INTRODUCTION
This Privacy Policy applies to your access to and use of the following services, which we collectively call the “988 Lifeline”:
● the website that we operate for the 988 Lifeline (www.stage.988lifeline.org) (the “Site”); and
● all related communication services and features that we administer and the nationwide contact centers provide (“988 Services”).
Throughout this Privacy Policy, we distinguish between people who use different aspects of our services with the following terms:
● “Help Seekers” refers to individuals that use the various communication methods (e.g., phone, chat, text, videophone) to seek help for themselves or for another person – these are the 988 Services; and
● “Site Visitors” refers to individuals that visit the Site while not interacting with us or the 988 Services as Help Seekers.
In this Privacy Policy, the 988 Lifeline describes how the 988 Lifeline collects, maintains, uses, discloses, and processes certain information about you. By accessing or using any aspects of the 988 Services, you consent to this Privacy Policy and to the 988 Lifeline’s collection, maintenance, use, disclosure, and processing of Personal Information, all as described in this Privacy Policy.
If you are a Help Seeker, you also expressly acknowledge that you have read and understood our Confidentiality Statement. Our Confidentiality Statement describes how the 988 Lifeline and any contact center communicating with you may use and disclose personal information that is collected automatically or received from you as the 988 Lifeline delivers support to you through the 988 Services.
WHAT IS THE PURPOSE OF THIS PRIVACY POLICY?
Protection and use of Personal Information are important parts of the 988 Lifeline. This Privacy Policy explains how the 988 Lifeline collects, maintains, uses, discloses, and processes your Personal Information.
These promises and terms do not apply to the practices of any third parties that the 988 Lifeline 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 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 988 Lifeline uses and discloses Personal Information that the 988 Lifeline gathers from you, beginning at the time that you first access our Site or as you use 988 Services. Vibrant and the individual contact centers are dedicated to maintaining the privacy and integrity of the personal information that the 988 Lifeline receives from Help Seekers.
Personal Information – In General
In this Privacy Policy, we use the term “Personal Information” to refer to information the 988 Lifeline gathers that could be used to identify or contact you and any identifiable information the 988 Lifeline gathers concerning your use or potential use of the 988 Services. Examples of Personal Information include your first and last name, your email address or other contact information, and all content of written communications or notes made by a counselor. Your Personal Information that the 988 Lifeline receives may include “personal information” as that term is defined by relevant laws and regulations.
Your privacy is important to us, and the 988 Lifeline is committed to carefully managing your Personal Information in connection with the Site and the 988 Services that the 988 Lifeline provides.
WHAT PERSONAL INFORMATION DO WE COLLECT?
The 988 Lifeline collects Personal Information from you and certain devices that you may use, as further described below. For Help Seekers, this includes information collected through your communications with a counselor via a phone call, or a chat, text, or videophone session, for example. For Site Visitors, this includes Personal Information that you may provide to us through the Site. For both Help Seekers and Site Visitors, the 988 Lifeline also receives some Personal Information that is collected automatically, as further described below. The 988 Lifeline also collects Personal Information in connection with inquiries you may make through the Site or the 988 Services. Collection starts from the time that you initially access the Site or the 988 Services.
Information that the 988 Lifeline gathers enables us:
● to provide you with the Site and the 988 Services,
● to respond to your inquiries, whether from Site Visitors or Help Seekers,
● to obtain your feedback on our services,
● to understand who is using our 988 Services and how the 988 Services are performing,
● to personalize and improve our Site and 988 Services,
● to conduct aggregated research activities,
● to manage the security of the Site, and
● to fulfill any requirements imposed on us or the 988 Lifeline by applicable laws and regulations.
The 988 Lifeline will use the Personal Information that you provide for the purposes described above (and any other purposes intrinsic to the Site or the 988 Services that you use) and to provide you with an engaging and personalized experience in using the Site and 988 Services.
Personal Information Collected Automatically
In addition to any information that you provide through the Site and the 988 Services, the 988 Lifeline 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 Site or other aspects of the 988 Services (“Usage Information”). Examples of Usage Information include: your IP address, your phone number if you have contacted the 988 Lifeline, other unique device identifiers assigned to your device that allow our computers to recognize you, details of your device’s characteristics and functionality (e.g., browser, operating system, mobile network information), the areas within the Site, potentially your device’s general location, and certain other data regarding your device.
To the extent the 988 Lifeline associates Usage Information with your Personal Information or Usage Information includes identifiable information, the 988 Lifeline will treat it as Personal Information. In addition, if you are a Help Seeker, to the extent the 988 Lifeline associates Usage Information with your participation in 988 Services, the 988 Lifeline protects that information per our Confidentiality Statement.
Information from Your Browser of Device
The 988 Lifeline automatically receives and records Usage Information from your browser on our server logs whenever you interact with the Site or other online communication aspects of the 988 Services. The 988 Lifeline may use this Usage Information to provide you with support. The 988 Lifeline also may use this Usage Information to recognize you when you arrive at the Site from an external link, such as a link appearing on a third-party site or in an email generated by us. We discuss this type of technology in more detail under “Tracking Technologies” below. Our Site also collects Usage Information to determine how often Site Visitors and Help Seekers use parts of the Site or other aspects of the 988 Services so that the 988 Lifeline can improve the services and strive to ensure that the 988 Services support as many Help Seekers as best possible.
You may set your browser to refuse or disable these data collection methods, but doing so may change your experience with the Site or the 988 Services. For example, the Site may not recognize or respond to your browser with “do not track” technologies employed.
Tracking Technologies
The 988 Lifeline may use various tracking methods or technologies (“Tracking Technologies”) to store or collect your Usage Information, including information about your visits to or interactions with our Site and the online aspects of the 988 Services. The 988 Lifeline uses Tracking Technologies for a variety of purposes the 988 Lifeline believes to be necessary or helpful in improving or assessing the performance of the Site and online 988 Services (for example, as part of our analytic practices).
Tracking Technologies may include the following technologies and methods as well as any subsequent technologies and methods later developed to perform similar functions:
- Cookies. Cookies are alphanumeric identifiers that the 988 Lifeline transfers to your device through your browser to enable our systems to recognize your browser and to tell us how and when you visit pages in our Site or online aspects of the 988 Services. The Site uses cookies to enhance the experiences of Help Seekers and Site Visitors by understanding how they engage with and navigate our Site and the 988 Services. Regular cookies may be disabled or removed generally by adjusting certain settings available as part of most browsers. In some (but not all) cases, these tools can block those cookies in the future. Each browser that you use would need to be set separately, and different browsers offer different functionality and options in this regard. In addition, these tools may not be effective for certain types of cookies (e.g., HTML5 cookies). Your ability to limit cookies when you revisit our Site or the online 988 Services is subject to your browser settings and limitations. Please note that, if you disable or remove cookies on your device, some parts of our Site or online 988 Services may not function properly.
- Embedded Scripts. An embedded script is programming code designed to collect information about your interactions with the Site and the online 988 Services, such as a link that you may click on. Embedded scripts are temporarily downloaded onto your device. Embedded scripts remain active only while you are connected to the Site and are then deactivated or deleted.
This Privacy Policy refers only to the use of cookies and other Tracking Technologies by Vibrant and does not cover the use of any Tracking Technologies by any other third parties. To confirm how any third party collects or uses your information, please refer to that third party’s website.
Social Media Site(s): The Site(s) include interfaces that allow you to connect with social media sites such as Facebook, Twitter, and Instagram. If you connect to a social media site through our Site(s), you authorize us to access, use, and store the information that you agreed these social media sites could provide to us based on your settings on that social media site. We will access, use, and store that information in accordance with this Privacy Notice. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable social media sites.
In addition, if you choose to interact with us or our partners on social media sites by posting to our pages, tagging us (or using certain hashtags or other identifiers) in posts, or participating in activities, we may collect certain information from the social media account you use to interact with us, including the name associated with the account, the account handle, recent activity, the content of any posts in which we are tagged, and other information that may be contained on your social media profile to allow us to respond to the posts and understand and engage with our audience.
WHAT PERSONAL INFORMATION DO WE SHARE?
The following sections describe certain circumstances when the 988 Lifeline may share your Personal Information.
Information Shared with Contracted Parties
The 988 Lifeline employs other people and companies to perform tasks on our behalf, and the 988 Lifeline must share your information with them to provide services to you. In addition, to the extent the 988 Lifeline shares Personal Information with these parties, the 988 Lifeline only shares with them the amount of information that is minimally necessary to assist us, and our contracts with these organizations require them to comply with stringent privacy protections.
Information Shared with Other Entities including Third-Party Administrators and Contact Centers
If you are a Help Seeker, the 988 Lifeline 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. The 988 Lifeline only shares Protected Information from Help Seekers in accordance with applicable legal requirements and as SAMHSA requires.
Protection of Vibrant and Others
The 988 Lifeline may release your Personal Information when the 988 Lifeline 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 Vibrant, crisis counseling teams, Help Seekers, Site Visitors, or others. If necessary and required by law, the 988 Lifeline 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 988 Lifeline 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 988 Lifeline 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 988 Lifeline may use that De-identified Data without restriction in any way allowed by law. For example, the 988 Lifeline might use De-identified Data to understand, evaluate, or modify the Site or the online 988 Services, to generate statistical information that the 988 Lifeline shares with other third parties who are evaluating, analyzing, accrediting, or researching the 988 Lifeline. When an applicable law requires that the 988 Lifeline use a particular method of de-identifying data or rendering it no longer attributable to you, the 988 Lifeline will comply with that law. Otherwise, the 988 Lifeline may use a method that is appropriate under the circumstances and would not reasonably identify you.
IS MY PERSONAL INFORMATION SECURE?
The 988 Lifeline 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 988 Lifeline collects, maintains, uses, discloses, and processes your Personal Information, the 988 Lifeline 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 988 Lifeline exercises great care to protect your Personal Information. However, the 988 Lifeline cannot ensure the security or confidentiality of any Systems or Connections that you use to transmit information to us. Furthermore, although the 988 Lifeline takes great care to protect your Personal Information, the 988 Lifeline 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.
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 SAMHSA. We will post the most recent version of this Privacy Policy on the Site and any changes to this Privacy Policy will become effective when posted. Use of information the 988 Lifeline 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 Site or the online 988 Lifeline Services 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, reach out directly to our Privacy Officer, or write us at the following address:
Vibrant Emotional Health
80 Pine Street 18th and 19th floor
New York, NY 10005
We will make every effort to respond to your questions, concerns, and requests within a reasonable time.