CALIFORNIA PRIVACY NOTICE
If you are a California Consumer, this California Privacy Notice explains your privacy rights and is intended to inform you at or before the time that you provide us with your Personal Information how and why we process Personal Information. In this California Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular California Consumer or household.
Please note, however, that much of the Personal Information that Company collects through the patient portals and Patient Concierge mobile application is “protected health information” (“PHI”) as defined under the Health Insurance Portability and Accountability Act (“HIPAA”). Company collects PHI in its role as a “business associate” (as defined under HIPAA) on behalf of our customers that are “covered entities” (as defined under HIPAA). CCPA DOES NOT APPLY TO INFORMATION THAT IS PHI WHICH COMPANY COLLECTS IN ITS ROLE AS A BUSINESS ASSOCIATE. THIS CALIFORNIA PRIVACY NOTICE ONLY APPLIES TO PERSONAL INFORMATION THAT COMPANY MAY COLLECT FROM CALIFORNIA RESIDENTS WHEN COMPANY IS NOT ACTING AS A BUSINESS ASSOCIATE.
CALIFORNIA RESIDENT PRIVACY RIGHTS
California Consumers also have the right to request information about the third parties to which or whom Company disclosed certain categories of Personal Information during the preceding calendar year for the third parties’ direct marketing purposes. At this time, the Company does not share Personal Information with third parties for direct marketing purposes.
COMPANY’S NOTICE AT COLLECTION OF PERSONAL INFORMATION
For CCPA purposes, Company generally acts as a “Business” with respect to Personal Information, which means that Company determines how and why the Personal Information that Company collects from or about you is processed. In the rare case when Company is handling Personal Information on behalf of a business customer, Company is acting as a “Service Provider,” which means that Company can only use Personal Information for specified purposes and as permitted in our contract with our business customer.
This Notice at Collection of Personal Information describes our Personal Information collection practices when we are acting as the Business, including a list of the categories of Personal Information we collect, the purposes for which we collect Personal Information and the sources from which we collect Personal Information. In general, we collect Personal Information directly from you, through our customers and through interactions with our Services.
Category of Personal Information listed in CCPA
Examples of Personal Information in CCPA Category
Whether and why Company Collects this Personal Information
Name, postal address, email address, unique identifier, Internet Protocol address, account name, and similar identifiers.
We collect name, telephone number(s), email address(es) and contact address when you create an account, an account is created for you or you complete a transaction. If you choose to create an account, you also create a username and we will assign one or more unique identifiers to your account.
We collect automatically IP address, computer and/or mobile device ID, domain server, type of device(s), operating systems and web browsers used to access the Services.
We do not collect social security number, driver’s license number or passport number.
We do not collect insurance policy number, education, employment history, medical information, or health insurance information.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Name, signature, address, telephone number and current employer and work address.
We collect name, phone number, email address and contact address for the reasons described in Row A above.
Protected classification characteristics under California or federal law
Information about legally-protected classifications includes race, national origin, citizenship, marital status, gender, sexual orientation/identity, medical condition, AIDS/HIV status, genetic information, military or veteran status, religion, disability, political affiliations or activities or status as a victim of domestic violence, assault or stalking.
We do not collect this category of Personal Information.
Records products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
We create records of the Services purchased or considered, as well as purchasing history in order to provide you with the Services that you have purchased and to offer other products that may be useful to you. You provide payment and billing information when you purchase our Services but we do not retain bank account number, credit card number, or debit card number – this information is collected by our payment processor and not maintained with us.
Physiological, biological or behavioral characteristics.
We do not collect this category of Personal Information.
Internet or other similar network activity
Browsing history, search history, information on a California Consumer’s interaction with online services and digital advertisements.
Physical location or movements from GPS, WiFi and/or Bluetooth (when a device’s operating system settings allow collection).
We collect IP address automatically. We may be able to determine general location based on the IP address. We collect GPS coordinates if you have selected to use the location tracking part of the Services.
Audio, electronic, visual, thermal, olfactory or similar information.
Recorded telephone calls and photographs.
If you contact us via telephone, we may record the telephone call. We will notify you if a call is being recorded at the beginning of the telephone call. We do not collect any thermal, olfactory or similar information.
Professional or employment-related information
Information about the employer who or that is our customer or prospective customer.
Depending on how and why you use the Services, we may collect and use information about position and current employer (that is the customer or prospective customer) to understand more about you in order to provide you with relevant information to promote our products and services, to deliver advertising, some of which is targeted based on online activity and inferred interests, and to communicate with you.
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99))(“FERPA”)
Information about the institutions you have attended, the level of education you have attained and other information as defined in FERPA.
We are not subject to FERPA but we may collect information about the institutions you have attended or the level of education you have attained if you apply for a job with Company.
Inferences drawn from other categories (A – L above) to create a profile about a California Consumer
Profile reflecting preferences and characteristics.
We may share certain Personal Information with our vendors and supplier (which are our “Service Providers” under CCPA) that we engage for our business purposes. Our Service Providers are restricted from using Personal Information for any purpose that is not related to our engagement. We provide contact information to public safety authorities where necessary.
When Company is acting as a Service Provider on behalf of one of our business customers, we may disclose information about interactions with the Services to the customer from which we receive Personal Information.
Company does not sell Personal Information and, accordingly, we do not provide information about how to opt out of the sale of Personal Information.
HOW TO SUBMIT A REQUEST TO EXERCISE YOUR CALIFORNIA PRIVACY RIGHTS
To submit a request to exercise your privacy rights: