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Rural Behavioral Health Teams

Rural Behavioral Health Teams: Built to Serve, Struggling to Survive

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Across rural America, something quietly remarkable has been taking shape for the better part of a decade. Communities facing persistent provider shortages and geographic isolation have stopped waiting for the healthcare system to come to them. Instead, they’ve built it themselves, from the ground up, with whatever staff, funding, and partnerships they could assemble. Rural behavioral health crisis teams are among the most significant products of this movement. Pairing mental health clinicians with law enforcement officers or EMS responders, these co-responder programs were designed to address what emergency rooms and squad cars were never equipped to handle: the human complexity of a mental health or substance use crisis unfolding in someone’s living room, on a rural highway, or in a county jail holding cell.

The model has shown real promise. But as rural health transformation enters a new phase, behavioral health crisis teams are confronting a threat unrelated to clinical competence. According to a national survey of 290 rural healthcare leaders commissioned by Julota and conducted by TrendCandy, the central challenge facing rural transformation programs today is no longer launching services. It is proving that those services work, and doing so across organizational boundaries that were never designed to share data.

Rural Behavioral Health Teams

The Scale of the Need

Before examining the proof problem, it helps to understand what’s at stake.

Rural Americans face some of the most acute behavioral health disparities in the country. According to the Rural Health Information Hub, rural communities experience higher rates of suicide, opioid overdose death, and serious mental illness than their urban counterparts, while having access to significantly fewer psychiatric providers, inpatient beds, and outpatient services. The shortage isn’t marginal. In many rural counties, the nearest behavioral health specialist may be hours away.

Into this gap stepped the behavioral health crisis team. Modeled in part on the Crisis Intervention Team (CIT) framework developed in Memphis in the late 1980s, modern rural crisis response programs vary in structure but share a common purpose: to divert individuals in mental health crisis away from emergency departments, jails, and unnecessary police escalation, and toward appropriate clinical care and community support.

These teams don’t operate alone. At their most effective, behavioral health crisis teams function as the coordinating spine of a broader community care network, linking EMS, hospitals, primary care, substance use treatment, housing services, and social supports. That complexity is part of what makes them valuable. It’s also part of what makes them so difficult to sustain.

Transformation Programs Are Raising the Bar

Rural Health Transformation Programs (RHTP), part of a broader federal push to modernize rural healthcare delivery, are accelerating both the opportunity and the pressure facing behavioral health teams. The Julota-commissioned survey found that 90 percent of rural healthcare leaders believe RHTP initiatives will significantly raise the bar for demonstrating measurable impact.

This finding reflects a broader shift across healthcare. The era of pilot innovation, where communities could launch programs on grant funding and demonstrate value through anecdotal outcomes, is giving way to an era of operational accountability. Policymakers and funders now expect standardized data, cross-agency reporting, and credible evidence that programs produce measurable results.

For behavioral health crisis teams, this shift is particularly acute. A successful crisis response intervention may prevent a psychiatric hospitalization, reduce law enforcement involvement, connect a patient to long-term treatment, and keep a family intact. Each of these outcomes touches a different organization. Each is tracked, if tracked at all, in a different system. And each requires a different set of data to document.

The Proof Problem Is Hardest Where It Matters Most

The survey’s most striking finding may be this: 61 percent of rural healthcare leaders say proving cross-agency impact is more difficult than delivering services themselves.

This cuts to the heart of rural behavioral health crisis teams sustainability challenge. Clinical staff can be recruited, trained, and deployed. Dispatch protocols can be established. Community relationships can be built. But demonstrating the cumulative impact of a crisis response intervention, across a patient’s journey through emergency services, behavioral health treatment, substance use programs, and follow-up care, requires a kind of infrastructure most rural communities simply don’t have.

The survey confirms just how manual these processes remain. Eighty-five percent of rural healthcare leaders report that at least one critical referral partner still relies on phone calls or faxes to coordinate care transitions. For behavioral health crisis teams, where 48 percent of referral coordination breakdowns occur specifically in behavioral health handoffs, these gaps are not inconveniences. They are points where patients fall out of care entirely.

When a crisis team clinician makes a warm handoff to a behavioral health provider following a field response, that referral often falls into a void, there may be no mechanism to confirm whether the patient followed through, no alert if a follow-up appointment was missed, and no way to measure whether the intervention reduced subsequent emergency utilization, all data points that funders and policymakers increasingly require to justify program continuation.

Workforce Shortages Compound the Challenge

The operational pressures on behavioral health crisis teams don’t stop at the data layer. The workforce constraints facing rural healthcare more broadly are felt with particular intensity in crisis response.

The survey found that 89 percent of rural healthcare leaders say provider shortages constrain how they design and scale transformation programs. Behavioral health clinicians ranked as the third hardest role to recruit across rural transformation programs, cited by 46 percent of respondents. When those positions go unfilled, programs don’t just scale more slowly. They collapse inward, reducing service hours, narrowing coverage geography, and placing unsustainable demands on the staff who remain.

For communities trying to stand up co-responder programs, this dynamic creates a compounding problem. The administrative burden of manual reporting and data reconciliation falls on the same clinical and operational staff already stretched thin by vacancy-driven increases in workload. As the Julota report notes, addressing workforce shortages requires not just recruitment strategies but operational systems that reduce administrative burden so clinicians can spend more time on patient engagement.

Investing in shared data infrastructure isn’t just a reporting strategy. For behavioral health crisis teams with limited staff, it may also be a workforce retention strategy.

The Financial Sustainability Question

Even programs that overcome clinical and workforce challenges face a harder question downstream: how do you pay for this after the grant runs out?

Rural healthcare leaders expect behavioral health crisis teams to rely on a patchwork of funding sources over the long term. According to the survey, 62 percent anticipate hospital shared-savings arrangements as part of their sustainability model, 52 percent expect EMS billing pathways to play a role, and 48 percent are counting on Medicaid reimbursement expansion.

Each of these funding mechanisms requires precisely the kind of outcome data that behavioral health crisis teams currently struggle to produce. A hospital shared-savings arrangement requires demonstrating how many psychiatric admissions a program prevented and what those prevented admissions were worth to the health system. A Medicaid reimbursement claim requires documentation of specific services rendered and their clinical justification. Neither is possible without an interoperable, cross-agency data infrastructure.

The economic opportunity here is substantial. Julota’s research identifies potential savings of $6.4 billion annually through hospital avoidance, $1.3 billion through reduced arrests and jail stays, and $1.2 billion through reduced EMS transports, much of it directly tied to the kinds of interventions behavioral health crisis teams are uniquely positioned to deliver. The savings are real. The problem is that most programs can’t yet prove their share of them.

What Behavioral Health Crisis Teams Must Build Next

The Julota report outlines five capabilities that rural healthcare organizations must develop to sustain transformation initiatives: shared care coordination frameworks, closed-loop referral management, standardized outcome measurement, clear data governance structures, and technology infrastructure that minimizes administrative burden on frontline staff.

For behavioral health crisis teams, each of these capabilities addresses a specific failure point in the current model. Shared care plans allow crisis clinicians, EMS, hospitals, and behavioral health providers to coordinate around a single patient rather than exchanging fragmented information through phone trees and fax machines. Closed-loop referrals create a mechanism to confirm whether patients actually receive the services they were referred to, a critical gap in behavioral health handoffs. Standardized outcome reporting produces the evidence that funders and policymakers require.

Julota’s own platform was built specifically to address these challenges in rural and community health settings, connecting behavioral health professionals with EMS, law enforcement, hospitals, and social services through a single secure, interoperable environment. For a deeper look at how rural co-responder programs are navigating coordination across multiple jurisdictions, Julota’s blog on the rural co-responder model offers a practical breakdown of how communities are structuring these programs today.

The Stakes Are Too High to Wait

Rural behavioral health crisis teams were created to fill a gap left by the formal healthcare system. They have done that, often with minimal resources and extraordinary commitment from frontline staff and community partners. But commitment alone does not make a program fundable. Impact does, and impact must be measured, documented, and communicated across organizations that have never been designed to share data.

The survey findings make clear that 82 percent of rural healthcare leaders consider cross-agency outcome reporting urgent this year. For behavioral health crisis teams, urgency is not abstract. Every unsustained program represents real people who will once again find themselves in emergency rooms, jails, or in crisis with nowhere to turn.

The communities that will sustain rural health transformation are not necessarily those with the most resources. They are the ones who build the infrastructure to prove what they are already doing. For behavioral health crisis teams, that infrastructure is the difference between a promising pilot and a permanent part of the care system their communities depend on.

Statistics in this article are drawn from The Proof Problem: Why Rural Healthcare Transformation Will Rise or Fall on Data Infrastructure, a national survey of 290 rural healthcare leaders commissioned by Julota and conducted by TrendCandy.

Author

  • Noah Weinberg is a Marketing Manager at Julota, where he focuses on elevating the alternative response space, specifically Mobile Integrated Healthcare (MIH), Community Paramedicine, and Co-Responder models. He writes about the intersection of law enforcement, healthcare, and community well-being, drawing on real-world experiences with community paramedicine programs in Ontario, Canada.

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Privacy Policy

Last Updated: July 30, 2024

Julota is committed to protecting your privacy and is constantly working to give you a safe online experience. This “Privacy Policy” applies to Julota and governs its data collection and usage. Please read our Privacy Policy for more information.

  1. DEFINITIONS
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  1. “Julota,” “we,” “us” and “our” refers to Julota.
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You do not have to provide any Personally Identifiable Information to browse the publicly available pages of the Site; however, in order to obtain or use products or services that are or may be provided through the Site or that we may otherwise offer online or offline (collectively, the “Services”) you may be required to register and/or provide Personally Identifiable Information.

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We may collect Personal Data from you in a variety of ways, including, but not limited to, when you (i) register on the Site; (ii) fill out forms or fields on the Site or offline; (iii) complete an application for a product or service available through the Site; (iv) communicate with us through the Site or by email, telephone, facsimile or other electronic means; (v) process payments; (vi) provide us with Personal Data; (v) participate in activities or utilize resources provided by or through Julota; or (vi) submit or authorize the submission by third parties to submit information through the Site. We collect or may collect, among other Personal Data you provide to us, the following categories of Personal Data from you:

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We will treat as Personal Data any item that, either alone or together with other information, we could use to identify an individual. Except as described below, we will not share with third parties any personal information without your permission.

By providing your Personal Data to us, you explicitly agree to our collection and use of such information as described in this Privacy Policy. By providing Personal Data belonging to another person, you expressly represent and warrant that you have the authority and right to do so, and that you obtained all appropriate and required consents.

We may also collect your Personal Data from sources that you have authorized to share with us or that you have authorized us to obtain information from.

We may also collect information about you from third parties related to transactions you are contemplating entering into with us or that you have entered into with us.

If you believe we received our personal information from a source without authority to share your personal information with us, please contact us so that we can resolve your complaint.

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Julota may collect information about you automatically when you visit the Site, communicate through the Site, or use any of our online Services.

System Information: We may automatically receive certain information from your browser or mobile device, such as your browser type, the operating system of your device, the equipment you use to access the Site, and the unique identifier of your mobile device.

IP Address: We may also receive your IP address and the name of the internet service provider (“ISP”) or your mobile carrier.

Browsing Information: We may collect the URL of the site from which you came and the URL of the site you visit when leaving the Site or any of our online Services and your activities on the Site, such as webpages you view and how you interact with those webpages.

Location: We may collect, depending on your device’s settings, location data and other types of information sent from third party services or GPS-enabled devices.

Site Usage: As you use the Site or any of our online Services, we may also collect information about such usage and your actions on the Site, such as pages you viewed, access times, and how long you spend on a page. We may use cookies to collect such information, as described in more detail below. This information is considered Non-Personal Data, which we can use for any purpose, including, without limitation, to help us improve the Site or the Services and to enhance your, and other users’, experience.

Aggregated Anonymized Data: We may also convert personal information into Non-Personal Information by excluding information that is personally identifiable. You acknowledge that Non-Personal Information and Personal Information that is converted into Non-Personal Information belongs to Julota and that Julota has the right to use such general information as it determines in its sole discretion.

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The Site or our online Services may use “cookies,” or other identifiers, which may be stored on your device, to recognize you as a user when you return to the Site or use the online Services using the same computer and web browser and to maintain your preferences. We use cookies and other identifiers to identify which areas of the Site or online Services you have visited and how you interact with the Site. We also may use this information to better personalize the content you see on the Site or online Services, serve you with personal advertisements for Julota and third-party products, either via email, on our Site, or on other websites on the internet . We do not store unencrypted Personal Data in cookies. We also do not link Non-Personal Information from cookies to your Personal Data.

In addition, we may use the services of advertising platforms to provide relevant marketing to consumers concerning our Services.

In general, we use four different types of cookies:

Strictly necessary cookies: These cookies are necessary to enable the basic features of the Site, including any of our applications, such as providing a secure login.

Functional cookies: These cookies allow our Site to remember your site preferences and choices you make on the Site. We also use functional cookies to facilitate navigation, to display content more effectively, and to personalize your experience.

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Opting-out of Personalized Ads: You can opt-out of receiving personalized ads from advertisers and ad networks that are members of the Network Advertising Initiative (“NAI”) or who follow the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising using their respective opt-out tools. The NAI’s opt-out tool can be found here: http://www.networkadvertising.org/choices and the DAA’s opt-out tool can be found here: http://www.aboutads.info/choices/.

In addition, your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioral advertising (for example, Apple iOS’ Advertising ID and Google Android’s Advertising ID). Please note that opting out does not prevent the display of all advertisement to you.

  1. HOW WE USE AND SHARE YOUR PERSONAL DATA

Except as described below, we will not share with third parties the link between your IP address and your Personal Data without your permission.

By providing your Personal Data to us, you explicitly agree to our collection and use of such information as described in this Privacy Policy. By providing Personal Data belonging to another person, you expressly represent and warrant that you have the authority and right to do so, and that you obtained all appropriate and required consents.

We may also collect your Personal Data from sources that you have authorized to share with us. We will use your Personal Data in those circumstances to provide the Services that your Personal Data was shared with us to fulfill. If you believe we received your Personal Data from a source without authority to share your Personal Data with us, please contact us so that we can resolve your complaint.

Julota may use personal information for the following purposes:

  1. To improve customer service: Your information helps us communicate more effectively with inquiries and existing customers, and to respond to your customer service requests and support needs.
  1. To personalize user experience: We may use information in the aggregate to understand how our users as a group use the Services and resources provided on the Site.
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  1. To provide products or services and to process transactions: Except as otherwise expressly provided in this Privacy Policy, we will use Data for the purposes of fulfilling our duties and providing the Services. Julota may use Non-Personal Information for statistical analysis, product development, research, or other purposes. We may use the information that you provide about yourself or that you have provided to our customers for the purpose of providing and fulfilling the Services. We do not share this information with outside parties except to the extent necessary to provide the Services.
  1. To send periodic mail, emails, and surveys: The email address you provide for the Services will only be used to send you information, newsletters, surveys, and updates pertaining to the Services requested, provided, or that we think you may be interested in. It may also be used to respond to inquiries and/or other requests or questions.
  1. To develop new products or services: We use your Personal Information and Non-Personal Information for research and commercial purposes. The information we collect may be used to develop new products or Services. Except as otherwise provided in this Privacy Policy, we may use your Personal Information and Non-Personal Information internally or, among other things, to offer our own or third-party products and Services. Only Julota, its subsidiaries, its suppliers and contractors involved in distributing the new product or Service, and those that you authorize us to share Personal Information with will have access to your Personal Information. Our subsidiaries, suppliers and contractors will be required to use any Personal Information we provide to them only for that intended purpose and subject to the terms of this Privacy Policy.
  1. Fulfillment Obligations: Comply with contractual obligations, relevant industry standards, and our policies.
  1. For marketing: Except as otherwise expressly provided for in this Privacy Policy or except as prohibited by applicable law, Julota may use your Personal Information and Non-Personal Information to enhance its networking, marketing, social, and recruiting activities, and for other similar business purposes. Julota may also use your Personal Information and Non-Personal Information to contact you on behalf of external business partners about a particular offering that may be of interest to you. In these cases, your Personal Information is not transferred to the third party. We may also use Personal Information to provide you information regarding new products or services or to post testimonials from you related to our products or services. Personal Data is not shared with entities outside of Julota other than service providers who assist us in carrying out these business functions. Julota does not use or disclose sensitive Personal Data, such as race, religion, or political affiliations, without your explicit consent.
  1. Compliance with applicable law: We may disclose your Personal Data as we may in our sole discretion determine is necessary or reasonably required to comply with law, applicable regulations, court orders or subpoenas; to enforce our Terms and Conditions; or to protect our rights, property, or safety; or the rights, property, or safety of others.
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  1. Business Transactions: We may disclose and/or transfer your Personal Data in connection with a potential or actual sale, merger, acquisition, bankruptcy or other transaction in which an affiliate or third party acquires all or any part of our businesses and/or assets (including, for example, this Site).
  1. Payment Processing: For processing payments related to the Services we provide you.
  1. RETENTION AND STORAGE OF PERSONAL DATA

We retain your Personal Data for as long as necessary to fulfill the purpose for which it was collected and to comply with applicable laws. We use reasonable security precautions to protect your information while in storage

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and applicable legal requirements.

  1. SECURITY

We will use commercially reasonable methods to keep your Personal Data securely in our files and systems, taking into account the nature and sensitivity of your Personal Data.

  1. DO NOT TRACK

Your browser may provide you with the option to send a “Do Not Track” signal to websites you visit. This signal is used to request that websites not send the requesting device cookies, but websites have no obligation to respond to such signal or to modify their operation. Our online sites may not recognize all web browser based “Do Not Track” signals. However, you may be able to modify your internet-enabled device’s web browser settings to block all cookies or third-party cookies.

  1. EXEMPTIONS FROM THE PRIVACY POLICY

Our Privacy Policy does not apply to any information you may send to Julota by email or instant messaging programs (e.g., AOL, Yahoo, etc.), or through social media networks, even if you open such programs or services by clicking a link displayed on the Site. Email, social media, and instant messages are not recognized as secure communication forms. Please do not send any information you consider private to us by email or instant message or through social media sites (e.g., Twitter, Facebook, etc.) due to the public nature of such postings.

  1. LINKS TO OTHER SITES

The Site and the online Services may contain links to other websites. Julota is not responsible for the actions, practices, or content of websites linked to, or from, the Site or the online Services. You understand such websites may require you to agree to their terms of use and that we have no control over these terms. As always, you understand it is your responsibility to verify your legal use of a website, and use of information from the website and the corresponding website owner.

  1. AGE OF CONSENT

Julota takes special care to protect the privacy needs of children under the age of 13 and we encourage parents to be an active participant in their child’s online activities. Julota abides by the Children’s Online Privacy Policy Act (COPPA) and other relevant laws. The Site does not target and is not intended for children under the age of 13, and Julota will not knowingly collect Personal Data directly from them. If Julota discovers that a child has provided Personal Data directly through the Site, Julota will eliminate that data. The Site is only intended for persons 18 years of age or older. If you are under the age of 18, you must ask a parent or legal guardian for permission prior to submitting any information to this Site.

If you have knowledge that a child 13 years of age or younger has submitted Personally Identifiable Information to us, please contact us and we will delete the Personal Data collected belonging to that child. You may contact us by writing to us at the address below. Parent and guardians can also contact us by mail but before any information is disclosed, the parent will be required to provide verification of his/her identity and authority related to any request. We will only send the information to the parent email address in the registration file.

  1. CAN-SPAM COMPLIANCE NOTICE

Julota fully complies with the federal CAN-SPAM Act. You can always opt-out of receipt of further email correspondence from us.

  1. CALIFORNIA PRIVACY RIGHTS

Under Section 1798.83 of the California Civil Code, residents of California can obtain certain information with whom they have an established business relationship. That information is about the Personal Data those companies have shared with third parties for direct marketing purposes during the preceding calendar year. The law requires companies to inform consumers about the categories of Personal Data shared with third parties, the names and addresses of those third parties, and examples of the services or products marketed by those third parties. To request a copy of the information disclosure provided by Julota under Section 1798.83 of the California Civil Code, please contact us via mail at the address below.

  1. PRIVACY RIGHTS

To the extent applicable, this Privacy Policy provides additional information to California, Colorado, Connecticut, Florida, Indiana, Iowa, Kentucky, Montana, Oregon, Texas, Tennessee, Utah, and Virginia residents whose Personal Information is collected pursuant to the California Consumer Privacy Act (“CCPA”)(as amended by the California Privacy Rights Act), Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CTDPA”), Florida Digital Bill of Rights (“FDBR”), Indiana Consumer Data Protection Act (“ICDPA”), Iowa Data Protection Act (“IDPA”), Kentucky Data Protection Act (“KDPA”), Montana Consumer Data Privacy Act (“MCDPA”), Oregon Consumer Privacy Act (“OCPA”), Tennessee Information Protection Act (“TIPA”), Texas Data Privacy and Security Act (TDPSA”), Utah Consumer Privacy Act (“UCPA”), Virginia Consumer Data Protection Act (“VCDPA”) and other states that may adopt laws after the publication of this Privacy Policy (generically referred to as “Privacy Laws”). The following rights do not all apply under each of the foregoing Privacy Laws. Some states and countries have adopted privacy laws that require specific disclosures. The following explains the rights you may have, depending on where you reside and the jurisdiction that Julota is subject to.

As applicable, the Privacy Laws supplement the information contained above in our general Privacy Policy and applies solely to visitors, users and others who reside in jurisdictions that Julota is subject to and that apply to you. Some or all of the privacy rights set forth below may apply to you. The following terms in this Section 13 supersede any inconsistent terms in any other sections of the Privacy Policy to the extent that any apply to you:

  1. We do not sell your personal information

We do not sell your Personal Information. Under Privacy Laws, a business that sells personal information to others: 1) must give notice to that person before selling his/her personal information to others; and 2) must provide the right to opt-out of the sale of their personal information.

  1. Your Rights Under Privacy Laws

 

  1. Right to Access and Know. You may request that we disclose the following information:
    1. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
    2. The specific pieces of Personal Information we collected about you;
    3. The business or commercial purpose of collecting or sharing Personal Information about you;
    4. The categories of Personal Information about you that we shared (as defined under the applicable privacy law) and the categories of third parties with whom we shared such Personal Information; and
    5. The categories of Personal Information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable).

Under Privacy Laws, the right to obtain “specific pieces” of Personal Information does not grant a right to the whole of any document that contains Personal Information, but only the right to obtain items of your Personal Information. Additionally, you have a right to know “categories” of sources of Personal Information and “categories” of third parties to which personal information is disclosed, but not the individual sources or third parties. Julota does not always track individualized sources or recipients.

  1. Right to be Informed. You may request the manner in which consent can be revoked, and the procedure for lodging grievances and complaints concerning the processing of your Personal Information. In addition, you also have the right to know the following information:
    1. the purposes of the processing;
    2. the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations;
    3. where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period;
    4. the existence of the right to request from the data controller rectification or erasure of Personal Data, or restriction of processing of Personal Data concerning you, or to object to such processing;
    5. the existence of the right to lodge a complaint with the applicable governmental authority;
    6. where the Personal Data is not collected from you, any available information as to their source; and
    7. the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for you.
  1. Right to Request Correction of your Personal Information. You may request that we correct inaccuracies in your Personal Information;
  1. Right to Request Deletion of Your Personal Information. You may request to have your Personal Information deleted;
  1. Right to Opt-out of Sharing for Cross-Context Behavioral Advertising. You may request to opt out of the “sharing” of your Personal Information for purposes of cross-context behavioral advertising.
  1. Right to Data Portability. You have the right to request a copy of your data in a machine-readable format.
  1. Right to Encryption. You may have the right to request that your Personal Information be encrypted at rest/while in storage and/or while in transit.
  1. Right to Restrict Processing. You may have the right to request the restriction of the processing of your Personal Data where one of the following applies:
    1. The accuracy of the Personal Information is contested by you, for a period enabling us to verify the accuracy of the Personal Information.
    2. The processing is unlawful, and you oppose the erasure of the Personal Information and request the restriction of their use instead.
    3. We no longer need the Personal Information for the purposes of the contemplated processing but it is required by us to exercise or defend legal claims.
    4. You have objected to processing of your Personal Information pending the verification of whether our legitimate grounds of processing override those of yours.
  1. Right to Object/Withdraw Consent. You may have the right to object to our reliance on our legitimate interests as the basis of our processing of your Personal Information that impacts your rights.  You also may have the right to withdraw your consent to our processing of your Personal Information at anytime.
  1. Right Not to Be Subject to Automated decision making. You may have the right to object to decisions based solely on automated processing, including profiling, which produces legal effects concerning you or affecting you.

 

  1. Verification of Requests to Exercise Rights.

 

When receiving a request, we will verify that the individual making the request is the individual to whom the Personal Information subject to the request pertains. You may exercise your rights yourself or may use an authorized agent to make requests to disclose certain information about the processing of your Personal Information or to delete Personal Information on your behalf. If you use an authorized agent to submit a request, we may request that you provide us additional information demonstrating that the agent is acting on your behalf.

 

  1. Additional Explanation of Categories of Personal Information We Collect

 

We collect information that may identify you, your household or your device or is reasonably capable of being connected with or linked to you, your household, or your device. “Personal Information” does not include public information available from government records, de-identified or aggregated information, or information that is protected by other laws.

  1. Additional Disclosure for How We Use Your Information

See above for how we use your information. We will not use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We are not required to (1) retain your Personal Information if collected for a single one-time transaction if, in the ordinary course of business, that information would not be retained and (2) re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a way that would be considered personal information.

  1. Exemptions to Request to Delete Requests

Unless otherwise required by applicable law, we are not required to grant your deletion request if retaining the Personal Information is necessary for us or our service providers to:

  1. Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall, or otherwise perform a contract between us and you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  3. Debug to identify and repair errors that impact existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act or any other applicable law.
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest when the deletion of the public information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
  7. For solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Internally make otherwise lawful uses of your Personal Information that are compatible with the context in which you provided your Personal Information.
  1. After You Make an Opt-Out Request

Once you make an opt-out request, we will wait at least twelve (12) months (unless a different period is legally required) before asking you to reauthorize Personal Information sharing with third parties. However, you may change your mind and opt back into Personal Information sharing with third parties at any time by mailing us at the address below.

We will only use Personal Information provided in an opt-out request to review and comply with the request. We will act upon your opt-out request within 15 days of receipt.

  1. We Will Not Discriminate Against You for Exercising Your Rights

 

We will not discriminate against you, including employees’, applicants’, and independent contractors’ right not to be retaliated against,  for exercising any of your rights under the Privacy Laws. We will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods and services or a different level or quality of goods or services.
  1. Legal Bases for Processing

We use your Personal Information only as permitted by law. Our legal bases for processing Personal Information are as follows:

  • To provide Services to you.
  • To perform our contractual obligations.
  • To perform pre-contractual measures.
  • For research and development.
  • To send you marketing communications.
  • For compliance, fraud prevention and safety.
  • To create anonymous data.
  • To comply with applicable law.
  • Processing of Personal Data with your consent.
  • Protect your vital interests or those of another natural person.
  • Processing operations that are pursued by Julota for our legitimate interests or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject/data principal which require protection of Personal Data.
  1. Exercising Your Right to Erasure

If you have such right, and you wish to request the erasure of Personal Data stored by us, you may, at any time, contact us via email to make such request as provided in Section 15 below.

Where we have made Personal Data public and are obliged to erase the Personal Data, we shall, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform others processing the Personal Data that you have requested erasure. We will arrange the necessary measures in individual cases.

 

  1. CONSUMER HEALTH DATA PRIVACY RIGHTS

This Privacy Policy provides additional information concerning the collection and use of consumer health information (“Consumer Health Data”) subject to the Washington State My Health My Data Act (“MHMDA”), the Nevada Health Data Privacy Act  (“NHDPA”), or other applicable state consumer health privacy laws.

  1. Consumer Health Data We May Collect

As described in Section 2 (Information Collected and Consent) of this Privacy Policy, the data we collect depends upon your interactions and the reason for your interactions with Julota and the information you choose to make available to Julota, your location, and applicable law. As Consumer Health Information is defined differently depending on the jurisdiction you are located in or the applicable jurisdiction that governs your Consumer Health Information, many categories of data we collect may be considered Consumer Health Information in some jurisdiction and not in other jurisdictions.

As described in Section 2 (Information Collected and Consent) of this Privacy Policy, we collect Personal Data (which may include Consumer Health Data) directly from you, from your interactions with our Services, from third parties, and from publicly available sources.

Some examples of Consumer Health Data may include (this is not intended to be an exhaustive list):

  • Information that could identify your attempt to seek health care services or information, including services that allow you to assess, measure, improve, or learn about your or another person’s health.
  • Your health condition and treatment you may receive that you submit to us or authorize/instruct a third party to submit to us for the Services.
  • The name of providers of health care services or products you interact with.
  • Location information that could indicate your attempt to acquire or receive health services or products.
  • Other information that may be used to infer or derive data related to the above or other health information.
  1. Our Sharing of Consumer Health Data

 

In addition to Section 4 (How We Use and Share Your Personal Data) of this Privacy Policy, we may share Personal Data, including Consumer Health Data, with your consent or as reasonably necessary to provide the Services you have requested or authorized.

  1. Exercising Your Rights

 

If you are covered by the MHMDA, the NHDPA, or other applicable consumer health privacy law then you may have certain rights with respect to your Consumer Health Data, including the right to access, delete, or withdraw consent relating to such data, subject to certain exceptions. You can exercise your rights by contacting us pursuant to Section 15 (How to Submit a Request to Julota to Exercise Your Privacy Rights) of this Privacy Policy.

If your request to exercise a right is denied, you may appeal that decision by contacting us pursuant to Section 15 (How to Submit a Request to Julota to Exercise Your Privacy Rights) of this Privacy Policy. If your appeal is unsuccessful, you may contact the Washington State Attorney general at www.atg.wa.gov/file-complaint, the Nevada State Attorney General at https://ag.nv.gov/complaints/file_complaint/, or other regulatory authority as applicable.

 

  1. HOW TO SUBMIT A REQUEST TO JULOTA TO EXERCISE YOUR PRIVACY RIGHTS.

You may submit your verifiable requests to Julota at the address or email address set forth below:

Mailing a request to Julota at:

Julota

[INSERT ADDRESS OR PO BOX ADDRESS]

Email: [INSERT EMAIL ADDRES]

Unless otherwise provided for under applicable privacy law, only you, or someone legally authorized to act on your behalf, may make a verifiable request to your Personal Information. Unless otherwise provided for in applicable privacy law, we are not required to provide you with Personal Information more than twice in a 12-month period.

We will not be able to respond to your request to provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Unless legally obligated to respond in a shorter timeframe, we will try to respond to your request within forty-five (45) days of receipt of your written request. If we require more time (up to 90 days), we will inform you of the extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

We may request specific information from you to help us confirm your identity and process your request.  Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

  1. YOUR NEVADA PRIVACY RIGHTS

Nevada law (SB 220) permits customers in Nevada to opt-out of the sale of certain kinds of Personal Information. A sale under Nevada law is the transfer of this Personal Information to third parties for monetary consideration so these third parties can then re-sell or license the sold information. We do not sell your Personal Information to third parties as defined in Nevada law. If you are a Nevada resident and wish to opt-out of the sale of your Personal Information, should we change our practices in the future, you must send a request to by mail.

  1. AMENDMENTS

Julota reserves the right to change the Privacy Policy from time to time as its sole discretion with or without notice. Revisions to the Privacy Policy regarding the use of Personal Information are not retroactive.

  1. INTERNATIONAL PROCESSING DISCLOSURE

Personal Information voluntarily submitted to Julota online, via electronic communication, or otherwise, may be maintained or accessed in servers or files in the United States of America, which the European Union has not deemed to provide “adequate” privacy protection. If you do not consent to having your information processed and stored in the United States of America, please do not provide it to Julota.

  1. EMPLOYEES, CONTRACTORS AND JOB APPLICANTS

To view or obtain a copy of our privacy policy related to employees, independent contractors, including individuals that perform work for Julota that are not employees, dependents, emergency contacts and beneficiaries of employees or independent contractors, please contact us. See Section 19 for contact information.

  1. CONTACT

If you have any questions about the Privacy Policy, or to report a violation of the Terms and Conditions, please contact us by mail or email at:

Julota

102 S Tejon St Suite 1100, Colorado Springs, CO 80903

Email: info@julota.com