit information back to us or third-party partners about your usage of that mobile application or other applications on your device. Such data, when collected by a 3rd party, that may show what click path was taken, what pages users visited and how long certain pages took to display, is not identifiable to you as an individual.
5) Emails, voice messages and SMS text messaging
Kyo may use a third-party vendor to help us manage some of our email, chat, and voice/text messaging communications with you. While we do supply these vendors with email addresses or mobile telephone numbers of those we wish for them to contact, your email address or mobile telephone number is never used for any purpose other than to communicate with you on our behalf. When you click on a link in an email, you may temporarily be redirected through one of the vendor’s servers (although this process will be invisible to you) which will register that you’ve clicked on that link, and have visited our Site. Kyo never shares any information, other than your email address or telephone number, with our third-party email and voice/text messaging vendors, which may only share this information with its authorized subcontractors.
At any time, and even if you have expressly given us permission to send voice/text messages to you, you may communicate your desire not to receive additional voice/text messages by adjusting your preferences on the Site (for only certain categories of communications), or by using the contact information in the “Questions, complaints, and contacts” section below.
6) Evaluation and quality improvement
We may periodically ask you to complete surveys asking about their experiences with features of the Site. Our surveys ask for demographic information but will not ask for personal health information. We use survey information for evaluation and quality improvement purposes, including helping Kyo to improve information and services offered through the Site. In addition, users giving feedback may be individually contacted for follow-up due to concerns raised during the course of such evaluation. Demographic information and log data may be stored for future evaluation and quality improvement activities.
7) Messages and transactions
Comments or questions sent to us using email, chat, or secure messaging forms will be shared with Kyo staff.
When you use our chat service on the secure section of the Site to interact directly with Kyo staff, please do not provide or discuss health information.
8) Data integrity and correction
You have the right to request to view and correct personal information from the Site. Such requests may be submitted using the contact information in the “Questions, complaints, and contacts” section below.
If your personal information changes, you have the right to update or request deletion of information collected on our Site, or if you believe a third party has provided us with your personal information and you would like to request that it be edited or removed from our database, please use the contact information in the “Questions, complaints, and contacts” section below. We will use commercially reasonable efforts to respond to all such requests within 60 days.
9) Children
We do not knowingly collect personally identifiable information directly from children under the age of 18 without the verifiable consent of the child’s parent or guardian. If Kyo is made aware of collecting information directly from a child under 18 without the verifiable consent of the child’s parent or guardian, we will delete this information.
10) Disclosures
We may also disclose your personal information to third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us pursuant to written instructions. In such cases, these companies must abide by our data privacy and security requirements, and are not allowed to use your personal information they receive from us for any other purpose.
These services may include:
We may also disclose your personal information:
11) Opt out
If a user makes a request to receive information (for example, requesting a subscription to one of our online publications) in an ongoing manner through the Site by providing an email address or mobile phone number the user may request to discontinue future mailings or messages. Similarly, if you receive information about a Kyo service through email or voice/text message, you may make a request to discontinue receiving similar messages in the future. Materials sent to you by email or voice/text message may contain information about how to opt out. Please note, however, that you cannot opt out of certain messages, such as an email letting you know that an appointment has been canceled.
On our Site, you may change your preferences regarding receiving emails or text messages by going to “Settings” in the menu, then modifying the “Communication Preferences”.
12) Data retention
We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, including to meet our legal obligations, resolve disputes, and enforce our agreements, unless a longer retention period is required or permitted by law.
13) Links to third party websites
Our Site may include links to other websites whose privacy practices may differ from those of Kyo. If you submit personal information to any of those sites, your information is governed by their Privacy Policies. We encourage you to carefully read the Privacy Policy of any website you visit.
QUESTIONS, COMPLAINTS, CONTACTS
If you have any questions about this Privacy Policy, our policies and practices concerning the Site, your rights under this statement, and your dealings with the Kyo Site, you can contact Kyo by telephone at 1 (877) 264-6747, by sending a message to info@kyocare.com, or by U.S. mail at the address below:
Kyo Autism Therapy, LLC
Attn: Privacy Team
295 89th Street, Suite 306
Daly City, CA 94015
Last revised: February 16 2022
