Privacy Notice for California Residents
Last Modified: March 18, 2021
Information We Collect
For the purposes of this notice, "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CCPA.
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information that is excluded from the CCPA’s scope, including but not limited to health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) and clinical trial data.
The CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some of its requirements.
The chart below provides the categories of Personal Information we have collected, disclosed for a business purpose, or used for business or commercial purposes in the preceding 12 months since the effective date of this Notice.
The examples of Personal Information provided for each category may not reflect all of the specific types of Personal Information associated with each category.
|A. Identifiers.||Name, alias, postal address, unique personal identifier, online identifier, IPaddress, email address, account name, or other similar identifiers.||Yes||Yes||No|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||Name, address, telephone number, passport number, driver's license or state identification card 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.||Yes||No||No|
|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).||Yes||No||No|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes||Yes||No|
|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.||No||N/A||N/A|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||Yes||Yes||No|
|G. Geolocation data.||Physical location or movements.||Yes||Yes||No|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No||N/A||N/A|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||Yes||Yes||No|
|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.||No||N/A||N/A|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Yes||No||No|
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you, based on forms you complete on the Website.
- Indirectly from you, such as from observing your actions on our Website.
HealthEC does not engage in the sale of personal information to third parties. To the extent "sale" under the CCPA and its associated regulations are interpreted in the future to include advertising technology activities as a "sale," we will update this notice and/or comply with applicable law as to any such activity.
HealthEC discloses the following categories of personal information for commercial purposes: identifiers, demographic information, commercial information, internet activity, geolocation data and inferences. We use and partner with different types of entities to assist with our daily operations and to manage our Website.
Our Website is intended to provide information to our prospective and actual customers and to job applicants. If you are a customer or job applicant, you understand and agree that information collected about you is solely within the context of (i) your role as an employee, job applicant, owner, director, officer, or contractor, or (ii) HealthEC conducting due diligence regarding, or providing or receiving a product or service to or from your employer.
Use of Personal Information
We collect and use personal information for business and commercial purposes in accordance with practices described in this Policy, including in the last 12 months, for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request pricing or ask a question about our products or services, we will use that personal information to respond to your inquiry. We may also save your information to facilitate commercial interactions.
- To provide, support, personalize, and develop our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and to prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Website experience and to deliver directly to your content and product and service offerings relevant to your interests, including offers and ads through our Website, and via email.
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- To help prevent and address fraud, breach of policies or terms, and threats or harm.
- Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
- To send you advertising.
- To fulfill any other business or commercial purposes at your direction or with your notice and/or consent.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information, including the rights of access, data portability and deletion.
If you are a California resident and we, as a service provider, have processed personal information about you on behalf of our customers, and you wish to exercise your CCPA rights, you are requested to inquire with our customer directly.
If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal information. We will refer your request to that customer and will support them to the extent required by CCPA or other applicable California privacy laws in responding to your request. You may submit a verifiable consumer request to us by sending an email to email@example.com, along with sufficient information that allows us to reasonably verify you are the person about whom we collect personal information or an authorized representative.
Response Timing and Format
We endeavor to respond to a consumer request within sixty (60) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
Right to Opt-Out and Opt-In
HealthEC does not engage in the sale of personal information to third parties. Notwithstanding, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). Consumers who opt-in to personal information sales may optout of future sales at any time.
To exercise the right to optout, you (or your authorized representative) may submit a request to us by emailing us at firstname.lastname@example.org.
Once you make an opt-out request, you may change your mind and opt back into personal information sales at any time by emailing us at email@example.com.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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 or services or a different level or quality of goods or services.
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes in particular: Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information.
To make such a request, please send an email to write to us at Compliance Officer, HealthEC, LLC, 343 Thornall Street, Suite 630, Edison, NJ 08837. We may require additional information from you to allow us to verify your identity and only required to respond to requests once during any calendar year.