Privacy Notice for California Residents

Document: 4831-4729-6188.2

Last Updated: June 10, 2020

1. Overview

This Privacy Notice for California Residents (the “Notice”) supplements the information contained in the Ursa Health, LLC (“Ursa Health,” “we,” “us,” “our”) Privacy Policy (the “Privacy Policy”) and applies solely to all visitors, users, and others who reside in the State of California (“user(s),” “you,” or “your”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice. This Notice governs your use of our website, https://www.ursahealth.com (the “Site”). 

2. Information We Collect

Our Site collects 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”). Below, we have provided a list of categories of Personal Information and examples of the types of Personal Information we collect that fall into those categories. For clarity, even where we indicate that we collect a category of Personal Information, we do not collect all types of Personal Information described in that category. 

Within the last twelve (12) months, our Site has collected the following categories of Personal Information from consumers (note that these categories may overlap): 

  • Identifiers, including first and last name, title, company, and email address.
  • Navigational information, including IP address, geographical location, browser type, referral source, search terms, length of visit, and pages viewed.
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including first and last name.

We have not collected the following categories of Personal Information from consumers within the past twelve (12) months: 

  • Protected classification characteristics under California or federal law.
  • Commercial information.
  • Biometric information.
  • Internet or other similar network activity.
  • Geolocation data.
  • Sensory data.
  • Professional or employment-related information.
  • Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
  • Inferences drawn from other Personal Information.

Ursa Health obtains the categories of Personal Information listed above directly from you, such as when you provide information through the Site and through any correspondences; and indirectly from you, such as information we collect when observing your actions on our Site using automated data collection tools.

3. Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following purposes: 

  • To fulfill or meet the reason you provided the Personal Information.  For example, if you share your name and contact information to ask a question about our Site, we will use that Personal Information to respond to your inquiry. 
  • 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 enforce, and to notify you of any changes to, relevant agreements, policies, or other terms.
  • To work with our service providers, who perform certain business functions or services on our behalf and who are bound by contractual obligations consistent with this Privacy Policy.
  • To prevent or investigate fraud, or for risk management purposes, and to help maintain the safety, security, and integrity of our Site, databases and other technology assets, and business.
  • To comply with legal obligations, court orders, or in order to exercise any legal claim or to defend against any legal claim.
  • 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 about our consumers is among the assets transferred.
  • As described to you when collecting your Personal Information or as set forth in the CCPA.

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.

4. Sharing Personal Information

We do not sell or rent your 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 into 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, Ursa Health has disclosed the following categories of Personal Information for a business purpose: 

  • Identifiers.
  • California Consumer Records Personal Information categories.

We have disclosed your Personal Information to service providers that help us administer and provide the Site (for example, a web hosting company whose services we use to host our platform). These third parties have access to your Personal Information only for the purpose of performing services on our behalf.  We have entered into contractual relationships with these service providers and require them to comply with all applicable information privacy laws and regulations and to use the Information only for the purposes for which it was disclosed.  We require that any service providers limit their use of your Personal Information solely to providing services to us and that they maintain the confidentiality, security, and integrity of your Personal Information and not make unauthorized use or disclosure of the Information.

5. Your Rights and Choices 

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. The following sections describe your CCPA rights and explains how to exercise those rights.

6. Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see How to Make a Request, below), 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 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 (also called a data portability request).
  • If we disclosed your Personal Information for a business purpose, a separate list identifying the Personal Information categories that each category of recipient obtained.

7. 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 (see Exercising Access, Data Portability, and Deletion Rights, below), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. 

8. How to Make a Request

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

  • Calling us at (888) 933-7671
  • Visiting https://www.ursahealth.com
  • Emailing us at privacy@ursahealth.com

Only you, or someone legally authorized 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 an agent to act on your behalf with respect to the rights contained in this Notice, we may require proof from the agent that you have provided the authorized agent written permission to do so, and we may require that you verify your own identity directly with us. If you have provided the agent with power of attorney, that may be sufficient.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. 

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. We verify requests by matching information you provide to information that we maintain in our records, so we ask that you provide information required to match your request with the consumer about whose information the request is being made. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

9. Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, up to an additional forty-five (45) days, we will inform you of the reason and extension period in writing. 

We will deliver our written response by mail or electronically, at your option. 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, specifically we will use a .CSV data format.

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. 

10. Non-Discrimination

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, provide you a different level or quality of goods or services, or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. We do not provide any such financial incentives at this time. 

11. Other California Privacy Rights

California Civil Code Section 1798.83 permits California residents to request and obtain a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such information, by e-mailing a request to privacy@ursahealth.com.  

12. Changes to Our Privacy Notice

Ursa Health reserves the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on the Site and update the Notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

13. Contact Information

If you have any questions or comments about this notice, the ways in which Ursa Health collects and uses your information described above and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact our representative(s) by e-mail at privacy@ursahealth.com, by phone at (888) 933-7671, or by regular mail at Ursa Health, LLC, Attn: Website Inquiry, 102 Woodmont Blvd, Suite 110, Nashville, TN 37205.

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