Privacy Policy for Community Benefit Programs

Effective Date: January 1, 2025

Community Benefit Programs, a DBA operating under the laws of California, is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you enroll in or participate in the TeleHealth Section (Hospital Component) of the H.A.M. Program, a prerequisite to the court-mandated hospital visit authorized by California Vehicle Code 23509. By enrolling via our website (www.cb-programs.org) or participating in the program, you consent to the practices described below. Please read this policy carefully.

1. Information We Collect

We collect only the information necessary to provide our court-mandated educational services and comply with legal obligations. The types of information we collect include:

  • Personally Identifiable Information:
    • Enrollment Data: Name, email address, phone number, and court case number, provided during registration to verify eligibility and issue Proof of Enrollment or Completion.
    • Course Data: Responses to quizzes, surveys, or health screening tools (e.g., worksheets) containing identifiable details, used solely to facilitate program completion and fulfill court requirements.
  • Anonymous/Aggregate Information: Statistical data from health screening surveys or course interactions (e.g., averages, percentages), which cannot be traced to an individual and is used to improve our services.
  • Technical Data: Device information, IP address, browser type, and cookies or similar tracking technologies to enhance your experience and monitor program usage (see Section 6 for details).

2. How We Use Your Information

We use your information to:

  • Provide and administer the TeleHealth Section, including issuing Proof of Enrollment and Proof of Completion for court submission.
  • Communicate with you about registration, course progress, updates, or surveys to improve the program.
  • Ensure compliance with California Vehicle Code 23509 and court requirements.
  • Analyze anonymous/aggregate data to enhance program quality and effectiveness.
  • Protect the integrity of the program and resolve disputes (e.g., chargebacks).

3. Consent

By providing personal information during enrollment, making a purchase, or participating in the program, you consent to our collection and use of that information for the purposes outlined in this policy. For secondary uses (e.g., program updates or surveys), we will request your express consent or provide an opportunity to opt out.

Withdrawing Consent

You may withdraw consent for non-essential uses (e.g., communications about updates) by contacting us at [email protected] with "Privacy Policy" in the subject line. Note that withdrawing consent does not affect information required for court-mandated purposes or legal obligations, nor does it entitle you to a refund (see Terms of Use).

4. Disclosure

We do not share your personal information with third parties except:

  • As required to provide our services (e.g., with Thinkific for hosting or Stripe for payment processing, as described in Section 5).
  • To comply with legal obligations, such as court orders or reporting requirements under California law.
  • If you violate our Terms of Use (e.g., initiating a fraudulent chargeback), we may disclose relevant information to courts, probation authorities, or payment providers to resolve disputes.

5. Third-Party Services

Our program is hosted on Thinkific Labs Inc.’s platform, which stores your data securely behind a firewall. Health screening survey data is processed via Google products with appropriate privacy settings and is not stored on Thinkific’s platform. For payments, we use Thinkific Payments (powered by Stripe), which adheres to the Payment Card Industry Data Security Standard (PCI-DSS) with encrypted transactions.

Third-party providers have their own privacy policies, which we encourage you to review:

If you are redirected to a third-party site or application, this Privacy Policy and our Terms of Use no longer apply. We are not responsible for the privacy practices of external sites.

6. Cookies and Tracking Technologies

We use cookies and similar technologies to:

  • Recognize your device and provide a personalized experience.
  • Track session activity to ensure proper course progression.
  • Measure program performance and engagement through web analysis tools.

We may also allow third-party advertisers (e.g., Google, Facebook) to use cookies to track visits for targeted ads. You can opt out of targeted advertising via the Digital Advertising Alliance’s Opt-Out page. You may adjust your browser settings to manage cookies, but this may affect program functionality.

We do not alter our data practices in response to “Do Not Track” signals due to the lack of a standardized industry approach.

7. Security

We take reasonable measures to protect your information, including:

  • Encryption of payment data using SSL and AES-256 standards.
  • Compliance with PCI-DSS for payment processing.
  • Health screening survey data is processed via third-party tools with appropriate privacy settings and is not stored on Thinkific’s platform.

While we follow industry best practices, no online transmission or storage is 100% secure. If you suspect a security breach, contact us immediately at [email protected].

8. Your Rights (California Residents)

Under the California Consumer Privacy Act (CCPA), you have the right to:

  • Request access to the personal information we collect about you.
  • Request correction, amendment, or deletion of your information, subject to legal retention requirements (e.g., court-mandated records).
  • Opt out of the sale of your personal information (note: we do not sell your data).

To exercise these rights, contact us at [email protected] with "Privacy Policy" in the subject line. We will respond within the timeframes required by law.

9. Age of Consent

By enrolling, you represent that you are at least 18 years old or the age of majority in California, unless you are a minor (under 18) who has been court-ordered to participate in the program due to a DUI or Minors in Possession or related conviction, at the discretion of the Bench Officer. For minors, a parent or legal guardian must provide consent for enrollment and data collection, which will be verified during the registration process. All participants, regardless of age, are subject to the same privacy protections and obligations outlined in this policy.

10. Retention

We retain your personal information only as long as necessary to:

  • Fulfill court-mandated requirements (e.g., issuing certificates, reporting to authorities).
  • Comply with legal obligations (e.g., recordkeeping under California law).
  • Resolve disputes or enforce our Terms of Use.

Health screening data and course responses are retained securely and deleted after the legally required period, unless otherwise mandated.

11. Changes to This Privacy Policy

We may update this policy to reflect changes in our practices or legal requirements. Updates take effect upon posting on www.cb-programs.org. If we make material changes, we will notify you via email or a website notice. Please review this policy periodically.

12. Business Transfers

If Community Benefit Programs is acquired or merged, your information may be transferred to the new entity solely to continue providing services, subject to this policy.

13. Contact Us

For questions, complaints, or to exercise your privacy rights, contact us at [email protected] with "Privacy Policy" in the subject line, or visit www.cb-programs.org.