Privacy Policy

CT Health Care Services Privacy Policy

Who We Are

CT Health Care Services (collectively referred to as “CT Health Care Services,” “we,” “our,” or “us”) is dedicated to providing high-quality care coordination and health services. This Privacy Policy outlines our commitment to protecting your privacy and managing your personal information responsibly.

Scope of Policy

This Privacy Policy explains how CT Health Care Services collects, uses, and shares your information, including through our digital properties on which this Privacy Policy is linked (“Site”). This policy applies generally to the information we collect about you as a consumer, employee, contractor, prospective employee, client, or another person whom you have the legal authority to represent (such as a family member or friend).

Scope Restriction: This policy is strictly limited to the data of US residents.

What This Policy Does Not Cover

Independent Third Parties: This policy does not apply to data collected, controlled, or processed by independent third parties acting on their own behalf, except to the extent your specific data has been shared with or collected by us.
Protected Health Information (PHI): This Privacy Policy does not apply to any protected health information covered by the Health Insurance Portability and Accountability Act (HIPAA) and its implementing regulations. Where subject to HIPAA, client health information is governed by our specific Notice of Privacy Practices.

Employment and Contractual Conflicts

If your data is collected, used, or shared in connection with your employment or contracting status with CT Health Care Services, your data is also subject to the terms of all applicable employment policies, handbooks, rules, and agreements, which will control in the event of any conflict.

Notice of Collection of Personal Information

We may collect the following categories of personal information:

Identifiers: (e.g., name, email, phone number)
Voluntarily provided information: on personal characteristics of protected classes
Commercial & financial information
Professional or employment-related information
Sensitive personal information
Website/Application interaction or similar network activity
Biometric Information
Sensory data (e.g., recorded phone calls for quality assurance)
Health & Physical Characteristics
Inferences drawn from any of the above

Categories of Sensitive Personal Information

Under applicable state regulations, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), we collect and use the following categories of sensitive personal information:

Social Security Numbers
Driver’s License or State Identification Card Numbers
Financial Account Information
Precise Geolocation
Health Information
Biometric Information
Contents of Mail, Email, and Text Messages

Why We Collect This Information

We collect this data to effectively run our operations and serve you better. Specifically, we use it for:

1. Communicating with you and providing care coordination & customer service
2. General business administration, audits, and compliance
3. Anonymizing and aggregating data for internal and external analytical use
4. Enhancing security, verifying identities, and preventing fraud
5. Performing contractual obligations or entering into agreements
6. Providing educational resources and learning management systems
7. Advertising and marketing for recruitment, employment, products, and services

Note: We may share identifiers, customer personal information, commercial information, and website interaction activity for targeted advertising purposes. We do not sell or share client health information.

Data Minimization, Purpose Limitation, and Retention

We adhere strictly to principles of data minimization and purpose limitation. We collect, use, retain, and share personal information only as reasonably necessary and proportionate to achieve the purposes for which it was gathered.

Retention Periods by Category

Personal Information Category | Retention Period Policy

Identifiers & Commercial Info: Retained for the duration of your relationship with us and a period thereafter to comply with legal obligations, resolve disputes, and enforce agreements.
Customer Personal & Financial Info: Retained for as long as needed to provide you with our services and for a period thereafter as required by law.
Protected Characteristics & Health Data: Retained for as long as necessary to fulfill the specific care or business purposes for which it was collected and as required by law.
Professional or Employment Info: Retained for the duration of your employment or application process and a period thereafter as required by law.
Sensitive & Biometric Info: Retained only for as long as necessary to provide the requested services or goods, and safely disposed of thereafter in accordance with applicable law.
Website/Application Interaction: Retained for the duration of your use of our website and a period thereafter for analytical integrity and security compliance.

Communications Consent and Practices

By utilizing our Services or providing your information, you acknowledge and consent to the terms of this Privacy Policy. You agree not to provide us with information about any other person unless you have that person’s explicit consent or legal authority.

Telephone and SMS Communications

Monitoring: Telephone communications with us may be recorded or monitored for quality control purposes.
Automated Technology: By providing your contact info (email or phone number), you agree to be contacted by us or our contracted providers. This includes communications via text message or telephone call using automatic telephone dialing systems, even if you are on a Do Not Call registry. Your consent is not a condition of purchase.
SMS Privacy: Mobile opt-in data, phone numbers, and SMS consent will not be shared with any third parties or affiliates for marketing or promotional purposes.

Examples of SMS Messages You May Receive

Service Updates: Hi Susan, it’s Barb at CT Health Care Services. Just wanted to let you know that your caregiver is running a little late today. Please give the office a call at 973-399-1500 if you have questions. Reply STOP to unsubscribe.
Job Opportunities: Hi Gabe, it’s Jane at CT Health Care Services. Your interview is scheduled for Monday at noon. We look forward to meeting you. Reply STOP to unsubscribe.
Billing: Hi Mr. Smith, a quick reminder from our billing group at CT Health Care Services. We show we have not received payment for this month’s care. Please reach out to us at 973-399-1500. Reply STOP to unsubscribe.

Opt-Out and Support

You can opt out of SMS communications at any time by replying “STOP”. To resume, reply “START”. For assistance, reply “HELP” or email us at compliance@cthcs.com.

Important: Opting out of one form of communication (e.g., email) does not automatically opt you out of others (e.g., SMS). Separate opt-outs must be submitted if you consented to them independently.

CAN-SPAM Act Compliance

We comply fully with the requirements of the CAN-SPAM Act. Our commercial email practices ensure that:

We do not use false or misleading header information or deceptive subject lines.
Our commercial emails clearly state that they are advertisements and include our valid physical address.
Each email includes a clear, easy-to-use unsubscribe link.
Opt-out requests are processed and honored within 10 business days.

Managing Web Tracking Technologies

Cookie Preferences

When you first visit our Site, a banner will request your consent for non-essential online tracking technologies. Our Site only deploys optional tracking cookies if you explicitly accept them. You can adjust your preferences at any time via the Cookie Preferences link in our footer.

Browser & Device Settings

Do Not Track (DNT) & Global Privacy Control (GPC): If you utilize DNT or GPC privacy signals on your browser, our cookie manager software will recognize this automatically as a valid request to opt out of targeted advertising.
Hardware Settings: You can limit ad tracking via your mobile device settings (e.g., “Limit Ad Tracking” on iOS or “Opt Out of Ads Personalization” on Android).

Data Sharing and Disclosure

We may disclose personal information to third parties for strictly defined business purposes as outlined below:

1. Affiliates and Partners: We may share identifiers, customer personal information, commercial information, financial information, professional/employment information, and health characteristics with our operational affiliates to coordinate care, enhance service quality, and administer business programs.
2. Third-Party Service Providers: We partner with service providers who are contractually bound to process data solely on our behalf. They are strictly prohibited from selling, retaining, or using your data for any secondary purpose.
3. Legal and Administrative Authorities: We will disclose personal information if required to do so by law, subpoena, or if we believe in good faith that such action is necessary to comply with legal proceedings, protect our property rights, or protect the personal safety of our users or the public.
4. Business Transfers: In the event of a merger, acquisition, debt financing, asset sale, or insolvency, customer data may be transferred as a business asset. The acquiring party will remain bound by the provisions of this Privacy Policy.

U.S. State-Specific Data Privacy Rights

General Privacy Rights (CA, VA, CO, CT, UT, etc.)

Residents of states with comprehensive privacy frameworks may possess the following legal rights regarding their data:

Right to Know/Access: Request a copy of the categories and specific pieces of personal information we hold about you.
Right to Correct: Request the correction of inaccurate or incomplete data.
Right to Delete: Request the deletion of your personal data, subject to legal exceptions.
Right to Portability: Obtain a portable, easily transferable copy of your data.
Right to Opt-Out: Request to opt out of the sale or sharing of your personal information for targeted advertising.
Right to Limit Sensitive Data: (California residents) Restrict the use of sensitive personal information to essential services.

Identity Verification Process

To protect your security, we must verify your identity before processing access, correction, or deletion requests. The request form will match details you provide against our internal records. You will also be required to complete an email verification step.

Note: By law, we cannot disclose highly sensitive structural data (such as full Social Security Numbers or financial account passwords) in a privacy response, but we will confirm if we possess it.

Contact Us

If you have questions regarding this Privacy Policy, wish to file a compliance concern, or want to exercise your privacy choices, please reach out to our team using the contact methods below:

CT Health Care Services Attn: Compliance Team

812 N Wood Ave, STE 101 Linden, NJ 07036

Online Requests: Data Privacy Request Form (available via our Site footer)

We are committed to resolving your privacy inquiries promptly and will not retaliate against any individual for filing a complaint.

Policy Updates

This Privacy Policy may change periodically to reflect updates in our operational practices or shifting legal landscapes. When changes are made, we will update the “Effective Date” at the top of the policy page. If you object to any structural modifications, you must cease using our Services immediately. We encourage you to review this page regularly.