Introduction
Zhu’s Neuro-Acupuncture & Rehabilitation Center, a company incorporated under the laws of the State of California, U.S.A., (referred to herein as “ZSA Center,” “we,” “us” and “our”) understands the importance of privacy of individuals (referred to as “users”, “you” and “your”). ZSA Center is committed to protecting your personal information. We have adopted the following policies in compliance with most state and federal privacy laws and GDPR in EU. This privacy notice outlines the personal information ZSA Center may collect and how ZSA Center will use and disclose that information.
Please note that by visiting and using our website you are agreeing to the terms and conditions of this Privacy Policy. If you do not agree to such terms and conditions, please discontinue use and exit our site.
We do not knowingly collect personal information from children (defined herein as minors younger than thirteen years of age). If you are under the age of thirteen, please do not submit any personal information via our site. Before using our website, persons under the age of eighteen must have their parents or legal guardians read our Terms of Use Agreement and this Web Site Privacy Policy and consent to the terms on their behalf.
Information Collection
ZSA Center may collect two different types of information, Personally Identifiable Information and Non-Personally Identifiable Information.
Personally Identifiable Information
Personally Identifiable Information (“PII”) is information that identifies you as an individual – for example, your name, address, telephone number, email address, credit card information, billing address and shipping information.
During your appointment booking process, class enrollment, email inquiry or while purchasing products on ZSA Center owned websites, ZSA Center may collect PII about you that may be considered sensitive.
ZSA Center may also collect PII about you from, among other places: information you provide directly to us, information regarding services that ZSA Center currently provides or has previously provided to you, information ZSA Center receives from our affiliated entities such as our Facebook page or third parties relating to the establishment of our relationship or the provision of services to you. For example, if you enroll in our healthcare professional classes hosted by our affiliated parties in different parts of the world, your PII will be forwarded to us for record keeping of your academic progress. Or you may occasionally be asked to complete patient surveys. ZSA Center may analyze information submitted via your account as part of descriptive (demographic) studies and reports. In such cases, we will make reasonable efforts to remove patient-identifying information.
PII information can be received in any manner, including in-person discussions, telephone conversations, and electronic or other written communications. Once we receive this information, we will use, disclose, and safeguard it as described in this Policy.
Non-Personally Identifiable Information
Non-Personally Identifiable Information (“Non-PII”) is aggregated information, demographic information, user behavior data from web interaction metrics tools and any other information that does not reveal your specific identity. Although IP addresses may not be personally identifiable, we can determine from an IP address a visitor’s Internet Service Provider and the geographic location of his or her point of connectivity.
Visitor Tracking Software
ZSA Center keeps track of visits to our Sites via Google Analytics, an automatic monitoring program that tells us, among other things, how many visits are made to the site; the time of day and date of those visits; which areas of the site individuals visited; your computer’s IP address; the type of browser and operating system you use; and the address of the Web site you linked from, if any. The monitoring program does not provide us with any personal information about a visitor. We cannot discern your name or physical address or other personal information about you. This information is used to evaluate the effectiveness of our site; resolve user, hardware and software problems; and make the site more useful to patients and other visitors. You may opt out of Google Analytics by following the instructions at: https://tools.google.com/dlpage/gaoptout.
Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Cookies
We may collect information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies help us to improve our site and to deliver a better and more personalized service. They enable us to estimate our audience size and usage pattern, to store information about your preferences, to speed up your searches and to recognize you when you return to our site. We use a ‘session cookie’ for the duration of one visit, or a ‘persistent cookie’ for repeat visits.
You may refuse to accept cookies by changing the setting on your browser. However, if you select this setting you may be unable to access certain parts of our site.
Information Use
ZSA Center may collect PII about you to establish or maintain our relationship with you, respond to your inquiries, provide you with services you have requested, personalize your experience with us, and other reasons. For example, you may receive emails or newsletters from us to inform you of services or health-related news or events we think may be of interest to you. A link will be provided if you choose to opt-out of such communications in the future.
Without PII, ZSA Center may be unable to provide you with the services you have requested.
Disclosure of Information
ZSA Center does not sell or lease PII about you to others.
ZSA Center may share PII about you with others as permitted by contractual agreement or as required by law, such as our affiliates, third parties in connection with the provision of services to you, government entities and regulatory bodies, and those with whom you have requested us to share information.
ZSA Center will not share PII about you with an unaffiliated third party who is not performing services for us without first obtaining your permission, except if such sharing is otherwise permitted by this privacy notice. ZSA Center will provide PII about you to the following types of third parties for the associated reasons:
- Carriers: ZSA Center will provide your name and address to companies which provide a delivery service between ZSA Center and its customers as a means of delivering our products to you as quickly as possible.
- Financial Institutions: ZSA Center will provide financial institutions with your payment information, name, address, and phone number in order to process any orders placed by you and complete payment of the transaction to ZSA Center.
- Legal Obligations: Notwithstanding any other provision of this notice or the Terms and Conditions of Use to the contrary, we reserve the right to disclose and use your PII if we believe that we are required to do so: (a) by law; (b) in response to legal process, for example, in response to a court order or a subpoena; (c) in response to a law enforcement agency’s request; (d) to enforce our other terms, conditions, or policies; (e) to protect our operations; (f) to protect the rights, privacy, safety or property of ZSA Center, you or others; and/or (g) to permit us to pursue available remedies or limit the damages we may sustain. For example, we may to the fullest extent the law allows, disclose PII about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities.
Because Non-PII does not personally identify you, we reserve the right to use Non-PII, and to disclose Non-PII to third parties, for any purpose.
Access and Update Personal Information
To request access to other personal information that we may have about you, or to request changes to that information, you can contact us at zhu@scalpacupuncture.org. We will honor any legal right you may have to access such information. You will not be permitted to access another individual’s personal information unless you have legal authority to do so. Requesting deletion of your information may result in deletion of your account. In some cases, we may be unable to update or delete your information, or may, in our discretion, deny a request for access, amendment, or deletion of your personal information if we believe doing so would violate our policies and procedures or legal requirements, or would create inaccurate information.
Links to Outside Web Sites
ZSA Center owned sites (www.scalpacupuncture.org and …..) have numerous links to outside Internet pages, including social media platforms and Web sites which might have information on health topics of interest to you. ZSA Center, however, does not sponsor or endorse any of these sites, nor does ZSA Center make any guarantee, warranty or representation regarding the accuracy of the information contained on these Web sites. In addition, ZSA Center has no control over the privacy or security practices of external Web sites. You should read and understand the policies of all Web sites with respect to these practices. These links are provided for your general information and education only, and should NOT be relied upon for personal diagnosis or treatment.
Information Security and Integrity
ZSA Center maintains reasonable physical, administrative and technical safeguards to protect PII from loss, misuse, or unauthorized access, disclosure, alteration or destruction. Our personnel and the personnel of our affiliates are provided access to PII about you only if they have a need to know the information in connection with a legitimate business purpose, such as (a) the provision of services to you or (b) to help identify other services that ZSA Center and its affiliates offer that may be of interest or use to you.
Additionally, ZSA Center will only use PII for the purpose which it was intentionally collected. ZSA Center will take reasonable measures to safeguard your information and ensure that it is accurate, complete and current. We keep your personal data for no longer than reasonably necessary.
While we take reasonable steps to protect your personally identifiable information, we cannot guarantee and do not warrant or represent, that all information will be protected against loss, misuse, or unauthorized access by third parties. By your use of the our website, you agree and stipulate that your use of the Internet and the ZSA Web Site is at your own risk, that no Internet data transmission can be guaranteed as secure from such incidents, and that you will not hold us responsible for any breach of security that is not solely caused by our negligence.
Changes to This Privacy Notice
ZSA Center reserves the right to change this privacy notice. Any changes to this notice will become effective upon posting of the revised notice on the Internet or as required by law. Your continued use of our Sites following the posting of changes will mean you accept those changes.
Questions
To exercise all relevant rights, queries or complaints please in the first instance contact us at zhu@scalpacupuncture.org or by regular mail to Zhu’s Neuro-Acupuncture Center, Inc., 2254 N First St, San Jose, CA 95131, USA. Note, email to us via this link is not encrypted or secure so please do not include any personal health information or other sensitive information in your email.