PRIVACY POLICY & DIGITAL COMMUNICATIONS AGREEMENT
Effective Date: July 13, 2026

Last Updated: July 13, 2026

This Privacy Policy and Digital Communications Agreement (“Policy”) describes how our company (“we,” “us,” or “our”) collects, uses, discloses, and protects your information when you visit or interact with our website, digital platforms, or any online services where this Policy is posted (collectively, the “Website”).

Please read this Policy carefully. By accessing or using this Website, you acknowledge that you have read and understood the terms described herein. If you do not agree with the terms of this Policy, you must immediately discontinue your use of the Website.

1. CORE STATUTORY NOTICE: INSTALLATION OF ROUTING AND SIGNALING TECHNOLOGIES (PEN REGISTER DISCLOSURES)
Pursuant to the California Invasion of Privacy Act (CIPA), California Penal Code §§ 638.50–638.55, and similar state digital privacy regulations, you are hereby notified that this Website utilizes software-based tracking processes that function as routing, dialing, signaling, and addressing identifiers.

A. Explicit Consent to Signaling and Routing Software
By clicking “Accept” on our Digital Tracking Consent Banner, you provide your prior, explicit, and informed written consent to the installation, execution, and operation of software-based tools (including pixels, scripts, web beacons, and cookies) that log, analyze, and transmit your digital routing and signaling metadata. This metadata includes, but is not limited to:

Your Internet Protocol (IP) Address;

Uniform Resource Locator (URL) parameters, tracking queries, and routing pathways;

Browser configurations, device type, screen resolution, and operating system characteristics (fingerprinting data); and

Timestamps, scroll depth, and clickstream sequencing data.

B. Purpose of Deployment
These tools are deployed exclusively for commercial business purposes, including web traffic analytics, security monitoring, operational diagnostic auditing, fraud prevention, and authorized marketing optimization.

C. Absolute Right to Opt-Out / Refuse Installation
You are under no obligation to authorize these routing tools. No pen register or trap-and-trace equivalent technology will execute or capture your routing data prior to your affirmative consent. You may withdraw or modify your choices at any time via the “Do Not Sell or Share My Personal Information” link located in the footer of this Website.

2. REAL-TIME COMMUNICATIONS & INTERACTION TRACKING (WIRETAPPING DISCLOSURES UNDER CIPA § 631)
When you interact with our Website’s communication channels—including search bars, interactive forms, text inputs, and customer support chat functions—your interactions are processed dynamically and in real time.

A. No Interception In Transit
We do not intercept, nor do we allow any unauthorized third party to intercept, your live communications “in transit.” Any processing of data occurs dynamically on our servers or within authorized environments to fulfill your direct requests.

B. Authorization of Service Providers (The “Tape Recorder” Carve-out)
To the extent that third-party analytics providers (such as Google Analytics) or operational software vendors are embedded within this Website, you explicitly acknowledge and agree that:

These vendors operate strictly as contracted service providers and data processors acting as our designated agents.

They function solely as an electronic extension of our company—analogous to a dual-party utility or a digital “tape recorder”—to securely store, reassemble, and analyze telemetry data for our exclusive business use.

Except where you provide separate, heightened consent for cross-context behavioral advertising (detailed in Section 4), our vendors are contractually prohibited from independent exploitation, commercialization, or ingestion of your communication contents for their own cross-site profiling or AI model training.

C. Keystroke and Input Logging Notice
If you use our on-site search bar or fill out an online form, your character inputs and queries are processed to deliver search results or fulfill your information requests. If you do not consent to this automated processing, do not utilize the interactive text inputs, search boxes, or chat widgets on this Website.

3. CATEGORIES OF PERSONAL INFORMATION WE COLLECT
In addition to the digital telemetry described above, we collect information that identifies, relates to, describes, or is reasonably capable of being associated with you. Within the past 12 months, we have collected the following categories of personal information:

Identifiers: Real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, or account name.

Commercial Information: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Internet or Other Electronic Network Activity: Browsing history, search history, and information regarding your interaction with our Website, applications, or advertisements.

Geolocation Data: Coarse/approximate physical location derived from your IP address.

Inferences: Profiles drawn from any of the information identified above reflecting your preferences, characteristics, and behavior.

4. THIRD-PARTY TRACKING PIXELS & VENDOR DATA FLOWS
We utilize specific categories of digital tracking technologies, categorized strictly by data rights and vendor access limitations:

First-Party Analytics & Performance (e.g., Google Analytics GA4): Processes IP addresses, anonymized telemetry, page engagement paths, and device types. Contractually designated as a service provider. Data is minimized and restricted from independent third-party processing.

Cross-Context Behavioral Advertising (e.g., Meta Pixel, TikTok Pixel, LinkedIn Insight Tag): Processes browser signatures, hashed identifiers, ad conversion tracking, and content viewed. Disabled by default. Fires only upon explicit opt-in confirmation via the tracking banner. Governed by your absolute right to opt-out.

5. USE AND DISCLOSURE OF PERSONAL INFORMATION
We use your personal information to run our business, fulfill your transactions, and maintain website security. We do not sell your personal information for monetary compensation. However, under certain state laws (including the California Consumer Privacy Act/CCPA), our use of third-party advertising pixels may be classified as “sharing” or “selling” data for cross-context behavioral advertising.

We disclose personal information to the following categories of third parties:

Service providers and vendors who assist with IT infrastructure, website maintenance, and business operations.

Data analytics providers to optimize website performance.

Targeted advertising partners, provided you have granted explicit tracking authorization.

Legal authorities, when required by law to respond to subpoenas, court orders, or legal process.

6. DATA RETENTION
We retain the personal information we collect for as long as reasonably necessary to fulfill the purposes outlined in this Policy, meet our legal or compliance obligations, resolve disputes, and enforce our contractual agreements. When information is no longer required, we securely de-identify or destroy it.

7. YOUR PRIVACY RIGHTS AND HOW TO EXERCISE THEM
Depending on your jurisdiction (including California, Colorado, Connecticut, Virginia, and others), you may possess specific rights regarding your personal information, subject to legal exceptions:

Right to Know / Access: The right to request the categories and specific pieces of personal information we have collected about you.

Right to Delete: The right to request that we delete the personal information we have collected from you.

Right to Correct: The right to request that we correct inaccurate personal information.

Right to Opt-Out: The right to direct us not to “sell” or “share” your personal information for targeted behavioral advertising.

How to Exercise Your Rights
To exercise your rights to access, delete, or correct your information, please submit a request by emailing us at [email protected]  or calling us at (877) 521-6337.

Automated Privacy Signals
Our servers are configured to automatically recognize and honor Global Privacy Control (GPC) signals transmitted by your browser. If a valid GPC signal is detected, our tag managers will automatically disable all non-essential third-party tracking pixels and pen-register-equivalent tools for that browser session.

You can also manually review, revoke, or change your tracking authorizations at any time by clicking the “Manage Tracking Preferences” link located in the footer of our web pages.

8. OUT-OF-STATE JURISDICTION, FORUM SELECTION, AND WAIVER OF STATUTORY PRIVACY CLAIMS
A. Governing Law
This Website is operated by a business entity formed and headquartered outside the State of California. This Policy and any disputes arising out of the use of tracking technologies, cookies, pixels, or alleged digital surveillance shall be governed exclusively by the laws of the State of [Insert Business Home State, e.g., Delaware/Texas], without regard to conflict of law principles.

B. Explicit Forum Selection & Mandatory Individual Arbitration
By accessing this Website, interacting with its contents, or submitting any digital transmission to our servers, you explicitly agree that any and all disputes, claims, or controversies arising under the California Invasion of Privacy Act (CIPA), the federal Electronic Communications Privacy Act (ECPA), or any state wiretapping or privacy statute shall be resolved exclusively through binding, individual arbitration administered by AAA or JAMS in [Insert Corporate Headquarters City and State].

C. Class Action Waiver
CRITICAL LEGAL NOTICE: YOU AND THE COMPANY AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING. You explicitly waive any right to pursue statutory damages on a class-wide basis under California Penal Code § 637.2 or any related privacy remedy.

9. TECHNICAL PROOF AND CONSENT AUDITING
To ensure complete compliance with judicial evidentiary standards, we log and maintain time-stamped, cryptographically verifiable records of your consent state choices. These logs capture the version of the privacy policy presented to you, your anonymous session identifier, and the exact timestamp of your affirmative tracking authorization. This information is preserved solely to defend against unauthorized tracking claims and to verify corporate statutory compliance.

10. CONTACT INFORMATION
If you have any questions, concerns, or comments regarding this Policy or our digital privacy practices, please contact us at:

Company Name: Good Shepherd Health

Attn: Legal & Privacy Compliance

Mailing Address: 266 South Cleveland Street, Suite 202 | Memphis, TN 38104-3505

Email Address: [email protected]