Privacy Policy

1. Information We Collect

1.1 Information You Provide Directly

We collect information that you voluntarily provide to us when you:

• Complete contact forms on our Website
• Request information about our programs and services
• Schedule an appointment or inquiry consultation
• Enroll in our treatment programs
• Communicate with us via email, phone, or other means

This information may include:

• Name and contact information (email address, phone number, mailing address)
• Date of birth and age
• Insurance information
• Treatment-related information
• Any other information you choose to provide

1.2 Information Collected Automatically

When you visit our Website, we automatically collect certain information about your device and browsing activity, including:

• IP address
• Browser type and version
• Operating system
• Referring website
• Pages visited and time spent on pages
• Date and time of visit
• Device identifiers

1.3 Information from Third Parties

We may receive information about you from third parties, such as:

• Healthcare providers who refer you to our services
• Insurance companies for verification and authorization purposes
• Family members or legal representatives (with appropriate consent)

2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 To Provide and Improve Our Services

• Respond to your inquiries and requests
• Process admissions and enrollment
• Deliver treatment services and care coordination
• Communicate with you about appointments and treatment
• Improve our programs and services

2.2 For Website Functionality and Analytics

• Operate and maintain our Website
• Analyze website traffic and user behavior
• Improve website design and user experience
• Troubleshoot technical issues

2.3 For Legal and Regulatory Compliance

• Comply with applicable laws and regulations
• Respond to legal requests and prevent fraud
• Protect the rights, property, and safety of Aquila Recovery, our patients, and others

2.4 With Your Consent

• Send marketing communications (only with your explicit consent)
• Any other purpose disclosed to you at the time of collection

3. How We Share Your Information

We do not sell, rent, or trade your personal information. We may share your information in the following circumstances:

3.1 Service Providers

We may share information with trusted third-party service providers who assist us in operating our business, including:

• HubSpot: Customer relationship management (CRM) and form processing
• Google Analytics and Google Tag Manager: Website analytics and tracking
• IT and security service providers
• Healthcare service providers involved in your treatment

These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

3.2 Legal Obligations

We may disclose information when required by law, including:

• In response to a court order or subpoena
• To comply with applicable laws and regulations
• To protect the rights, property, or safety of Aquila Recovery, our patients, or others
• In connection with legal proceedings

3.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the successor entity, subject to the protections described in this Privacy Policy.

3.4 With Your Consent

We may share your information for any other purpose with your explicit consent or at your direction.

4. Cookies and Tracking Technologies

Our Website uses cookies and similar tracking technologies to enhance your browsing experience and analyze website usage.

4.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help websites remember your preferences and understand how you use the site.

4.2 Types of Cookies We Use

• Essential Cookies: Necessary for the Website to function properly
• Analytics Cookies: Help us understand how visitors interact with our Website (Google Analytics, Google Tag Manager)
• Functional Cookies: Remember your preferences and settings

4.3 Google Analytics

We use Google Analytics to collect information about Website usage. Google Analytics uses cookies to track and report website traffic. The information generated about your use of the Website (including your IP address) is transmitted to and stored by Google. Google uses this information to evaluate your use of the Website, compile reports on website activity, and provide other services relating to website activity and internet usage.

For more information about Google Analytics, please visit: https://policies.google.com/privacy

You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout

4.4 Managing Cookies

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. Please note that disabling cookies may affect the functionality of our Website.

5. HIPAA and Protected Health Information

HIPAA governs how we use and disclose your health information when you are a patient receiving treatment services. Key protections include:

• We will only use and disclose your PHI for treatment, payment, healthcare operations, and other purposes authorized by law
• You have the right to access, amend, and request restrictions on the use of your PHI
• We maintain administrative, physical, and technical safeguards to protect your PHI
• We train all staff members on HIPAA compliance and privacy practices

Website Limitations: This Website is not intended for the transmission of PHI. Do not submit detailed health information, medical records, or other sensitive health data through our Website contact forms. If you need to share protected health information, please contact us directly by phone at (703) 454-5874.

6. 42 CFR Part 2 - Substance Use Disorder Records

If you receive substance use disorder treatment services from Aquila Recovery, the following additional protections apply:

6.1 Consent Required for Disclosure

We generally cannot disclose information about your substance use disorder treatment without your written consent, except in limited circumstances permitted by law, such as:

• Medical emergencies
• Internal communications within our program
• Court orders that meet specific legal requirements
• Reports of suspected child abuse or neglect
• Disclosures to qualified service organizations (with a business associate agreement)

6.2 Restrictions on Use in Legal Proceedings

Part 2 records cannot generally be used to criminally investigate or prosecute patients without specific consent or a qualifying court order.

6.3 Patient Notice

Upon admission to our substance use disorder treatment program, you will receive a detailed Part 2 Patient Notice that explains:

• How your SUD treatment records are protected
• When we may use or disclose your records
• Your rights regarding your records
• How to file a complaint if you believe your privacy rights have been violated

6.4 Breach Notification

In the event of a breach of unsecured Part 2 records, we will provide notification in accordance with federal requirements.

7. Data Security

We implement appropriate technical, administrative, and physical security measures to protect your information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit and at rest
• Secure servers and firewalls
• Access controls and authentication procedures
• Regular security assessments and updates
• Staff training on information security and privacy
• Business associate agreements with third-party service providers

While we strive to protect your information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security but will notify you in accordance with applicable law if a data breach occurs.

8. Your Privacy Rights

Depending on your location and the nature of your relationship with us, you may have the following rights regarding your information:

8.1 Access and Portability

You have the right to request access to the personal information we hold about you and to receive a copy of that information in a portable format.

8.2 Correction

You have the right to request correction of inaccurate or incomplete personal information.

8.3 Deletion

You may request deletion of your personal information, subject to certain legal exceptions (e.g., we may need to retain records for legal compliance or legitimate business purposes).

8.4 Restriction and Objection

You may request that we restrict the processing of your information or object to certain uses.

8.5 Opt-Out of Marketing

You may opt out of receiving marketing communications from us at any time by following the unsubscribe instructions in our emails or by contacting us directly.

8.6 Do Not Track

Our Website does not currently respond to "Do Not Track" browser signals.

To exercise any of these rights, please contact us using the information provided in Section 13.

9. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

9.1 Right to Know

You have the right to request information about the categories and specific pieces of personal information we have collected about you, the sources of that information, the purposes for collection, and the categories of third parties with whom we share that information.

9.2 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions.

9.3 Right to Correct

You have the right to request correction of inaccurate personal information.

9.4 Right to Opt-Out

You have the right to opt out of the "sale" or "sharing" of your personal information. Note: Aquila Recovery does not sell or share personal information for cross-context behavioral advertising purposes.

9.5 Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights.

9.6 Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We may require verification of the agent's authority.

9.7 Categories of Personal Information Collected

In the past 12 months, we have collected the following categories of personal information:

• Identifiers (name, email, phone number, IP address)
• Demographics (age, date of birth)
• Commercial information (treatment program enrollment)
• Internet activity (website usage data)
• Health information (treatment-related information)
• Insurance and financial information

10. Children's Privacy

Our Website is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13 without parental consent. If you believe we have inadvertently collected information from a child under 13, please contact us immediately, and we will take steps to delete such information.

For minors between 13 and 17 who may receive treatment services, we comply with applicable laws regarding parental consent and the rights of minors to consent to substance use disorder treatment.

11. Third-Party Links

Our Website may contain links to third-party websites, services, or resources that are not operated or controlled by Aquila Recovery. This Privacy Policy does not apply to third-party websites. We are not responsible for the privacy practices of third parties, and we encourage you to review the privacy policies of any third-party websites you visit.

Third-party services referenced in this Privacy Policy:

• HubSpot: https://legal.hubspot.com/privacy-policy
• Google Analytics: https://policies.google.com/privacy

12. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. When we make changes, we will update the "Last Updated" date at the top of this page. If we make material changes to how we handle your personal information, we will provide notice through our Website or by other appropriate means.

We encourage you to review this Privacy Policy periodically to stay informed about our privacy practices.

13. Contact Us