PRIVACY STATEMENT – CALIFORNIA

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in Medecision’s Privacy Policy.  This Privacy Statement is applicable to Medecision’s websites and websites of its affiliates linking to this California Supplemental Privacy Policy, and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). Specifically, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, address, telephone number, passport 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.
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data. Physical location
I. Professional or employment-related information. Current or past job history.
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, or student schedules.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from consumers.
  • Directly and indirectly from activity on our websites.
  • From third-parties that interact with us in connection with the products and services we offer.
  • From third-parties related to the website.
  • From Data analytics providers, social media platforms, and data brokers.

 

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided. For example, we may use personal information about you to respond to your requests, fulfill your purchase requests, send you publications or other information, and to answer your questions.
  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To improve our website and present its contents to you.
  • To ensure security and integrity of your personal information.
  • For testing, research, analysis and product development.
  • For our internal business purposes, such as data analysis, audits, enhancing the websites, identifying usage trends and determining the effectiveness of our promotional messaging.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • 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.

 

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:             Identifiers
Category B:             California Customer Records personal information categories

Category F:             Internet or other similar network activity
Category G:            Geolocation data
Category I:              Professional or employment-related information
Category J:             Non-public education information (per the Family Educational Rights    and Privacy Act

 

We disclose the above categories of personal information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

 

In the preceding twelve (12) months, we have not sold any personal information, including personal information of individuals under the age of 16.

Sharing Personal Information

We may share your [internet or similar network activity] to advertising networks to provide you targeted advertising based upon your interests.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you in a portable format about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

 

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the personal information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).

 

  1. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  2. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  3. Comply with a legal obligation.
  4. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Correction Request Rights

You have the right to request that we correct any personal information that is inaccurate. Once we receive and confirm your verifiable consumer request, we will correct (and direct our service providers to correct) your personal information from our records, unless an exception applies.

 

We may deny your correction request if we believe the information is more likely than not accurate based on the totality of the circumstances.

 

Right to Opt-Out of “Selling” or “Sharing” of Your Personal Information

You have the right to request that we do not sell or share your personal information. However, as noted above, we do not sell your personal information.

 

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to request that we limit our use and disclosure of your sensitive personal information. However, because we already limit our use and disclosure of your sensitive personal information, you do not need to take any steps to exercise this right. We also do not infer any characteristics about you based on your sensitive personal information.

 

Exercising Access, Data Portability, Deletion Rights, and Correction Rights

To exercise the access, data portability, deletion, and correction rights described above, please submit a verifiable consumer request to us by either:

 

Only you or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize such a request, we may require you to submit a written statement and for your agent to submit their name and email address.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

To make a verified request, we may ask for certain personal information including your name and email address. We cannot respond to your request or 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.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 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.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, 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.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Exercising Your Right to Opt-Out

If you wish, you can choose how web browser cookies are handled by your device via your browser settings. Some devices allow you to control this through your device settings. Each browser and device is different, so check the settings menu of the browser or device to learn how to change your settings and cookie preferences.

Many browser manufacturers provide helpful information about cookie management, including, but not limited to:

If you choose not to receive cookies at any time, websites may not function properly, and certain services may not be provided. We currently do not respond to preference signals.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from companies that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative and the Digital Advertising Alliance.

You may also contact us to opt-out, as discussed further below.

Non-Discrimination or Retaliation

We will not discriminate or retaliate 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.

 

Retention of your Personal Information

We retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Please note that in many circumstances we must retain all, or a portion, of your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, to protect against fraudulent, deceptive, or illegal activity or for another one of our business purposes.

 

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make material changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (866) 459-3339
Website: www.medecision.com

Email: Legal.CCPA@medecision.com
Postal Address: Privacy Officer, Medecision, 8111 Preston Road, Suite 900, Dallas, TX  75225

 

This policy was last updated on 03/22/2024