PRIVACY POLICY

Effective: 04/23/2020

Welcome to the FrontlineMA.org website (“FrontlineMA.org”). Your privacy is one of our top priorities. The following policy applies only to the use of FrontlineMA.org and all its subdomains (collectively, “FrontlineMA.org”). As you navigate FrontlineMA.org, you will see links that, when clicked, will take you to other websites operated by state agencies (the “Other Commonwealth Websites”) or to other websites external to Massachusetts state government. The Other Commonwealth Websites have individual privacy policies tailored to the interactions available through each site. You may also see links that will take you to websites external to Massachusetts state government.

In particular, please note that although some of the social media pages used by FrontlineMA.org might appear to be part of FrontlineMA.org or at a web page under control of FrontlineMA.org, some of these sites are actually hosted by a third-party provider. Thus, when visiting these third party social media sites, you are subject to different privacy policies and terms of service. We strongly suggest that you read the site policies, including the privacy policies, for each Commonwealth website that you visit and any external site that you visit through a link appearing at FrontlineMA.org.

A privacy partnership

Your privacy with respect to the use of FrontlineMA.org results from a partnership between the Massachusetts Office of Attorney General and you, the user. At FrontlineMA.org, we attempt to protect your privacy to the maximum extent possible. However, because some of the information that we receive through FrontlineMA.org is subject to the Public Records Law, Massachusetts General Laws Chapter 66, Section 10, we cannot ensure absolute privacy. Information that you provide to us through FrontlineMA.org may be made available to members of the public under that law. This policy informs you of the information that we collect from you at FrontlineMA.org, what we do with it, to whom it may be disseminated, and how you can access it. Based on this information, you can make an informed decision about your use of FrontlineMA.org. You can maximize the benefits of your privacy partnership with the Commonwealth by making informed decisions about whether to share personally identifiable information with us through FrontlineMA.org.

Personally identifiable information

We use the term “personally identifiable information” to mean any information that could reasonably be used to identify you, including your name, address, telephone number, email address, birth date, or any combination of information that could be used to identify you.

You should not submit sensitive personal information, such as personal health information, social security numbers, credit or debit card numbers, bank account information, passport numbers, driver’s license numbers or similar identifiers to FrontlineMA.org.

Information voluntarily provided by you

FrontlineMA.org collects voluntary information from you through surveys, online forms, any emails sent to FrontlineMA.org and comments posted on pages hosted by FrontlineMA.org (such as blogs or wikis). All such information, including comments and emails sent by you to FrontlineMA.org may contain personally identifiable information.

While FrontlineMA.org is intended as a medium for disseminating information from state agencies, non-profit organizations, and private businesses, if you need to contact any entity that is referenced by FrontlineMA.org, you should use the contact information for that entity posted on its FrontlineMA.org website.

Information automatically collected and stored by FrontlineMA.org

FrontlineMA.org employs the use of "Persistent Cookies." The purpose of these Persistent Cookies is to collect and aggregate data regarding FrontlineMA.org’s visitor activity in order for us or our service providers to continuously evaluate and improve its website services, including on FrontlineMA.org or affiliated websites such as sites hosted at http://blog.mass.gov (collectively, the “Offerings”). You may elect to disable the Persistent Cookies. Please be advised that disabling the Persistent Cookies may affect your ability to view or interact with FrontlineMA.org.

FrontlineMA.org does collect and store your “Internet Protocol (“IP”) address,” (which does not identify you as an individual) indefinitely, as well as information about the date and time of your visit, whether a file you have requested exists, and how many “bytes” of information were transmitted to you over the Web from FrontlineMA.org. We use your IP address to assess the frequency of visits to FrontlineMA.org and the popularity of its various pages and functions. We will not attempt to match any personally identifiable information that you provide to us with your IP address, unless there are reasonable grounds to believe that doing so would provide information that is relevant and material to a criminal investigation. The one exception is that when you fill out information in a form on FrontlineMA.org, we do receive your IP address along with this submission. We do not use this form-related IP address information unless it may be relevant and material to a criminal investigation.

Usage data and known persistent cookies

FrontlineMA.org uses (or may use) the following tools (each a “Tool” and collectively, the “Tools”):

Tool name: Twitter™ widget

Purpose: Display various Twitter feeds on FrontlineMA.org

Data collected: The Twitter widget uses Twitter’s persistent cookie(s) to allow you to retweet from and access other Twitter functions related to your account. Twitter accesses this cookie on every page where the Twitter widget is displayed. This could allow Twitter to determine which websites you have visited.

Privacy Policy: http://twitter.com/privacy

Terms of Use: http://twitter.com/tos

Express opt out:

1) https://support.twitter.com/articles/20169421

2) You are not required to log in to your Twitter account (if you have one) to use FrontlineMA.org.

Special notes: Twitter may personalize your user experience on Twitter based on what pages you have visited that contain a Twitter widget.

Tool Name: Facebook™ “Like” widget

Purpose: Allows user to “Like” a web page and also displays whether user has already “Liked” the webpage.

Data collected: The Facebook widget uses Facebook’s persistent cookie(s) to determine whether you have “Liked” a page. Facebook accesses this cookie on every page where the Facebook “Like” widget is displayed. This could allow Facebook to determine which websites you have visited.

Privacy Policy: www.facebook.com/help/186325668085084/ and www.facebook.com/about/privacy/

Terms of Use: www.facebook.com/policies/

Express opt out: You are not required to log in to your Facebook account (if you have one) to use FrontlineMA.org.

Tool Name: Flockler widget

Purpose: Allows user to view to an aggregate social media feed from FrontlineMA.org’s associated Twitter account, @frontlinemaorg.

Data collected: Flockler does not store any cookies or track the visitors. Flockler does store anonymous data regarding the aggregated traffic volumes of all Flockler accounts. This data is automatically deleted every 21 days, and it doesn’t enable Flockler to identify or track a specific user visiting FrontlineMA.org.

Privacy Policy: https://flockler.com/privacy-policy  

Terms of Use: https://flockler.com/terms-and-conditions

Tool Name: HubSpot 

Purpose: The HubSpot tracking code uses cookies to collect information about visitors to FrontlineMA.org. These cookies collect information that is used either in aggregate form to help us understand how our website is being used or to help us customize the website for you. 

Data collected: The HubSpot tracking code collects anonymous website visitor information. When a visitor provides personally identifiable information to the website - for example, fills out a form - the tracking code identifies individual users. The type of data collected includes page visits, first visit, and last visit. To learn more about the cookies used by HubSpot, please review this page

Privacy Policy: https://legal.hubspot.com/privacy-policy

Terms of Use: https://legal.hubspot.com/legal-stuff

Express opt out: You may disable the collection and use of your data through browser-, operating system- or device-level settings.

Additional general information related to tools

We use the information we get from the Tools only to improve the Offerings. The Tools may also collect data such as browser information, operating system, and page views through the implementation of session cookies or persistent cookies. Except as set forth in this Privacy Policy (e.g., possibly in response to a public records request), we do not combine the information collected through the use of any Tool with personally identifiable information. Although each of the Tools plants a persistent cookie on your web browser to identify you as a unique user the next time you visit FrontlineMA.org, the cookie cannot be used by anyone but  and/or the software publisher of the respective Tool (the “Software Publisher”). The Software Publisher’s ability to use and share information collected by the Software Publisher about your visits to FrontlineMA.org is restricted by the Software Publisher’s Terms of Use and Privacy Policy, links to which have been provided above. You may prevent the Tools from using persistent cookies by disabling cookies on your browser. Some of the Tools permit you to opt-out of the Tool by allowing that Tool to plant a persistent cookie on your web browser indicating that you have opted out. If you disable cookies on your browser or use a different browser, different computer, different user account, etc., you will need to opt-out again. If you allow persistent cookies in your web browser, Software Publishers have the technical ability to track your activity, even if you change your IP address, so long as you are using the web browser where the persistent cookie was planted. You should refer to the Software Publisher’s Privacy Policy and Terms of Use to determine whether they do, in fact, track you via the persistent cookie.

Links to social media sites

Certain links on FrontlineMA.org (whether integrated with Tools or otherwise) facilitate interaction with third-party social media sites. Accessing third-party social media functions (whether through a Tool or otherwise) may require you to log in to your social media provider, and that social media provider may plant a persistent cookie on your web browser to keep you logged in. Any interaction with any such social media provider (whether through a Tool or otherwise) is subject to such social media provider’s site policies, and such provider may plant one or more additional persistent cookies on your web browser as a result of your interaction with it.

Website Hosting with HubSpot

We use HubSpot to host our website https://www.frontlinema.org/. We use HubSpot forms to collect your personal information and operate certain features on our website, and we store the information you submit via a form in the HubSpot contact management system. We may use the personal information you submit to email you using the HubSpot service. 

When you visit our website, HubSpot automatically collects information about your computer hardware and software (‘log files’). This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by HubSpot to ensure the optimal operation of HubSpot service and for security purposes.  For security purposes, HubSpot may link these log files to other personal information such as name, email address, address, and phone number.

HubSpot does not sell personal information collected by its customers. HubSpot shares personal information collected by its customers with third party service providers to provide HubSpot’s products and services. HubSpot may share or disclose certain information you provide if necessary to fulfill government functions or legal obligations. The information and content of our website are stored on HubSpot’s cloud infrastructure, which you can learn more about here

You can learn more about HubSpot and how it protects your data, and privacy by reviewing HubSpot’s Privacy Policy.

 Online forms on FrontlineMA.org

Online forms may be provided by a third party service Formstack. When you use this service, your form submission is securely made to Formstack and stored there. Form submissions are then transmitted to state government staff. State government staff will delete form submissions from Formstack when there is no longer any administrative need to retain them there. Formstack only uses your form submissions for internal purposes and the data is considered private. Formstack will not distribute or sell your information to a third party unless required by law or a valid government request. Formstack may also share information if it is acquired by or merged with another company. Please see the Formstack privacy policy at www.formstack.com/privacy.

Dissemination of your personally identifiable information

We do not sell any personally identifiable information collected through FrontlineMA.org or submitted to the Commonwealth in conjunction with using functions on FrontlineMA.org, and there is no direct or online public access to the information. However, once you voluntarily submit personally identifiable information to us related to your use of FrontlineMA.org, its dissemination is governed by the “Public Records Law,” the “Fair Information Practices Act” (Massachusetts General Laws Chapter 66A), Executive Order 504, and other applicable laws and regulations. For this reason, part or all of the information you send us may be provided to a member of the public in response to a public records request. There are pieces of information, such as credit card numbers, TIN, username, or password that are not considered public for the purposes of a public records request. For more information on types of data exempted from disclosure under the Public Records Law, please read the Secretary of the Commonwealth’s Public Records Law.

In addition, the information that you voluntarily submit will be disclosed only to Commonwealth employees or officials, or those under contract with the Commonwealth, with a “need to know” for purposes of fulfilling their job responsibilities. The information will be used for such purposes as; answering your questions, responding to any requests for assistance, generating summary statistics about usage, auditing applications and detecting fraud, aiding in the planning, design and development of FrontlineMA.org, and fulfilling the Commonwealth's legal obligations.

We will collect and aggregate the information you provide through surveys and through FrontlineMA.org’s collection of non-personally identifying analytics data for purposes of market research to improve the Offerings by making them more responsive to customer needs. Where appropriate, we may provide the information you submitted voluntarily through an email to the person or company that is the subject of your inquiry, or to a government agency responsible for the matters referred to in your communication.

 Your access and opportunity to correct

The “Public Records Law” and the “Fair Information Practices Act” provide you certain rights to get information about you that is in our records. To learn more about the circumstances under which you can get and correct this information, please click on the above references to these laws.

Security

Because information sent to the Commonwealth is not encrypted, you should not send messages containing information that you consider highly sensitive to FrontlineMA.org. We use standard security measures to ensure that information provided by you, including your personally identifiable information, is not lost, misused, altered, or unintentionally destroyed. We also use software to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage. Except for authorized law enforcement investigations, no attempts are made to identify individual users or their usage habits.

Special protections against misuse of personally identifiable information within Commonwealth offices

This website complies with the Acceptable Use of Information Technology Policy of the Enterprise Security Office of the Commonwealth of Massachusetts. All of the personally identifiable information that you submit to FrontlineMA.org is given the privacy protections set forth in the Commonwealth’s Enterprise Information Security Policies and Standards.

Policy changes

We will post substantive changes to this policy at least one business day before they take effect. Any information we collect under the current privacy policy will remain subject to the terms of this policy. After any changes take effect, all new information we collect, if any, will be subject to the new policy.

Contact Information

For questions about your privacy while using FrontlineMA.org, please contact helpourheroes@mass.gov.

Definitions

Cookies are files that a website can place on your computer. A cookie file contains unique information that a website can use to track such things as your password, lists of Web pages you have visited, and the date when you last looked at a specific Web page, or to identify your session at a particular website. A cookie file allows the website to recognize you as you click through pages on the site and when you later revisit the site. A website can use cookies to “remember” your preferences, and to record your browsing behavior on the Web. Although you can prevent websites from placing cookies on your computer by using your browser’s preference menu, disabling cookies may affect your ability to view or interact with some websites.

An “Internet Protocol Address” or “IP Address” is a series of numbers that identifies each computer and machine connected to the Internet. An IP address enables a server on a computer network to send you the file that you have requested on the Internet. The IP address disclosed to us may identify the computer from which you are accessing the Internet, or a server owned by your Internet Service Provider. Because it is machine-specific, rather than person-specific, an IP address is not, in and of itself, personally identifiable information.

Social Media: A social media website is a website or a social media application that is usually maintained by an individual and has regular entries of commentary, descriptions of events, or other material such as graphics or video. A social media identity is a specific user identity that has been registered on a third party social media site and is associated with the Agency. Government social media sites or identities typically provide forums for commentary or news on topics related to the government agency that hosts the social media site or has secured the social media identity. A typical social media site (whether hosted by the Agency or a third party) combines text, images, and links to other websites including blogs, wikis, and other media related to the topic and enables readers to leave comments in an interactive format.

© 2020 Commonwealth of Massachusetts.