SOMERSET HOUSE AND NOTICE OF PRIVACY PRACTICES THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Somerset House take the protection of personal information very seriously.  This Notice of Privacy Practices (“Notice”) is given to you by the Community to describe the ways in which the Community may use and disclose your information (called “protected health information” or “PHI”) and to notify you of your rights with respect to PHI used and disclosed by the Community.  PHI is information that may identify you and that relates to your past, present, or future physical or mental health or condition; the provision of health care services to you; or the payment for such services. 

The Community is required by law to maintain the privacy of your PHI, to provide individuals with notice of their legal duties and privacy practices with respect to PHI, and to abide by the terms described in this Notice. The Community reserves the right to change the terms of this Notice and of its privacy policies, and to make the new terms applicable to all of the PHI it maintains. Before the Community makes a material change to its privacy policies, it will promptly revise this Notice and post a new Notice in registration, admitting areas and its website.  

This Notice applies to the affiliated covered entities of Somerset House. The affiliated covered entities of the Community are found on Exhibit A on the back of this Notice and may share protected health information with each other as if they were a single covered entity. 

Because the Community comprises operations that are not defined as covered operations as defined by HIPAA, the Community has decided to designate itself as a hybrid entity. This Notice applies to the privacy practices of the following health care components included in the hybrid entity that may share your Protected Health Information as needed for treatment, payment, and health care operations other non-covered operations shall be protected under applicable laws. If you have questions regarding such practices, please let us know.   

Uses and Disclosures of PHI for which Authorization is Not Required

The Community may use or disclose your PHI for the purposes of treatment, payment and health care operations, described in more detail below, without obtaining written authorization from you. 

FOR TREATMENT: The Community may use and disclose PHI in the course of providing, coordinating, or managing your medical treatment, including the disclosure of PHI for treatment activities at another healthcare facility. These types of uses and disclosures may take place between physicians, nurses, technicians, and other health care professionals who provide your health care services or are otherwise involved in your care. For example, if you are being treated by a primary care physician, that physician may need to use/disclose PHI to a specialist physician whom he or she consults regarding your condition, or to a nurse who is assisting in your care. 

FOR PAYMENT: The Community may use and disclose PHI in order to collect payment for the health care services provided to you. For example, the Community may need to give PHI to your health plan in order to be reimbursed for the services provided to you. The Community may also disclose PHI to their business associates, such as billing companies, claims processing companies, and others that assist in processing health claims. The Community may also disclose PHI to other health care providers and health plans for the payment activities of such providers or health plans. 

FOR HEALTH CARE OPERATIONS: The Community may use and disclose PHI as part of their operations, including for quality assessment and improvement, such as evaluating the treatment and services you receive and the performance of our staff in caring for you. Other activities include hospital and personnel training, underwriting activities, compliance and risk management activities, planning and development, and management and administration. The Community may disclose PHI to doctors, nurses, technicians, attorneys, consultants, accountants, and others for review and learning purposes. These disclosures help make sure that the Community is complying with all applicable laws and continue to provide quality health care to patients. The Community may also disclose PHI for certain operations, including quality assessment and improvement activities, credentialing and peer review activities, and health care fraud and abuse detection or compliance.  

FOR SHARING PHI AMONG THE COMMUNITY AND PROFESSIONAL STAFF: The Community works together with physicians and other care providers on their professional staff to provide medical services to you when you are a resident at the Community and members of their respective professional staff will share PHI with each other as needed to perform their treatment, payment and health care operations activities. In addition to using or disclosing PHI for treatment, payment and health care operations, the Community may use and disclose PHI without your written authorization under the following circumstances: 

BUSINESS ASSOCIATES:  The Community may use or disclose your PHI with outside companies that perform services for us such as monitoring, operations, accreditation, legal, computer, or auditing services. These outside companies are called “Business Associates” and are required by HIPAA and by contract to keep your medical information confidential. 

INDIVIDUALS INVOLVED IN YOUR CARE: The Community may share your PHI with a family member, guardian or other individuals who are involved in your care, or who help pay for your care. If you have any objection to sharing your PHI in this way, please contact the Executive Director, whose contact information is listed at the end of this Notice. 

TO YOU OR YOUR PERSONAL REPRESENTATIVE:  The Community may disclose your PHI to you, or a representative appointed by you or designated by applicable law. 

AS REQUIRED BY LAW AND LAW ENFORCEMENT: The Community may use or disclose PHI when required by law, the Community also may disclose PHI when ordered to in a judicial or administrative proceeding; in response to subpoenas or discovery requests; to identify or locate a suspect, fugitive, material witness, or missing person; when dealing with gunshot and other wounds; about criminal conduct; to report a crime its location or victims, or the identity, description, or location of a person who committed a crime; or for other law enforcement purposes. 

JUDICIAL AND ADMINISTRATIVE PROCEEDINGS: Your PHI may be disclosed in response to a court or administration order, subpoena, discovery request, or other lawful process. 

FOR PUBLIC HEALTH ACTIVITIES AND PUBLIC HEALTH RISKS: The Community may disclose PHI to government officials in charge of collecting information about births and deaths, preventing and controlling disease, reports of child abuse or neglect and of other victims of abuse, neglect, or domestic violence, reactions to medications or product defects or problems, or to notify a person who may have been exposed to a communicable disease or may be at risk of contracting or spreading a disease or condition. 

FOR HEALTH OVERSIGHT ACTIVITIES: The Community may disclose PHI to the government for oversight activities authorized by law, such as audits, investigations, inspections, licensure or disciplinary actions, and other proceedings, actions, or activities necessary for monitoring the health care system, government programs, and compliance with civil rights laws. 

CORONERS, MEDICAL EXAMINERS, AND FUNERAL DIRECTORS: The Community may disclose PHI to coroners, medical examiners, and funeral directors for the purpose of identifying a decedent, determining a cause of death, or otherwise as necessary to enable these parties to carry out their duties consistent with applicable law. 

ORGAN, EYE, AND TISSUE DONATION: The Community may release PHI to organ procurement organizations to facilitate organ, eye, and tissue donation and transplantation.  

RESEARCH: Under certain circumstances, the Community may use and disclose PHI for medical research purposes. A researcher may have access to information that identifies you only through the special review process, or with your written permission. In addition, researchers may contact patients regarding their interest in participating in certain research studies. Researchers may only contact you if they have been given approval to do so by the special review process. You will only become a part of one of these research projects if you agree to do so and sign a consent form. 

TO AVOID A SERIOUS THREAT TO HEALTH OR SAFETY: The Community may use and disclose PHI to law enforcement personnel or other appropriate persons, to prevent or lessen a serious threat to the health or safety of a person or the public. 

LAWSUITS AND DISPUTES: If you are involved in a lawsuit or a dispute, the Community may disclose health information about you in response to a court or administrative order.  

SPECIALIZED GOVERNMENT FUNCTIONS: The Community may use and disclose PHI of military personnel and veterans under certain circumstances and may also disclose PHI to authorized federal officials for intelligence, counterintelligence, and other national security activities, and for the provision of protective services to the President or other authorized persons or foreign heads of state or to conduct special investigations.  

WORKERS’ COMPENSATION: The Community may disclose PHI to comply with workers’ compensation or other similar laws that provide benefits for work-related injuries or illnesses. 

HEALTH-RELATED BENEFITS AND SERVICES; LIMITED MARKETING ACTIVITIES: The Community may use and disclose PHI to inform you of treatment alternatives or other health-related benefits and services that may be of interest to you, such as disease management programs.  

DISASTER RELIEF: The Community may disclose medical information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status, and location.  

DISCLOSURES FOR HIPAA COMPLIANCE INVESTIGATIONS: The Community may disclose your PHI to the Secretary of the U.S. Department of Health and Human Services (the “Secretary”) when requested by the Secretary to investigate compliance with privacy regulations issued under the federal Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).  

Other Uses and Disclosures of PHI for Which Authorization Is Required: Other types of uses and disclosures of your PHI not described above will be made only with your written authorization, which you have the limited right to revoke in writing.  Your PHI may not be used or disclosed for marketing purposes or sold by the Community without your prior written authorization.  If you sign a written authorization permitting uses and disclosures of your PHI other than those described in this Notice, you may revoke your authorization by submitting a written request to the Executive Director at any time. However, the Community is unable to retract or invalidated any uses or disclosures that were made with your permission before you revoked your authorization.   

HIPAA provides additional protection for psychotherapy notes, and most uses or disclosures of psychotherapy notes require your written permission.  Psychotherapy notes are the personal notes of a mental health professional about a private or group counseling session. 

In addition, other types of information may have greater protection under federal or state law, such as certain drug and alcohol information, HIV/AIDS and other communicable disease information, genetic information, mental health information, or information about developmental disabilities. For this type of information, we may be required to get your written permission before disclosing it to others; we may seek that permission in Insight’s intake forms if permitted by law. If you have any questions about this, contact the Executive Director, whose contact information is provided at the end of this notice. 

You have the following rights regarding your PHI You have the following rights regarding your PHI.  All Requests must be submitted in writing to the Executive Director.  Please contact the Executive Director for additional information regarding any of these rights.  The contact information for the Executive Director can be found at the end of this Notice. 

You may request the Community restrict the use and disclosure of your PHI. The Community is not required to agree to any restrictions you request, but if the entity does so it will be bound by the restrictions to which it agrees except in emergency situations. To request restrictions, you must make your request in writing. In your request, you must tell us: (1) What information you want to limit; (2) Whether you want to limit our use, disclosure, or both; and (3) to whom you want the limits to apply, for example, disclosures to your spouse. 

You have the right to request that communications of PHI to you from the Community be made by particular means or at particular locations. For instance, you might request that communications be made at your work address, or by e-mail rather than regular mail. Your requests must be in writing and sent to the Executive Director. The Community will accommodate your reasonable requests without requiring you to provide a reason.  

Generally, you have the right to inspect and/or copy your PHI in the possession of The Community within a Designated Record Set if you make a request in writing to the Medical Records Department. The Community will inform you of the extent to which your request has or has not been granted. In some cases, the Community may provide you a summary of the PHI you request if you agree in advance to such a summary and any associated fees. If you request copies of your PHI or agree to a summary of your PHI, the Community may impose a reasonable fee to cover copying, postage, and related costs. If the Community denies access to your PHI, it will explain the basis for denial and your opportunity to have the denial reviewed by a licensed health care professional (not involved in the initial denial decision) designated as a reviewing official. If the Community does not maintain the PHI you request, if it knows where that PHI is located it will tell you how to redirect your request.  

If you believe that your PHI maintained by the Community in a Designated Record Set contains an error or needs to be updated, you have the right to request that the Community correct or supplement your PHI. Your request must be made in writing, and it must explain why you are requesting an amendment to your PHI. Within sixty (60) days of receiving your request (unless extended by an additional thirty (30) days), the Community will inform you of the extent to which your request has or has not been granted. The Community generally can deny your request if your request relates to PHI: (i) not created by the Community; (ii) that is not part of the records the Community maintains; (iii) that is not subject to being inspected by you; or (iv) that is accurate and complete. If your request is denied, the Community will give you a written denial that explains the reason for the denial and your rights to: (i) file a statement disagreeing with the denial; (ii) submit a request that any future disclosures of the relevant PHI be made with a copy of your request and the Community’s denial attached, if you do not file a statement of disagreement; and (iii) complain about the denial.  

You generally have the right to request and receive a list of certain types of disclosures of your PHI the Community has made during the six (6) years prior to your request. The list will not include disclosures (i) for which you have provided a written authorization; (ii) for treatment, payment, and health care operations; (iii) made to you; (iv) for a Community patient directory or to persons involved in your health care; (v) for national security or intelligence purposes; (vi) to correctional institutions or law enforcement officials; or (vii) of a limited data set. You should submit any such request to the Executive Director, and within sixty (60) days of receiving your request (unless extended by an additional thirty (30) days), the Community will respond to you regarding the status of your request. The Community will provide the first accounting you request in any 12-month period free of charge.  The Community may impose a reasonable, cost-based fee for each subsequent request for accounting within the 12-month period. The Community will notify you of the fee in advance and provide you with an opportunity to withdraw or modify your request. 

You have the right to receive a paper copy of this notice upon request even if you have agreed to receive this notice electronically.  To obtain a paper copy of this notice, please contact the Executive Director, whose contact information is provided at the end of this Notice.  

You have the right to receive notice in the event of a breach of confidentiality. As required by law, the Community will notify you of any breach of your PHI that is unsecured, as defined by law 

You have the right to restrict disclosures of PHI to health plans if you have paid for services out of pocket in full Complaints

You may complain to the Community if you believe your privacy rights with respect to your PHI have been violated by contacting the Executive Director, whose contact information provided at the end of this Notice and submitting a written complaint. The Community will not penalize you or retaliate against you for filing a complaint regarding their privacy practices. 

You also have the right to file a complaint with the Secretary of the Department of Health and Human Services.  To submit a complaint to the Department of Health and Human Services, you must contact the Office for Civil Rights of the Department of Health and Human Services, Hubert H. Humphrey Building, 200 Independence Avenue, SW, Room 509F, Washington, D.C. 20201.  Further information and regional contact information is also available on the Office for Civil Rights’ website at www.hhs.gov/ocr/hipaa. 

Somerset House and its affiliates (“Somerset House,” “we,” “us,” or “our”) value your privacy and are committed to protecting your personal information. This Privacy Policy outlines the types of information we collect, how we use and share it, your rights under applicable laws, including California Consumer Privacy Laws, and the measures we take to protect your privacy. 

Scope of Policy and Information Collection

This Privacy Policy applies to personal information collected through Somerset House’s website, services, and interactions, including:

• Data collected via cookies, third-party tools, and analytics.
• Email marketing communications and associated tracking.
• Advertising, remarketing, and data-matching activities conducted through digital channels.
  
  

For California residents, this policy incorporates rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

Information We Collect

We may collect personal information such as:

• Identifiers: Name, email address, telephone, physical address, IP address, and device identifiers.
• Sensitive Information: Health-related data, and other sensitive data as needed to provide care or services.
• Behavioral Data: Website usage, geolocation, browsing history, email engagement (e.g., clicks, opens), and inferred interests for analytics and advertising purposes. 

How We Collect Data

• Directly from you: When you provide information through forms, surveys, or interactions (e.g., contact forms, email sign-ups, event registrations).
• Automatically: Via cookies, tracking pixels, and third-party analytics tools (e.g., Google Analytics, Facebook Pixel, email marketing platforms).
• Through third-party sources: Such as advertising networks, data aggregators, affiliates, and public databases.

We collect or obtain data relating to you in a variety of ways, as described below. Such data may include personal data, i.e., information that alone or in combination with other information identifies you as an individual or can be reasonably linked to your identity.

Data You Provide: When you submit questions, request information, or give us feedback via this Site, we may ask you for data, like your name, postal address, telephone, and email address so we can respond or follow up. We may also ask you to provide other data relevant to your question, request, or feedback, such as your geographical location, industry, and preferred contact method.

You may also make requests through this Site to exercise your individual rights under applicable privacy laws. We will collect and maintain data related to such requests in order to respond to you and for our audit and legal compliance purposes.

We generally do not seek data that may be considered “special” or “sensitive” personal data (e.g., government-issued identification or information related to an individual’s racial or ethnic origin, political opinions, religious or other beliefs, health, criminal background, or trade union membership) from visitors of this Site, and we ask that you do not provide such data. If we specifically require “special” or “sensitive” personal data in connection with one or more of the uses described below, we will request your consent to use the data in accordance with this Privacy Statement and/or in the ways described at the point where you were asked to disclose the data. If you voluntarily share with us or post/upload any “special” or “sensitive” personal data to this Site for any other reason, you consent that we may use such data in accordance with applicable law and this Privacy Statement.

Please note that any information or materials you post or disclose on this Site via message boards, chats, profile pages, blogs, and other services (including social media services) are publicly available and will be seen by other visitors to this Site. You should consider this when deciding to disclose any personal data or any other information on this Site.

Data Collected from your Use of this Site: We automatically receive certain data about the computer or device you are using when you visit this Site, including: your Internet Protocol (IP) address; information about the browser or type of device you are using; data collected through cookies, pixel tags, and other similar technologies (as described below in the “Cookies and Other Internet Technologies” section); the date and time of your visit; and the web page you visited immediately prior to visiting this Site. We also collect data about videos or other content you view on this Site, like the type and name of the content and the time viewed.

Purpose of Data Collection and Use

We may use personal information for data-matching purposes to improve security, enhance services, and personalize user experiences. This includes fraud prevention by identifying and blocking unauthorized activities or access, customer profiling to better understand user demographics and behavior, and tailoring services by providing recommendations, offers, and content that align with individual preferences. Additionally, data matching helps optimize website navigation, improve content relevance, and ensure seamless service delivery. To comply with applicable laws, we conduct all data-matching activities in a lawful, fair, and transparent manner. Users can opt out of data matching, where applicable, by contacting us directly or adjusting their cookie preferences.

We use your email address and engagement data, such as email opens and link clicks, to deliver newsletters, promotions, and updates specifically tailored to your interests. This information allows us to analyze the performance of our email campaigns and refine our messaging to better suit your preferences. Additionally, your interaction history helps us customize future communications to ensure relevance. Should you choose to stop receiving marketing emails, you can unsubscribe at any time by clicking the “Unsubscribe” link in the email footer or contacting us directly. Please note that unsubscribing will not impact transactional or service-related emails necessary for your account.

Remarketing allows us to display relevant advertisements based on your previous interactions with our website or email campaigns. For example, Google Remarketing uses cookies to show targeted ads on other websites, while Facebook Custom Audiences leverages hashed data, such as email addresses, to deliver personalized ads on Facebook and Instagram. If you prefer, you can opt out of Google’s use of cookies for advertising or adjust your cookie settings to limit data collection. These options ensure that you have control over how your data is used for remarketing purposes.

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.

To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

To manage Your requests: To attend and manage Your requests to Us.

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.

For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Data Sharing and Security

We may share your personal information with:

• Service providers: To perform operational functions (e.g., email delivery, advertising management, website hosting).
• Third-party vendors: For analytics, advertising, and remarketing purposes.
• Partners and affiliates: For co-branded campaigns or joint service offerings.
• Legal or regulatory entities: As required by law or to respond to lawful requests.

Security Measures

We implement robust security measures to protect your data, including:

• Encryption: During transmission and storage of sensitive data.
• Access Controls: Restricting data access to authorized personnel.
• Regular Audits: To ensure compliance with privacy and security standards.

De-identification Techniques

We may de-identify your personal information for analysis or sharing purposes by:

• Hashing or encrypting data to anonymize identifiers.
• Aggregating data to remove specific details tied to an individual.

We use data about you for the purpose(s) for which it was collected or provided to us (as stated at the point of collection) or as otherwise obvious from the context of collection.

We may also use data to:

Administer and manage this Site, communicate with you about this Site, process your request for information, or otherwise complete a transaction or service you request or authorize.

Customize or personalize your user experience and the content we deliver to you, including to provide you with content that is more relevant to you.

Contact you about Somerset House products and services, provide you with promotional materials or offers for products/services from Somerset House, or send you other communications about Somerset House business and events (including communications based on your interests, personal and business characteristics, and location) (collectively, “marketing communications”). We may provide these communications and offers via email, postal mail, online, social media platforms, text messages, and other means.

Carry out our internal business purposes, such as corporate transactions, audits, and data analysis; conduct research and analytics about your use of this Site and interaction with us; develop new products; improve this Site and our existing products and services; identify usage trends; assess the performance of our advertisements; optimize our advertising campaigns; and determine the effectiveness of our communications.

We will never use to advertise, promote, or market third-party goods or services to you. Additionally, we will not license or publish any of your personal data. We do not and will not sell any personal data to third parties for their own commercial use.

Disclosures of Personal Data

In connection with one or more of the purposes outlined in the “Data Use” section above, we may disclose your data to:

Third parties that provide services to us, such as system hosting, management, and support; data analysis; facilitation of advertisements; data backup; and data security and storage services.

Relevant third parties as part of a corporate transaction, such as a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding).

Competent governmental and public authorities, in each case to comply with legal or regulatory obligations or requests; and other third parties as we believe necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to enforce our terms and conditions; (d) to protect our operations and those of any of our affiliates; (e) to protect our rights, privacy, safety, or property, and/or those of our affiliates, you, or others; and (f) to allow us to pursue available remedies or limit damages that we may sustain.

In addition, this Site may contain content and plugins from social media platforms, like Facebook (“Like” button), Twitter (“Share to Twitter”), Linkedin, and others. These plugins allow you to share information from this Site to your timeline or account. When you connect to these services, the third parties may store and/or access data (including through the use of cookies and other similar technologies) over which we do not have control. If you are logged into one of your social media accounts while visiting a webpage on this Site that contains a social media plugin, the social media plugin may allow the relevant social media platform to receive information that you visited this Site and link it to your social media account. We do not control these third-party platforms, and information collected is governed by the privacy statement of the third party that provides the relevant platform. We encourage you to review these platforms’ privacy statements for more information.

The disclosures described in this section may result in the transfer of your data to countries or regions with data protection laws that differ from those in your country of residence. By providing us with your data and using this Site, you are acknowledging that your data may be transferred to countries outside of your country of residence.

In cases where your data is transferred outside of your country of residence, we take steps to ensure that appropriate safeguards are in place to protect such data. If you are based in the EU/EEA, such safeguards may include a data transfer agreement with the data recipient based on standard contractual clauses or such other mechanism as is approved by the European Commission for transfers of personal data to third countries. For further details relating to the transfers described above and the adequate safeguards used with respect to such transfers, please contact us as stated below.

Cookies

We use various types of cookies to enhance your experience:

• Session Cookies: Temporary cookies used for website functionality.
• Persistent Cookies: For analytics, preference storage, and remarketing.
• Third-Party Cookies: For advertising and campaign management.

We may collect information about your computer, including your IP address, operating system and browser type, for system administration and in order to create reports. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

Advertising and Analytics

We use advertising and analytics technologies to:

• Deliver personalized advertisements based on your browsing behavior, preferences, and inferred interests.
• Conduct remarketing campaigns, including displaying ads to users who have previously visited our site.
• Measure the performance of advertising campaigns and improve their effectiveness.

Technologies used include:

• Cookies: For user session tracking and preference storage.
• Tracking Pixels: To monitor ad impressions and engagement.
• Third-Party Analytics Tools: Such as Google Analytics, Meta (Facebook) Ads Manager, Google Tag Manager, Google Maps, and others.

We use Google Analytics, a web analytics tool that helps website owners understand how visitors engage with their website. Google Analytics customers can view a variety of reports about how visitors interact with their website so that they can improve it.

Like many services, Google Analytics uses first-party cookies to track visitor interactions as in our case, where they are used to collect information about how visitors use our site. These cookies are used to store information, such as the time that the current visit occurred, whether the visitor has been to the site before and what site referred the visitor to the web page. We then use the information to compile reports and to help us improve our site.

Google Analytics collects information anonymously. It reports website trends without identifying individual visitors. You can opt-out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this page https://tools.google.com/dlpage/gaoptout.

We may use cookies in partnership with select third-party vendors, such as Google and AOL Networks, in the delivery of Somerset House display advertisements to our website visitors on various sites across the internet. These campaigns do not collect any personally identifiable information.

We retain personal information only as long as necessary to fulfill the purposes outlined in this policy or as required by law. Retention periods vary based on the type of data and its intended use.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Your Privacy Rights

For All Users:

• Access and Correction: Request access to or correction of your personal data.
• Deletion: Request deletion of your data unless retention is required by law or for operational purposes.
• Opt-Out: Manage cookie preferences and opt out of targeted advertising or data-matching activities.

Your Rights Under California Consumer Privacy Laws

If you are a resident of the state of California, you are entitled to request information regarding the disclosure of your personal data to third parties for direct marketing purposes. Please note that we do not share your personal data with non-affiliated third parties for such purposes. California residents have additional rights under the CCPA and CPRA:

• Right to Know: What personal information we collect, its sources, and how it’s used/shared.
• Right to Delete: Request the deletion of personal information we’ve collected.
• Right to Opt-Out: Stop the sale or sharing of your personal data (if applicable).
• Right to Correct: Correct inaccuracies in your personal data.
• Right to Limit Use of Sensitive Data: Restrict the use of SPI for secondary purposes.
• Right to Non-Discrimination: We will not deny services or discriminate against you for exercising your privacy rights.

We respect your choices about how your personal data is managed and are committed to ensuring you have reasonable access to review and control its use in compliance with applicable laws. If you no longer wish to receive electronic newsletters or marketing communications from Somerset House, simply click the ‘unsubscribe’ link found in those communications. Additionally, depending on your location, you may have specific rights regarding your personal data, including requesting a copy, correcting inaccuracies, limiting its use, or even requesting its deletion. You also have the right to object to data processing, withdraw your consent, and file a complaint with your local data protection authority.

To exercise these rights, you can submit a request using our online form or contact us directly. To protect your data, only you or an Authorized Agent acting on your behalf can submit such requests. We may require proof of identity or authorization to process your request. For verification purposes, your request should include sufficient information to confirm your identity or authority and provide the necessary details for us to evaluate and respond appropriately. If we are unable to verify your identity or match your data, we will inform you of any limitations on fulfilling your request.

For residents of the EU or EEA, additional protections apply. If you have concerns about how your data is handled, you may contact our EU Data Protection Officer for assistance. Should you remain unsatisfied, you have the right to file a complaint with your local National Data Protection Authority. To locate the appropriate authority, please visit this EU link. We are committed to safeguarding your rights and maintaining transparency in our data practices.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Contact Us

For questions, concerns, or to exercise your privacy rights, please contact the Executive Director at the address or telephone number provided below:

Phone: (772) 778-8181

Website: vbsomersethouse.com

Somerset House

1540 Oak Harbor Blvd., Vero Beach, FL 32967

Effective: 7/1/2025

Your Consent

By filling out a form on our website (e.g., contact forms, event registrations, information requests), you consent to the collection, use, and sharing of your information as outlined in this Privacy Policy. You also agree to receive communications related to your inquiry and our services. You may opt out of future communications at any time by contacting us or following the unsubscribe link in our emails.

Updates

This Privacy Policy may be updated periodically. Changes will be posted on this page with the date of the most recent revision. Continued use of our services constitutes your acknowledgment of updated terms. By using this site, you consent to be governed by this Privacy Policy. We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Please review this Privacy Policy from time to time to ensure your familiarity with its terms, as your continued use of Somerset Housealbuquerque.com following changes to these terms means you accept those changes.