This privacy policy outlines the information the Text Line Program of Crisis Support Services of Alameda County (CSS) collects from you (the texter) when you utilize our program’s services and how we handle that information. The Privacy Policy works jointly with the Crisis Support Services Text Line Program Terms of Service and the Educational Message Services Privacy and Terms & Conditions.
INTRODUCTION
In this Privacy Policy, the Crisis Support Services Text Line program describes how the Text Line collects, maintains, uses, discloses, and processes certain information about you. The Crisis Support Services Text Line program uses PreventionPays™ for its texting platform. This Privacy Policy applies to your access to and use of the following services, which we collectively call the “Crisis Support Services Text Line” (https://www.crisissupport.org/programs/text-line/).
Throughout this Privacy Policy, we will be using the term “texters” to refer to people who use our program’s services with the following terms:
- “Texters” refers to individuals that use the communication method, SMS text, to seek help for themselves or for another person.
By texting “SAFE” to 20121, texters consent to this Privacy Policy and to the Text Line Program’s collection, maintenance, use, disclosure, and processing of Personal Information, all as described in this Privacy Policy.
If you are a Texter, you also expressly acknowledge that you have read and understood our Confidentiality Statement. Our Confidentiality Statement describes how your communications with the Text Line Program may be used and what personal information is automatically received and collected from you.
WHAT IS THE PURPOSE OF THIS PRIVACY POLICY?
Protection and use of Personal Information is important to the Text Line Program. These promises and terms do not apply to the practices of any third parties that the Text Line Program does not control or the products or services that they provide. For more information on Third-Party Offerings and Third-Party Providers, please review the Text Line Program Terms of Service. You are solely responsible for understanding the terms of service and privacy policies of those non-affiliated companies and how they use and maintain your information.
WHAT DOES THIS PRIVACY POLICY COVER?
This Privacy Policy covers how the Text Line Program uses and discloses Personal Information that the 988 Lifeline gathers from you, beginning at the time that you first access our service. The crisis counselors at the Text Line Program are dedicated to maintaining the privacy and integrity of the personal information that it receives from Texters.
Personal Information – In General
In this Privacy Policy, we use the term “Personal Information” to refer to information the Text Line Program gathers that could be used to identify or contact you and any identifiable information the Text Line Program gathers concerning your use or potential use of the Text Line Program service. Examples of Personal Information include your first and last name, your phone number or other contact information, and all content of written communications or notes made by a crisis counselor. Your Personal Information that the Text Line Program receives may include “personal information” as that term is defined by relevant laws and regulations.
Your privacy is important to us, and the Text Line Program is committed to carefully managing your Personal Information in connection with the service that the Text Line Program provides.
WHAT PERSONAL INFORMATION DO WE COLLECT?
The Text Line Program collects Personal Information from you and certain devices that you may use, as further described below. For Texters, this includes information collected through your communications with a counselor via text, for example. The Text Line Program also receives some Personal Information that is collected automatically, as further described below. The Text Line Program also collects Personal Information in connection with inquiries you may make through the service. Collection starts from the time that you initially access the service.
Information that the Text Line Program gathers enables us:
- to provide you with the service,
- to respond to your inquiries, whether for yourself or a person you’re reaching out for,
- to obtain your feedback on our service,
- to understand who is using our service and how the service is performing,
- to personalize and improve our service,
- to conduct aggregated research activities,
- to manage the security of the service, and
- to fulfill any requirements imposed on us or the Text Line Program by applicable laws and regulations.
The Text Line Program will use the Personal Information that you provide for the purposes described above (and any other purposes intrinsic to the service that you use) and to provide you with an engaging and personalized experience in using the Text Line service.
Personal Information Collected Automatically
In addition to any information that you provide through the service, the Text Line Program and our third-party service providers may use a variety of technologies that store or collect certain information from you automatically (or passively) when you visit or interact with the service (“Usage Information”). Examples of Usage Information include: your phone number if you have contacted the Text Line service, potentially your device’s general location, and certain other data regarding your device used to access the Text Line service.
To the extent the Text Line Program associates Usage Information with your Personal Information or Usage Information includes identifiable information, the Text Line Program will treat it as Personal Information. In addition, if you are a Texter, to the extent the Text Line Program associates Usage Information with your participation in Text Line service, the Text Line Program protects that information per our Confidentiality Statement.
WHAT PERSONAL INFORMATION DO WE SHARE?
The following sections describe certain circumstances when the Text Line Program may share your Personal Information.
Information Shared with Contracted Parties
The Crisis Support Services Text Line program uses PreventionPays™ for its texting platform. It is a secure, enterprise website and database developed according to HIPAA guidelines.
Information Shared with Other Entities including Third-Party Administrators
If you are a Texter, the Text Line Program may, in its sole discretion, share, transfer, or otherwise disclose certain of your Personal Information to entities that are authorized to receive that information for legally permitted purposes.
This type of sharing is described in more detail in our Confidentiality Statement.
Protection of Text Line Program
The Text Line Program may release your Personal Information when the Text Line Program believes in good faith that releasing that information is necessary to comply with applicable law or the subpoena or warrant of a court of law or similar authority with jurisdiction, to enforce our conditions of use and other agreements, or to protect the rights, property, or safety of Text Line Program, Texters or others. If necessary and required by law, the Text Line Program will disclose any breach of the security, confidentiality, or integrity of your Personal Information, including, without limitation, breaches of your unencrypted, electronically stored “personal information” or “health information” (as defined by applicable laws). To the extent permitted by applicable laws, the Text Line Program may make these disclosures to you in the most expedient manner and time possible and without unreasonable delay, so long as we have a means of contacting you and it is consistent with the legitimate needs of law enforcement and any other measures necessary to determine the scope of the breach and assists to restore the reasonable integrity of the data system.
De-identified Data
As described in our Terms of Service, the Text Line Program may de-identify Personal Information that you share with us, including any Personal Information, or otherwise process them so that they are no longer attributable to you without additional information (“De-identified Data”). The Text Line Program may use that De-identified Data without restriction in any way allowed by law. For example, the Text Line Program might use De-identified Data to understand, evaluate, or modify the service, to generate statistical information that the Text Line Program shares with other third parties who are evaluating, analyzing, accrediting, or researching the Text Line Program. When an applicable law requires that the Text Line Program use a particular method of de-identifying data or rendering it no longer attributable to you, the Text Line Program will comply with that law. Otherwise, the Text Line Program may use a method that is appropriate under the circumstances and would not reasonably identify you.
IS MY PERSONAL INFORMATION SECURE?
The Text Line Program employs industry-standard administrative, physical, and technical measures designed to safeguard and protect information under our control from unauthorized access, use, and disclosure. In addition, when the Text Line Program collects, maintains, uses, discloses, and processes your Personal Information, the Text Line Program will do so using systems and processes consistent with the information privacy and security requirements of applicable federal and state laws and best practices.
The Text Line Program exercises great care to protect your Personal Information. However, the Text Line Program cannot ensure the security or confidentiality of any Systems or Connections that you use to transmit information to us. Furthermore, although the Text Line Program takes great care to protect your Personal Information, the Text Line Program cannot guarantee that criminals or others acting unlawfully will not succeed in efforts to undermine our security measures. Unauthorized entry to, access to, or use of our systems or locations, hardware or software failure, loss, and other factors may compromise the security of your information at any time.
If you have reason to believe that your data or your interactions with us are no longer secure or if you have questions related to privacy or data security, you may contact us in any of the manners described at the end of this Privacy Policy.
You have the right to opt out of communications at any time by sending the keyword “STOP”.
Can my parents/guardians request my information?
CSS does not share information about services provided to anyone. A parent has a right under Children’s Online Privacy Protection Act (COPPA) to request that the personal information collected from their child no longer be used. CSS will make every effort to comply with any direction from parents/guardians within compliance of laws governing provision of mental health services.
HOW CAN WE CHANGE THIS PRIVACY POLICY?
We may prospectively change or replace any terms of this Privacy Policy at any time and for any reason after consultation with AAS. We will post the most recent version of this Privacy Policy on the CSS and any changes to this Privacy Policy will become effective when posted. Use of information the Text Line Program collects is subject to the Privacy Policy (including, as relevant, the Confidentiality Statement) in effect at the time the information is used or disclosed. You are responsible for checking this Privacy Policy periodically for changes. If we change or replace any terms of this Privacy Policy in a manner that meaningfully reduces your rights, we will attempt to notify you and designate a reasonable time period before the new terms will take effect. By continuing to use or access the service after any changes come into effect, you agree to be bound by the updated Privacy Policy.
HOW CAN YOU CONTACT US WITH QUESTIONS OR CONCERNS?
If you have any questions or concerns regarding this Privacy Policy or the 988 Lifeline’s privacy practices, please contact us, or write us at the following address:
Crisis Support Services of Alameda County
P.O. Box 3120
Oakland, California 94609
We will make every effort to respond to your questions, concerns, and requests within a reasonable time.
