Last modified: 3/15/19

Introduction

Janus Associates, Inc., dba BHS (“BHS” or “We”), an Employee Assistance Program (“EAP”), Workplace Wellness Program and a Guide + Thrive Program respects your privacy and is committed to protecting the privacy and security of information through compliance with this privacy policy (this “Privacy Policy”). We believe in protecting the privacy of your information in accordance with any and all applicable laws, regulations, and standards, including, but not limited to, any standards established in the United States under the Health Insurance Portability and Accountability Act (“HIPPA”) and the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), effective as of May 25, 2018.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.bhsonline.com (our “Website”) or otherwise provide information to BHS. This Privacy Policy is designed to explain our practices for collecting, using, maintaining, protecting, and disclosing that information. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

What Kind of information do we collect?

Information Automatically Collected

BHS only collects information about your computer hardware and software automatically. This information can include: your IP address, browser type, domain names, access times, and referring website addresses. BHS also keeps track of the pages our customers visit within our Website in order to determine what BHS services are the most popular.

Information Collected with Your Consent

Depending on your choices, products, and services (e.g., for behavioral and health services), BHS may with your explicit consent collect and process personal information (“PHI”), which may include the following:

(1) name
(2) mailing/physical address
(3) e-mail address
(4) telephone number
(5) social security number
(6) date of birth/other vital statistics records
(7) racial or ethnic origin
(8) sexual orientation or religious beliefs
(9) private ID number/residency number
(10) personal health information
(11) family health information.

Other Information You Provide to Us

We may also collect and process information that you provide by filling in forms on our Website or communicate by other means. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of our Website or transmitted to other users of our Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Additionally, we cannot control the actions of other users of our Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through BHS’ public message boards, if any, this information may be collected and used by others.

BHS does not read any of your private online communications. BHS encourages you to review the privacy statements of websites you choose to link to from BHS so that you can understand how those websites collect, use and share your information. BHS is not responsible for the privacy statements or other content on websites outside of the BHS and BHS family of websites.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

(1) Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on our Website.

(2) Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

(1) Estimate our audience size and usage patterns.

(2) Store information about your preferences, allowing us to customize our Website according to your individual interests.

(3) Speed up your searches.

(4) Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

(1) Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

(2) Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

(3) Web Beacons. Pages of our our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

How will your personal information be used?

Your employer will not have access to your personal data stored on BHS or its affiliates systems. If your employer offers an incentive plan that offers rewards for completion of BHS’s online programs, with your explicit consent via tick box on the registration page, BHS may share your personal information with your employer including your name, employee identification number, and details of which online programs or assessments were completed. Neither the scores, nor responses, from your online programs will be disclosed to your employer as part of an incentive plan.

If your employer provides a coaching plan that includes an outreach call from a BHS coach, with your explicit consent via the tick box on the registration page, a coach may contact you using the contact information and preferences you provide. Your employer will not be given any detail regarding the content of your discussion with a coach; however, BHS may share with your employer your personal data including your name, employee ID, and number of coaching sessions your have completed, and the date(s) on which coaching sessions were completed.

What is information transfer?

BHS may transfer the personal information collected about you to countries other than the country in which the information was originally collected. These transfers will be to a service center operated by BHS or one of BHS’ network of providers in order to provide you with the service you requested. BHS adheres to adequate safeguards required for the international transfer of your personal information to and from the European Economic Area. Significantly, access to your personal information may be provided only on a “need-to-know” basis so that BHS may deliver its services upon your request. Unless you provide written consent to the contrary, your personal information will not be disclosed to any other person or entity other than in aggregate reports or in de-identified form without your written consent.

Who do we share your information with?

BSH does not sell your contact information or other information identifying you to third parties. Where necessary to pursue the objectives set out in this policy, however, we do share your information with affiliates and other selected third parties.

Consistent with applicable law, we may share personal information that we collect or you provide as described in this Privacy Policy with:

(1) our subsidiaries and affiliates.

(2) contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

(3) a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of BHS’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by BHS about our Website users is among the assets transferred.

(4) other parties on an “as needed” basis to fulfill the purpose for which you provide it or for any other purpose disclosed by BHS when you provide the information.

What information may be required to be disclosed?

Under certain circumstances, BHS may be expected or required to disclose personal information. The circumstances include those as set out in Article 6.1 of the GDPR, which establishes that processing shall be lawful only if and to the extent that at least one of the following applies:

(1) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;

(2) processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;

(3) processing is necessary for compliance with a legal obligation to which the controller is subject;

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on our Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on our Website or through any of its features, register on our Website, utilize our Website, use any of the interactive features of our Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at coach@bhsonline.com.

Changes to Our Privacy Policy

It is our policy to post any changes we make to this Privacy Policy on this page of our Website. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on our Website home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions, provide comments, or register a complaint or concern about this Privacy Policy, our privacy practices, or the collection of your information, please contact us at:

Data Protection Officer of BHS
Janus Associates, Inc., dba BHS
6225 Smith Avenue, Suite 203
Baltimore, MD 21209
coach@bhsonline.com