California Consumer Privacy Act (CCPA) Information

This section supplements the information contained elsewhere in this Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this section to comply with the California Consumer Privacy Act of 2018, as amended, California Civil Code §1798.100 et seq., and regulations promulgated thereunder (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this CCPA section.

Information We Collect, Use, and Disclose

We collect Personal Data that is “personal information” as defined in the CCPA and subject to the specific protections of the CCPA. Personal information, however, does not include:

Publicly available information or lawfully obtained, truthful information that is a matter of public concern.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:

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), clinical trial data, or other qualifying research data;
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Personal Information does not include Personal Data collected from California-based employees, job applicants, officers or board members, contractors, medical staff members or similar individuals, or business-to-business personal information.

We have collected the following categories of personal information from consumers within the last twelve (12) months and disclosed for a business purpose with the following categories of third-party recipients:

Category of Personal Information	Examples	Categories of Recipients
Identifiers	Real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, or other similar identifiers	Affiliates Data Analytics Providers Contractors Service Providers Marketing Partners Business Associates Social Media Companies Other third parties where individuals have provided consent or direction or to comply with law or protect our rights
Personal information categories listed in the California Customer Records statute	Name, signature, address, telephone number, bank account number, credit card number, debit card number, or other financial information, medical information or health insurance information (to the extent not excluded from the CCPA)	Affiliates Contractors Service Providers Marketing Partners Business Associates Other third parties where individuals have provided consent or direction or to comply with law or protect our rights
Commercial information	Records of products or services you purchased or considered	Affiliates Contractors Service Providers
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement	Data Analytics Providers Service Providers Social Media Companies
Geolocation data	Physical location	Data Analytics Providers Service Providers
Sensory data	Audio, electronic, visual and similar information (for example video recordings or recordings of calls with us, where permitted by law)	Affiliates Service Providers Contractors Other third parties where individuals have provided consent or direction or to comply with law or protect our rights
Sensitive personal information	Medical information or health insurance information (to the extent not excluded from the CCPA as covered by HIPAA or CMIA), or your account log-in, financial account, debit card, or credit card number in combination with any required security code, password, or credentials allowing access to an account (for example, when making payments through our Website)	Affiliates Contractors Service Providers Other third parties where individuals have provided consent or direction or to comply with law or protect our rights

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you.

For example, from forms you complete or information you submit on our Website.
When you make payments through our Website. We do not store or retain financial account information, though we may receive transaction identifiers and summary information that does not include credit card or bank account numbers.

Indirectly from you.

For example, from observing your actions on our Website and through your browser or device when interacting with our Website.

Affiliates, service providers and business partners.
Third-party information providers, including marketing service providers.
Publicly available sources, such as government or agency records or publicly available websites.

We may use or disclose the personal information we collect for one or more of the following purposes:

As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To communicate with you or otherwise fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request more information about our services or products, we will use that personal information to respond to your inquiry and assist with offering you our services. If you provide your personal information to make a payment or purchase a product, we will use that information to process your order and payment, as well as create, maintain, customize and secure your account.
As needed to carry out our business activities and operations and allow its Service Providers and Contractors to carry out contracted activities.
To provide, maintain, develop and improve our website, products, and services, including to perform analytics and non-personalized advertising activities.
To provide you with customer support, to respond to your inquiries, and to perform audit, quality assurance, and improvement activities, including to investigate and address your concerns and monitor and improve our responses.
To personalize your website experience and to deliver content and product and service offerings relevant to your interests.
To help maintain the safety, rights, security, and integrity of our website, products and services, databases and other technology assets, employees, third parties, members of the public and/or business, including at any physical facilities.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
For branding, marketing and community outreach purposes and events.
To exercise or comply with our legal obligations, rights, and policies, including to provide information to our legal and tax advisors.

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.

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.

Sharing Personal Information

We do not sell any personal information to third parties for monetary or other valuable consideration.

However, in the preceding twelve (12) months, we have allowed certain third-party providers to collect information about consumers directly through the Website for the purpose of analyzing and optimizing our services, allow sharing of Website webpages and blog posts to social media sites, delivering non-personalized ads and content, measuring statistics, and the success of ad campaigns, and detecting and reporting fraud. As a result of this practice, in the last 12 months, we have “shared” the following categories of personal information with service providers, social media companies, and data analytics providers:

Identifiers, such as unique ID and IP address
Internet or other similar network activity, such as log data, browser type, and analytics data
Geolocation data, such as geographic location based on IP address.

We do not sell or share the personal information of consumers we know to be under the age of 16.

Data Retention

As a general matter, we retain your personal information for as long as necessary for our legitimate business interests and/or as needed or permitted for legal reasons. In certain situations, we will delete your information after it is no longer needed to provide a service.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. Below we describe your CCPA rights and explain how to exercise those rights.

Right to Know and Data Portability

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 (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights), 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.
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.

The specific pieces of personal information we collected about you.

Right to Delete

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 (the “right to delete”). Once we receive your request and confirm your identity (see, Exercising Your Rights), we will review your request. We may deny your deletion request, in whole or in part, if compliance would be impossible or involve disproportionate effort for us or if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

Debug products to identify and repair errors that impair existing intended functionality.

Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

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 information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

Comply with a legal obligation.

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these or any other available exception under the CCPA from our records and will direct our service providers to take similar action.

Right to Correct

You have the right to request that any inaccuracies in your personal information be corrected by us (“right to correct”), taking into account the nature of the personal information and the purposes of our processing your personal information.

Opt-Out Rights

You have the right to direct us to not sell or share your personal information at any time (the “right to opt-out”). We do not currently sell any personal information as defined in the CCPA.

If you make a request to receive information through the Website by providing an email address or phone number, you may request to discontinue receiving similar messages in the future. Materials sent to you by email or text message contain information on how to opt-out.

Clicking the “Do Not Sell or Share My Information” link in our Website footer will present you with a form to complete to request to opt out. To opt out, please follow the instructions provided when you click on the “Do Not Sell or Share My Information” link.

The Website may partner with third parties, including Google (Google Analytics), to use cookies, web beacons and other storage technologies to collect or receive information from the Website and elsewhere on the internet. These companies collect information from across the internet and are not controlled or managed by us. You can opt-out of having your browsing data collected by these companies by managing your ads preferences or privacy settings on these companies’ websites. If you wish to opt out of these analytics tracking services, visit these websites at the following links:

Google Analytics, Google Analytics Opt-Out Browser Add-on.

Right to Limit Use or Disclosure of “Sensitive” Personal Information

You have the right to limit our use or disclosure of “sensitive” personal information. However, we process “sensitive” personal information only for the limited purposes specified under the CCPA that do not require a corresponding right to limit our use or disclosure of such information.

Exercising Your Rights

To exercise your rights described above, please submit a request by either:

Mailing us at Emanate Health Medical Group, 1041 W. Badillo St., Suite 102, Covina, CA 91722, Attn: Marketing & Communications Department
Sending an electronic request to Marketing & Communications Department at Chong@EmanateHealth.org
Sending a verbal request to 833.658.3126

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. To designate an authorized agent, you must provide a written, signed letter to us authorizing the agent to act on your behalf.

Your 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.

You may only submit a request to know twice within a 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. To verify your request, you must provide your name, email address, and phone number. If we believe we need further information to verify your request as required by law, we may ask you to provide additional information to us.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact the Marketing & Communications Department at 626.938.7533.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 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 our receipt of your request. 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.

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, 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.