Privacy Policy
Last updated August 5, 2022
At Master Clinician Network (“MCN,” “us” or “we”), we are committed to protecting your privacy. This Privacy Policy explains how we treat information we collect about you through our services, products, and your interactions with us via www.masterclinician.org or www.mcnslp.com (collectively, our “Services”) and how you can exercise your privacy rights. This Privacy Policy is governed by and part of our Terms of Use.
By accessing our Services in any manner, you agree to our privacy practices as described in this Privacy Policy. If you do not agree with this Privacy Policy, do not access or use our Services. If you have questions about our privacy practices or would like to make a complaint, please contact MCN at support@masterclinician.org or by mail at 1002A N Springbrook Rd #176, Newberg, OR 97132.
Personal Data
As used in this Privacy Policy, “Personal Data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Data falls within certain categories, for example:
Identifiers (e.g., name, email, telephone number, address, username);
Sensitive Personal Data (e.g., government identification number; precise geolocation; racial or ethnic origin; religious beliefs; health information; contents of messages when we are not the recipient; in some cases, information about a known child);
Legally protected information (e.g., race, citizenship, marital status, sex);
Employment-related information (e.g., current or past employment);
Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
Biometrics (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, or olfactory information;
Inferences drawn from Personal Data to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes;
Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); and
Internet or other similar activity (e.g., browsing history; content interactions).
Information that is not protected as Personal Data includes (i) publicly available information; (ii) aggregated information (meaning data summaries or reports with Personal Data removed); and (iii) anonymized information that cannot be linked back to an individual.
Code of Ethics
To use MCN Services, you must abide by the code of ethics of the American Speech-Language-Hearing Association as it pertains to client confidentiality. Clients and clinicians appearing in MCN videos have signed confidential authorization and release forms. You are strictly prohibited from disclosing any videos or other content on the Services with any third party.
HIPAA & FERPA
MCN is not subject to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). We do not claim that the Services or disclosures of information are permissible under HIPAA or other healthcare or medical laws. If MCN contracts with your educational institution, we do so as a contractor and a “school official” under the Family Educational Rights and Privacy Act (“FERPA”). Each educational institution using the Services, and not MCN, is responsible for using the Services in compliance with HIPAA and FERPA, as well as any other applicable laws and regulations governing health professions or educational institutions.
Collection & Use of Personal Data
MCN may collect Personal Data from you as a faculty, student, graduate assistant, or clinician user (“User”), a participant in a video or other content (“Participant”), or a visitor to our website. We only collect, use, retain, and disclose Personal Data as is adequate and relevant to the specific, express purposes described below or as reasonably necessary and proportionate to provide our Services or for other purposes that we disclose to you and are compatible with the context of how we collected your Personal Data.
MCN collects your Personal Data (1) with your consent as informed by this Privacy Policy and freely given at the time you provide the information; (2) if we have a legitimate interest in doing so; or (3) as authorized or required by law. Over the last 12 months, we have collected the following categories of personal information: identifiers, education and employment-related information, biometrics, sensitive Personal Data, and legally protected information. MCN collects Personal Data from:
Users, with consent – When you register to use the Services, we collect identifiers including your name, address, email, and a password to login. We also collect your educational or professional information associated with your educational institution and any details you choose to include in your profile. Please note that if you are a student or graduate assistant, the faculty User associated with your course of study can access and maintain information associated with your account. Please contact your faculty member or educational institution with any questions.
A faculty User or educational institution, as a service provider – Your faculty member or educational institution might provide MCN with Personal Data on your behalf. For example, if you are a graduate assistant, your faculty member may register and create an account or submit some or all of your account registration information on your behalf. MCN collects and uses this information in our role as a service provider to provide the Services to you and your educational institution. We do not control or verify the information provided to us by a faculty User or educational institution. If you have any questions about information on your account not input by you directly, please contact your faculty member or educational institution.
Participants, with consent – If you are a Participant in a video or other content on the Services, MCN may collect your name or other identifiers, your image and audio, health information, and information about yourself or your family life that relate to the purpose of the video. MCN collects this information with your consent, subject to a confidentiality agreement and waiver, and we use it to provide and improve the Services for faculty, student, and clinician Users. MCN cannot control the privacy practices of educational institutions or Users of the Services. An educational institution or User may choose to use a video or other content according to their own privacy practices. MCN is not responsible for any other party’s compliance or noncompliance with a code of ethics or any laws or regulations. Please contact the Medical Center or Educational Institution directly if you have questions about their privacy practices.
Website visitors, with a legitimate interest – When you visit MCN’s website or otherwise interact with the Services, MCN automatically collects data about your internet activity such as your IP address, internet service provider, browser, information, device data, date and time of access, and the content with which you interact. We collect this information to achieve our legitimate interest of managing and improving our Services. We use this information to administer the website, provide and improve the Services, analyze usage, protect the Services and its content from inappropriate use, and improve the nature and marketing of the Services.
Other Uses of Personal Data
In addition to the uses specified above, MCN uses your Personal Data to provide you with the Services, for our internal business purposes, and to: (i) fulfill any purpose to which you consent; (ii) monitor your compliance with our agreements and policies; (iii) help maintain the safety, security, and integrity of our technology assets; (iv) conduct internal testing, research, analysis, and product development, including to develop and improve our content and offerings; (v) personalize your experience or deliver targeted ads according to your consent and stated preferences; (vi) respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; (vii) identify, contact, or bring legal action against persons or entities who may be causing injury to you, to MCN, or to others as we determine necessary; or (viii) evaluate or conduct a business transition involving some or all of our company assets where Personal Data held by MCN is among the assets transferred.
We will not collect additional categories of Personal Data or use already collected Personal Data for purposes that are materially different, unrelated, or not reasonably necessary or compatible with the original purpose without notice and consent to you as required by law.
Sensitive Personal Data
MCN only collects sensitive Personal Data as necessary for videos on certain subjects related to health information with consent. In no case will MCN use your sensitive Personal Data in any manner without your consent or disclose any sensitive Personal Data for the purpose of inferring characteristics about you. If this ever changes in the future, we will update this Privacy Policy and provide you with methods to opt-out or limit our use and disclosure of sensitive Personal Data.
Children’s Privacy
The Services are intended for use by adults, not children. MCN obtains parent or guardian consent before collecting any Personal Data from children. If we learn we have collected or received Personal Data from a child without parent or guardian consent, we will delete that information. Please contact support@masterclinician.org if you believe we might have collected any information without necessary authorization.
Disclosing Personal Data
MCN will only disclose Personal Data to the third parties as described in this section, with your permission, or as required by law. In the preceding 12 months, we have disclosed Personal Data for a business purpose to:
Service Providers. MCN’s third-party service providers like email and data hosting providers, IT service providers, billing processors, and payment processors may have access to Personal Data as needed to perform their contractual obligations to MCN. We prohibit our service providers from selling or disclosing the Personal Data we provide, and we require all service providers to maintain confidentiality standards and appropriate technical and organizational measures to ensure the security of your Personal Data.
Law enforcement, and other governmental agencies, as permitted or required by law.
Other third parties, as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.
No Sale of Personal Data
MCN does not exchange Personal Data with third parties for monetary or other valuable consideration. If this changes in the future, we will update this Privacy Policy and provide you with a method to opt-out.
Aggregated and Deidentified Information
MCN reserves the right to share aggregated, anonymized, or deidentified information about any individuals with nonaffiliated entities for marketing, advertising, research or other purposes, without restriction.
Retaining Personal Data
MCN only retains Personal Data for the minimum period necessary to provide our Services or achieve our business goals. For example, we retain information associated with your User account while your account remains active. Personal Data included in our videos or other content is retained as long as the video remains relevant to our provision of Services, subject to the applicable confidentiality agreements and waivers. Other information is retained according to our company policies and code of ethics. We securely delete data at the conclusion of the applicable retention period. MCN reserves the right to retain data for longer periods as required by law or court order or if doing so is critical to our business.
Controlling Your Personal Data
MCN provides you a variety of methods and options to directly control how we collect and use your Personal Data:
Your Account Profile and Device Settings – Users can login to access, update, or delete certain Personal Data in their account at any time. You can also control the data we collect by adjusting your device settings.
Emails from MCN – If you provide us with your email address, we may send you informational or support emails or, if you opt-in, marketing emails about the Services. You can opt-out of marketing emails but not our service emails. To opt-out, change your preferences via the links provided in the emails or write to support@masterclinician.org.
Texting Consent – If you provide MCN with your wireless number, you consent to MCN sending you text messages for informational or authentication purposes. The number of texts that we send to you will be based on your circumstances and requests. You can unsubscribe from text messages by replying STOP or UNSUBSCRIBE to any of these text messages. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.
Do Not Track Requests – Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests. If this changes in the future, we will update this Privacy Policy.
Consumer Privacy Requests – If you wish to exercise your rights beyond the methods provided, express concerns, lodge a complaint, or obtain additional information about the use of your Personal Data, please contact your educational institution. Alternatively, you can send us a Consumer Privacy Request or email MCN at support@masterclinician.org. We will relay your request to your educational institution or fulfill it directly if we can. MCN does not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We endeavor to respond to privacy requests in accordance with the requirements of the law applicable to your jurisdiction. If we do not fulfill your request within the legally required timeline, you can appeal our response by contacting MCN at support@masterclinician.org or by mail at 1692 Orenco Station Parkway, Hillsboro, OR 97124.
United States Consumer Privacy Rights
In the United States, consumer privacy is governed by federal privacy laws covering specific industries or data uses and state privacy laws providing with general consumer privacy rights. This section provides informational notices for state privacy laws like the California Consumer Privacy Act of 2018 (“CCPA”) and similar laws in Colorado, Connecticut, Nevada, Utah, Virginia, and other states require companies to inform consumers about their privacy rights and provide a method to exercise those rights. Residents of states offering privacy protections (each a “Consumer”) can exercise their privacy rights as applicable to our Services by submitting a Privacy Request. MCN offers these notices as a courtesy with respect to any privacy law not applicable to MCN.
Right to Correct. You have the right to request that we correct inaccurate Personal Data about you on our systems. If you become aware that the Personal Data that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.
Right to Deletion. You have the right to request that we delete your Personal Data that we collected and retained, with certain exceptions. MCN may permanently delete, deidentify, or aggregate the Personal Data in response to a request for deletion.
Right to Access. You have the right to request confirmation that we have collected Personal Data about you and that we provide you with access to that Personal Data. If you submit an access request, we will provide you with copies of the requested pieces of Personal Data in a portable and readily usable format. Please note that MCN may be prohibited by law from disclosing certain pieces of Personal Data, and we may be limited in the number or frequency of requests we must fulfill.
Right to Disclosure. You may request that we disclose information to you about our collection and use of your Personal Data, such as: (i) the categories of Personal Data we have collected about you; (ii) the categories of sources for the Personal Data we have collected about you; (iii) our business purpose for collecting, using, processing, sharing or selling that Personal Data, as applicable; (iv) the categories of third parties with whom we share that Personal Data; and (v) if we sold or shared your Personal Data under the CCPA, two separate lists stating: (a) sales or sharing, identifying the Personal Data categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained. Certain laws may limit the number or frequency of requests we must fulfill.
Limited Use and Disclosure of Sensitive Personal Data. You have the right to opt-out or limit our use of your sensitive Personal Data. MCN only collects sensitive Personal Data with your consent and as necessary for videos on certain subjects related to health information. In no case will MCN use your sensitive Personal Data in any manner without your consent or disclose any sensitive Personal Data for the purpose of inferring characteristics about you. If this ever changes in the future, we will update this Privacy Policy and provide you with methods to opt-out or limit our use and disclosure of sensitive Personal Data.
No Selling or Sharing. Some states entitle consumers to opt-out of the sale or sharing of Personal Data or targeted advertising practices. MCN does not sell your Personal Data or share your Personal Data with third parties for cross-contextual behavioral advertising purposes. If this changes in the future, we will update this Privacy Policy and provide you with a method to opt-out.
No Profiling. You have the right to opt-out of automated profiling. MCN does not process your Personal Data to evaluate, analyze, or predict your interests and preferences or otherwise use automated profiling to produce significant effects that concern you. If this changes in the future, we will update this Privacy Policy and provide you with a method to opt-out.
Right to Nondiscrimination. We will not discriminate against you for exercising your privacy rights. For example, unless permitted by law we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services; (iii) provide you a different level or quality of goods or services; (iv) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under applicable privacy laws.
Right to Disclosure of Marketing Information. California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California residents to request certain disclosures regarding Personal Data sharing with affiliates and/or third parties for marketing purposes.
European Economic Area and United Kingdom Privacy Rights
This section provides the disclosures and notices required under the General Data Protection Regulation (“GDPR”) and its counterpart regulation applicable to residents of the United Kingdom. This section applies solely to residents of the European Economic Area (“EEA”) and the United Kingdom (“Data Subjects”). When serving educational institutions, MCN collects and processes Personal Data of Data Subjects as a processor. Data Subjects have the following rights over their Personal Data, subject to applicable limitations:
Right to know how we process your Personal Data. We have set the required notices in this Privacy Policy. We may provide you with additional notices about other ways we process your Personal Data by sending you a notice via email or by another method. If you have questions or concerns, you can contact us any time at support@masterclinician.org.
Right to access your Personal Data. Upon request, we will provide you with a copy of your Personal Data and details about the types of Personal Data we process, why we process it, and any third parties we work with to collect Personal Data on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example, to protect the rights of other individuals.
Right to restrict processing of your Personal Data. You can request that we restrict the processing of your Personal Data if: (a) the data is inaccurate; (b) the processing is unlawful; (c) we no longer need the Personal Data; or (d) you exercise your right to object.
Right to rectify your Personal Data. If you become aware that the Personal Data that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.
Right to data portability. In some circumstances, we are required to provide your Personal Data to another organization at your request and in a structured, commonly used and machine-readable format.
Right to erasure (a.k.a. the “right to be forgotten”). Upon your request, we must delete your Personal Data in certain circumstances and where required by law. This right is not absolute, and we may be entitled to retain and process your Personal Data despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Data.
Right to object to certain processing of your Personal Data. Upon your request, we will limit our processing of your Personal Data as you request in certain circumstances and where we are required to do so by law.
Right not to be subject to automated decision-making. MCN does not use automated decision-making to provide the Services. If this changes in the future, we will update this posting to describe our use of automated decision-making and your options to exercise your privacy rights related to your Personal Data processed using automated decision-making.
Right to lodge a complaint with a supervisory authority. Data Subjects can submit requests, questions, or complaints to MCN using the methods described under Privacy Requests. If, after contacting us, you feel a privacy issue has not been resolved, you have the right to file a complaint with a supervisory authority. We suggest the Data Protection Commissioner of Ireland.
Canadian Privacy Rights
This section provides the disclosures and notices required under Canada’s Personal Data Protection and Electronic Documents Act (“PIPEDA”) and solely to residents of Canada where PIPEDA applies (“Canadian Consumers”). PIPEDA gives Canadian Consumers specific rights regarding Personal Data offering details on an identifiable person without the inclusion of name, title, telephone number, and business address of an employee of a business or organization. The rights afforded under PIPEDA are described below.
Right to know why we collect, use, and distribute the Personal Data we process. We have set the required notices in this Privacy Policy. We may provide you with additional notices about other ways we process your Personal Data, such as by sending you a notice via email or by other means of communication.
Right to expect us to collect, use, or disclose Personal Data responsibly and not for any other purpose other than which you consented. We set your expectations in this Privacy Policy and collect express or implied consent at various stages of collection or processing. If we collect or use your Personal Data based on your consent, we will also notify you of any changes and will request your further consent as needed. You may withdraw your consent at any time with reasonable notice by contacting us at support@masterclinician.org.
Right to accuracy of your Personal Data. We take steps to reasonably ensure that your Personal Data we are using is accurate. If you become aware that the Personal Data that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.
Right to access your Personal Data. Upon written request and identity authentication, we will provide you with your Personal Data under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within 30 days or provide written notice where additional time is required to fulfil the request. We may not be able to provide access to some or all of the Personal Data you request if limited by law or potential infringement of another’s privacy rights. If we must refuse an access request, we will notify you in writing, document the reasons for refusal, and outline further steps that are available to you.
Consent to Cross-Border Data Transfers
MCN is owned and operated in the United States and is designed to serve educational institutions and Users located in the United States. If you are a User or Participant who is a non-US resident or if you visit the website from outside of the United States, you acknowledge that Personal Data we collect about you will be transferred to our servers in the United States and maintained there in accordance with our retention policy. This may require the transfer of your Personal Data out of your country of origin with laws governing data collection and use that may differ from or be more restrictive than U.S. law, or may result in governments, courts, law enforcement, or regulatory agencies having access to or obtaining disclosure of your Personal Data pursuant to the laws of the applicable foreign jurisdiction. By allowing us to collect Personal Data about you, you consent to this Privacy Policyand the transfer and processing of your Personal Data as described in this paragraph, and you waive any and all remedies that you may have based on the laws of your jurisdiction.
Cookies
Cookies are small text files downloaded and stored on your computer or mobile device when you visit or use an online platform. Cookies help the platform recognize your device, store your preferences, or perform certain functions for the platform. Cookies are used for functionality, security, analytics, or advertising. Some cookies are strictly necessary to the function of the website or other platform, while others enable certain features.
MCN uses the following functionality cookies on the Services:
Stripe cookies to enable payment processing on the website (e.g., stripe_mid, __stripe_sid, __stripe_orig_props, and cid).
Google Analytics to support Stripe functionality on the Services (e.g., ga_SEKYWD1C9J, _gat_UA-12675062-1, _gat_UA-12675062-8, _gat, _ga, _gcl_au, _gid).
You can read about Stripe Cookies to learn more about the cookies that support Stripe functionality.
You can directly control how cookies interact with your device. You can change your device settings to alert you when cookies are sent to your device, or to refuse some or all cookies from being set on your device. Alternatively, you can install a third-party plugin to control cookie behavior. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly. If you get a new device, install a new browser, or erase or alter your device’s cookie file or privacy settings, your privacy preferences may not be saved.
Data Security
MCN has implemented and maintains reasonable security measures to secure your Personal Data from accidental loss and unauthorized access, use, alteration, and disclosure. For example, MCN’s website uses the highest levels of encryption and password identification to ensure its security. Our security measures are appropriate to the volume, scope, and nature of the personal data processed and designed to meet our duty of care with respect to your Personal Data. Please note that submission of information over the Internet is never entirely secure. You are responsible for keeping your device access and login information confidential. You are also encouraged to install anti-virus and anti-malware software on your devices and keep all software updated to avoid security risks. We cannot guarantee the security of information you submit via our Services while it is in transit over the Internet, and any such submission is at your own risk.
Third-Party Services
This Privacy Policy does not apply to any third-party platforms or services, or any third-party services linked or accessible from our Services. When using our Services, you may have the option to link from or access third-party services via the Services. Please note that MCN has no control over third-party websites, apps, devices, or systems, and you should exercise caution when deciding to disclose your Personal Data.
Changes to this Privacy Policy
MCN may update this Privacy Policy from time to time. You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy. We will notify you about material changes to this Privacy Policy by email or by other measures that are appropriate to provide you with notice. We will collect your consent to these changes to the extent required by applicable law.