0
☰ Menu hexagon
×

Data, Privacy and Security Policy

Toomey & Associates, Inc. ensures the privacy and security of data through the adherence to the following policy for data collection.

hexagon hexagon hexagon hexagon hexagon hexagon

Privacy Statement

Introduction

Toomey & Associates, Inc. (SOS Approach to Feeding respects your privacy and wants to provide you with information about our privacy practices in this Privacy Statement (“Privacy Statement”). This Privacy Statement applies to information collected on the websites located at www.sosapproach.com (the “Website”), any mobile applications associated with the Website (the “Mobile Applications”), as well as any services and features available on or through the Website or the Mobile Applications, such as sub-sites, blogs, user communities, social networks, or other online or wireless offerings that post a link to this Privacy Statement, whether accessed via computer, mobile device, or other technology or any associated content, material, or functionality contained on the Website or the Mobile Applications (collectively, the “Services” and, together with the Website and the Mobile Applications, the “System”). Toomey & Associates, Inc. is referred to in this Privacy Statement as “we,” “us,” “our,” or other similar pronouns.

This Privacy Statement includes, without limitation, the following information:

This Privacy Statement is incorporated into and is a part of the Terms of Use Agreement (the “Terms of Use”). We encourage you to become familiar with the terms and conditions of both this Privacy Statement and the Terms of Use. By accessing and using the System, or any part thereof, you agree that you have read and understand this Privacy Statement and are agreeing to the terms of this Privacy Statement.

For purposes of applicable data protection laws, Toomey & Associates, Inc. is the controller of the personal data you provide to us.  Our business office address is listed below.

Contact Information

We appreciate your questions and comments about this Privacy Statement, the System, and our privacy practices generally and welcome your e-mail messages to [email protected]. If you correspond with us through the System or via e-mail, the Collected Information may include the content of, and metadata regarding, any correspondence you may have with us. We may share your messages with those within our organization who are most capable of addressing the issues contained in your message. We will keep a copy of your message until we have had an opportunity to address your concerns.

If you feel that Toomey & Associates, Inc.  is not abiding by this Privacy Statement, you should first contact the Toomey & Associates, Inc. at (720) 672-1143.  We also offer you the option to write to us at:

Toomey & Associates, Inc.
1200 South Vine Street
Denver, CO 80210

Information Collection

As described in detail below, Toomey & Associates, Inc., or third parties designated by Toomey & Associates, Inc., may collect certain personal data from or about you in connection with your use of, or your submissions to, the System (“User Information”) as well as other data from or about you (together with the User Information, the “Collected Information”) in a variety of ways. Collected Information includes, without limitation, a first and last name; a home, business, or other physical address; geographic location; a business or nonprofit entity name and address; a phone number; an e-mail address; date of birth; gender; race/ethnicity; employment status; employer name; employer information; username, and password; credit card number and other credit card information; education status and information; credentials; areas of expertise; clinical service information; as well as additional personally identifiable information about you that we may collect from time to time. We use the Collected Information to provide the Services described below; to open, maintain, and close user accounts; for marketing purposes; for publication and distribution of information; to provide continuing education services; and to more efficiently and effectively respond to user queries.

Registration

To access areas of the System designated as “protected areas,” you must register with Toomey & Associates, Inc. If you wish to use the “protected areas” of the System, you will be required initially to enter certain Collected Information (e.g., first name, last name, mailing address, e-mail address, username, and password and verification of attendance to the SOS Basic Course through the submission of a Certificate of Attendance) to gain access.

Online Orders

Toomey & Associates, Inc. requests information from its users to purchase products and memberships, renew membership dues, register for conferences and events an, register for online courses and events; such information includes contact information (such as name, phone number, email address and mailing/billing address) and financial information (such as credit card number, expiration date, etc.). This information is primarily used by Toomey & Associates, Inc. and third parties designated by Toomey & Associates, Inc. for billing and to fill customer orders, but may be used by Toomey & Associates, Inc., or third parties designated by Toomey & Associates, Inc., for other business purposes. For example, if there is a problem processing an order, this information may be used to contact the user.

Business Forms

Toomey & Associates, Inc., or third parties designated by Toomey & Associates, Inc., requests information from users via online forms for specific business purposes. For example, online forms will be used to obtain sign-ups for events, request documents, contact specific departments, request copyright permission, request to be included on a therapist referral list, surveys to review services.  Information requested may include contact information (e.g., name, mailing address, phone number, certificate of attendance from an SOS Approach to Feeding conference or course). Business form information may be used by Toomey & Associates, Inc., or third parties designated by Toomey & Associates, Inc., for a variety of business purposes.

Information Use

In addition to the uses mentioned or described elsewhere in this Privacy Statement or in the Terms of Use, we, our affiliates, and designated third parties may use the Collected Information to analyze and improve the content, features, Services, Website, and Mobile Applications that we make available on the System, as well to conduct certain targeted marketing activities specific to users. We may send you information that you request from us, promotional materials regarding Toomey & Associates, Inc.’s services, and any other communication for any other legitimate and lawful business purposes. Additionally, we may retain and use certain Collected Information to facilitate and otherwise address certain inquiries, requests, subscriptions, or business transactions and relationship with Toomey & Associates, Inc., or any of our affiliates, or respond to your questions or requests for information about or from Toomey & Associates, Inc. or any of our affiliates or trusted business partners. If you contact us for support or assistance, we may use information about you or your system for purposes such as verifying whether your system meets the minimum requirements needed to use the System and our various Services. Additionally, we may transfer your Collected Information to our affiliates or trusted business partners for the purpose of advertising certain services provided by such affiliates or trusted business partners. We may also use Collected Information as necessary to ensure compliance with any Toomey & Associates, Inc. policies and any applicable laws. Toomey & Associates, Inc. may also exchange Collected Information with other companies and organizations for fraud protection, credit risk reduction, and collection activities.

Toomey & Associates, Inc. may use various analytics tools and technologies regarding how users interact with the various portions of the System that require storage of web-session data. These tools and technologies are used to assist System users by using cookies and scripts (as described in the “Cookies” section below) to collect and store information—such as how users interact with the System, errors users encounter when using the System, device identifiers, how often users visit certain portions or components of the System, what pages they visit, and what other sites they used prior to using the System. Stored web-session data used by such analytics services or tools are used in accordance with this Privacy Statement.

Additionally, we may offer message boards, voice communication features, and other interactive or social-type features on the System. Please be aware that these areas may allow you to publicly post, and share with other users, certain messages, content, or other information. Although we may take certain precautions to protect those who use these areas of the System, we encourage you to be wary of giving out any User Information—or any personally identifiable information of others to which you may have access—in such public forums. The information you post or disclose can be collected and used by people you don’t know to identify you or others. We cannot guarantee the privacy and safety of these areas and are therefore not responsible for any information you choose to post. Your use of these features is fully at your own risk.

Cookies

Please see our Cookie Statement for full details on how we use cookies on our website.

Log Files

Each view of a page on the System is logged. Information such as the user’s Internet Protocol (“IP”) address, browser type, time of day, and duration of activity on the website is recorded. This information may be used by Toomey & Associates, Inc., or third parties designated by Toomey & Associates, Inc., to analyze trends, administer the System, track users’ movements, and gather broad demographic information for aggregate use or for other business purposes.

If illegal activity is detected on the System, Toomey & Associates, Inc., or third parties designated by Toomey & Associates, Inc., may—but have no obligation to—attempt to connect an IP address to User Information. Except as otherwise required by law or regulation, Toomey & Associates, Inc. has no obligation to monitor the System, or any portion thereof, for any illegal or improper activity.

Links

For your convenience, the System may contain links to other Internet sites not under Toomey & Associates, Inc.’s control. Please be aware that Toomey & Associates, Inc.  is not responsible for the privacy practices of such other websites. In addition, should you happen to initiate a transaction on a website that our System links to, even if you reached that site through the System, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked website. You should read that website’s privacy statement or privacy policy to understand how personal data that is collected about you is used and protected by such third party. We encourage our users to be aware of when they leave the System and to read the privacy statement of each website that collects personal data. This Privacy Statement applies solely to information collected on the System.

Surveys and Promotions

From time to time, Toomey & Associates, Inc., or third parties designated by Toomey & Associates, Inc., requests information from users via surveys. Information requested may include contact information (e.g., name, mailing address) and demographic information (e.g., zip code, education and position credentials). Survey information may be used by Toomey & Associates, Inc., or third parties designated by Toomey & Associates, Inc., for a variety of business purposes. For example, surveys will be used for the purpose of improving services offered by Toomey & Associates, Inc. Participation in Toomey & Associates, Inc. surveys are completely voluntary.

In addition, you may wish to participate in online contests, sweepstakes, and other promotions that we may offer from time to time. Participation in these contests, sweepstakes, and promotions is completely voluntary; you have a choice about whether to disclose information required to enter. Information requested may include personal contact information, such as your name, address, date of birth, phone number, mobile phone number, e-mail address, username, and/or similar information. In addition, as noted above, we may share this information with our third-party providers or other entities. Through these online promotions, you may choose to participate in activities such as sharing information found on the System with others and sending e-mail invitations. In connection with any online contests, sweepstakes, and other promotions that we may offer from time to time via the System, we use the information you provide to administer the polls, contests, sweepstakes, and other promotions. Subject to applicable contractual or legal restrictions, we also may use the information to communicate with you, or the other people you select, about our services, or our marketing partners may use such information to communicate with you about the online contests, sweepstakes, or other promotions or about their products and services.

Information Submission Choices

When submitting information, corresponding, making requests for information, and otherwise interacting with Toomey & Associates, Inc. and its representatives through or in connection with the System, you choose what information to supply or submit, whether you wish to receive further information, and how you may be contacted. Please take care to share only such information as is needed or that you believe is appropriate. Note, however, that if you don’t provide certain requested information, we may be unable to provide certain Services to you, you may be unable to take full advantage of the System (or some portion thereof) and its capabilities, or some features of the System may function improperly. Any promotional e-mail we send to you will contain a link that will allow you to opt out of receiving any further correspondence. If you have created an online account, you may have the ability to change your correspondence preferences by logging into your account and selecting your preferences.

Sharing

In addition to the uses mentioned or described elsewhere in this Privacy Statement or in the Terms of Use, Toomey & Associates, Inc. may share Collected Information in a variety of ways:

Toomey & Associates, Inc. may share your User Information with authorized service providers, affiliates, or partners to provide certain administrative, marketing, or technology services—such as survey administration, database management, transaction processing, event management, and bulk mailing, or any other Services. The authorized service providers, affiliates, and partners we work with are not allowed to use the information outside of the function of providing the Services designated by Toomey & Associates, Inc.

Toomey & Associates, Inc. may share your User Information with our authorized service providers, affiliates, or partners to the extent necessary for purposes of communicating with you or fulfilling your requests for any content, materials, and opportunities.

Toomey & Associates, Inc. does not sell lists of e-mail addresses or phone numbers to third parties. Toomey & Associates, Inc. may send e-mail messages on behalf of selected third parties (e.g., company partners and allied organizations).

Toomey & Associates, Inc. and our authorized service providers, affiliates, or partners may also produce reports on the System’s traffic or usage patterns and share these reports with us and others; Toomey & Associates, Inc.  will share aggregate statistics and other non-personally identifiable information with the media, government agencies, advertisers, and other third parties. These aggregate statistics will not allow anyone to identify your name or other personally identifiable information. Toomey & Associates, Inc. also may release aggregated, anonymized Collected Information in connection with joint marketing efforts and strategic alliances.

Toomey & Associates, Inc. may disclose your User Information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement agency or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law.

Toomey & Associates, Inc. may disclose your User Information when we believe disclosure is necessary to investigate, prevent, or take action regarding illegal activity, suspected fraud, or other wrongdoing; to protect and defend the rights, property, or safety of our company, our employees, our website users or others; or to enforce our website terms and conditions or other agreements or policies.

If Toomey & Associates, Inc. changes its corporate or organizational structure, files for bankruptcy, liquidates its assets, merges/combines with another entity, or undergoes a corporate reorganization, your information is, and should be expected to be, one of the transferred assets; you consent to such transfer by using the website.

Legal Basis for Processing Personal Data

Where required by the EU General Data Protection with Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”), we will only collect and process personal data about you where we have a legal basis. Examples of legal bases include consent (where you have given consent), contract (where processing is necessary for entering into or the performance of a contract with you), and “legitimate interests”.

Where we process personal data based on consent, we will ask for your consent. You may withdraw your consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal. Where we rely on contract, we will ask that you agree to the processing of personal data that is necessary for entering into or the performance of your contract with us, and we will inform you whether the provision of your personal data is mandatory and of the possible consequences if you do not provide your personal data.

We may process your personal data for the purposes of our legitimate interests, provided that such processing does not outweigh your rights and freedoms.  Where we rely on legitimate interests, you have the right to object.  We process your personal data based on legitimate interests in order to:

Retention Period

We retain User Information that we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with the Services you requested or to comply with an applicable legal requirement).

Security

When you submit information via the website, Toomey & Associates, Inc., or third parties designated by Toomey & Associates, Inc., takes certain precautions to protect your user information both online and offline. Nevertheless, no security system is impenetrable. We cannot guarantee that information transmitted or supplied by users to the System will be totally secure. You agree to immediately notify us of any breach of the security of the System, this Privacy Statement, or the Terms of Use of which you become aware.

If you have any questions about the current state of security with respect to information collected at the Website or stored offline, you may send an e-mail to [email protected].

 Submissions to the System and Social Media Websites

Any information, communications, or material of any type or nature that you submit to the System—as well as to any of our pages contained on a social media platform or website—by e-mail, posting, messaging, uploading, downloading, or otherwise (each a “Submission”) is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of the System or a social media platform and are therefore not responsible for any Submissions contained on the System or any social media platform or website. Furthermore, by visiting any of our pages that are contained on any social media platform or website, you are representing and warranting to us that you have reviewed the applicable Privacy Statement and terms of use of such website or social media platform and that you will abide by all such provisions contained therein.

Children

The System (including the Website, Mobile Applications, and Services included therein) is intended for a general audience and is not intended for use or view by children under 13 years of age, and we do not knowingly collect information about children or sell products to children. Consistent with the Children’s Online Privacy Protection Act, we will not knowingly collect any information from children under the age of 13. If you are under the age of 13, you must ask your parent or guardian to assist you in using the System. Furthermore, we may restrict entries to any contests, sweepstakes, or promotions to entrants who are at least 18 years of age.

Visiting the System From Outside the United States

If you are visiting the System, or any part thereof, please be aware that your information may be transferred to, or stored or processed in, the United States and other countries. Our primary web and database servers are located in the United States; however, some of our third-party providers that provide certain portions of the System or the Services may use servers located in other countries. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy. By using any portion of the System, you understand and consent to the transfer of your information to our facilities in the United States and those facilities of the third parties with whom we share it—as described in this Privacy Statement—that are located in the United States or other countries. For purposes of applicable data protection laws, we will rely on legally-provided mechanisms to lawfully transfer personal data across borders, including consent and performance of a contract.

California Privacy Rights and Do Not Track Disclosures

Under California law, California residents have the right to request in writing from businesses with whom they have an established business relationship (a) a list of the categories of personally identifiable information—such as name, e-mail and mailing addresses, and the type of services provided to the customer—that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please e-mail Toomey & Associates, Inc. at [email protected] with a reference to California Disclosure Information.

Correcting and Updating Personal Data

If a user’s personal data changes or if a user no longer desires our services, we will endeavor to provide a way to correct or update personal data provided to us by that user. This can usually be done by contacting us at [email protected].

Choice and Opt-out

Only those individuals who have created an account on the Website or a Mobile Application or have otherwise evinced an interest in or consent to receiving communications from Toomey & Associates, Inc.  (including, for clarity, those individuals or organizations that have found Toomey & Associates, Inc. through Toomey & Associates, Inc.’s marketing pages or microsites) will receive e-mail or other communications from Toomey & Associates, Inc. We consider—and all Toomey & Associates, Inc. account holders or other users of the System hereby acknowledge and agree—that providing contact information (such as an e-mail address) as part of creating a Toomey & Associates, Inc. account (or otherwise through the System) constitutes an individual’s consent to receive messages or other communications from Toomey & Associates, Inc. However, if you no longer wish to receive our e-mail newsletters or promotional e-mails, you may opt out of receiving a specific communication from Toomey & Associates, Inc. by using sending your request to [email protected], or you may follow the unsubscribe instructions in any e-mail message you receive. Please allow a reasonable period of time for us to satisfy your request, as some promotions may already be in process. Please note that there are certain communications that will still be sent to users by Toomey & Associates, Inc., or third parties designated by Toomey & Associates, Inc. These communications include, without limitation, account updates, certification maintenance reminders, and invoice and membership renewal notices. Please note that even if you opt out as described above, Toomey & Associates, Inc. will retain your Collected Information for analytical purposes and other internal purposes, including an ability to reconnect you with such Collected Information if you later opt in to any of the data sharing, use, or communications set forth above.

European Economic Area (EEA) Residents

Using the contact details provided under the “Contact Information” heading above, if you are an EEA resident (specifically, any country in the EU, Lichtenstein, Norway, Iceland), for personal data that we have about you, you can also ask us for a copy of your personal data, ask us to erase or delete all or some of your personal data, ask us to stop using all or some of our personal data or limit our use of it, or ask us for a copy of your personal data provided in a machine readable form.

If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

We share your personal data with the following categories of recipients:  our authorized service providers, affiliates, or partners to the extent necessary for purposes of communicating with you or fulfilling your requests for any content, materials, and opportunities.  The majority of these recipients are located in the United States.

We do not make use of automated decision-making.  As defined under current data protection laws, automated decisions are defined as decisions about individuals that are based solely on the automated (i.e., no human involvement) processing of data and that produce legal effects or that significantly affect the individuals involved.

You have the right to complain to a data protection authority about our collection and use of your personal data.  For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA and Switzerland are available on the EU website.

We respond to all requests we receive from individuals residing in the EEA and who wish to exercise their data protection rights in accordance with applicable data protection laws.  We may ask you to verify your identity in order to help us respond efficiently to your request.

Data Subject Request

Notification of Changes

If we decide to change our Privacy Statement, we will post changes to our Privacy Statement on Toomey & Associates, Inc.’s homepage so that our users are always informed of what information we collect, how we use it, and under what circumstances, if any, we disclose it. The most recent version of the Privacy Statement is reflected by the version date located at the bottom of this Privacy Statement. All such updates and amendments are effective immediately upon notice thereof, which we may give by any means, including, but not limited to, posting a revised version of this Privacy Statement or other notice on the Website and the Mobile Applications. You should view this Privacy Statement often to stay informed of changes that may affect you, as your continued use of the System signifies your continuing consent to be bound by this Privacy Statement. We expressly reserve the right to make any changes to this Privacy Statement at any time, without prior notice to you. The version of this Privacy Statement posted here on each respective date you visit the System shall be the Privacy Statement applicable to your access and use of the System on that date. Our electronically or otherwise properly stored copies of this Privacy Statement shall be deemed to be the true, complete, valid, authentic, and enforceable copies of the version of this Privacy Statement in force on each respective date you visit the System. This Privacy Statement is not intended to—and does not—create any contractual or other legal right in or on behalf of any party other than Toomey & Associates, Inc.

This Privacy Statement was last updated on February 3, 2019.

Copyright SOS Approach to Feeding © 2024 | SOS Approach to Feeding - Denver, Colorado USA | Web Design by Webolutions

Crop Image