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At Southern Sky Recovery ("SSR"), we respect the privacy of others. This PRIVACY POLICY (this "Privacy Policy") is intended to explain SSR’s privacy practices with respect to the newport-academy.com website (together with its features and services, the "Site"). This Privacy Policy is also intended to provide you and any person helping you visit, access, or use the Site (whether as a buyer, seller, visitor, or otherwise) (collectively, "you" or "your") with an overview of the following:

• the type of information about you SSR collects through the Site;
• how Southern Sky Recovery Client Portal collects such information;
• how Southern Sky Recovery Client Portal uses such information;
• who will have access to such information; and
• Southern Sky Recovery Client Portal ’s security measures for protecting such information.

This Privacy Policy only applies to information collected through the Site.

Southern Sky Recovery Client Portal has additional privacy and security policies related to certain of its operations, such as its Health Insurance Portability and Accountability Act (HIPAA) policies and procedures.

Carefully read each and every term and condition of this Privacy Policy in its entirety. By visiting, accessing, or using the Site, you are automatically accepting and agreeing to the most-recent version of this Privacy Policy, as well as the Site’s Terms of Use, and your continuing visit, access or use of the Site reaffirms your acceptance and agreement of the foregoing in each instance.

As used herein, the term "personal information" means information that would allow someone to contact you physically or online, including, for example, your name, physical address, telephone number, e-mail address, or social security number; and the term "non-personal information" means any information other than personal information that SSR may collect from you.

A Special Note About Minors

The Site is a general audience website intended for use by adults. The Site is not designed or intended to attract, and is not directed to, children under eighteen (18) years of age, let alone children under thirteen (13) years of age. Southern Sky Recovery Client Portal does not collect personal information through the Site from any person it actually knows to be under thirteen (13) years of age. If Southern Sky Recovery Client Portal obtains actual knowledge that it has collected personal information through the Site from a person under thirteen (13) years of age, then it will use reasonable efforts to refrain from further using such personal information or maintaining it in retrievable form.

Furthermore, if you are under eighteen (18) years of age, then you (or your parent or legal guardian) may at any time request that Southern Sky Recovery Client Portal remove content or information about you that is posted on the Site. Please submit any such request ("Request for Removal of Minor Information") to any one of the following:

By mail: Newport Academy, Attn.: Support, 811 North Ranch Wood Trail, Orange, California 92869, with a subject line of "Removal of Minor Information." By e-mail: inquiries@newport-academy.com, with a subject line of "Removal of Minor Information."

For each Request for Removal of Minor Information, please state "Removal of Minor Information" in the e-mail or letter subject line, and clearly state the following in the body:

1. the nature of your request;
2. the identity of the content or information to be removed;
3. whether such content or information if found on the Site;
4. the location on content or information on the Site (e.g., providing the URL for the specific web page the content or information is found on);
5. that the request is related to the "Removal of Minor Information"
6. your name, street address, city, state, zip code, and e-mail address; and
7. whether you prefer to receive a response to your request by mail or e-mail.

If you send a Request for Removal of Minor Information by mail, then please do so by U.S. Certified Mail, Return Receipt Requested to allow for confirmation of mailing, delivery, and tracking. Southern Sky Recovery Client Portal will not accept any Request for Removal of Minor Information via telephone or facsimile. Southern Sky Recovery Client Portal is not responsible for failing to comply with any Request for Removal of Minor Information that is incomplete, incorrectly labeled, or incorrectly sent.

Please note that the aforementioned removal does not ensure complete or comprehensive removal of such content or information posted on the Site.

Also, please note that Southern Sky Recovery Client Portal is not required to erase or otherwise eliminate, or to enable erasure or elimination of, such content or information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule, or regulation requires Southern Sky Recovery Client Portal to maintain the content or information; when the content or information is stored on or posted to the Site by a third party other than you (including any content or information posted by you that was stored, republished, or reposted by the third party); when Southern Sky Recovery Client Portal anonymizes the content or information, so that you cannot be individually identified; when you do not follow the aforementioned instructions for requesting the removal of the content or information; and when you have received compensation or other consideration for providing the content or information.

The foregoing is a description of Southern Sky Recovery Client Portal 's' voluntary practices concerning the collection of personal information through the Site from certain minors, and is not intended to be an admission that Southern Sky Recovery Client Portal is subject to the Children’s Online Privacy Protection Act, the Federal Trade Commission’s Children’s Online Privacy Protection Rule(s), or any similar international, federal, state, or local laws, rules, or regulations.

Categories of Information Collected

Southern Sky Recovery Client Portal may collect personal and non-personal information about you through the Site.

Categories of Information Collected Through the Site

The categories of personal and non-personal information collected from you through the Site might include:

• Your first, last, and/or middle name;
• A patient’s (or a prospective patient’s) first, last, and/or middle name;
• A patient’s (or a prospective patient’s) first, last, and/or middle name;
• Your personal contact information (e.g., mailing address, e-mail address, telephone number);
• A patient’s (or a prospective patient’s) first, last, and/or middle name;
• A patient’s (or a prospective patient’s) first, last, and/or middle name;
• A patient’s (or a prospective patient’s) first, last, and/or middle name;
• A patient’s (or a prospective patient’s) first, last, and/or middle name;
• A patient’s (or a prospective patient’s) personal contact information (e.g., mailing address, e-mail address, telephone number);
• Your gender;
• A patient’s (or a prospective patient’s) gender;
• Your date of birth;
• A patient’s (or a prospective patient’s) date of birth;
• Your electronic signature;
• Your insurance information (e.g., the primary subscriber’s name, contact information, date of birth, and/or insurance member identification number, the primary subscriber’s name, contact information, and/or date of birth, and the insurance company’s name and contact information);
• A patient’s (or a prospective patient’s) insurance information (e.g., the primary subscriber’s name, contact information, date of birth, and/or insurance member identification number, the primary subscriber’s name, contact information, and/or date of birth, and the insurance company’s name and contact information);
• The name and/or location of the school(s) where you attend;
• The name and/or location of the school(s) where a patient (or a prospective patient) attends;
• Billing, payment, or shipping information (e.g., payor or payee name, checking account number, credit card number, expiration date, verification code, accountholder name, cardholder name, billing address, mailing address, tax ID number);
• Business contact information (e.g., company, title, mailing address, e-mail address, telephone number, facsimile number, tax ID number);
• Computer, mobile device, and/or web browser information (e.g., IP address, mobile device ID information, operating system, browser type, referring/exist web pages, web page requests, cookie information, hardware attributes, software attributes);
• Third-party website, network, platform, server, and/or application information (e.g., Facebook, LinkedIn);
• Usage activity concerning your interactions with the Site and/or third-party websites, networks, platforms, servers, or applications accessed through the Site (e.g., number of clicks on a page or feature, amount of time spent on a page or feature, identity of third-party websites, networks, platforms, servers, and applications being access through the Site);
• Transactional information, including but not limited to enrollment or pre-enrollment submissions, insurance verifications or applications, payments, and comments, feedback, and/or other communications made in or through the Site;
• Information set forth in the Site’s online enrollment or pre-enrollment forms, online insurance verification forms, and/or online contact or communication forms; and/or
• Information about content and/or communications that you submit to or publish on or through the Site.

Categories of Other Information Collected From Your Mobile Device

If you use your mobile device to visit, access, or use the subscription or members-only area of the Site, then additional categories of personal and non-personal information collected from you through the Site might include:

• Your name associated with your mobile device;
• Your address associated with your mobile device;
• Your telephone number associated with your mobile device;
• Your geolocation;
• Your mobile device ID information;
• With your express agreement, your mobile contacts and/or contact information (e.g., names, telephone numbers, physical addresses, e-mail addresses, photos); and/or
• With your express agreement, information about third-party software applications on your mobile device (including, without limitation, general software apps, and online social media apps).

How Information is collected

Southern Sky Recovery Client Portal might collect personal and non-personal information from you when you register with or subscribe to the Site (e.g., by subscribing to Southern Sky Recovery Client Portal regular or promotional e-mail lists through the Site); complete and submit any online enrollment, pre-enrollment, insurance verification, and/or contact us forms; when you allow the Site to access, upload, download, import, or export content found on, or to otherwise interact with, your computer or mobile device (or any other device you may use to visit, access, or use the Site) or online accounts with third-party websites, networks, platforms, servers, or applications (e.g., your online social media accounts, your cloud drives and servers, or your mobile device service provider); when you share certain content or communications from the Site with third parties; or whenever Southern Sky Recovery Client Portal asks you for such information, such as, for example, when you answer an online survey or questionnaire.

In addition, if you or a third party sends Southern Sky Recovery Client Portal a comment, message, or other communication (such as, by way of example only, e-mail, letter, fax, phone call, or voice message) about you and/or your activities on or through the Site, then Southern Sky Recovery Client Portal may collect any personal or non-personal information provided therein or therewith.

Finally, Southern Sky Recovery Client Portal may use various tracking, data aggregation, and data analysis technologies, including, for example:

• Cookies, which are small data files (such as, by way of example only, text files) stored on the computer or device you use to view a website, and which help store user preferences and activity. Cookies may record information you access on one page of a website to simplify subsequent interaction with that website, or to help streamline your transactions on related pages of that website. Most major web browsers are set up so that they will initially accept cookies, but you might be able to adjust your computer’s, device’s or web browser’s preferences to issue you an alert when a cookie is downloaded, or to disable the use of some or all cookies on your computer or other devices. Please be advised that if you choose to reject all cookies, then certain areas of the Site might not function properly.
• Web beacons, which are pieces of code embedded in a website or e-mail to monitor your activity on the website or your opening of the e-mail, and which can pass along information such as the IP address of the computer or device you use to view the website or open the e-mail, the URL page on which the web beacon is located, the type of web browser that was used to access the website, and previously set cookie values. Web beacons are sometimes used to collect advertising data, such as counting page views, promotion views or advertising responses. Disabling your computer’s, device’s or web browser’s cookies may prevent some web beacons from tracking or recording certain information about your activities. Please be advised that if you disable all such cookies, then certain areas of the Site might not function properly.
• Scripts, which are pieces of code embedded in a website to define how the website behaves in response to certain key or click requests sent by the user. Scripts are sometimes used to collect information about the user’s interactions with the website, such as the links the user clicks on. Scripts are often times temporarily downloaded to the user’s computer or device from the website server, active only while the user is connected to the Site, and deactivated or deleted when the user disconnects from the website. Please be advised that if you disable any scripts through your web browser or other means, then certain areas of the Site might not function properly.
• Google Analytics, which is a digital analytics service offered by Google Inc. that tracks, measures and generates information about a website’s traffic, sales, and similar information, and which may be used for statistical and marketing research. Please see http://www.google.com/analytics for more information about Google Analytics. We may use other third party analytic services as well.

By visiting, accessing or using the Site, you acknowledge and agree in each instance that you are giving Southern Sky Recovery Client Portal permission to monitor or otherwise track your activities on the Site, and that Southern Sky Recovery Client Portal may use the aforementioned and/or other tracking, data aggregation, and data analysis technologies.

Use of Information Collected

SSR may use the personal and/or non-personal information it collects from you through the Site in a variety of ways, such as, for example, to:

• Fulfill your requests;
• Process your or our own insurance request and/or payments;
• Facilitate your movement through the Site;
• Facilitate your use of the Site’s features, products, and/or services;
• Send you communications like, for example, administrative e-mails, promotional e-mails, answers to your questions, and updates about the Site;
• Provide you with information about SSR and its businesses, products, and services by letter, e-mail, text, telephone, or other forms of communication;
• Provide you with information about third-party businesses, products, and services by letter, e-mail, text, telephone, or other forms of communication;
• Improve the Site and/or the Site’s content, features, and/or services;
• Improve SSR’s products, services, and/or marketing efforts;
• Create new SSR products, services and/or marketing efforts;
• Help personalize user experiences with the Site and/or the Site’s products and/or services;
• Analyze traffic to and through the Site;
• Analyze user behavior and activity on or through the Site;
• Conduct research and measurement activities;
• Monitor the activities of you and others on or through the Site;
• Protect or enforce SSR’s rights and properties; and/or
• Protect or enforce the rights and properties of others (which may include you).

SSR reserves the right to use your personal and non-personal information when:

• Required by applicable law, court order, or other governmental authority (including, without limitation and by way of example only, in response to a subpoena or other legal process); or
• SSR believes in good faith that such use is otherwise necessary or advisable (including, without limitation and by way of example only, to investigate, prevent, or take legal action against someone who may be causing injury to, interfering with, or threatening the rights, obligations, or properties of SSR, a user of the Site [which may include you], or anyone else who may be harmed by such activities, or to further SSR’s legitimate business interests).

Sharing of Information Collected

SSR reserves the right to share your personal information with its employees, agents, administrators, and legal advisors; and with those third parties who help manage, administer distribute, and/or operate the Site and/or the Site’s services and/or features (e.g., web hosting companies, website administrators, mobile app distribution platforms, support services companies, payment processing companies, and insurance companies), as needed in order for them to perform such services.

In addition, your name, user name, and/or contact information may be disclosed in SSR’s membership directory or elsewhere through the Site, and/or in connection with SSR’s display or performance of photographs, images, and/or videos of you on or through the Site.

SSR does not limit the ways in which it may use or share non-personal information because non-personal information does not identify you. For example, SSR may freely share non-personal information with its affiliates, suppliers, and representatives, as well as with other individuals, businesses, and government entities.

You may choose to share certain information and/or follow other users on the Site. You may choose to share your contact information with other users or provide it publicly.

Data Retention

SSR may retain your personal information for as long as it believes necessary; as long as necessary to comply with its legal obligations, resolve disputes, and/or enforce its agreements; and/or as long as needed to provide you with the features, products, and/or services of the Site.

Transactions

In connection with any transaction that you conduct through the Site (e.g., subscribing to SSR’s regular or promotional e-mail lists, submitting enrollment or pre-enrollment information, submitting insurance verification information, or the purchase or sale of any products on or through the Site), you may be asked to supply certain information relevant to the transaction, including, without limitation, name, your mailing address, your insurance information, date of birth, your credit card number and expiration date, your billing address, your shipping address, your phone number, and/or your e-mail address. By submitting such information, you grant SSR without charge the irrevocable, unencumbered, universe-wide, and perpetual right to provide such information to third parties (e.g., insurance companies, payment processing companies) for the purpose of facilitating the transaction.

Third Party Applications and Networks

The Site and/or any communications sent through or as a function of the Site may contain links to third-party websites, networks, platforms, servers, and/or applications. To the fullest extent permitted by law, SSR is not responsible for, and you hereby release SSR from any and all liability which may arise from, such third party websites, networks, platforms, servers, and applications (including, without limitation, the privacy policies and practices of such third-party websites, networks, platforms, servers, and applications, any information or misinformation found on or through such third-party websites, networks, platforms, servers, and applications, and any acts, errors, and omissions of such third-party such third-party websites, networks, platforms, servers, and applications).

You may have the opportunity to access the Site with or through certain third-party websites, networks, platforms, servers, or applications, which may be subject to separate privacy policies pertaining to those third-party websites, networks, platforms, servers, or applications. SSR may also collect information from those third-party websites, networks, platforms, servers, or applications (such as, for example, your name, gender, date of birth, and personal interests, when you "like" or click links provided by or through those third-party websites, networks, platforms, servers, or applications, and other information available through your online account or page with those third-party websites, networks, platforms, servers, or applications). IT IS YOUR RESPONSIBILITY TO CAREFULLY READ, ACCEPT, AND COMPLY WITH THE RELEVANT TERMS OF USE AND PRIVACY POLICIES ASSOCIATED WITH THOSE THIRD-PARTY WEBSITES, NETWORKS, PLATFORMS, SERVERS, AND APPLICATIONS.

Security

SSR implements security measures to help protect the personal information it collects through the Site. For example, SSR encrypts the transmission of information through the Site by using secure socket layer (SSL) technology.

REGARDLESS OF THE FOREGOING, PLEASE OBSERVE THAT "PERFECT" OR "100%" SECURITY DOES NOT EXIST ON THE INTERNET. THEREFORE, YOUR ACCESS AND USE OF THE SITE, AND YOUR OPENING OF ANY COMMUNICATIONS SENT THROUGH OR AS A FUNCTION OF THE SITE, ARE DONE AT YOUR OWN RISK.

To help maintain the security of your personal information, SSR asks that you please notify it immediately of any unauthorized visit, access, or use of the Site.

Retention, Review, and Change of Information Collected

You may request at any time that SSR provide you with an opportunity to review and change your personal information collected through the Site, or to no longer use your personal information to provide you with any products or services. Please submit any such request ("Request Concerning Personal Information") to any one of the following:

By mail: Southern Sky Recovery, Attn.: Support, 60 Pennington Dr, Bluffton, SC 29910, with the subject line of "Your Personal Information." By e-mail: , with a subject line of "Your Personal Information."

For each Request Concerning Personal Information, please state "Your Personal Information" in the e-mail or letter subject line, and clearly state the following in the body:

1. the nature of your request;
2. that the request is related to "Your Personal Information;"
3. your name, street address, city, state, zip code, and e-mail address; and
4. whether you prefer to receive a response to your request by mail or e-mail.

If you send a Request Concerning Personal Information by mail, then please do so by U.S. Certified Mail, Return Receipt Requested to allow for confirmation of mailing, delivery, and tracking. SSR will not accept a Request Concerning Personal Information via telephone or facsimile. SSR is not responsible for any Request Concerning Personal Information that is incomplete, incorrectly labeled, or incorrectly sent.

You are solely responsible for the accuracy and content of your personal information, and for keeping your personal information current and correct.

Your California Privacy Rights

If you are a resident of the State of California and SSR has an established business relationship with you, then, pursuant to Section 1798.83 of the California Civil Code, you have the right to request the following at any time: (a) information from SSR free of charge regarding the manner in which SSR shares certain personal information collected through the Site with third parties who use such information for direct marketing purposes; and (b) the discontinuation (or opt-out) of SSR’s sharing of such information with such third parties. Please submit any such request ("California Privacy Rights Request") to any one of the following:

By mail: Southern Sky Recovery, Attn.: Support, 60 Pennington Dr, Bluffton, SC 29910, with the subject line of "Your Personal Information." By e-mail: , with a subject line of "Your California Privacy Rights."

For each California Privacy Rights Request, please state "Your California Privacy Rights" in the e-mail or letter subject line, and clearly state the following in the body:

1. the nature of your request;
2. that the request is related to "Your California Privacy Rights;"
3. your name, street address, city, state, zip code, and e-mail address; and
4. whether you prefer to receive a response to your request by mail or e-mail.

If you send a California Privacy Rights Request by mail, then please do so by U.S. Certified Mail, Return Receipt Requested to allow for confirmation of mailing, delivery, and tracking. SSR will not accept a California Privacy Rights Request via telephone or fax; and is not responsible for a California Privacy Rights Request that is incomplete, incorrectly labeled, or incorrectly sent.

You are solely responsible for the accuracy and content of your personal information, and for keeping your personal information current and correct.

Finally, as explained further above, SSR does not authorize third parties to collect your personal information when you use the Site, except as expressly stated in this Privacy Policy. To the fullest extent permitted by law, SSR is not responsible for, and you hereby release SSR from any and all liability which may arise from, such third parties’ unauthorized collection of your personal information.

Further, SSR does not respond to "do not track" (DNT) signals

Modifications of this Privacy Policy

SSR may supplement, amend, or otherwise modify this Privacy Policy at any time without notice to you. Such supplements, amendments, and other modifications will be posted on this or a similar page of the site, and shall be deemed effective as of their stated effective or modification date. It is your responsibility to carefully review this Privacy Policy each time you visit, access, or use the Site.

Again, by visiting, accessing, or using the Site, you are automatically accepting and agreeing to the most-recent version of this Privacy Policy, as well as the most-recent version of the Site’s Terms of Use, and your continuing visit, access, or use of the Site reaffirms your acceptance and agreement in each instance.

Severability

If any term or condition of this Privacy Policy is deemed invalid or unenforceable by a court of law with binding authority, then the remaining terms and conditions shall not be affected, and the court shall reform the invalidated or unenforceable term or condition to the maximum extent permitted under the law and consistent with the intent of this Privacy Policy.

Contact Us

Please direct any questions you may have about this Privacy Policy to any one of the following:

By mail: Southern Sky Recovery, Attn.: Support, 60 Pennington Dr, Bluffton, SC 29910, with the subject line of "Your Personal Information." By e-mail: , with a subject line of "Privacy Policy" Information."

The foregoing contact information may change from time-to-time by supplementation, amendment, or modification of this Privacy Policy.

International Users

For any of the above purposes and in view of SSR’s global operations, you agree that SSR may transfer some or all of your personal data to countries outside your resident jurisdiction and may process and/or store such information in the United States of America. You agree and recognize that countries outside of your jurisdiction may not have as comprehensive data protection laws as those existing in your resident jurisdiction. For more information please contact us at the information provided in Section 14 above.

Last Modified

This Privacy Policy was last modified on July 1, 2016.

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