Privacy Policy

Notice of Privacy Practices

Jewish Family Service of the Cincinnati Area (JFS)
9395 Kenwood Road, Suite 100
Cincinnati, OH 45242

For Your Protection	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.
About Jewish Family Services Health Care Services	JFS provides a wide variety of services, some related to health care and some unrelated. The following JFS services adhere to the federal HIPAA regulations regarding privacy of health information: VSC Care Management, Youth Mental Health, Adult Counseling, Medical Interpretation and Supportive Services, and internal Data Services. The privacy practices described in this Notice apply only to these services.
Your Records Are Private	We understand that information we collect about is personal. Keeping these records private is one of our most important responsibilities. JFS follows the HIPAA regulations which require many safeguards to protect your privacy. For this notice, we will use the term “records” to mean the paper or electronic records we maintain about you.
Who Sees and Shares My Records?	Your records may be used and disclosed by the employees at JFS who serve you, as well as persons or agencies who work for us and sign strict confidentiality contracts. We may use and disclose your information for treatment, payment and healthcare operations. Specific examples include: Providing treatment for your medical problems, for example ordering 3rd party assessments, making referrals to other healthcare providers or other JFS services not covered by this Notice, or consulting with other medical providers you have seen, To secure payment, for example, a billing clerk will electronically transmit billing information to your insurance company or 3rd party payer, Certain business associates, who are under contract to maintain confidentiality, may see your information. For example, if you accidentally overpay, and we send a refund check, our accountant may see this refund check. For other operations to operate and manage JFS: these include improving quality of care, training staff, managing costs, and conducting other business duties. For example, a quality assurance reviewer may audit your records to determine whether appropriate services were provided, To remind you of an appointment for services, To raise funds for JFS. You have the right to opt out of receiving these communications.
Could My Records Be Released Without My Permission?	There are limited situations when we are permitted or required to disclose your records, or parts of them, without your signed permission. These situations include: Reports to public health authorities to prevent or control disease or other public health activities, To protect victims of abuse, neglect, or domestic violence, For oversight including investigations, audits, accreditation and inspections, such as are conducted by the State Department of Health, or State Pharmacy Board, and federal agencies, When a court order, subpoena or other legal process compels us to release information, Reports to law enforcement agencies when reporting suspected crimes, when responding to an emergency, or in other situations when we are legally required to cooperate, In connection with an emergency, or to reduce or prevent serious threat to public health and safety, To coroners, medical examiners and funeral directors, To victims of alleged violence or sex offenses, For workers’ compensation programs, For specialized government functions including national security, protecting the president, operating government benefit programs, and caring for prisoners, In connection with “whistleblowing” by an employee of JFS. All other uses not described above require that we obtain your signed permission as described below.
What If My Records Need to Go Somewhere Else	For any purpose not described above, we will release your information only with your explicit written authorization. Federal law requires that we notify you that all healthcare providers must obtain your explicit permission to release your information for any of the following: To release Psychotherapy Notes, For marketing purposes, To sell information about you. Please note that it is not and has never been JFS’ policy to sell information about you or to use your information for marketing. Your written permission, called an “authorization,” tells us what, where, why and to whom the information must be sent. Your signed authorization is valid until the date you specify. You can revoke this authorization at any time by letting us know in writing. Redisclosure Possibility – This notice describes many situations where we may send your information to someone else. When records are sent somewhere else, they might not be protected by HIPAA. For example, if a court requires us to send them your records for a criminal case, your records might be disclosed publicly in court.
Abortion and Reproductive Health Services	Our records might contain information about a legal abortion or other reproductive health service you received. If you had a legal abortion (or other reproductive health service), JFS is prohibited from releasing any records related to these services to any third party who wants to investigate or prosecute you. For example, if your state Attorney General requested records regarding your legal abortion to prosecute you we would refuse to release the records. Any record requests from health oversight agencies, courts, law enforcement agencies, coroners or medical examiners about your abortion or other reproductive health care will be honored only if the requesting court or agency submits a formal Attestation regarding their intent. They must state either that their request is NOT to investigate or prosecute you for a legal abortion, or on the other hand that they have evidence that your abortion (or other reproductive health service) was illegal and that they intend to prosecute you. For example, if a court requested records in a case regarding another matter (such as a guardianship case), they would attest that their intended use of your records was NOT to investigate or prosecute you for an abortion that you had, and we would release your records as ordered.
Records Relating to Substance Use Disorder Treatment	Certain medical records regarding treatment for drug or alcohol abuse are protected by federal laws known as 42 CFR Part 2. While JFS does not provide drug or alcohol abuse treatment, if we receive protected records from a treatment center, JFS will ensure the following protections for you: JFS will not release your drug or alcohol abuse treatment records to any civil, criminal, administrative, or legislative proceeding against you unless 1) you either provide us your written consent, or 2) a court first provides either you or JFS the opportunity to challenge the release, and after due process issues us an order and subpoena compelling us to release your records. JFS will notify you prior to any fundraising campaigns for our agency so that you may opt-out of any fundraising solicitations.
What Are My Rights Regarding Privacy, Access to My Records, and the Accuracy of My Records?	You have legal rights concerning your privacy, access to your records, and the accuracy of your records: If you request, we will show you your records, or give you a copy. If you think some of the information is wrong, you may ask that it be changed, or that new information be added. If you request, we will mail all communications to a confidential address. If you request, we will provide a list of any places where your records have been sent. You may request that we make additional limits on how we use or disclose your information. We must honor requests to not bill a 3rd party payer if you pay the invoice in full. For other requests, we will consider but are not obliged to honor these requests. You may receive a paper copy of this notice. To exercise any of these rights, mail or email your request to: Leslie Brody, HIPAA Privacy Officer Jewish Family Services of the Cincinnati Area 9395 Kenwood Road, Suite 100 Cincinnati, OH 45242 LBrody@JFSCinti.org 513-766-3351
Our Duties	We are required by law to abide by the terms of this notice. In the event of a breach, that is, an unintended release of your information contrary to these practices, we will notify you via first class mail. From time to time we may make changes to our policies, and if and when we do, your records will be protected by our new, changed policies. Our current notice will always be available on our website.
Questions or Complaints?	If you have any questions about this notice, or you think that we have not protected your records and you wish to complain about any privacy or records access matter, please contact: Leslie Brody, HIPAA Privacy Officer Jewish Family Services of the Cincinnati Area 9395 Kenwood Road, Suite 100 Cincinnati, OH 45242 LBrody@JFSCinti.org 513-766-3351 We will never retaliate against you for filing a complaint. Further, if you are not satisfied with the results, you may also complain to the federal government: Secretary of Health and Human Services 200 Independence Avenue, SW Washington, D.C. 20201 www.hhs.gov/ocr/privacy/hipaa/complaints/index.html

Current Revision effective 6/12/25

At Jewish Family Service of the Cincinnati area, your privacy is very important to us. The following information will help you to understand more clearly our privacy practices, the importance of protecting the privacy of personally identifiable information (“PII”), including how we collect, use, share, disclose, maintain, and protect information about users and donors (each a “User”, “you”, or “your”) and information you may share with us.

Websites

Our websites include www.jfscinti.org, www.agewellcincy.org, and all other affiliated websites (“Sites”).

Our Sites are used to provide information about the impact and work of Jewish Family Service; as well as services provided by our departments. By accessing and using our Sites, you agree that you have read and understand this Privacy Policy and you consent to the privacy practices (and any collection, uses and disclosures of information about you) that are described in this Privacy Policy.

Collected information

Through your involvement with Jewish Family Service, you may disclose or update personal information such as your name, address, e-mail address, telephone number(s), cell phone number(s), date of birth, credit card information, or details about your interests. This is most often done through donations, reservations made on our Sites, completed pledge cards and/or invitation response cards, surveys, or taken over the telephone in conversation with a Jewish Family Service staff member or volunteer. We collect and store this information in a secure database. We do not store credit card or financial account information. We may store financial transaction information about your donations to Jewish Family Service for up to 26 years and donor data (including but not limited to giving information) permanently. We may also store information about your Jewish Family Service Create Your Jewish Legacy planned giving including, but not limited to, related documents such as contracts, wills, and other records.

Web browser cookies

Our Sites may use “cookies” to enhance our Users’ experiences. Your web browser places cookies on your hard drive for record-keeping purposes and to identify you should you visit the Site again. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you reject cookies you may still use the Site, but please note that some parts of the Site may be limited or not function properly.

Other information

We also may collect other identifying information from or about you in connection with your use of our Sites, social media, text messaging, and interactions with us via email. For example, we may collect and store the content of, and data regarding, any correspondence you may have with us or our representatives, regardless of the subject matter or the mode of communication by which such correspondence is made. As with many other websites, the Internet servers used to operate our Sites may collect certain information pertaining to you and the software, equipment, and communications method that you use to access the Internet and our Sites. This information can include: browser type, device type, domain names, access times, referring website addresses, and IP addresses for logged in users.

How we use collected information

We may collect, use, and/or disclose your information for the following purposes:

To fulfill or meet the reason for which you provided the information or process you requests, transactions, and payment
To support, create, maintain, customize and secure your account with us
To run, operate, and market our Sites and services

We may use the personal information you give us for confirmation of donations, registrations, or other actions you take on our Sites, and for related customer service needs. We also use your information in order to maintain, develop, and market the Sites and in connection with other programs and services we provide.

To research our programs and services

We may use information in the aggregate to understand how our Users as a group use the programs and services provided by Jewish Family Service to evaluate the effectiveness of Jewish Family Service, our Sites, and our marketing and business efforts. We may use such information in the aggregate to analyze our Sites usage. We may use the information that is not personally identifiable to analyze the design and functionality of our Sites and communication in order to make improvements.

To improve our Sites

We use User information and feedback and share it with select third parties to improve our Sites and programs and services.

To send emails

We may use the information you give us to communicate with you through periodic messages regarding programs and services, events, and other information and notices we believe you may find interesting or useful.

Electronic newsletters

At any time, you may opt-out of receiving communications from us or may choose to receive only specific communications by contacting us at info@jfscinti.org or call 513-469-1188. In addition, if at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

Disclosure of your personal information

We do not sell, rent, swap or otherwise share or disclose our mailing lists or your email address with external organizations except as follows:

Any personal information you provide to us will not be disseminated to third parties outside of Jewish Family Service except where that information is stored briefly with a third-party database, such as a mailhouse. We maintain agreements with all third-party providers to protect your privacy.

We use your information and share it with select third parties in order to display content on the Sites correctly and to otherwise make the Sites function properly, and in order to maintain, develop, and market the Sites and in connection with other programs and services we provide.

We may share your information as may be described to you when collecting information or as otherwise set forth in this Privacy Policy.

How We Secure Your Data

Jewish Family Service uses appropriate procedures to ensure the security of your personal information and to protect it from unauthorized access. We have adopted appropriate data collection, storage, and processing practices and security measures to help protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information, and data stored. In particular, when we ask you to enter credit card information, we use the top industry standard security protection, including encryption, a PCI environment, SSL transmission connection, and a secure server for information transmission. We use third-party credit card processors to process credit card transactions. Once your credit card has been processed, your credit card information is not stored on our servers or our processor’s servers.

Information from Children

The Sites are not designed to solicit or collect date from individuals under the age of 13. In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we do not knowingly collect or store any personal information, even in aggregate, about children under the age of 13.

Opt-Out or Change Your Contact Information

It is your responsibility to provide us with accurate personal data. To the extent necessary for these purposes, we will take reasonable steps to ensure that personal data is accurate, complete, current, and relevant to its intended use. These steps may include comparing and/or supplementing your personal data with information from external data providers. You may update your Personal Information and prevent unwanted communication. You cannot remove yourself from our database. For more information on changing, correcting, or updating your Personal Information and communications preferences, please contact us at info@jfscinti.org with the subject line “Update Information” or call 513-469-1188.

Other Website Policies

Use of Links

Throughout the pages on our Sites, we may provide links to other websites which may contain information of interest to you. We take no responsibility for, and exercise no control over, the organizations, views, privacy practices, security, content or accuracy of the information contained on other websites. We recommend that you review the privacy policy or notice of each linked website that you visit.

Creating a text link from your website to one of our Sites does not require permission. If you have a link you would like us to consider adding to one of our websites, please send an email to info@jfscinti.org with the subject “Link request.”

Use of Text and Images

If you would like to publish information that you find on one of our Sites, please send your request to info@jfscinti.org with the subject “Text and images.” Where text and/or images are posted on one of our Sites with the permission of the original copyright holder, a copyright statement appears at the bottom of the page, or a photo credit appears underneath the photo or in “alt” text.

Email us at info@jfscinti.org with the subject “Use of logo and images” for information about using our logo and images according to Jewish Family Service brand standards.

Advertising

We use your personal information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt out portal at: http://optout.aboutads.info/

Google Adsense

Some of the ads may be served by Google. Google’s use of the DART cookie enables it to serve ads to Users based on their visit to our Site and other sites on the Internet. DART uses “non-personally identifiable information” and does NOT track personal information about you, such as your name, email address, physical address, etc. You may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy at http://www.google.com/privacy_ads.html

Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy at our sole discretion at any time. When we make changes to this Privacy Policy we will post the updated policy on our Sites and update the Privacy Policy’s effective date. Your continued use of our Sites and/or our programs and services or efforts following the posting of changes constitutes your acceptance of such changes.

Contacting us

If you have any questions about this Privacy Policy, the ways in which we collect, use or disclose information, the practices of this Site, or your dealings with this Site, please contact us at info@jfscinti.org.

This document was last updated on March 2020.

Website Analytics with Google Analytics

This website utilises Google Analytics 4, a web analytics service provided by Google LLC, after obtaining user consent. The relevant controllers are Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, for users from the EU/EEA and Switzerland. Google Analytics 4 practices IP anonymisation by default, meaning your IP address is instantly shortened when interacting with this website. Only under rare circumstances will your full IP be transferred to a US-based Google server and shortened there. Google maintains that the IP transferred via Google Analytics will never be combined with other Google data. Google Analytics 4 only activates upon your approval via the cookie banner, and can be undone anytime through the cookie settings.

Data processed includes: usage data such as page views, website interaction, general location, and visit duration; and communication data like shortened IP addresses, user agent, language preference and screen resolution. The purpose of this data processing is for Google to evaluate your website use on behalf of the website operator, compile reports on activity and analyze site performance. This data processing is legal, based on your consent under Art. 6 para.1 p.1 lit. a GDPR and § 25 para. 1 p.1 TDDDG.

Google Ireland Limited, Google LLC and Alphabet Inc are the recipients of this data. Your website usage information is typically sent to a Google server in the U.S., an action legitimized by the European Commission’s recent adequacy decision from July 10th, 2023, which recognizes Google LLC’s certification under the EU-US Privacy Framework. In terms of data storage, any data linked to cookies is automatically deleted after a certain period of time, which is monthly for data that has reached its retention period, and a maximum of 2 years for Google Analytics cookies.

For more information on Google Analytics’ terms of use and Google’s privacy policy, please visit https://policies.google.com/ and https://support.google.com/analytics/answer/12017362

Google Analytics verwendet sog. “Cookies”, Textdateien, die auf dem Computer des Seitenbesuchers gespeichert werden und die eine Analyse der Benutzung der Website durch den Seitenbesucher ermöglichen. Die durch das Cookie erzeugten Informationen über die Benutzung dieser Website durch den Seitenbesucher (einschließlich der gekürzten IP-Adresse) werden in der Regel an einen Server von Google übertragen und dort gespeichert.

Google Analytics wird ausschließlich mit der Erweiterung “_anonymizeIp()” auf dieser Website verwendet. Diese Erweiterung stellt eine Anonymisierung der IP-Adresse durch Kürzung sicher und schließt eine direkte Personenbeziehbarkeit aus. Durch die Erweiterung wird die IP-Adresse von Google innerhalb von Mitgliedstaaten der Europäischen Union oder in anderen Vertragsstaaten des Abkommens über den Europäischen Wirtschaftsraum zuvor gekürzt. Nur in Ausnahmefällen wird die volle IP-Adresse an einen Server von Google in den USA übertragen und dort gekürzt. Die im Rahmen von Google Analytics von dem entsprechenden Browser übermittelte IP-Adresse wird nicht mit anderen Daten von Google zusammengeführt.

Im Auftrag des Seitenbetreibers wird Google die anfallenden Informationen benutzen, um die Nutzung der Website auszuwerten, um Reports über die Websiteaktivitäten zusammenzustellen und um weitere mit der Websitenutzung und der Internetnutzung verbundene Dienstleistungen dem Seitenbetreiber gegenüber zu erbringen (Art. 6 Abs. 1 lit. f DSGVO). Das berechtigte Interesse an der Datenverarbeitung liegt in der Optimierung dieser Website, der Analyse der Benutzung der Website und der Anpassung der Inhalte. Die Interessen der Nutzer werden durch die Pseudonymisierung hinreichend gewahrt.

Google LLC. ist nach dem sog. Privacy Shield zertifiziert (Listeneintrag hier) und gewährleistet auf dieser Basis ein angemessenes Datenschutzniveau. Die gesendeten und mit Cookies, Nutzerkennungen (z. B. User-ID) oder Werbe-IDs verknüpften Daten werden nach 50 Monaten automatisch gelöscht. Die Löschung von Daten, deren Aufbewahrungsdauer erreicht ist, erfolgt automatisch einmal im Monat.

Die Erfassung durch Google Analytics kann verhindert werden, indem der Seitenbesucher die Cookie-Einstellungen für diese Website anpasst. Der Erfassung und Speicherung der IP-Adresse und der durch Cookies erzeugten Daten kann außerdem jederzeit mit Wirkung für die Zukunft widersprochen werden. Das entsprechende Browser-Plugin kann unter dem folgenden Link heruntergeladen und installiert werden: https://tools.google.com/dlpage/gaoptout.

The website visitor can prevent data collection via Google Analytics on this website by clicking here. An “Opt-out Cookie” shall then be applied which shall prevent any future collection of the site visitors data when visiting this website.

Weitere Informationen zur Datennutzung durch Google, Einstellungs- und Widerspruchsmöglichkeiten, finden sich in der Datenschutzerklärung von Google (https://policies.google.com/privacy) sowie in den Einstellungen für die Darstellung von Werbeeinblendungen durch Google (https://adssettings.google.com/authenticated).

Spam Protection with Google reCAPTCHA

We have implemented Google reCAPTCHA in forms on our website to check whether the data entered in the forms comes from human visitors or from machines or automated programs, also known as “bots”. This tool automatically analyzes the behavior of website visitors as soon as they interact with the website using various information like IP address, length of stay, and mouse movements. The data processed includes usage data such as the website accessed, date and time of access, and mouse movements, as well as communication data like IP addresses, browser type, and operating system. This processing is targeted at website visitors and users of online services. The primary purpose of this processing is to prevent the misuse of our contact form, thereby enhancing security. The legal basis for this is our legitimate interest according to Art. 6 para. 1 p. 1 lit. f. GDPR. The data recipients include Google Ireland Ltd, based at Google Building Gordon House, Barrow St, Dublin 4, Ireland, (https://policies.google.com/privacy) and our website hosting provider. While your personal data is processed within the EU, the retention time for the processed data is determined by Google Ireland Limited. Additional information can be found in the Google reCAPTCHA privacy policy: https://policies.google.com/privacy

Website Analytics (Creator Statistics)

When you visit our website, we collect information about your usage through a web analytics tool provided by our hosting service. This tool collects and combines your IP address and user agent, shortens it and stores this data using a hash function. This process creates a visitor identifier that is encrypted with a randomly generated value (SALT) that changes every 24 hours. This method ensures that your IP address cannot be reconstructed from the stored visitor identifier, thus maintaining your anonymity. In addition, we do not merge this information with any other data and it is stored only on the hosting provider’s server.

We also process web analytics data, HTTP data and web analytics profile data. The web analytics tool we use creates and stores a web analytics profile, which includes details about your use of the website, such as page views, visit frequency, time spent on each page, and the user agent of your device. This includes usage data (such as web pages visited and access times) and communication data (such as browser type, operating system and IP addresses).

Our purpose in processing this data is to analyse user behaviour in aggregate form in order to improve the presentation and content of our website. The legal basis for this processing is our legitimate interest (Art. 6 para. 1 lit. (f) GDPR), in particular in carrying out web measurements in order to improve our products and website.

The data collected is shared with our website hosting provider and processed within the EU.