Table of Contents
- Few Quick Terms for Reference
- Who is PCM?
- What is this Statement About?
- What Personal Data Do We Collect?
- Processing of Your Personal Data
- Your Data Processing Choices
- GDPR & CCPA Data Subject Rights
- Data Retention
- Passive Collection
- Cookies and Tracking Technologies
- Sharing Your Personal Data
- Security of Your Personal Data
- Linked Websites and Third-party Services
- Transfer and Storage of Personal Data
- Children’s Data
- Changes to This Policy
- Privacy Shield
- Contact Us
Cold War Patriots, Professional Case Management, and its affiliates are committed to protecting your privacy and ensuring you have a positive experience on our websites and when using our services. When we use your information or your Personal Data, we always use it in a reasonable and responsible way, minimizing the type of information we collect and hold about you, the period of time we store it, and the ways we use it. This Privacy Statement covers all our operations: outreach, client onboarding and care, project management, administration, and the use of our websites and mobile applications.
- Controller: is the entity or person who decides what Personal Data to collect and how it is to be used.
- Data Protection Officer (“DPO”): is the person you will reach out to at CWP/PCM to ask questions about your data.
- E.E.A.: the European Economic Area. This includes all of the countries in the EU (see below) as well as Iceland, Liechtenstein, and Norway.
- E.E.O.I.C.P.A.: is the Energy Employees Occupational Illness Compensation Program
- E.U.: This includes the European Union. This includes the countries of Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden.
- PCM: as noted above, PCM is Professional Case Management. This Privacy Statement also applies to Professional Case Management Trials. Just in case there’s a question, “we,” “us” and “our” means PCM.
- Personal Data: this is the information (name, IP address, email) about you that we collect in order to provide you our services, including the functioning of this website. This includes any data that can individually identify a person. Such data is referred to by other names, including Personal Information, or Personally Identifiable Information. We refer to these collectively as Personal Data. As you read this, “data” is Personal Data.
- Processing: it is any use of your Personal Data, including collection, storage or using your address to send you an email or a flyer in the mail.
- Processor: is an entity or person who processes (uses) the data for the Controller. Typically a service provider, such as WordPress, is a Processor.
PCM is a group of interrelated companies headquartered in Denver, Colorado dedicated to providing superior, personal in-home care to clients the world over. When you provide or PCM collects your information from you, PCM is the controller. PCM is a processor or service provider when we act or provide services on behalf of an authorized third party.
Please note CWP/PCM does not sell Personal Data. Period.If you have questions about how we use your Personal Data or any requests relating to your information, please email PCM’s Data Protection Officer at [email protected]. If you prefer to write or call, additional contact information can be found here, in the “Contact Us” section of this statement.
Our purpose here is to provide our current, former, and potential clients with an understanding of:
- How and why we collect your data
- The types of Personal Data we collect
- Who we share your data with
- How we protect, use, and store your Personal Data
- Contact details to PCM so you can request information about the Processing of your data and your rights to do so.
Note that under the E.U.’s General Data Protection Regulation (the GDPR), residents of the E.U., United Kingdom, or E.E.A. may have additional data rights, as do California residents under the California Consumer Privacy Act (CCPA), further outlined below.
Type of Personal Data Categories Who Data is Shared With Why We Collect It Identifiers
- Physical address
- Phone number
- IP addresses
- Impairment Date
- White Card status
- EEOICPA status
- Company name
- WordPress Engine
- Provide services requested, e.g., request for information or access to an event
- General website administration such as surveys and records
- Marketing & advertising
- Survey purposes
- Records, e.g., a request for services
- Survey answers
Service Providers including:
- Google Analytics
- Website administration, including record keeping, data analysis, testing, surveys, and troubleshooting
- Marketing & advertising
- Trend (aggregate) monitoring
- Ensure website security
Internet/Network Activity Information
- IP address
- Browser type
- Internet service provider
- Referring/exit pages
- Files viewed (HTML pages, graphics, etc.)
- Operating system
- Date/time stamp
- Clickstream data
Service providers including:
- Google Analytics
- Google Adwords
- Internet or network activity for trend (in the aggregate) monitoring
- Marketing & advertising
- Ensure website security
CWP/PCM collects identifiers and commercial information directly from you. We collect Internet or other electronic network activity from your use of this Website and its services.
If you reside in the United States, from time to time CWP/PCM may ask for your voluntary participation in a survey or poll, such as feedback on Website content or services. Your responses are anonymized unless you opt-in or ask to be contacted.
Your Personal Data is used by CWP/PCM in accordance with this Privacy Statement. If you do not wish us to continue using your data in this manner, you can request deactivation by contacting us at [email protected], or as noted in the “Contact Us” section below.
CWP/PCM will Process your Personal Data only if there is a lawful basis for doing so. A “lawful basis” may include consent, contractual necessity (to fulfill a contract), and PCM’s legitimate interests or the legitimate interest of others (e.g. our users) such as:
- Receive access to our services online;
- Obtain information about our services;
- Participate in surveys or questionnaires posted on our Website;
- Enable us to respond to your requests;
- Comply with our legal obligations, resolving disputes with clients, enforcing our agreements
- Protecting, investigating, and deterring against fraudulent, harmful, unauthorized, or illegal
- Support recruitment inquiries
You can choose not to disclose your data. However, if you elect to skip such disclosures, our ability to respond to inquiries or provide services will be limited to the information you chose to share.
If you have previously consented, requested, or had a relationship with PCM, you may receive marketing materials, including emails, from PCM or our Affiliates. You may opt-out of those marketing emails by unsubscribing through the “unsubscribe” or “opt-out link” in an email or via one of the following opt-out forms:
- Consumer (e.g. client, member, etc.): Consumer Unsubscribe
- Business (e.g. professional contacts such as doctor office, etc.): Business Unsubscribe
We will do our best to comply with your request(s) within 10 days. Please note that if you opt-out of receiving our marketing-related emails, PCM or our Affiliates may still need to send transactional emails regarding important service communications because of our relationship or contract with you.
Residents of the E.U., United Kingdom, Switzerland, E.E.A., and California may have certain rights with respect to their Personal Data, which is more fully set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask for additional personal information or Personal Data in connection with your request if, for example, we need to verify your identity or the nature of your request. CWP/PCM will make every effort to respond in a reasonable timeframe with a determination of our responsibilities or seeking verification of the request.
To make any of the following requests pursuant to your rights under the GDPR or CCPA, please contact CWP/PCM at [email protected] or by using the contact details below in the “Contact Us” section of this Privacy Statement.
Data Subject Rights:
- Access: You can request more information about the Personal Data we hold about you. You can also request a copy of your Personal Data.
- Correction: If you believe the Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
- Objection/Opt Out: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.
- Erasure: You can request the deletion of some or all of your Personal Data from our systems.
- Restriction of Processing: You can ask to restrict further processing of your Personal Data.
- Portability/Transfer: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where feasible.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent, you have the right to withdraw your consent at any time.
- Right to File Complaint: You have the right to lodge a complaint about PCM’s practices with respect to your Personal Data with the supervisory authority of your country or E.U. Member State, or with the California Attorney General’s Office.
- DO NOT SELL: Applicable to California residents only. However, PCM does not sell any Personal Data.
CWP/PCM stores your data no longer than necessary. How long we retain your data depends on the type of data and the purpose for which the data was collected and processed.
As noted above, certain limited information is automatically collected when you click on our website address. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the website.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites.
By default, only necessary cookies are placed on your device when you visit CWP/PCM websites: they are essential for the webpage to function. Additional cookies can be accepted (analytics, social media plugins or advertising uses) through the control panel that appears when you access our websites. CWP/PCM will not place any cookies which are not otherwise necessary for webpage functionality on your device unless accepted through the cookie banner.
PCM websites use a few distinct types of cookies:
- Necessary cookies: these assist in making the website usable by enabling basic functions like page navigation and access to secure areas of the website and are necessary for proper functioning of the website
- Statistic cookies: they help website owners understand how visitors interact with websites by collecting and reporting information anonymously
- Marketing cookies: these are used to track visitors across websites so ads relevant to the user can be displayed
When you consent to certain services, or purposefully download and use our services, we automatically collect information on the type of device you use, operating system version, and the device identifier (or “UDID”). We send you push notifications from time-to-time to update you about any events or promotions that we may be running. To ensure you receive proper notifications, we will need to collect certain information about your devices such as operating systems and user identification information. If you no longer wish to receive these types of communications, you can turn them off at the device level.
CWP/PCM does not sell or rent your Personal Data to third-parties for marketing purposes. We do share Personal Data within the CWP/PCM sister companies and with third-party service providers for data processing or storage.
We also share Personal Data with business partners, service vendors, and/or authorized third-party agents or contractors; however, this sharing is limited to fulfillment of requested information, services, business inquiries, conference registration, and/or providing customer support. We limit what we share and provide only the minimum amount of data necessary to complete our service to you, allow you to utilize the requested products or services, or to complete a transaction. These third-parties are not permitted to use your data except for the limited purpose of assisting PCM in providing the requested services or information.
As required by law, we may respond to subpoenas, court orders, or similar legal processes by disclosing your Personal Data and other related information, if necessary. We also may use Personal Data and other related information to establish or exercise our legal rights or defend against legal claims.
We collect and may possibly share a limited amount of Personal Data or other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of PCM’s terms of service, or as otherwise required by law. CWP/PCM will endeavor to provide notice of such disclosures as soon as legally and practicably possible.
CWP/PCM is committed to protecting the Personal Data you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use, or disclosure. When we transfer Personal Data over the Internet, we protect it using multiple encryption methods as required by system protocols.
We recommend you take every precaution in protecting your Personal Data when you are on the Internet: check to see if a website is secure, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser. If you have any questions about the security of your Personal Data, you can contact us at [email protected] or 303-317-2406.
Our websites and services may provide links to other third-party websites and services which are outside our control and not covered by this Privacy Statement. We encourage you to review the privacy policies/statements/notices posted on these (and all) sites you visit or services you use.
We may transfer your Personal Data to the United States, to a CWP/PCM affiliate worldwide, or to third-parties acting on our behalf for the purposes of processing or storage. Please note that by using our services or providing Personal Data for any of the purposes stated above, you consented to the transfer and storage of your Personal Data, whether provided by you or obtained through a third-party, to the U.S. as set forth herein, including the hosting of such Personal Data on U.S. servers.
No part of our Website is designed to appeal to anyone under the age of 13, nor is the website intended for minors under the age of 18. PCM does not knowingly collect or solicit information about anyone under the age of 18. If you are under the age of 18, please do not provide any Personal Data or information about yourself to us. Children of any age should get their parents’ or legal guardians’ consent before disclosing any Personal Data on the Internet. If you believe we have mistakenly or unintentionally collected such information, please notify us at [email protected] or 303-317-2406 so that we may delete the information from our servers.
We may make changes to this Statement from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business. Any changes made in the future will be posted on this page, accompanied by a notice on our home page that this Statement has changed.
PCM has elected to self-certify to the EU-U.S. Privacy Shield Framework and the Swiss-US Privacy Shield Framework (collectively, Privacy Shield) as set forth by the U.S. Department of Commerce and may also use other mechanisms for the protection and transfer of data, as appropriate. We are committed to subjecting all Personal Data received from the European Union (EU) member countries, the United Kingdom, and Switzerland in compliance with the Privacy Shield Framework, to the Framework’s applicable Principles. If there is any conflict between the terms of this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles will govern. For Personal Data originating in the EU, Switzerland, and the United Kingdom, this Privacy Statement demonstrates our commitment to Processing your Personal Data in accordance with the Privacy Shield Principles:
- Accountability for Onward Transfer
- Data Integrity & Purpose Limitation
- Access, and
- Recourse, Enforcement and Liability
CWP/PCM is responsible for the processing of Personal Data it receives under each Privacy Shield Principle and subsequent transfers to a third party acting as an agent on its behalf. PCM complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, Switzerland and the United Kingdom, including the onward transfer liability provisions.
CWP/PCM has and will continue to work diligently to establish a program to monitor adherence to the Privacy Shield Program and to address questions and concerns. Individuals having concerns or wishing to file a complaint regarding PCM’s processing of their Personal Data pursuant to the Privacy Shield Principles may do so by directly contacting our Data Protection Officer a [email protected], or by using the information in the “Contact Us” section below.
With respect to any dispute relating to this statement that cannot be resolved directly through PCM internal processes:
- Concerning disputes related to an employment relationship, we will cooperate with EU data protection authorities and the Swiss Federal Data Protection and Information Commissioner, and comply with the advice of such authorities. In the event it is determined that PCM did not comply with this Statement, we will take appropriate steps to address any adverse effects and improve future compliance.
- If the dispute involves other types of data, individuals may file a claim with Judicial Arbitration and Mediation Services (JAMS) here.
- Personnel who violate our privacy program requirements will be subject to disciplinary process.
- An individual may under certain conditions invoke binding arbitration. Please see the Privacy Shield website here for more information on conditions giving rise to binding arbitration.
For purposes of enforcing compliance with the Privacy Shield, PCM is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
To learn more about the Privacy Shield Framework please visit the U.S. Federal Trade Commission’s website on Privacy Shield located here. To review PCM’s representation on the Privacy Shield list, see the U.S. Department of Commerce’s Privacy Shield self-certification list located here.
If the dispute involves other types of data, individuals may file a claim with Judicial Arbitration and Mediation Services (JAMS) here.
Any Personal Data questions or comments related to this Privacy Statement can be emailed to [email protected], or called into the PCM Compliance department at 303-317-2406.
You may also contact us by writing to this address:
Professional Case Management
Attention: Privacy – PCM Data Protection Officer
500 E. 8th Avenue
Denver, CO 80203
For any other questions regarding our services or sister companies, please email [email protected] or write to the following address:
Professional Case Management
Attention: Outreach Help Center
500 E. 8th Avenue
Denver, CO 80203