California Consumer Privacy Act

Notice for California Consumers

Last revised January 1, 2024

This notice outlines the rights of California residents under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, collectively referred to as “CCPA.” CCPA mandates that businesses like ours provide specific information to California consumers. While our Privacy Policy comprehensively describes our practices for all members and visitors, this separate notice is intended to ensure compliance with CCPA requirements. The notice consists of four key sections:

1. You Can Opt Out of Our Sharing Your Personal Information. We Do Not Sell Your Personal Information.

CCPA necessitates the disclosure of personal information sharing practices. We may share your personal information, including data related to your interactions with CaduceusLink, with partners for the purpose of promoting CaduceusLink’s services on other platforms. For CaduceusLink members, we may also share your personal information with Microsoft to personalize the ads you encounter while using Microsoft services. Importantly, we do not sell your personal information.

• CaduceusLink members can click here to opt out of sharing.
• Guests can opt out by visiting guest controls.
• In the U.S., we automatically opt you out of sharing upon receiving a Global Privacy Control signal that indicates your preference to opt-out of sharing.

2. Your Rights Under the CCPA

2.1 Requests for Information: If you are not a CaduceusLink member, you can submit your request here. Since we do not sell personal information, we do not offer an opt-out option.

Under CCPA, you have the right to opt out of sharing your personal information with third parties for cross-context behavioral advertising. You can instruct us not to share your personal information, as described in Section 1.

Furthermore, CCPA allows you to limit a business’s use and disclosure of your sensitive personal information to specific purposes defined by law (e.g., providing requested services, fraud prevention, or purposes not involving the derivation of your attributes). We exclusively employ sensitive personal information for these authorized purposes, and thus, an opt-out option is unnecessary.

CCPA mandates that businesses like CaduceusLink must notify you before collecting new categories of personal information or using them for significantly different purposes.

The CCPA prohibits businesses from discriminating against you for exercising your rights under the law. Such discrimination may include refusing services, applying different prices or rates, delivering varying levels or quality of services, or implying that you will receive different goods or services as a result of exercising your rights.

Like all our members, you can update much of your personal information through your CaduceusLink account, including profile details. Additionally, you can request corrections to inaccurate personal information.

Similarly, like all members, you can request the deletion of your personal information by either closing your CaduceusLink account or requesting the removal of specific information about you. We comply with such requests unless exceptions apply, such as when information is essential for completing a transaction or contract, detecting or preventing security incidents, complying with legal obligations, addressing bugs, or safeguarding another consumer’s ability to exercise their free speech or other legally provided rights.

Please visit CaduceusLink’s CCPA Annual Metrics page to access CCPA-mandated metrics for the previous calendar year.

CCPA regulations compel us to confirm whether we possess actual knowledge of selling or sharing the personal information of consumers under 16 years of age. As stipulated in our user agreement, CaduceusLink services are not intended for use by individuals under 16. We neither knowingly offer services to individuals under 16 nor possess knowledge of selling or sharing the personal information of consumers under 16.

2.2 Your Right to Opt Out of Sales

2.3 Your Right to Opt Out of Sharing

2.4 Your Right to Limit the Use of Sensitive Personal Information

2.5 Your Right to Notification

2.6 Nondiscrimination for Exercising Your CCPA Rights

2.7 Your Right to Correct Inaccurate Personal Information

2.8 Your Right to Delete Personal Information

2.9 CaduceusLink Annual CCPA Metrics

2.10 Statement Regarding Selling or Sharing the Personal Information of Consumers Under Age 16

Like all our members, you or your authorized agent can request a copy of your personal information. Under CCPA, you can also request a disclosure of how we have collected, used, and disclosed your personal information over the past 12 months. This includes categories of personal information collected, purposes for collection, sources of information, categories of third parties with whom we shared or disclosed it for business purposes, and our reasons for doing so. It’s important to note that companies engaged in selling personal information, which we do not, are subject to additional disclosure requirements.

3. The CCPA Categories of Personal Information We Collect and the Sources

This section aligns CCPA categories of personal information with their respective sources. Our Privacy Policy comprehensively details the information we collect and its sources. This notice organizes that information around CCPA’s personal information categories.

We utilize and retain this personal information for purposes outlined in Sections 2 and 4.1 of our Privacy Policy. Generally, we retain the types of personal information listed below as long as your account remains active or as needed to provide services.

• CCPA Personal Information Categories and corresponding sources of this info.

1. CCPA Personal Information Category	Sources of this Information
   Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)	The personal information we collect comes from the following sources: Information you provide directly or through your interactions with our Services: This includes information you provide when using our services, as explained in our Privacy Policy. It encompasses data you input directly into CaduceusLink or provide through interactions with our partners. Vendors: We receive information from vendors who assist us in delivering relevant advertisements to our members and assessing the effectiveness of these ads. Information from other CaduceusLink members or customers: We may collect data from other CaduceusLink members or customers as part of our interactions and services.
   Characteristics of protected classifications under California or Federal law (e.g., your gender or age) (“Characteristics of Protected Classifications”)	We gather characteristics of protected classifications from the following sources: Information you provide to us directly: This includes data you actively provide to us, such as when you create an account or engage with our services. It also encompasses inferences we draw from the information you provide. Information from our customers: We may obtain data from our customers as part of our business operations and service delivery.
   Commercial information (e.g., information regarding products or services purchased, obtained, or considered)	We collect commercial information from the following sources: Information you provide directly to us: This includes data you provide when purchasing a Premium service or engaging with us in other direct interactions. Your interactions with our Services: We gather information based on your interactions with our platform and services as described in our Privacy Policy. Information from our partners and customers: We may receive data from our partners and customers as part of our collaborative efforts and service delivery.
   Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, and information regarding your interactions with our Services)	We collect internet and other electronic network information from the following sources: Your interactions with our Services: This includes data we gather from your interactions with our platform and services, as detailed in our Privacy Policy. Your visits to third-party sites: When you visit third-party websites that offer our autofill, follow, or “Apply with CaduceusLink” functionality, we may collect information for fraud prevention and security purposes. Interactions with partners and customers: If you are a member, we may collect data on your interactions with the services offered by our partners and customers who utilize the CaduceusLink Vision Tag or similar technologies.
   Geolocation Data	We collect geolocation data from the following sources: Information you provide to us directly or through your interactions with our Services, as explained in our Privacy Policy: This encompasses data you actively supply to us and information gathered through your interactions with our platform and services, as detailed in our Privacy Policy.
   Professional or Employment-Related Information	We collect professional or employment-related information from the following sources: Information you provide to us directly: This includes data you actively submit to us through your interactions with our platform and services. Information from our customers, partners, or other members: We may obtain data from our customers, partners, or fellow members as part of our collaborative efforts and service delivery. For example, if a connection endorses you, this contributes to the information we gather.
   Inferences	We gather inferences information from the following sources: Information you provide to us directly or through your interactions with our Services: This includes data you actively supply to us and information collected through your engagement with our platform and services. Information from our customers and partners: We may receive data from our customers and partners as part of our business operations and collaborations.
   Personal information described in Cal. Civ. Code §1798.80(e)(such as name, address, telephone number, education, employment history, credit card or debit card number)	We collect personal information from the following sources: Information you provide directly or through your interactions with our Services: This encompasses data you actively provide to us and information gathered through your interactions with our platform and services. Information from our customers or partners: We may obtain data from our customers or collaborative partners as part of our business operations and service delivery.
   Audio, electronic, visual or similar information	We collect audio, electronic, visual, or similar information from the following sources: Information you provide directly or through your interactions with our Services: This includes data you actively provide to us and information gathered through your interactions with our platform and services. Information from our customers or partners: We may obtain data from our customers or collaborative partners as part of our business operations and service delivery.
   Sensitive personal information, which may include:   – Data generated when you communicate on our services (e.g., messages to other members)   – Data used to secure your account (e.g., login information or proof of identification if you are unable to verify your account)   – Data you add to your profile or submit via your settings, which may include information about your race or ethnicity	We collect sensitive personal information from the following source: Information you provide to us directly or through your interactions with our Services: This includes data you actively supply to us and information gathered through your interactions with our platform and services.

   4. The CCPA Categories of Personal Information We “Share”: As described above, CaduceusLink members can opt out of “sharing” by visiting member settings [here](link to member settings), and guests can opt out by using guest controls. We will automatically opt you out of sharing if we receive a Global Privacy Control signal from you that reflects your choice to opt-out of sharing.

   While we do not sell your personal information, we may engage in “sharing” under the CCPA, which broadly defines this term as disclosing personal information for purposes of cross-context behavioral advertising. This includes instances where companies target advertising based on personal information obtained from a consumer’s activity across distinctly-branded websites or services. CaduceusLink’s practices and the categories of data we share are described in Section 1 of our Privacy Policy. We do not share sensitive personal information.

   5. The CCPA Categories of Personal Information We Disclose for a “Business Purpose”:

   5.1 Auditing Interactions: We may disclose personal information to audit interactions and transactions, such as to count or verify the positioning and quality of ad impressions.

   5.2 Security and Integrity: Personal information may be disclosed to secure our Services, detect and prevent security incidents, and investigate violations of our Professional Community Policies or applicable laws.

   5.3 Service Improvements: We may disclose personal information to improve our Services, identify bugs, repair errors, or ensure proper functionality.

   5.4 Service Providers and Other Notified Purposes: Disclosure to service providers and others may occur to perform services specified by a written contract or for notified purposes permitted by the CCPA, such as responding to law enforcement requests.

   5.5 Marketing and Advertising: Personal information may be disclosed to partners, service providers, and related companies for marketing and advertising services, as allowed by the CCPA (e.g., sending communications).

   5.6 Operational Purposes: We may disclose the types of personal information listed in Section 3 of our Privacy Policy to support our own operational purposes in providing our Services to you. Additionally, personal information may be disclosed at your direction, such as when you choose to communicate with other members through our Services.