CliniContact Privacy Notice Addendum for California Residents

Effective Date: May 1, 2023
This Privacy Notice Addendum for California Residents (referred to as the "California Addendum") outlines how we collect and use Personal Information. It supplements the information provided in CliniContact's Privacy Policy and applies exclusively to visitors, users, and residents of California ("consumers" or "you"). We have implemented this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA"). Any terms defined in the CCPA have the same meaning in this notice.

Please note that this California Addendum does not apply to personal information collected from our California-based employees, job applicants, contractors, or similar individuals in an employment context. If you are a California employee and require more information about how we handle your Personal Information, please contact your local human resources department.

Additionally, this California Addendum does not apply to personal information related to business-to-business communications ("B2B Personal Information") whether written or verbal, unless otherwise specified. This exemption will expire on January 1, 2021, unless otherwise stated.

INFORMATION WE COLLECTOur websites, https://mainpage.clinicontact.com/ and https://clinicontact.com (collectively referred to as our "Website"), collect various types of personal information that can be associated with a particular consumer or device. This includes but is not limited to:
CATEGORY APPLICABLE PIECES OF PERSONAL INFORMATION COLLECTEDA. Identifiers.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)).
Name, signature, physical characteristics or description, address, telephone number, education information, health insurance information, or medical information. Some personal information in this category may overlap with other categories.

C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, country of residence, religion or creed, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status, genetic information (including familial genetic information), or sexual orientation.

D. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

E. Geolocation data.
Physical location or movements.

F. Inferences drawn from other personal information.
Profile reflecting a person's psychological trends, predispositions, and behavior.
Personal information does not include publicly available information from government records, deidentified or aggregated consumer information, or information excluded from the scope of the CCPA, such as 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), or clinical trial data.

USE OF PERSONAL INFORMATIONWe may collect, use, "sell" (for monetary or other valuable consideration), or disclose personal information for one or more of the following business or commercial purposes:

To fulfill the purpose for which the information was provided, such as responding to inquiries or matching individuals with clinical trials.
To provide, support, personalize, and develop our Website and services.
To create, maintain, customize, and secure user accounts.
To personalize user experiences and deliver relevant content, product offerings, and targeted advertisements.
For internal testing, research, analysis, and service development.
To respond to law enforcement requests and comply with applicable laws, regulations, or legal processes.
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.
As otherwise described to you when collecting your personal information or as permitted or required by applicable law.

YOUR CALIFORNIA PRIVACY RIGHTSThe CCPA provides consumers 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 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 (also called a data portability request).
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 RightsYou 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.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:
Sending an email to support@clinicontact.com.

Visiting our Privacy Center on our Website.

Only you or a person registered with the California Secretary of State 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.

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.
We will not respond to requests if we cannot verify the requestor's 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 FormatWe 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. 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.
Non-DiscriminationWe 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.
We may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

CHANGES TO OUR PRIVACY NOTICEWe reserve the right to amend this California Addendum at our discretion and at any time. When we make changes to this California Addendum, we will notify you by email or through a notice on our Website homepage.

CONTACT INFORMATIONIf you have any questions or comments about this California Addendum, the ways in which we collect and use your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Email: support@clinicontact.com
Website: https://mainpage.clinicontact.com
We are committed to working with you to obtain a fair resolution to any complaint or concern you may have about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to lodge a complaint with the supervisory authority responsible for data protection in your country.
Thank you for taking the time to review our CliniContact Privacy Notice Addendum for California Residents.