This notice informs you, as a user of our systems and applications, about how YELED V'YALDA EARLY CHILDHOOD CENTER INC ("Yeled", "we", "us") collects, uses, and protects information about you through your use of Yeled-created websites and Yeled-computer applications. We also describe other policies that directly affect you, as users of these services. Please read this notice carefully before using our websites or applications. We may change this notice from time to time, and reserve the right to do so without advance notice. By accessing and using our websites and applications, you consent to these uses and any other uses.

Collection of Information

In order to improve the content and usability of Yeled websites and applications, we may automatically collect certain information from you, including:

• The Internet Protocol ("IP") address of your Internet Service Provider ("ISP") and/or computer.
• The Domain Name of your ISP and/or computer.
• The type and version of your operating system and browser (such as Internet Explorer, Opera, Firefox, Chrome, etc.).
• The date, time, and duration of your visit.
• Your clicks within the application.
• The web address of the previous site visited by your browser (if detectable).

We also may request and collect information from you when you interact with our websites and applications, such as information you provide when creating an account, submitting an electronic form, participating in a survey, etc.

Use of Information and Privacy

We do not collect personally identifiable information for commercial or marketing purposes, and we do not sell the personally identifiable information we collect. The personally identifiable information we collect is stored in a secure environment.

We use and may share the information we collect to make sure our systems are up-to-date and compatible with other systems, and to improve services offered through Yeled applications and websites. We may also use it to fulfill our duties, comply with regulatory and contractual obligations, and for other educational and service related purposes, including, but not limited to:

• Developing new application functionality;
• Providing notifications, alerts, or event updates;
• Responding to requests made under the Freedom of Information Law ("FOIL"), through subpoenas, court orders and other administrative, judicial and legal processes (however, we may withhold certain information if the law permits us to do so);
• Providing technical notices, updates, security alerts, and administrative messages;
• Responding to user comments, questions, and requests for customer service;
• Monitoring and analyzing trends, usage and activities in connection with services;
• Personalizing and improving services;
• Complying with any allowable purpose, applicable law, regulation, legal process, or governmental request; and
• Conducting statistical analyses for any of the above reasons.

Certain laws and regulations govern our ability to share or otherwise disclose information about you that we collect. For example, disclosure and release of personally identifiable information of our current and former students is governed by the Health Insurance Portability and Accountability Act (HIPAA), the Family Educational Rights and Privacy Act (FERPA), and the Individuals with Disabilities Education Act (IDEA) and their implementing regulations. Other laws and regulations may apply, depending on the types of information at issue.

We may monitor and review all content and traffic on Yeled-provided networks and applications. This includes traffic on or from devices that are owned by the Yeled, as well as devices not owned by Yeled when Yeled resources are being accessed or have been accessed from such devices.

Data Security

Yeled takes reasonable measures to help protect its websites and applications and the information within them from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction.

If you receive or create a password when registering for any of our applications, you should not divulge this password to anyone. When you are finished with an application, you should sign out of the application. If the browser you used to access the application is publicly accessible (such as on a computer at a public library or internet cafe), you should close the browser session and, if possible, clear any browser history, cookies, or other areas where your password might have been stored. Otherwise, you risk having information about you becoming available to third parties.

Account Information

You can update your account information at any time by logging into the application and modifying your personal profile. If you wish to delete or suspend your account, you must contact us at info@yeled.org.

Cookies

Cookies are computer files that enable an application or website to distinguish between users. We use "temporary cookies" on some parts of our sites and applications, which expire when you close the browser session. We may also use "persistent cookies" to understand the how people access and use our sites and applications.

You can customize most browsers to reject cookies, to accept or reject cookies after a visual warning, or to delete cookies. However, some application and website features may require cookies to function properly.

Web Bugs

We do not use web bugs (also known as "web beacons") on our web pages or in email for any purposes other than:

• to identify site performance needs;
• to ensure compatibility with the technology used by site visitors; and
• to add and improve services offered by our applications.

Intellectual Property

The content of our applications and websites is copyrighted, and may contain third-party images or graphics that are used with permission. You must obtain permission from the copyright holder before reproducing or otherwise using images/graphics from our websites or applications.

Mission and Values

YELED V’YALDA EARLY CHILDHOOD CENTER (sometimes referred to as “Yeled” or “Organization”) is committed to providing children and families with the highest quality and caring educational and/or therapeutic services. Yeled delivers those services in a manner that encompasses the highest professional standards, that places the interest of the children and families it serves first and foremost in all aspects of Yeled’s services and activities, that is culturally sensitive and that respects the privacy of the children and families Yeled serves. As such, Yeled expects all its personnel and others associated with Yeled to provide these services pursuant to the highest degree of ethical, professional, and legal standards and to apply these high standards to any and all interactions with the children and families Yeled serves, any school personnel or health care provider persons come into contact with, any governmental agencies or Federal, State or local authorities who oversee the various Yeled programs, any public entities or contracting parties from whom Yeled seeks or receives reimbursement, any auditing personnel and agencies, whether such auditor is conducting an audit internally or externally to Yeled, any vendors contracting with Yeled and any other persons or entities associated with Yeled in any manner whatsoever.

In short, Yeled does not, and will not, tolerate any form of unlawful, unethical or unprofessional behavior by anyone associated with Yeled’s services. We expect and require all personnel, program directors, supervisors, managers, executives, members of Yeled’s governing body, service providers and independent contractors related to Yeled’s services (referred to as “Affected Individuals”) to be law abiding, ethical, honest, trustworthy, fair, courteous, sensitive and professional in all of their services provided to and via Yeled. To ensure that these expectations are met, we maintain a Compliance Program and consider the Compliance Program, including the Standards of Conduct, to be an integral and essential component of Yeled’s mission, operations and ethical and professional atmosphere.

Intent

Yeled has adopted this Standards of Conduct, applicable to all the various programs Yeled operates, as a central part of its Compliance Program. All Affected Individuals must adhere both to the spirit and the language of the standards, maintain a high level of ethics and integrity in their professional conduct and avoid any conduct that conflicts in any way with, or could reasonably be expected to reflect adversely upon, the integrity or reputation of Yeled V’Yalda Early Childhood Center. Violation or noncompliance of these standards will result in disciplinary action, up to and including, termination.

The Standards of Conduct were approved by YELED V’YALDA EARLY CHILDHOOD CENTER’s Board of Directors. This document is a formal statement of the Organization’s commitment to the standards and rules of ethical conduct.

YELED V’YALDA EARLY CHILDHOOD CENTER is committed to compliance with all applicable Federal and State laws and the prevention of unethical, improper or unlawful behavior or acts in the delivery and billing of services, and prevention and detection of fraud, waste and abuse. YELED V’YALDA EARLY CHILDHOOD CENTER is committed to stopping such behavior as soon as possible after discovery, and to discipline those persons involved in such behavior or acts, including those who fail to report a violation.

All Affected Individuals, as defined above, must comply with the Standards of Conduct, immediately report any alleged violations of wrongdoing, and assist Management and the Compliance Officer in investigating allegations of wrongdoing.

While the standards addressed in this document are intended to guide Affected Individuals in their daily responsibilities, they do not replace any Yeled policies and procedures. There may be instances not addressed by the Standards of Conduct or existing policies and procedures, or there may be activities that seem to conflict with the Standards. Affected Individuals must seek direction from their supervisor, other Management staff, or the Compliance Officer in these instances.

Ethics

It is the policy of YELED V’YALDA EARLY CHILDHOOD CENTER to comply with all laws and regulations applicable to its business and to conduct business with the highest degree of integrity. To accomplish this, all Affected Individuals must obey the laws and regulations that govern their work and always act in the best interest of those who receive services and their families (collectively referred to as service recipients) and the Organization. Affected Individuals must strive to avoid even the appearance of impropriety or illegality and must never act in a dishonest or misleading manner when dealing with others.

• • Affected Individuals are expected to keep Management staff informed of what you are doing; to document or record all services or transactions accurately; and to be honest and forthcoming with the Organization, regulatory agencies, and internal and external auditors.
• • Affected Individuals are expected to comply with the Organization’s policies and procedures, accounting rules, and internal controls.
• • Affected Individuals are expected to function with honesty in their work for the Organization and with service recipients, other providers, suppliers, and all others with whom the Organization does business.

Maintenance of Records

Affected Individuals must record and report all information related to Yeled and its operations, its service recipients, and financial information fully, accurately, and honestly. Records include, but are not limited to, records of the service recipients, documentation of services, accounting books or records, financial statements, timesheets or records, expense reports, vouchers, bills, payroll, claims, payment records, correspondence, and any other method of communication.

Affected Individuals are expected to maintain complete, accurate, and contemporaneous (timely) records as required by the Organization. The term “records” includes all documents, both written and electronic, that relate to the provision of Yeled services or provide support for the billing of Yeled services. Records must reflect the actual service provided.

No Falsification of Records

• • Personnel and others associated with Yeled’s services must not make any false entries in any of the Organization’s records or in any public record for any reason.
• • Personnel and others associated with Yeled’s services may not alter any permanent entries in the Organization’s records. Any records to be appropriately altered must reflect the date of the alteration, the name, signature, and title of the person altering the document, and the reason for the alteration, if not apparent.
• • Affected Individuals may not create or participate in the creation of any records that are intended to mislead or to conceal anything that is improper.
• • Backdating and predating documents is unacceptable.

Retention of Records

• • The retention, disposal, or destruction of records of or pertaining to the Organization must always comply with legal and regulatory requirements and Yeled policy.
• • Affected Individuals may not destroy records pertaining to any legal action or government investigations or audit without written approval of the Compliance Officer.

Protection of Confidential Information

During employment, contract, or association with the Organization, individuals may acquire confidential information about YELED V’YALDA EARLY CHILDHOOD CENTER, its staff, and service recipients which must be handled in strict confidence and not discussed with outsiders, without authorization to share such information. The protection of confidential business, employee, and service recipient information is very important. Violations may result in fines and penalties, legal action, or criminal charges.

Kickbacks and Rebate

• • Kickbacks and rebates in cash, credit, or other forms are prohibited. They are not only unethical, but also in many cases illegal.
• • Affected Individuals may not without permission of the Organization accept, solicit, or offer anything of more than nominal value from anyone doing business with the Organization.
• • Affected Individuals may not solicit money, gifts, gratuity, or any other personal benefits or favors of any kind from providers, contractors, accounts, or service recipients and their families.

Improper Use of Funds or Assets

Use of the Organization’s funds or assets for any improper purpose is strictly prohibited. If an individual is aware of or has reason to believe that funds or assets are being improperly used, such individual must report this immediately to a supervisor or the Compliance Officer.

Federal and State Programs

YELED V’YALDA EARLY CHILDHOOD CENTER is committed to complying with the laws and regulations that govern the Federal and State programs that it administers. The Compliance Program, these Standards of Conduct, and policies and procedures are developed to provide guidance in the day-to-day work and activities performed on behalf of the Organization. Affected Individuals must abide by the policies and procedures and the Standards set by the Organization.

YELED V’YALDA EARLY CHILDHOOD CENTER’s programs and services are largely funded by Federal and State education and healthcare programs, including Medicaid. Yeled is committed to full compliance with all Federal and State healthcare program requirements. Yeled must also comply with laws and regulations designed to combat fraud, waste, and abuse and the submission of inaccurate or false claims.

YELED V’YALDA EARLY CHILDHOOD CENTER has put in place procedures and practices to ensure that:

• • All service documentation, records, and reports are prepared timely, accurately, and honestly;
• • All documentation supporting claims for service is complete and maintained in accordance with regulatory requirements and the Organization’s policies;
• • All claims submitted to any government or private healthcare program are accurate and comply with all Federal and State laws and regulations and payer requirements;
• • Claims are only submitted for medically necessary services provided by eligible providers;

Employees and independent contractors responsible for the documentation, charging, coding, billing, and accounting of services must comply with all applicable State and Federal regulations and with Yeled’s policies and procedures.

All Affected Individuals have a responsibility to notify the Compliance Officer promptly if they are charged with a criminal offense related to healthcare or are proposed or found to be subject to exclusion from Federal or State healthcare programs.

Governmental Investigations

There may be times that the Organization is asked to cooperate with an investigation by a Federal or State governmental agency, or to respond to a request for information. A request may be formally addressed to the Organization or to an individual employed by or associated with the Organization. All Affected Individuals must report any requests for information or cooperation with an investigation to the Compliance Officer immediately.

Seeking Guidance and Reporting Violations

All Affected Individuals must report any suspected fraud, waste, and abuse; illegal or unethical acts; actual or suspected violations of Federal or State laws and regulations; actual or suspected violations of the Standards of Conduct, the Compliance Program and Yeled’s policies and procedures; improper acts in the delivery or billing of services; and other wrongdoing (collectively referred to as “compliance concerns”) to their immediate supervisor, member of Management, Compliance Committee member or the Compliance Officer. A Compliance Hotline is also available for confidential or anonymous reporting of such issues. The Compliance Hotline number is posted on the Organization’s website.

When actual or suspected noncompliance is reported to any Affected Individual, it must be promptly referred to the Compliance Officer. Steps will be taken to protect the confidentiality and anonymity of the reporters. The Organization will not tolerate any form of retaliation or intimidation against a person who makes a good-faith report in accordance with the Standards of Conduct and its Compliance Program.

All Affected Individuals must cooperate fully and honestly in any investigation into reported noncompliance.

Corrective Action and/or Discipline

Affected Individuals found to have engaged in non-compliant activity or wrongdoing addressed in these Standards of Conduct will be subject to appropriate disciplinary action, up to and including termination of employment, contract, assignment, or association with Yeled.

Affected Individuals who knowingly fail to report compliance concerns are subject to appropriate disciplinary action, up to and including termination of employment, contract, assignment, or association with the Organization.

Cooperation with the Compliance Program

Affected Individuals must fully cooperate with YELED V’YALDA EARLY CHILDHOOD CENTER’s Compliance Program. The Compliance Program will work effectively only if everyone works together to ensure its success, understands what is required under the law, and under the Organization’s Standards of Conduct and Policies and Procedures. To achieve Yeled’s aim to ensure that its personnel have full knowledge of, and cooperate with, its Compliance Program, the Organization requires its personnel to be oriented in and trained in any and all aspects of its Compliance Program. Personnel and others associated with Yeled must also cooperate with all inquiries concerning any compliance matter, including, but not limited to, improper or inaccurate professional licensure and/or certification; improper, incomplete or inaccurate documentation; and/or improper coding or billing practices and respond to any reviews or inquiries, as well as actively work to correct any improper practices identified.