Last updated: October 2023
1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT FROM CALIFORNIA CONSUMERS
In the preceding 12 months, we have collected the following categories and types of personal information from California consumers, and intend to continue doing so subject to the requirements under the CCPA:
|Category||Description||☐Y / ☐N|
|A. Identifiers||Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.||☒Y / ☐N|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||☒Y / ☐N|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||☒Y / ☐N|
|D. Commercial information.||Records and history of products or services purchased or considered||☒Y / ☐N|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data||☐Y / ☐N|
|F. Internet or other similar network activity.||Interaction with our Service or advertisement||☒Y / ☐N|
|G. Geolocation data||Approximate physical location||☒Y / ☐N|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information||☒Y / ☐N|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||☐Y / ☐N|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||☐Y / ☐N|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||☐Y / ☐N|
2. HOW WE COLLECT YOUR INFORMATION
- Personal Information you provide to us when you use our Services (i.e., registration information)
- Information which we automatically collect when you use or access the Site (i.e., device information, automatically generated information, usage data, and information derived from tracking technologies such as cookies)
- Non-Personal Information is collected through your use of the Site (i.e., analysis aggregation, anonymized information)
3. BUSINESS OR COMMERCIAL PURPOSE FOR COLLECTING, SHARING AND SELLING INFORMATION
We collect and share your personal information for the following business and commercial purposes: to authenticate your identity when you use our Site to provide you with the Site, to provide customer support, where you chose to exercise rights entitlements you may have vis a vis your healthcare network and benefit plan administrators – to report to such providers and administrators regarding the exercise of insurance plans or benefits they administer, to adhere to your instructions and transmit your information accordingly, to give you a better browsing experience, to detect security incidents, to debug and fix errors associated with our Site, improve our Site and offerings, to encourage and enable purchases and delivery of our products and services, such as through our various promotions, to comply with any applicable rule or regulation and/or respond to or defend against legal proceedings versus us or our affiliates, or to enroll you in our newsletter subscription program.
We do not make your data publicly available, we do not act as data brokers and we do not trade in your data. However, certain standard generally accepted business practices may be deemed as “Sale” of data under the CCPA, such as when we utilize third party service providers that provide us with services, while they retain certain rights to use your data for their own business needs (e.g. Google Analytics, fraud detection services, etc.).
4. YOUR CALIFORNIA CONSUMER RIGHTS
Right to Access
California consumers have the right to request access to the specific pieces of personal information we have collected about them in the last 12 months. You may make this request up to two times in a 12-month period.
You may also request additional details about our information practices, including the categories of personal information we have collected about you, the categories of sources of such collection, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share and sell your personal information, the categories of personal information we have disclosed and “sold” about you in the preceding 12 months, and the categories of third parties to whom we sold personal information in the preceding 12 months.
Right to Correct
You have the right to request the correction of inaccurate personal information if that information is inaccurate. We reserve the right to request identifying documentation from you in certain circumstances, as permitted by law.
Right to Delete
You have the right to request deletion of your personal information (subject to certain exceptions). Once we receive and confirm a consumer request, we will delete (and direct our Service Providers to delete) your personal information from our records, unless an exception applies.
Right to Non-Discrimination
You have the right to receive equal service and price and not be discriminated against even if you exercise any of your CCPA rights. Unless otherwise permitted by applicable law (such as if the differences are reasonably related to your information), we will not:
- Deny you goods or services;
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits, or imposition of penalties.
- Provide a different level or quality of goods or service; or
- Suggest that you will receive a different price or rate for goods or services, or a different level or quality of goods or services.
Right to Limit or Opt-Out of the Sale or Sharing of Your Information
Our Services do not sell (as “sell” is traditionally defined) your personal information. That is, we don’t provide your name, phone number, address, email address or other personally identifiable information to third parties in exchange for money. However, under California law, certain cases of sharing information, such as for advertising purposes, may be considered a “sale” of personal information. If you’ve visited our digital properties within the past 12 months, personal information about you may have been “sold” under the CCPA to our advertising or other partners for their own use.
Under the CCPA, California residents now have the right to opt out of both the “sale” and “sharing” of personal information. We’ve made it easy for anyone to stop the information transfers that might be considered such a “sale” from our website. And just for clarification, sharing your personal information with our service providers that may send you an email communication on our behalf isn’t considered a “sale” under the CCPA.
Finally, we may collect certain categories of personal information from you and third parties as described in the “COLLECTION” section above that may be considered “Sensitive Personal Information” under California law. Our use of your Sensitive Personal Information is generally limited to performing services or providing goods you requested. You have the right to limit the use and disclosure of your personal information to whatever use is necessary for us to make the Services available to you.
California consumers may make a rights request by sending us an email at email@example.com. or calling customer service at 866-971-8986. Your request must include sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, which may include your email address, name and account ID (which is required only if you already have an account with us). If you have an account with us, you can find your account ID on your main account page after you log in. Additionally, users may opt-out of the “sale” of information as described above, by clicking the “Do Not Sell My Personal Information” link at the bottom of this page.