Privacy Notice for California Residents - California Consumer Privacy Act of 2018 (CCPA)

Uploaded: January 1, 2020

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Introduction
What Information Do We Collect?
How Do We Use This Information for Business Purposes?
How Do We Share and Disclose Information to Third Parties?
Your Privacy Rights

Retention
International Data Transfers
Security
Children
Cookies and Other Tracking Technologies
Terms and Conditions
Updates to the Privacy Notice
Contact Us

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Introduction

This Privacy Notice for California residents supplements the information contained in Prescient’s GDPR Privacy Policy and applies solely to visitors to and users of our website (www.PrescientHG.com) who reside in the State of California (“consumers” or “you”). This notice is provided 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.

To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/privacy-laws.

Prescient takes privacy very seriously. We are committed to respecting your privacy and any 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 (“Personal Information”). This Privacy Notice aims to inform you about how we collect, use, disclose, store and protect your Personal Information in connection with our website and our business activities in compliance with the CCPA.

“Prescient” here means:

Prescient Healthcare Group, Inc.
New Jersey Office
15 Exchange Place, Suite 730
Jersey City, NJ 07302
United States

California Office
1875 S. Grant Street
San Mateo, CA 94402
United States
Toll-Free: +1 (833) 744 7440

Prescient Healthcare Group (UK) Ltd.
CP House, 97-107 Uxbridge Road
Ealing, London, W5 5TL
United Kingdom

Prescient Healthcare Group Pvt. Ltd.
105-106, MG Road, Time Tower
Gurugram, Haryana 122002
India

Prescient Healthcare Group, Inc., serves as the US-based representative of both Prescient Healthcare Group (UK) Ltd. and Prescient Healthcare Group Pvt. Ltd.

What Information Do We Collect?

Prescient gathers various types of information, including the categories of Personal Information listed below.

Category

Collected

(A). Identifiers

Such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers.

Yes

(B). Personal Information categories listed in the California Customer Records statue (Cal. Civ. Section Code 1798.80(e))

“Personal information” means any information that identifies, relates to, describes, or is capable of being associated with a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy 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.

Yes

(C). Protected classification characteristics under California or federal law

No

(D). Commercial information

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

Yes

(E). Biometric information

No

(F). Internet or other similar electronic network activity information

Yes

(G). Geolocation data

Yes

(H). Audio, electronic, visual, thermal, olfactory or similar information

No

(I). Professional or employment-related information

Yes

(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)

No

(K). Inferences drawn from other Personal Information

No

When you visit the Prescient website, we collect information related to your device, such as your device’s IP address, location data, referring website, which of our website pages your device visited and the time that your device visited our website.

For further information, please read the “Cookies and Other Tracking Technologies” section below.

Personal Information does not include:

  • Publicly available information from government records
  • Deidentified or aggregated consumer information

Information excluded from the CCPA’s scope includes:

  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the Californian Confidentiality of Medical Information Act (CMIA) or clinical trial data
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach Bliley Act (GLBA) or Californian Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Please note that, for users located in the European Union or European Economic Area countries, the General Data Protection Regulation (GDPR) applies. You may review our GDPR Privacy Notice at www.prescienthg.com/privacy/gpdr.

How Do We Use This Information for Business Purposes?



Prescient uses the information we collect for business purposes, such as:

  • To provide the services requested by our clients
  • To tell prospective clients about new services
  • To manage our website and services
  • To process job applications
  • To conduct research commissioned by our clients
  • To carry out business development
  • To invoice our clients
  • To pay our vendors
  • To facilitate market research
  • To comply with legal and contractual obligations

How Do We Share and Disclose Information to Third Parties?



We do not rent or sell your Personal Information to anyone.

We may share and disclose information (including Personal Information) in the following limited circumstances:

  • With third-party service providers that perform business operations on our behalf
  • With clients in relation to the research work performed
  • To protect and defend Prescient (including enforcing our Terms and Conditions)
  • When required by law and/or government authorities

If you do not wish to provide your Personal Information to us, we may not be able to provide the services you request or tell you about other services offered by Prescient.

Your Privacy Rights



The CCPA provides consumers (i.e., Californian 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 Prescient disclose certain information to you about our collection and use of your Personal Information over the past 12 months. One we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of Personal Information we collect 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 which we share that Personal Information
  • The specific pieces of Personal Information we collected about you (also used for data portability requests)

Deletion Request Rights

You have the right to request that Prescient delete any of your Personal Information that we have collected and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your Personal Information from our records. We will also direct our service providers to delete your Personal Information from their records.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

(1) Complete the transaction for which the Personal Information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
(2) Detect security incidents; protect against malicious, deceptive, fraudulent or illegal activity; or prosecute those responsible for that activity.
(3) Identify and repair errors that impair existing intended functionality.
(4) Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
(5) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
(6) 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 business’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
(7) Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
(8) Comply with a legal obligation.
(9) Otherwise use the consumer’s Personal Information internally in a lawful manner that is compatible with the context in which the consumer provided the information.

Exercising Access, Data Portability and Deletion Rights

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

Calling us:
+1 (833) 744 7440

Emailing us:
dataprotection@prescienthg.com

Writing to us:
Prescient Healthcare Group, Inc.
1875 S. Grant Street
San Mateo, CA 94402

Verifiable Consumer Requests

Only you, or a person registered with the Californian 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 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 will only use Personal Information provided in a verifiable consumer request to verify the requester’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing within the forty-five (45) days.

We will deliver our written response by mail or electronically. Any disclosures of information we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

If provided electronically, the information will be provided in a portable and, to the extent technically feasible, in a readily useable format that allows the consumer to transmit this information to another entity without hindrance. This will also be the format for data portability requests.

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 reasonable fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. 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

Prescient retains Personal Information, as necessary, for the duration of the relevant business relationship or activity. We may also retain Personal Information for longer than the duration of the business relationship or activity to: protect ourselves against legal claims, use the data for analysis or historical recordkeeping, or comply with our information management policies and schedules.

International Data Transfers

Prescient has offices in the United Kingdom and in India to which we may transfer Personal Information from our offices in the United States. The relevant legal entities have signed standard contractual clauses, as required under the GDPR to ensure adequate safeguards of these cross-border transfers.

Security

We use technical, organizational and administrative security measures to protect any information we hold from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to Personal Information transmitted, stored or otherwise processed.

Children

We do not intend to collect or solicit Personal Information from anyone under the age of 13. The only exception to this is when we conduct research under the legal basis of explicit consent.

Cookies and Other Tracking Technologies

What Are Cookies?
A cookie is a small piece of data (text files) that a website asks to place on users’ devices to remember information about them, such as language preference or login information. Cookies placed by us are called first-party cookies. We may also use third-party cookies from a domain other than www.PrescientHG.com for our advertising and marketing efforts to understand how you browse our website (for example, which pages you visit or how long you remain on each page).

Why Do We Use Cookies?
We use cookies and other tracking technologies for the following purposes:

  • To help us and third parties obtain information about your visits to our website
  • To analyze your visiting patterns to improve our website
  • To deliver advertising, communications and content that are specific to your interests from Prescient and third parties on our website and third-party websites
  • To remember your language and other preferences
  • To help you obtain information
  • To measure how many people use our website and how they use it
  • To keep our website running efficiently

What Types of Cookies Do We Use and How Do We Use Them?
Below is a detailed list of the cookies we use on our website. Our website is regularly scanned with our cookie scanning tool to maintain a list that is as accurate as possible. We classify cookies in the following categories:

  • Strictly necessary cookies
  • Performance cookies
  • Functional cookies
  • Targeting cookies

How Can I Control Cookies?

You can opt out of each cookie category (except strictly necessary cookies) by clicking on the “cookie settings” button at the bottom of the page or the Cookie Notice on our website.

By using our website, you have the option to consent to the collection, use and storage of your Personal Information by Prescient. If you do not consent to the use of our cookies by accepting the cookies banner, then no Personal Information will be collected from you.

You can stop receiving promotional email communications from Prescient by following the instructions in those messages or by clicking here to unsubscribe.

Terms and Conditions

Prescient provides its website content subject to the following terms and conditions. Prescient may periodically change these terms and conditions, so please check back from time to time. By accessing and using this website, you agree to these terms and conditions.

Use of Website Content
You may not modify, publish, license, create derivative works from or sell any of the content or communications featured or displayed on the website without Prescient’s express written consent. You acknowledge that unauthorized use of any content could cause irreparable harm to Prescient and agree that, in the event of any such unauthorized use, Prescient will be entitled to an injunction in addition to any other remedies available.

Code of Conduct
By accessing or using any feature provided through our website, you agree to abide by the following standards of conduct. You agree that you will not attempt, nor authorize or facilitate any attempt by another person or entity, to use the website to:

  • Violate any of these terms
  • Reproduce, duplicate, copy, sell or exploit for any commercial purposes any portion of the website
  • Engage in disruptive activity, such as sending multiple messages in an effort to monopolize a forum or posting content unrelated to a forum’s designated topic or theme
  • Introduce viruses, worms, Trojan horses, harmful codes or any software or other materials that contain a component harmful to the website
  • Gain unauthorized access to any computer system or non-public portion of the site or interfere with or disrupt the website or servers or networks connected to the website
  • Invade the privacy of any person, including posting personally identifying or otherwise private or sensitive information about a person on the website without his or her consent or harvesting Personal Information about the website’s users
  • Engage in, encourage, advocate, provide instructions for or discuss with the intent to commit conduct that would constitute a criminal or civil offense or otherwise violate any federal, state, local or international law or regulation

Prescient cannot and does not ensure that other users are or will be compliant with the above Code of Conduct or any other provisions of these terms. You hereby assume all risk of harm or injury resulting from any lack of compliance.

Updates to the Privacy Notice

We constantly strive to improve our website and services and we recognize that data protection and data privacy is an ongoing responsibility, so we will update this Privacy Notice from time to time as we implement new practices or adopt new privacy policies. We will, for example, alert you of material changes by placing a notice on our website and/or by sending you an email (if you have registered your email address with us) when we are required to do so by applicable law. You can see when this Privacy Notice was last updated by checking the date at the top of this page. You are responsible for periodically reviewing this Privacy Notice.

Contact Us

Prescient Healthcare Group, Inc.

California Office
1875 S. Grant Street
San Mateo, CA 94402
Toll-Free: +1 (833) 744 7440

If you have any questions or concerns regarding our Privacy Notice, the ways in which Prescient Healthcare Group, Inc. collects and uses your information described above, your choices and rights regarding such use, or if you wish to exercise your rights under Californian law, please send a detailed message to our Data Protection Officer at dataprotection@prescienthg.com, call us at +1 (833) 744 7440 or write to us at our office in San Mateo.