California-specific description of consumers’ privacy rights

If you are a resident of the State of California, we provide you with information on how to exercise your disclosure choice options such as your right to opt-out regarding to use of your personal information by third parties (such as advertisers and promotional partners) for marketing purposes.

Legal Basis for processing personal information

We collect a variety of personal information from you. California Consumer Privacy Act (“CCPA”) defines “personal information” as 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. Personal information does not include deidentified or aggregated consumer information.

We collect personal information for business and commercial purposes including: enhancing our products and services; fraud prevention; analytics; any other purpose not prohibited by applicable laws or privacy regulations, including the CCPA.

What data is collected?

The type of personal information we collect will depend on how you engage with us (as described below).

In the last 12 months we have collected the following personal information:

Upon your visit – Device type, IP address, Browser settings, Language, GEO, version and type of OS;

Upon your registration – all of the above plus First name, Last name, email address, company name, company address, company website and phone number.

The table below outlines the categories of personal information (which are defined by the CCPA) that we have collected and/or disclosed for a business purpose in the preceding twelve months. The examples of personal information provided for each category are taken from the CCPA and are included to help you understand what the categories mean. The examples are not meant to indicate what we actually collect or disclose, and more information about our specific practices can be found in this Privacy Policy.

 

Category Examples Collected
A. Identifiers. A name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, address, telephone number, passport number, driver’s license or state identification card number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.

YES

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).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

E. Biometric information.

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

F. Internet or other similar network activity.

Browsing history and search history within our website; information on a consumer’s interaction with a website and advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

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

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO


However, please keep in mind that we do not collect any personally identifiable information, unless you provide it directly to us by registering at the Site.

In the preceding twelve (12) months, we have not disclosed any personal information to third parties for a business or commercial purpose.

In the preceding twelve (12) months, we have not sold any personal information to third parties for a business or commercial purpose.

WHAT ARE YOUR RIGHTS?

Under the CCPA you are granted certain rights with respect to your personal information. Only you, a resident of the State of California, a person that you authorize to act on your behalf, or an entity registered with the California Secretary of State that you authorize to act on your behalf, may exercise these rights. We are permitted to reject your request if we reasonably determined that you are not a resident of the State of California.

Right to Access. The right to know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity: the categories and specific pieces of personal information we collect, use, disclose, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have disclosed for a business purpose, and the categories of third parties with which we have shared personal information.

Please consider that we do not sell personal Information collected through our Services, including not knowingly selling personal Information about consumers under the age of 16.

Right to be Forgotten. The right to request that we delete the personal information we have collected from you or maintain about you, subject to certain exceptions for business purposes outlined in the applicable law. Once we receive and confirm your verifiable consumer request, we will delete your personal information from our records, unless an exception applies.

Right to Non-Discrimination. The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA. If you exercise your rights under the CCPA we will not do any of the following: (a) deny you any goods or services; (b) charge you a different price or rate for goods or services, including through the use of discounts or other benefits or imposing penalties; (c) provide to you a different level or quality of goods or services; or (d) suggest to you 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 Opt-Out. You have the right to direct us to not sell your personal information to third parties at any time. We only share information as outlined herein. If you choose to opt-out of the sharing of your personal information, HealthyHub will no longer send your personal information to third parties. You can choose, at any time, to opt back in to the sale of your personal information.

However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our Services or engage with you in the same manner.

HOW TO EXERCISE YOUR RIGHTS?

To exercise any of the above rights, please contact us (alternatively you may use the “Do Not Sell My Personal Information” button in the footer of every Site page) and submit the required verifying information.

We use any personal information collected from you in connection with the verification of your request solely for the purposes of verification.

We may require additional information to verify your requests to exercise your rights or understand the scope of your request, although you will not be required to create any account on this Site to submit a request or have it fulfilled. You may designate an authorized agent to make a CCPA request on your behalf.

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.