Last Modified February 1st, 2023
Scope.
1. This section is intended to describe our practices and your rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”). This Supplement provides rights and other terms relating to CCPA Personal Information (defined below) that are in addition to those provided in our Privacy Notice. These additional rights and other terms are only available to California residents about whom we collect CCPA Personal Information. This Supplement takes precedence over the Privacy Notice with respect to CCPA Personal Information for California residents if there is a conflict between the two.
2. In this Supplement, when we talk about “CCPA Personal Information”, we mean 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 household as set forth in the CCPA.
3. You should be aware that CCPA Personal Information doesn’t include:
- Publicly available information from government records,
- De-identified or aggregated consumer information, and
- Information excluded from the CCPA’s scope, such as:
- Protected Health Information under HIPAA, information subject to the California Confidentiality of Medical Information Act, or clinical trial data; or
- “Business to business” information, which is information related to communications or transactions between a business collecting the information and a consumer who is acting on behalf of another business where the communications or transaction relate solely to an exchange of products or services between the two businesses.
4. Based on this scope, our collection and use of CCPA Personal Information described in this section 2 is limited to visitors to our Sites. For more information on our practices related to Personal Information more generally, please refer to our Privacy Policy.
What CCPA Personal Information We Collect.
5. We have collected the following categories of CCPA Personal Information from consumers in the past 12 months:
How We Collect Your CCPA Personal Information.
6. We collect each of the categories of CCPA Personal Information listed above in one or more of the following ways:
- When you contact us (e.g., from forms you complete on our Sites.
- Automatically when you use the Sites, such as Personal Information related to your device.
- From other sources, including the Internet and other publicly-available sources and databases, data aggregators, marketing companies, and other third parties. For example, if you are on a third-party website and request information from us, that website will send us your contact information.
How We Use Your CCPA Personal Information.
7. In the past 12 months, we have used each of the categories of CCPA Personal Information described above for one or more of the following business purposes:
- Provide You with Information and Fulfill Your Requests. We may use your CCPA Personal Information to verify your identity or provide you the information, products, and services that you request. For example, we provide information or respond to your questions when you contact us, provide demos of the Services to those who request them, or, if you visit one of our locations, we collect your CCPA Personal Information for purposes of security and visitor management.
- Enhance Your Experience. We use your CCPA Personal Information to personalize and enhance your experience when you visit our Sites, such as tailoring content and advertising and remembering your preferences.
- Improve the Sites. Your CCPA Personal Information helps us improve the content and functionality of the Sites.
- For Legal Purposes: We will use your CCPA Personal Information when we think it is necessary to investigate or prevent actual or expected fraud, criminal activity, injury or damage to us or others; when otherwise required by law, regulation, subpoena, court order, warrant or similar legal process; or if necessary to assert or protect our rights or assets.
- As Described when Collected. As described to you when we collect your CCPA Personal Information or as otherwise set forth in the CCPA.
How We Disclose Your Information For Business Purposes
In the past 12 months, we have disclosed the following categories of Personal Information for a Business Purpose:
- Identifiers
- Demographic information
- Internet or other similar network activity
- Geolocation data
- Device data
- Professional or employment-related information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- 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.
- To third-parties that support our efforts to manage cookie-based marketing information.
How We Share or Sell Your CCPA Personal Information.
8. In the past 12 months, we have shared or sold (as defined by the CCPA) your Personal Information:
- Identifiers
- Internet or other similar network activity
- Geolocation data
- Device data
We share or sell (as defined by the CCPA) your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- 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.
- To third-parties that support our efforts to manage cookie-based marketing information.
Your Rights and Choices under the CCPA.
Below please find a description of key rights California consumers have under the CCPA and an explanation of how to exercise those rights with us.
- The Right to Know. You have the right to request that we disclose certain information to you about our collection and use of your CCPA Personal Information over the past 12 months. Once we receive and verify your request, we will disclose to you:
- The categories of CCPA Personal Information we collected about you.
- The categories of sources for the CCPA Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling that CCPA Personal Information.
- The categories of third parties with whom we share that CCPA Personal Information.
- The specific pieces of CCPA Personal Information we collected about you (also called a data portability request).
- If we sold or disclosed your CCPA Personal Information for a business purpose, two separate lists setting out:
- sales, identifying the CCPA Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the CCPA Personal Information categories that each category of recipient obtained.
- The Right to Deletion.
- You have the right to request that we delete any of your CCPA Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your CCPA Personal Information from our records, unless an exception under the CCPA applies.
- We may deny your deletion request for reasons permitted by the CCPA. For example, if the information is excluded from the CCPA or does not constitute CCPA Personal Information, such as Protected Health Information held on behalf of a Provider who uses our Sites. Please submit all requests related to your Protected Health Information directly to your Provider. We may also deny your deletion request if the information is required to complete the transaction for which the information was collected or to provide you with requested goods or services.
- The Right to Limit Our Use Of Sensitive Personal Information
- Some of the information we collect may be considered sensitive under the CCPA. You have the right to request that we limit the use of your Sensitive Personal Information.
- The Right to Correction
- You have the right to correct any inaccurate Personal Information that we maintain about you.
- Exercising Your Rights
- To exercise your rights, please submit a request to us at the contact information below, or by completing the form located here.
- Only you or an authorized representative may make a request related to your CCPA Personal Information. You may also make a request on behalf of your minor child.
- You may only make a Right to Know or Right to Delete request twice within a 12-month period. The request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected CCPA Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- We will take steps to verify your identity before processing your request, and we may request additional information from you for verification purposes. We will only use the CCPA Personal Information you provide to us in response to this request to verify your identity and to process your request, unless you initially provided the information for another purpose.
- You may use an authorized agent to exercise your rights. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request for you. To protect your CCPA Personal Information, we reserve the right to deny a request from an agent that does not submit adequate proof that you authorized them to act for you.
- We cannot respond to your request or provide you with CCPA Personal Information if we cannot verify your identity or authority to make the request and confirm the CCPA Personal Information relates to you.
- Response Timing and Format. Once we have verified a request from a California consumer, we will try to respond within 45 days. If we need more time, we will tell you in writing why and how much longer we need (up to 45 days), either by mail or electronically (based on your choice). Our responses will include the CCPA-required information.
- CCPA Personal Information Sales or Sharing Opt-Out Rights. You have the right to opt out of the Sale of Sharing of your CCPA Personal Information. If you do not affirmatively opt out, and you are not a minor (less than 16 years of age), your CCPA Personal Information may be sold or shared as disclosed in this Supplement. You (or your authorized representative) may submit your request to opt out of the sale of your CCPA Personal Information by clicking here, selecting the “Do Not Sell or Share My Personal Information” link at the bottom of our website, or by emailing privacy@stellar.heatlh.
- Non-Discrimination. We will not discriminate against you for choosing to exercise any of your CCPA rights, including with respect to the pricing of any Services. If you exercise certain CCPA rights, understand that you may be unable to use or access certain features of the Services. Additionally, please note that we may still charge you a different price or rate for Services, including through granting of discounts or other benefits, for reasons unrelated to your exercise of these rights, unless prohibited by the CCPA.
- The Right to Know. You have the right to request that we disclose certain information to you about our collection and use of your CCPA Personal Information over the past 12 months. Once we receive and verify your request, we will disclose to you:
CHANGES TO OUR PRIVACY NOTICE OR THIS SUPPLEMENT
We may change this Supplement at any time. Unless we say otherwise, changes will be effective upon the last updated date at the top of this Supplement. Please check this Supplement regularly to ensure that you are aware of any changes. We may try to notify you of material changes to this Supplement, which if we do so may be by means such as by posting a notice directly on the Sites, by sending an email notification (if you have provided your email address to us), or by other reasonable methods. In any event, your use of the Sites after changes to this Supplement means you have accepted the changes. If you do not agree with the changes, immediately stop using the Sites.
CONTACTING US
Consumers with disabilities may access this notice in an alternative format by contacting privacy@stellar.health. If you have any questions or comments about this Supplement, including how we collect and use your CCPA Personal Information or your choices and rights regarding such use, or if you wish to exercise your rights under California law, please contact us by either:
- Calling us at (877) 509-2808 and asking to speak with the Privacy Officer or
- Emailing privacy@stellar.health
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