PRIVACY POLICY

Who We Are

CorrectiveSolutions and its affiliated programs (collectively, “CorrectiveSolutions,” “we,” “us” or “our”) provide diversion programs, classes, case management and related services for courts, prosecutors, law‑enforcement agencies and participants in the United States. This Privacy Policy explains how we collect, use, disclose and safeguard personal information when you interact with our websites (including SnapView and any CorrectiveSolutions online portals) and when you participate in our programs or contact us. This privacy notice also applies to all information collected through our Services (which, as described above, includes our website), as well as any related services, sales, marketing or events. It supersedes the California‑specific policy posted in 2020 and applies across the United States.

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We update our Privacy Policy at least once per year as required by the California Consumer Privacy Act (CCPA/CPRA) and other state privacy laws. The effective date above shows when the current version took effect.

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TABLE OF CONTENTS

1. Information We Collect

2. How We Collect Information

3. How We Use Personal Information

4. SMS Communications & Mobile Information

5. Cookies and Tracking Technologies

6. How We Share Information

7. Data Retention and Deletion

8. Data Security

9. Your Privacy Rights

10. Do‑Not‑Sell or Share and Global Privacy Control

11. Additional Disclosures for California Residents

12. Notice to Nevada Residents

13. Notice to Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Other State Residents

14. Changes to This Privacy Policy

15. Contact Us

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1. Information We Collect

We collect personal information that you provide to us, that we automatically collect when you use our services, and that we obtain from third parties. The categories of personal information we may collect include:

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• Identifiers and contact information, such as full name, mailing address, email address, telephone number, date of birth, driver’s license or state‑issued ID, Social Security Number (when required by law), and account credentials.

• Program and participation information, including citation numbers, court case or docket numbers, program enrollment details, completion status, test results, class attendance records and documentation you submit.

• Payment information, such as transaction amounts, payment method and billing address. We process payments through payment processors and do not store full credit card numbers.

• Government‑issued documents and biometrics (only when legally required), such as fingerprints, breath or urine test results, photographs or video images for identity verification. We do not collect voiceprints or facial recognition templates for marketing.

• Communications, including emails, telephone calls, text messages, voicemails and chat communications with our staff.

• Usage information, such as IP address, device identifiers, log data, cookie identifiers, browser type, operating system, referring/exit pages and interactions with our websites.

• Geolocation information derived from IP addresses or device settings to determine general location (city or region) and tailor services; we do not collect precise real‑time geolocation without your consent.

• Inferences drawn from the information above to assess program eligibility, compliance, risk of recidivism, scheduling needs and marketing preferences.

• Sensitive personal information (as defined by state laws) such as Social Security numbers, government ID numbers, health information, or information about minors. We handle sensitive information only for legally required purposes and do not use it for marketing.

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We do not knowingly collect personal information from children under 13. Under the Children’s Online Privacy Protection Act (COPPA), businesses that collect personal data from children must obtain verifiable parental consent. Our services are directed to adults. If we learn that a child under 13 has provided personal information without parental consent, we will delete that information.

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2. How We Collect Information

We collect information from several sources:

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1. Information you provide directly. You may provide personal information when you:

   • Register for a diversion program or class.

   • Submit a Contact Us form, enrollment form, payment form or other web form.

   • Speak with our staff by phone, send us an email or text, participate in a video call or interact through chat.

   • Complete surveys or provide feedback.

2. Automatically collected information. When you access our websites or mobile portals, we automatically collect usage information through cookies, pixels and similar technologies. State privacy laws require websites to display a clear cookie notice, provide a “Do Not Sell or Share My Personal Information” option, allow users to opt out of targeted advertising, and respect browser‑based opt‑out signals like Global Privacy Control. We honor these requirements and will present appropriate banners and options based on your location.

3. Information from third parties. We may collect personal information from law‑enforcement agencies, courts, prosecutors, public databases, licensed data providers, referral partners (such as attorneys) and background check providers as needed to verify identity, confirm eligibility or comply with legal obligations.

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3. How We Use Personal Information

We use the personal information we collect for the following purposes:

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• Provide and administer services. To register you for programs, deliver educational content, monitor participation, schedule classes, provide case management, process payments, send certificates of completion, and otherwise fulfill our contractual obligations.

• Communicate with you. To respond to inquiries, send appointment reminders, program updates, compliance notices, receipts, and other transactional communications. With your consent, we may also send promotional messages about new programs, payment plans or services.

• SMS and voice communications. When you voluntarily provide a mobile phone number, we may send SMS text messages or place voice calls as described under SMS Communications & Mobile Information below.

• Program evaluation and analytics. To analyze participation, outcomes and operational efficiency; evaluate recidivism, compliance and program effectiveness; and improve our services.

• Marketing and outreach (with consent). To inform you about new services, promotions or community resources. We will only send marketing communications if you have opted in.

• Compliance with laws and legal processes. To comply with court orders, subpoenas, legal reporting requirements and law‑enforcement requests; collect debts; protect our rights, property and safety; investigate and prevent fraud; and meet other legal obligations.

• Security and fraud prevention. To detect and prevent misuse of our services, unauthorized access, spam, or other fraudulent or malicious activity. The law requires businesses to implement reasonable security measures, including encryption, access controls and regular security assessments; we maintain these safeguards to protect personal information.

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4. SMS Communications & Mobile Information

If you provide a mobile phone number through a web form, by text, or by enrolling in a program, you may receive SMS text messages from us. Our SMS practices are designed to comply with A2P 10DLC registration requirements, the Telephone Consumer Protection Act (TCPA) and CTIA carrier guidelines. Key points include:

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• Consent to receive SMS messages. By entering your phone number into a form or otherwise providing it to us, you consent to receive text messages related to your inquiry, program enrollment, account updates, appointment reminders, testing instructions, payment notifications, and other service‑related communications. You are not required to provide a phone number or consent to SMS messages as a condition of receiving our services.

• Contact Us form disclaimer. If a form on our site requires a phone number, we will display the following notice immediately below the form field: “By providing a telephone number and submitting this form, you are consenting to be contacted by SMS text message and agreeing to our Privacy Policy. Message frequency may vary. Message and data rates may apply. Reply STOP to opt out of further messaging. Reply HELP for more information.” If the phone number field is optional, providing your number still signifies consent to receive SMS messages.

• Message frequency and carrier charges. You may receive periodic texts related to promotions, account updates or customer support; message frequency varies and message and data rates may apply.

• Opting out. You may unsubscribe from SMS messages at any time by replying STOP, END, CANCEL, UNSUBSCRIBE or QUIT to any message we send. Upon opting out, we will send a confirmation and no further texts will be sent. For help, reply HELP or contact us at the email or phone number listed below.

• No sharing of mobile information. We do not sell, share or transfer mobile phone numbers or SMS consent data to third parties for marketing or promotional purposes. All categories of personal information exclude text‑messaging opt‑in data and consent; these records are only used to deliver messages and comply with legal obligations. We do not purchase third‑party phone lists.

• No transfer of consent. Consent to receive messages from CorrectiveSolutions cannot be transferred to or relied upon by any other company. We will not pass your opt‑in to third parties, and we will not send texts on behalf of unrelated businesses.

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5. Cookies and Tracking Technologies

We use cookies and similar technologies to operate our websites, analyze traffic and improve user experience. As required by U.S. state privacy laws, we provide a clear cookie notice, a “Do Not Sell or Share My Personal Information” link, and mechanisms to opt out of data sales or targeted advertising. We also respect browser‑based Global Privacy Control (GPC) signals. For more detail about the types of cookies we use and how to manage your preferences, please see our Cookie Policy (link provided on our site).

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6. How We Share Information

We do not sell personal information. We may share personal information with the following categories of recipients, subject to confidentiality obligations:

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1. Service providers and contractors. Vendors that assist us in operating our websites, processing payments, providing customer support, sending communications (including SMS providers), performing analytics, hosting data, conducting audits, or providing program content. We require these vendors to use personal information only to perform services on our behalf and to protect it.

2. Government agencies and courts. Courts, prosecutors, law‑enforcement agencies or other governmental authorities when necessary to comply with court orders, subpoenas, reporting obligations, audits, or other legal processes.

3. Authorized third parties. With attorneys, counselors, or authorized representatives assisting you with your program participation; with the referring government agency that enrolled you; or with others whom you instruct us to share information with.

4. Business transfers. In the event of a merger, acquisition, financing, asset sale or other transaction involving CorrectiveSolutions, your personal information may be transferred to another entity subject to this policy and applicable laws.

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We do not share mobile phone numbers or SMS consent data with third parties for marketing or promotional purposes. If our privacy policy or practices require sharing for another purpose, we will update this policy and provide notice.

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7. Data Retention and Deletion

We retain personal information only as long as needed for the purposes described above, including:

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• The duration of your participation in a program or service.

• Periods necessary to comply with legal obligations (e.g., record retention requirements under state law, financial regulations, or court orders).

• Periods needed to resolve disputes, collect fees, enforce agreements and maintain security.

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When personal information is no longer required, we will securely delete or de‑identify it. You may request deletion of your information as described under Your Privacy Rights.

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8. Data Security

We maintain reasonable and appropriate technical, administrative and physical safeguards designed to protect personal information. As required by the CCPA/CPRA, businesses must implement “reasonable” security measures to prevent data breaches. Our safeguards include encryption of data in transit and at rest, multi‑factor authentication for our systems, restricted access based on roles, periodic security assessments, staff training and incident response procedures. Nonetheless, no system is completely secure, and we cannot guarantee absolute security.

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9. Your Privacy Rights

We respect the privacy rights provided by the CCPA/CPRA and other U.S. state privacy laws. Depending on your state of residence, you may have some or all of the following rights:

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• Right to know and access. You can request disclosure of the categories of personal information we collected about you, the purposes for collecting it, the categories of sources, the categories of third parties with whom we share it, and specific pieces of your personal information.

• Right to delete. You can request that we delete personal information we have collected from you, subject to legal exceptions.

• Right to correct. You may ask us to correct inaccurate personal information about you.

• Right to opt out of sale or sharing. You can direct us not to sell or share your personal information for cross‑context behavioral advertising. We do not sell personal information but provide this option for compliance.

• Right to limit sensitive information. You can instruct us to limit the use and disclosure of sensitive personal information to what is necessary to provide goods or services.

• Right to non‑discrimination. We will not discriminate against you for exercising your privacy rights (for example, by denying services or charging different prices).

• Right to data portability. Some state laws grant the right to obtain your personal information in a portable format.

• Rights related to automated decision‑making and profiling. In certain states, you may have the right to opt out of profiling or automated decision‑making, and to appeal decisions.

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We extend these rights to all individuals whose personal information we collect, regardless of state of residence, to the extent feasible.

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How to Submit a Request

To exercise your rights, please contact us at info@correctivesolutions.org or call (925) 930‑4062. You may also submit a request via our web form (link available on our website). We may need to verify your identity (for example, by matching information you provide with our records) before processing your request. We will respond within the timeframe required by applicable law—typically 45 days—and may extend that period by an additional 45 days if necessary.

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Authorized agents may submit requests on your behalf if they provide proof of authorization and we can verify your identity.

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10. Do‑Not‑Sell or Share and Global Privacy Control

We do not sell personal information. However, to comply with CCPA/CPRA and other state laws, we provide a “Do Not Sell or Share My Personal Information” link on our website. When you click this link, we will treat it as a request to opt out of any sale or sharing of your personal information for cross‑context behavioral advertising. We also honor browser signals such as Global Privacy Control (GPC). Activating GPC in your browser will automatically opt you out of sales or sharing when supported.

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11. Additional Disclosures for California Residents

CorrectiveSolutions is subject to the CCPA/CPRA. For transparency, the table below summarizes the categories of personal information we collected in the past 12 months, the sources, and the business purposes. All categories exclude mobile phone numbers and SMS consent, which are never sold or shared.​