Adonis Health Inc.™
California Consumer Privacy Act (CCPA)
(DBA: Henry Meds™) (DBA: Henry™)
Last updated: November, 2022
Privacy Statement-California
This PRIVACY NOTICE IS APPLICABLE TO CALIFORNIA RESIDENTS (“consumers” or “you”) ONLY and supplements the information in Adonis Health, Inc.’s general Privacy Statement. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act (“CPRA”), and other California privacy laws. Any terms defined in the CCPA or CRPA have the same meaning when used in this notice.
Information We Collect
We collect 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”).
We have collected the following categories of Personal Information from California consumers since January 1, 2020:
Category
Examples
Collected
Identifiers.
Account Name, Address, Beneficiary Name, Beneficiary Relationship, Client ID Number, Client Reference Number, Contract Number, Date of Birth, Date of Death, Driver’s License Number, Email Address, Emergency Contact Name, Emergency Contact Number, Employee Identification Number, Name, Passport Number, Phone Number, Policy Number, Policy Rating Information
Yes
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A 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. Some personal information included in this category may overlap with other categories
Yes
Characteristics of protected classifications under California or federal law.
Gender, Age, Citizenship Status, Disability, Marital Status
Yes
Commercial information.
FEIN, HH Premium, Home Value, Income Line of Business, Lines of Insurance Purchased, Net worth, Payment Information, Pension Dollar Amounts, Personal Property Records, Policy Count by Product, Policy Number, Property Address, Property Ownership, Vehicle Information
Yes
Biometric information.
Blood Sample, Health Information, Medical Conditions, Medical Information, Urine Sample, Vital Information
Yes
Internet or other similar network activity.
Advertising Recall, App Usage, Browser Type, Chat Transcripts, Cookies, Device, Email Transcripts, HM Drive Usage, Interaction with Website, IP Address, Location, My Account Activity Log, Web Message Transcripts, Web Site Usage
Yes
Geolocation data.
Direction of Travel, Latitude, Longitude, Rate of Acceleration, Rate of Speed, Survey Location
Yes
Sensory data.
Audio Recordings of Historic Transfer Requests, Audio Recordings of Medical Interviews, Audio Recordings of Phone Calls
Yes
Professional or employment-related information.
Annual Salary, Bank Account Information, Educator vs Non Educator, Employer Name, Employment Location, Employment Status, Hire Date, Household Income, Job Title, Length of Service, Number of years working in Education, Occupation, Occupation Code, Percentage of Increase, Resume, Tenure, Termination Date, Transfer Date, Work History
Yes
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
No
Inferences drawn from other personal information.
Paperless Preferences, Login Email, Security Preferences, Address Preferences, Consumer Preferences, Attitudes, Psychographic data, Survey Comments, Investment Strategy, E-delivery Preferences
Yes
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
- Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them and from activity on our website.
- From third-parties that interact with us in connection with the services we perform (such as consumer reports that provide us information related to driving and claim history).
Personal Information does NOT include:
Information that is lawfully made available from federal, state, or local government records (“Publicly Available Information”).
De-identified or aggregate consumer information (as such terms are defined in the CCPA).
Information excluded from the CCPA’s scope, 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;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Sensitive personal information means Information that reveals:
- Your social security, driver’s license, or passport number.
- Your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to the account.
- Your precise geolocation.
- Your racial or ethnic origin, religious or philosophical beliefs, or union membership.
- Contents of your mail, email, and text messages unless Henry Meds is the intended recipient of your communication.
- Your genetic data.
Unless the information is publicly available, sensitive personal information also includes:
Use of Personal Information
We may use or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided.
- To issue and service your policy and to offer you other insurance or financial products.
- To provide you with information, products or services.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As reasonably necessary and proportionate to protect the rights, property or safety of us, our clients or others.
- To respond to regulatory and/or law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To third party service providers who perform marketing or other services on our behalf
- To our affiliates and subsidiaries.
- As otherwise required or permitted by law
We will not collect additional categories of Personal Information from those identified above or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your Personal Information to a third party for a business purpose.
In the preceding twelve (12) months, we have disclosed the following categories of personal information to third parties for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories. Category C: Protected classification characteristics under California or federal law. Category D: Commercial Information. Category H: Sensory Data Category I: Professional or employment-related information. Category K: Inferences drawn from Personal Information
Category B: California Customer Records personal information categories. Category C: Protected classification characteristics under California or federal law. Category D: Commercial Information. Category H: Sensory Data Category I: Professional or employment-related information. Category K: Inferences drawn from Personal Information
We disclose your Personal Information for a business purpose to the following categories of third parties:
Selling Personal Information
We do not sell your personal Information to anyone.
Your Rights and Choices
The CCPA provides California 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 we disclose certain information to you about our collection and use of your Personal Information collected on or after January 1, 2020. Once we receive and verify your request, we will disclose to you any of the following in accordance with your request:
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 have collected about you (also called a data portability request) – but only if specifically requested by you.
If we have sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
Correction Requests
You have the right to request that we correct personal information about you. After we receive and verify your request, we will evaluate the requested correction against information we receive from other sources. We will disclose to you the actions taken pursuant to your request.
Opting Out of Use and Disclosure of Sensitive Personal Information
You have the right to request that we limit the use and disclosure of your Sensitive Personal Information, subject to certain exceptions. We use your Sensitive Personal Information to perform the services reasonably expected. We may also use your Sensitive Personal Information to ensure the security and integrity of your Personal Information, conduct non-personalized advertising, perform services on behalf of our business, and undertake activities to improve or enhance our services.
Deletion Request Rights
You have the right to request that we delete (and direct our Service Providers to delete) your Personal Information from our records. Subject to the exceptions set forth below, we will comply with your deletion request and will direct our Service Providers to delete your Personal Information.
Deletion Request Exceptions
We (or our Service Providers) do not have to comply with your deletion request with regard to your Personal Information that we (or our Service Provider) maintain for any of the following reasons:
- 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, 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 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.
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 either:
Only you or a person registered with the California Secretary of State for which 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:
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. Making a verifiable consumer request does not require you to create an account with us. Personal Information provided will only be used by us to verify the requestor’s identity and/or authority to make the request.
Response Timing and Format
We 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. 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 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 usable 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 provide you with a cost estimate and rationale before completing your request. We also reserve the right to deny excessive, repetitive, or manifestly unfounded requests.
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.
Changes to Our Privacy Notice
We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will notify you by email or through a notice on our website homepage.
Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your options and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
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