This Supplemental U.S. Privacy Statement (“U.S. Statement”) supplements our Privacy Statement and addresses legal obligations and rights arising from U.S. state privacy laws, such as those in California and Virginia. This Supplemental U.S. Privacy Statement only applies to residents of states with comprehensive privacy laws. If you are a consumer residing in a U.S. state with a comprehensive consumer health data privacy law, such as the state of Washington, please review our Consumer Health Data Privacy Policy for our privacy practices related to your consumer health data.
“Personal Information” is any information—as electronically or otherwise recorded—that can be used to identify a person or that we can link to or associate with a specific individual. Personal Information may include information considered sensitive in some jurisdictions, such as biometric information, genetic information, health information, financial account information, specific geolocation, ethnic or racial origin, information concerning your sex life or your sexual orientation, social security number, driver’s license, state identification card, passport number, and other similar information. Some of the Personal Information we collect may be considered “Sensitive Personal Information.” For more information about how we collect, disclose, and share your Personal Information, please see the sections below that represent your relationship with MDD Options. Data that could be considered Sensitive Personal Information is noted in purple below.
We will process any Personal Information we collect in accordance with applicable law and as described in this Statement (unless, as explained above, a separate policy or notice governs). In some circumstances, if you do not provide us with your Personal Information, certain Products and Services may be unavailable to you.
This U.S. Statement provides the information required under applicable U.S. state laws and applies to both MDD Options’ online and offline activities relative to our processing of your Personal Information. This U.S. Statement and the relevant U.S. state laws do not apply to information that has been de-identified or aggregated. Some of the Personal Information that we collect, use, and disclose may, pursuant to provisions in the relevant laws, be exempt because it is regulated by other federal and state laws that apply to us.
FOR CONSUMERS
(Including those interested in our distributed products or services, patients, caregivers, facility visitors, etc.): The following provides you with a notice of the Personal Information we may collect from or about you, including Sensitive Personal Information, as well as information about how we will use it and the manner in which it will be processed and information about the categories of third parties with whom it is shared.
Some of this will depend on the nature of our interaction with you but can include the following with respect to Personal Information categories that we may have collected in the preceding twelve (12) months:
Contact Information
Category and Sources of Personal Information
We may collect this type of information from:
- You
- Third parties, such as ad delivery companies who place cookies containing advertising IDs on your devices for us
- Healthcare providers
- Health insurance companies (health plans) and other payors
- Authorized/legal representatives, family members, and caregivers
- Consumer reporting agencies and other third parties who verify the information you provide
- Third parties who help us maintain the accuracy of our data and data aggregators that help us complete and enhance our records
- Third parties who provide digital marketing and analytics services for us using cookies and similar technologies that contain a unique identifier, such as an advertising ID
Representative Data Elements
Data elements in this category include:
- Full name, or unique pseudonym
- Honorifics and titles, preferred form of address Postal address
- Email address
- Phone number
- Fax number
- Contact information for related persons, such as authorized users of your account
- Company ID number (e.g., customer number, account number, subscription number)
- System identifiers (e.g., usernames or online credentials)
Purpose for Collecting and Sharing the Personal Information
We may use this type of information:
- To identify you and communicate with you
- To send transactional messages such as confirmations or responses for assistance
- To send marketing communications, surveys, and invitations
- To personalize our communications and provide customer service
- To administer and manage events
- To identify you or your device, including to associate you with different devices that you may use
- For record-keeping and reporting, including for data matching
- For metrics and analytics
- To track your use of distributed products, services, websites, including for ad delivery and personalization
- To troubleshoot product issues
- To determine and verify program, product, and service eligibility and coverage
- To enroll you in our programs and provide our distributed products and services to you
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations
- To analyze and better understand your needs, preferences, and interests, as well as those of other consumers
- To conduct internal business analysis and market research
- Advertising and product promotion, including to contact you regarding programs, distributed products, services, and topics that may be of interest or useful
- To engage in joint marketing initiatives
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- To provide access to, monitor, and secure our facilities, equipment, and other property
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To comply with legal and regulatory obligations
- To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, products, services, and advertisements for such purposes
- To evaluate a potential employment or contractor relationship with you
- To perform background checks and verify past employment, educational history, and professional standing and qualifications
- To evaluate, determine, and arrange compensation, payroll, and benefits
- To assess your fitness for work
- To contact you regarding your application and potential employment or contractor relationship with us
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
- We may disclose this type of information to our Affiliates and Service Providers and to:
- Service Providers, including to social media companies such as Facebook, which use the data only to identify which of our customers use their platforms so that we can deliver ads to you on the platform
- Service providers such as companies who help manage and coordinate events
- Service providers, including those who help administer our call center hosting platforms and phone systems
- Service providers, including those who host websites, and companies who assist with our information technology and security programs
- Third parties who deliver our communications, such as the postal service and couriers
- Other third parties (including government agencies) as required by law, such as pursuant to legally binding subpoenas, court orders, and similar instruments
- Service providers, including companies who assist with our information technology and security programs
- Third party advertising network companies, when you opt-in via our cookie banner to have such Personal Information disclosed for advertising (see Third Party Advertising below)
- Third parties who assist with fraud prevention, detection, and mitigation
- Healthcare providers (including specialty pharmacies)
- Health insurance companies (health plans) and other payors
- Authorized/legal representatives, family members, and caregivers
- Third parties with whom we have joint marketing and similar arrangements
- Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our distributed products and services
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
- Other third parties as necessary to complete transactions and provide our distributed products/services, including delivery companies, agents, and manufacturers
- Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
- Consumer reporting agencies
- Our lawyers, accountants, and consultants
- Legal and regulatory bodies and other third parties as required
Other Unique Identifiers
Category and Sources of Personal Information
We may collect this type of information from:
- You
- Healthcare providers
- Health insurance companies (health plans) and other payors
- Authorized/legal representatives, family members, and caregivers
- Third parties, such as ad delivery companies who place cookies containing advertising IDs on your devices for us
- Consumer reporting agencies and other third parties who verify the information you provide
- Third parties who help us maintain the accuracy of our data and data aggregators that help us complete and enhance our records
- Third parties who provide digital marketing and analytics services for us using cookies and similar technologies that contain a unique identifier, such as an advertising ID
- Service Providers who provide benefit verification, program enrollment, and product fulfillment services in connection with our distributed products and services
Representative Data Elements
Data elements in this category include:
- Government issued identifiers, such as Social Security Numbers, Birth Certificate Number, Driver’s or Operator’s license number, Passport Number, Alien Number or I-94 Number
- Device identifier
- Advertising ID
- Customer number
- IP address
- Service Request ID number
- Cookie ID
- Online User ID
Purpose for Collecting and Sharing the Personal Information
We may use this type of information:
- To identify you and communicate with you
- To send transactional messages such as confirmations or responses for assistance
- To send marketing communications, surveys and invitations
- To personalize our communications and provide customer service
- To administer and manage events
- To identify you or your device, including to associate you with different devices that you may use
- For record-keeping and reporting, including for data matching
- For metrics and analytics
- To track your use of distributed products, services, websites, including for ad delivery and personalization
- To troubleshoot product issues
- To determine and verify program, product, and service eligibility and coverage
- To enroll you in our programs and provide our distributed products and services to you
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To procure vendor/supplier distributed products and services, including to manage and satisfy related vendor/supplier contractual obligations
- To analyze and better understand your needs, preferences, and interests, as well as those of other consumers
- To conduct internal business analysis and market research
- Advertising and product promotion, including to contact you regarding programs, distributed products, services, and topics that may be of interest or useful
- To engage in joint marketing initiatives
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- To provide access to, monitor, and secure our facilities, equipment, and other property
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To comply with legal and regulatory obligations
- To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, distributed products, services, and advertisements for such purposes
- To evaluate a potential employment or contractor relationship with you
- To perform background checks and verify past employment, educational history, and professional standing and qualifications
- To evaluate, determine, and arrange compensation, payroll, and benefits To assess your fitness for work
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Service Providers, including to social media companies such as Facebook which use the data only to identify which of our customers use their platforms so that we can deliver ads to you on the platform
- Service providers such as companies who help manage and coordinate events
- Service providers, including those who help administer our call center hosting platforms and phone systems
- Third parties who deliver our communications, such as the postal service and couriers
- Other third parties (including government agencies) as required by law, such as pursuant to legally binding subpoenas, court orders, and similar instruments
- Service providers, including those who host websites, and companies who assist with our information technology and security programs
- Third party advertising network companies
- Third parties who assist with fraud prevention, detection and mitigation Healthcare providers
- Health insurance companies (health plans) and other payors
- Authorized/legal representatives, family members, and caregivers
- Third parties with whom we have joint marketing and similar arrangements
- Third parties who provide program enrollment, and product fulfillment services in connection with our distributed products and services
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
- Other third parties as necessary to complete transactions and provide our distributed products/services, including delivery companies, agents, and manufacturers
- Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
- Consumer reporting agencies
- Our lawyers, accountants, and consultants
- Legal and regulatory bodies and other third parties as required by law
Characteristics or Description of Individuals
Category and Sources of Personal Information
We may collect this type of information from:
- You
- Healthcare providers
- Health insurance companies (health plans) and other payors
- Authorized/legal representatives, family members, and caregivers
- Third parties who provide program enrollment, and product fulfillment services in connection with our distributed products and services
- Third parties that provide access to information you make publicly available, such as social media platforms
- Third parties who provide us with supplemental consumer data or data analytics and market research services, such as data aggregators
Representative Data Elements
- Data elements in this category include:
- Height
- Weight
- Hair & eye color
- Age/Date of Birth
- Gender
- Race and Ethnicity
- Citizenship Status
- Religion
- Information concerning sexuality or sex life
- Disability
- Personal characteristics and preferences, marital and family status , shopping/ product preferences, languages spoken
- Other similar data elements
Purpose for Collecting and Sharing the Personal Information
We may use this type of information:
- To help manage emergency incidents that occur on the premises or involve company property
- To determine and verify program, distributed product, and service eligibility and coverage
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To analyze and better understand your needs, preferences, and interests, as well as those of other consumers
- To conduct internal business analysis and market research
- To comply with legal and regulatory obligations
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Emergency personnel
- Service Providers which use the data only to assist in incident management and reporting
- Service providers, including those who help administer our call center hosting platforms and phone systems
- Service providers, including those who host websites, and companies who assist with our information technology and security programs
- Healthcare providers
- Health insurance companies (health plans) and other payors
- Authorized/legal representatives, family members, and caregivers
- Third parties with whom we have joint marketing and similar arrangements
- Third parties who provide program enrollment and product fulfillment services in connection with our distributed products and services
- Other third parties as necessary to complete transactions and provide our distributed products/services
- Our lawyers, accountants, and consultants
- Legal and regulatory bodies and other third parties as required by law
Commercial Information
Category and Sources of Personal Information
We may collect this type of information from:
- You
- Third parties that provide access to information you make publicly available, such as social media
- Third parties that provide information that helps us understand our customers, including data aggregators and public records providers
- We may also infer information about you based on information that you have given us and your past interactions with us and other companies
- Consumer reporting agencies and third parties who assist with fraud prevention, detection, and mitigation
- Payment processors and other financial institutions
- Other third parties who facilitate, process, and complete transactions for us, such as resellers, sales agents, and program partners
Representative Data Elements
Data elements in this category include:
- Propensity scores obtained from third parties, such as likelihood that you may be interested in certain purchases or may be experiencing life events
- Products or services you have purchased
- Records of distributed products or services purchased, obtained, reviewed, or considered
- Records of program enrollment and activity
Purpose for Collecting and Sharing the Personal Information
We may use this type of information:
- To better understand you and to understand our customers generally
- To design distributed products, services and programs including subscription and special offer programs
- To identify prospective customers
- For internal business purposes, such as quality control, training and analytics To enroll you in our programs and provide our distributed products and services to you
- To fulfill our business relationship with you, including processing payments, issuing refunds, billing support, and collections
- For recordkeeping and compliance, including dispute resolution
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To communicate with you regarding our programs, distributed products, and services
- To procure vendor/supplier distributed products and services, including to manage and satisfy related vendor/supplier contractual obligations
- To analyze and better understand your needs, preferences, and interests, as well as those of other consumers
- To conduct internal business analysis and market research To engage in joint marketing initiatives
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To comply with legal and regulatory obligations
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Third parties with whom we have joint marketing and similar arrangements Service Providers, including companies who assist us in program administration
- Our lawyers, accountants, and consultants
- Third parties with whom we have joint marketing and similar arrangements
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
- Other third parties as necessary to complete transactions and provide our distributed products/services
- Third party network advertising partners
- Consumer reporting agencies
- Legal and regulatory bodies and other third parties as required by law
Transaction and Interaction Information
Category and Sources of Personal Information We collect this type of information from:
- You
- Third parties that provide access to information you make publicly available, such as social media
- Automatically, such as when you interact with our websites or mobile apps
Representative Data Elements
Data elements in this category include:
- Personal characteristics and preferences, such as your age range, marital and family status , languages spoken
- Subscription program data
- Household demographic data
- Data from social media profiles, such as Facebook, X, LinkedIn, and similar platforms
- Education information
- Professional information
- Hobbies and interests
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- To fulfill our business relationship with you, including customer service
- For recordkeeping and compliance, including dispute resolution
- For internal business purposes, such as finance, quality control, training, reporting, and analytics
- For risk management, fraud prevention and similar purposes
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Third parties with whom we have joint marketing and similar arrangements
- Service providers, including third parties as needed to complete the transaction, including delivery companies, agents, and manufacturers
- Our lawyers, accountants, and consultants
- Customers, in connection with their audits of our business
- Other third parties as required by law
- Inferred and Derived Information
Category and Sources of Personal Information
We create inferred and derived data elements by analyzing our relationship and transactional information. We draw inferences from the information we collect from and about you, such as your preferences, characteristics, attributes, and abilities.
We also may collect this type of information from:
- Service Providers
- Third parties with whom we have joint business agreements for marketing and development and similar agreements
- Third party network advertising partners
Representative Data Elements
Data elements in this category include:
- Propensities, attributes and/or scores generated by internal analytics programs and used for marketing
- Propensities, attributes and/or scores generated by internal analytics programs and used for information security and fraud purposes
- Preferred language
- Inferences reflecting a consumer’s wellness, health, preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, or other inferred data
Purpose for Collecting and Sharing the Personal Information
We combine inferred data with other relationship information and use this type of information:
- To better understand you and to understand our customers generally
- To design services and programs that interest our customers, including subscription programs
- To identify prospective customers
- For internal business purposes, such as quality control, training, and analytics
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To analyze and better understand your needs, preferences, and interests, as well as those of other consumers
- For advertising and product promotion, including to contact you regarding programs, distributed products, services, and topics that may be of interest or useful
- To engage in joint marketing initiatives
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- To comply with legal and regulatory obligations
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and to:
- Service providers, including those who analyze data on our behalf and who help execute programs
- Our lawyers, accountants, and consultants
- Third parties with whom we have joint marketing and similar arrangements
- Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
- Legal and regulatory bodies and other third parties as required by law
Internet and Online/Electronic Technical Information
Category and Sources of Personal Information
We collect this type of information from:
- You and from your computer or devices when you interact with our platforms, websites and applications; for example, when you visit our websites, our server logs record your IP address and other information
- Automatically, via technologies such as cookies, web beacons, when you visit our website or other websites
- Third parties, including computer security services and advertising partners
- We also associate information with you using unique identifiers collected from your devices or browsers
- Third parties who provide website and online security services
Representative Data Elements
Data elements in this category include:
- IP Address
- MAC Address, SSIDs or other device identifiers or persistent identifiers
- Online user ID
- Password
- Device characteristics (such as browser information)
- Web Server Logs
- Application Logs
- Browsing and search history
- Viewing Data (site and app usage)
- First Party Cookies
- Third Party Cookies
- Web beacons, clear gifs and pixel tags
- Internet service provider
- Referring/exiting URL Request/response date and time
- Clickstream data
- Ads and web pages viewed
- Time spent on a web page or mobile app
- Other information regarding your interactions with our websites, applications, emails, and advertisements
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- For system administration, technology management, including optimizing our websites and applications
- For information security and cybersecurity purposes, including detecting threats
- For recordkeeping, including logs and records that are maintained as part of Transaction Information
- For online targeting and advertising purposes
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To conduct internal business analysis and market research
- To engage in joint marketing initiatives
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To comply with legal and regulatory obligations
- To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, distributed products, services, and advertisements for such purposes
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and to:
- Service providers including companies who assist with our information technology and security programs, including companies such as network security services who retain information on malware threats detected
- Service providers who assist with fraud prevention, detection, and mitigation Third party advertising network companies
- Our lawyers, accountants, and consultants
- Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
- Legal and regulatory bodies and other third parties as required by law
Audio Visual Information
Category and Sources of Personal Information
We collect this type of information from:
- You
- Automatically, such as when we record calls to our call center and use video cameras in our facilities
- Companies conducting research such as market research companies
- Third parties that provide access to information you make publicly available, such as social media
Representative Data Elements
Data elements in this category include:
- Photographs
- Video images
- Video recordings
- Call center recordings and call monitoring records
- Voicemails
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- For internal business purposes, such as call recordings used for training, coaching or quality control
- For relationship purposes, such as use of photos and videos for social media purposes
- For premises security purposes and loss prevention
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Service providers, including companies who assist with our information technology and security programs, and our loss prevention programs
- Service providers, including companies who conduct market research on our behalf Our lawyers, accountants, and consultants
- Other third parties as required by law
Financial Information
Category and Sources of Personal Information
We collect this type of information from:
- You
- Payment processors and other financial institutions Healthcare providers
- Health insurance companies (health plans) and other payors
- Authorized/legal representatives, family members, and caregivers
- Third parties who provide program enrollment and product fulfillment services in connection with our distributed products and services
- Third parties who assist with fraud prevention, detection, and mitigation
Representative Data Elements
Data elements in this category include:
- Bank account number and details
- Payment card information
- Debit or credit card number and details
- Payment and reimbursement amounts
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- To fulfill our business relationship with you, including processing payments, issuing refunds and collections
- For recordkeeping and compliance, including dispute resolution
- For internal business purposes, such as finance, audits, training, reporting and analytics
- For risk management, fraud prevention and similar purposes
- To determine and verify program, product, and service eligibility and coverage
- To enroll you in our programs and provide our distributed products and services to you
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To issue invoices and collect payments
- Reimburse customers, satisfy warranty obligations, and fulfill payment obligations
- To procure vendor/supplier distributed products and services, including to manage and satisfy related vendor/supplier contractual obligations
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To comply with legal and regulatory obligations
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and to:
- Service providers, including payment processors, financial institutions and others as needed to complete the transactions and for authentication, security, and fraud prevention
- Our lawyers, accountants, and consultants
- Customers, in connection with their audits of our related business
- Health insurance companies (health plans) and other payors
- Authorized/legal representatives, family members, and caregivers
- Third parties who provide program enrollment, and product fulfillment services in connection with our distributed products and services
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
- Other third parties as necessary to complete transactions and provide our distributed products/services
- Consumer reporting agencies
- Legal and regulatory bodies and other third parties as required by law
Health Information
Category and Sources of Personal Information
We collect this type of information from:
- You
- Healthcare providers
- Health insurance companies
- Authorized/legal representatives, family members, and caregivers
- Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our distributed products and services
- We may also infer health information about you based on other information, including lifestyle factors.
Representative Data Elements
Data elements in this category include:
- Information about physical or mental health, disease state, medical history or medical treatment or diagnosis, medicines taken
- A Name/Contact of a patient’s healthcare providers
- General disease or product interest
- Health insurance company Insurance account number
- Information on payment for healthcare services (EOB forms, HSA statements, claims data, claims assistance records)
- Health plan beneficiary names/numbers
- Information needed to accommodate disabilities
- Information about workplace accidents and occupational safety
- Medical record information, such as medical diagnosis, disease information, and treatment history
- Health values and sensor readings data, such as steps taken, blood glucose levels, heart rate, and blood pressure
- Drug allergies
- Prescriptions and dosing
- Medical appointment dates
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- To determine and verify program, distributed product, and service eligibility and coverage
- To enroll you in our programs and provide our distributed products and services to you
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To procure vendor/supplier distributed products and services, including to manage and satisfy related vendor/supplier contractual obligations
- To analyze and better understand your needs, preferences, and interests, as well as those of other consumers
- To conduct internal business analysis and market research
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To comply with legal and regulatory obligations
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Healthcare providers
- Health insurance companies (health plans), other payors and others as needed to provide the contemplated services or transactions involving the data, such as for processing health care payments
- Our lawyers, accountants, and consultants
- Other third parties as permitted by HIPAA and/or CMIA for treatment, payment, and authorization
- Authorized/legal representatives, family members, and caregivers
- Third parties who provide program enrollment, and product fulfillment services in connection with our distributed products and services
- Other third parties as necessary to complete transactions and provide our distributed products/services Legal and regulatory bodies and other third parties as required by law
Electronic and Sensor Data
Category and Sources of Personal Information
We collect this type of information automatically when you use our internet-enabled distributed products such as mobile apps and connected devices from:
- You
- When you contact or visit us (automatically), such as when we record calls to our call center or use video cameras in our facilities
- Your mobile devices and other internet-connected devices and applications (automatically)
- Third parties that provide access to information you make publicly available, such as social media platforms
Representative Data Elements
Data elements in this category include:
- Smart device records
- Health values and sensor readings data, such as steps taken, movement information, data collected by our mobile apps, blood glucose levels, heart rate, and blood pressure
- Recording of a customer service call
- Recording from a video camera in our facilities
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- To enable product functionality
- For internal business purposes, such product development, security, and quality control
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To analyze and better understand your needs, preferences, and interests, as well as those of other consumers
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To provide access to, monitor, and secure our facilities, equipment, and other property
- To comply with legal and regulatory obligations
- To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, distributed products, services, and advertisements for such purposes
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
- We may disclose this type of information to our Affiliates and Service Providers and to:
- Service providers, including companies who host our data, assist with our information technology and security programs, including network security services and cybersecurity
- Service providers, including companies who assist with fraud prevention, detection, and mitigation
- Third party network advertising partners
- Our lawyers, accountants, and consultants
- Healthcare providers, health insurance companies (health plans), other payors and others as needed to provide the contemplated services or transactions involving the data, such as for processing health care payments
- Authorized/legal representatives, family members, and caregivers
- Third parties who provide program enrollment, and product fulfillment services in connection with our distributed products and services
- Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
- Third parties who assist with our information technology and security programs Third parties who assist with fraud prevention, detection, and mitigation
- Other third parties as necessary to complete transactions and provide our distributed products/services
- Other third parties as required by law
Geolocation Data
Category and Sources of Personal Information
- We may collect this type of information automatically from your mobile device and computer when you visit or interact with our websites, applications, and online platforms.
Representative Data Elements
Data elements in this category include:
- Precise location data
- Geofencing data
Purpose for Collecting and Sharing the Personal Information
We may use this type of information:
- To provide the information, distributed products or services requested
- For information security and fraud prevention
- For our everyday business purposes
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To conduct internal business analysis and market research
- For advertising and product promotion, including to contact you regarding programs, distributed products, services, and topics that may be of interest or useful
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- To monitor, investigate, and enforce compliance with our policies, distributed product/service terms and conditions, and legal and regulatory requirements
- To comply with legal and regulatory obligations
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Third parties who assist with our information technology and security programs
- Third parties who assist with fraud prevention, detection, and mitigation
- Our lawyers, accountants, and consultants
- Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
- Legal and regulatory bodies and other third parties as required by law
FOR CALIFORNIA PROFESSIONALS.
The following provides detail for residents of California who interact with us in a professional capacity, such as (i) health care providers and their staff, and (ii) employees of companies with whom we conduct business, including employees of service providers, with respect to the category of Personal Information collected, the source of that information, the purposes for collection and sharing/disclosure, and the categories of third parties to whom the category of Personal Information is shared.
Contact Information
Category and Sources of Personal Information
We may collect this type of information from:
- You
- Consumer reporting agencies and other third parties who verify the information you provide
- Third parties who provide us with supplemental consumer data or data analytics and market research services, such as data aggregators
Representative Data Elements
Data elements in this category include:
- Full name, or unique pseudonym
- Honorifics and titles, preferred form of address
- Postal address
- Email address
- Phone number
- Fax number
- Contact information for related persons, such as authorized users of your account
- Company ID number (e.g., customer number, account number, subscription number)
- System identifiers (e.g., usernames or online credentials)
Purpose for Collecting and Sharing the Personal Information
We may use this type of information:
- To identify you and communicate with you
- To send transactional messages such as confirmations or responses for assistance
- To send marketing communications, surveys, and invitations
- To personalize our communications and provide customer service
- To administer and manage events
- To identify you or your device, including to associate you with different devices that you may use
- For record-keeping and reporting, including for data matching
- For metrics and analytics
- To procure vendor/supplier distributed products and services, including to manage and satisfy related vendor/supplier contractual obligations
- To conduct internal business analysis and market research
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- To provide access to, monitor, and secure our facilities, equipment, and other property
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To comply with legal and regulatory obligations
- To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, distributed products, services, and advertisements for such purposes
- To evaluate a potential employment or contractor relationship with you
- To perform background checks and verify past employment, educational history, and professional standing and qualifications
- To evaluate, determine, and arrange compensation, payroll, and benefits
- To assess your fitness for work
- To contact you regarding your application and potential employment or contractor relationship with us
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and to:
- Service providers such as companies who help manage and coordinate events
- Service providers, including those who help administer our call center hosting platforms and phone systems
- Service providers, including those who host websites, and companies who assist with our information technology and security programs
- Third parties who deliver our communications, such as the postal service and couriers
- Other third parties (including government agencies) as required by law, such as pursuant to legally binding subpoenas, court orders, and similar instruments
- Service providers, including companies who assist with our information technology and security programs
- Third party advertising network companies, when you opt-in via our cookie banner to have such Personal Information disclosed for advertising (see Third Party Advertising below)
- Third parties who assist with fraud prevention, detection, and mitigation
- Healthcare providers (including specialty pharmacies)
- Health insurance companies (health plans) and other payors Authorized/legal representatives, family members, and caregivers
- Third parties with whom we have joint marketing and similar arrangements
- Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our distributed products and services
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
- Other third parties as necessary to complete transactions and provide our distributed products/services, including delivery companies, agents, and manufacturers
- Service Providers who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
- Consumer reporting agencies
- Our lawyers, accountants, and consultants
- Legal and regulatory bodies and other third parties as required by law
Other Unique Identifiers
Category and Sources of Personal Information
We may collect this type of information from:
- You
- Consumer reporting agencies and other third parties who verify the information you provide
- Third parties who provide us with supplemental consumer data or data analytics and market research services, such as data aggregators
Representative Data Elements
Data elements in this category include:
- Government issued identifiers, such as Social Security Numbers, Birth Certificate Number, Driver’s or Operator’s license number, Passport Number, Alien Number or I-94 Number
- Device identifier
- Advertising ID
- Customer number
- IP address
- Service Request ID number
- Cookie ID
- Online User ID
Purpose for Collecting and Sharing the Personal Information
- We may use this type of information:
- To identify you and communicate with you
- To send transactional messages such as confirmations or responses for assistance
- To send marketing communications, surveys, and invitations
- To personalize our communications and provide customer service
- To administer and manage events
- To identify you or your device, including to associate you with different devices that you may use
- For record-keeping and reporting, including for data matching
- For metrics and analytics
- To procure vendor/supplier distributed products and services, including to manage and satisfy related vendor/supplier contractual obligations
- To conduct internal business analysis and market research
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- To provide access to, monitor, and secure our facilities, equipment, and other property
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To comply with legal and regulatory obligations
- To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, distributed products, services, and advertisements for such purposes
- To evaluate a potential employment or contractor relationship with you
- To perform background checks and verify past employment, educational history, and professional standing and qualifications
- To evaluate, determine, and arrange compensation, payroll, and benefits
- To assess your fitness for work
- To contact you regarding your application and potential employment or contractor relationship with us
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and to:
- Service providers such as companies who help manage and coordinate events
- Service providers, including those who help administer our call center hosting platforms and phone systems
- Service providers, including those who host websites, and companies who assist with our information technology and security programs
- Third parties who deliver our communications, such as the postal service and couriers
- Other third parties (including government agencies) as required by law, such as pursuant to legally binding subpoenas, court orders, and similar instruments
- Service providers, including companies who assist with our information technology and security programs
- Third party advertising network companies, when you opt-in via our cookie banner to have such Personal Information disclosed for advertising (see Third Party Advertising below)
- Third parties who assist with fraud prevention, detection, and mitigation Healthcare providers (including specialty pharmacies)
- Health insurance companies (health plans) and other payors Authorized/legal representatives, family members, and caregivers
- Third parties with whom we have joint marketing and similar arrangements
- Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our distributed products and services
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
- Other third parties as necessary to complete transactions and provide our distributed products/services, including delivery companies, agents, and manufacturers
- Service Providers who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
- Consumer reporting agencies
- Our lawyers, accountants, and consultants
- Legal and regulatory bodies and other third parties as required by law
Characteristics or Description of Individuals
Category and Sources of Personal Information
We may collect this type of information from:
- You
- Third parties that provide access to information you make publicly available, such as social media platforms
- Third parties who provide us with supplemental consumer data or data analytics and market research services, such as data aggregators
Representative Data Elements
Data elements in this category include:
- Height
- Weight
- Hair & eye color
- Age/Date of Birth
- Gender
- Race and Ethnicity
- Citizenship Status
- Religion
- Information concerning sexuality or sex life
- Disability
- Personal characteristics and preferences, marital and family status , shopping/ product preferences, languages spoken
- Other similar data elements
Purpose for Collecting and Sharing the Personal Information
We may use this type of information:
- If you visit our physical site, to help manage emergency incidents that occur on the premises or involve company property
- To determine and verify program, product, and service eligibility and coverage
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To analyze and better understand your needs, preferences, and interests, as well as those of other consumers
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To conduct internal business analysis and market research
- To comply with legal and regulatory obligations
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Emergency personnel
- Service Providers which use the data only to assist in incident management and reporting
- Service providers, including those who help administer our call center hosting platforms and phone systems
- Service providers, including those who host websites, and companies who assist with our information technology and security programs
- Third Party Advertising companies (See Third Party Advertising below)
- Third parties with whom we have joint marketing and similar arrangements
- Other third parties as necessary to complete transactions and provide our distributed products/services Our lawyers, accountants, and consultants
- Legal and regulatory bodies and other third parties as required by law
Commercial Information
Category and Sources of Personal Information
We may collect this type of information from:
- You
- Third parties that provide access to information you make publicly available, such as social media
- Third parties that provide information that helps us understand our customers, including data aggregators and public records providers
- We may also infer information about you based on information that you have given us and your past interactions with us and other companies
- Consumer reporting agencies and third parties who assist with fraud prevention, detection, and mitigation
- Payment processors and other financial institutions
- Other third parties who facilitate, process, and complete transactions for us, such as resellers, sales agents, and program partners
Representative Data Elements
Data elements in this category include:
- Propensity scores obtained from third parties, such as likelihood that you may be interested in certain purchases or may be experiencing life events
- Products or services you have purchased
- Records of distributed products or services purchased, obtained, reviewed, or considered
- Records of program enrollment and activity
Purpose for Collecting and Sharing the Personal Information
We may use this type of information:
- To better understand you and to understand our customers generally
- To design distributed products, services and programs including subscription and special offer programs
- To identify prospective customers
- For internal business purposes, such as quality control, training and analytics To enroll you in our programs and provide our distributed products and services to you
- To fulfill our business relationship with you, including processing payments, issuing refunds, billing support, and collections
- For recordkeeping and compliance, including dispute resolution
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To communicate with you regarding our programs, distributed products, and services
- To procure vendor/supplier distributed products and services, including to manage and satisfy related vendor/supplier contractual obligations
- To analyze and better understand your needs, preferences, and interests, as well as those of other consumers
- To conduct internal business analysis and market research To engage in joint marketing initiatives
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To comply with legal and regulatory obligations
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Third parties with whom we have joint marketing and similar arrangements Service Providers, including companies who assist us in program administration
- Our lawyers, accountants, and consultants
- Third parties with whom we have joint marketing and similar arrangements
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
- Other third parties as necessary to complete transactions and provide our distributed products/services
- Third party network advertising partners
- Consumer reporting agencies
- Legal and regulatory bodies and other third parties as required by law
Transaction and Interaction Information
Category and Sources of Personal Information We collect this type of information from:
- You
- Third parties that provide access to information you make publicly available, such as social media
- Automatically, such as when you interact with our websites or mobile apps
Representative Data Elements
Data elements in this category include:
- Personal characteristics and preferences, such as your age range, marital and family status , languages spoken
- Subscription program data
- Household demographic data
- Data from social media profiles, such as Facebook, X, LinkedIn, and similar platforms
- Education information
- Professional information
- Hobbies and interests
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- To fulfill our business relationship with you, including customer service
- For recordkeeping and compliance, including dispute resolution
- For internal business purposes, such as finance, quality control, training, reporting, and analytics
- For risk management, fraud prevention and similar purposes
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Third parties with whom we have joint marketing and similar arrangements
- Service providers, including third parties as needed to complete the transaction, including delivery companies, agents, and manufacturers
- Our lawyers, accountants, and consultants
- Customers, in connection with their audits of our business
- Other third parties as required by law
- Inferred and Derived Information
Category and Sources of Personal Information
We create inferred and derived data elements by analyzing our relationship and transactional information. We draw inferences from the information we collect from and about you, such as your preferences, characteristics, attributes, and abilities.
We also may collect this type of information from:
- Service Providers
- Third parties with whom we have joint business agreements for marketing and development and similar agreements
- Third party network advertising partners
Representative Data Elements
Data elements in this category include:
- Propensities, attributes and/or scores generated by internal analytics programs and used for marketing
- Propensities, attributes and/or scores generated by internal analytics programs and used for information security and fraud purposes
- Preferred language
- Inferences reflecting a consumer’s wellness, health, preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, or other inferred data
Purpose for Collecting and Sharing the Personal Information
We combine inferred data with other relationship information and use this type of information:
- To better understand you and to understand our customers generally
- To design services and programs that interest our customers, including subscription programs
- To identify prospective customers
- For internal business purposes, such as quality control, training, and analytics
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To analyze and better understand your needs, preferences, and interests, as well as those of other consumers
- For advertising and product promotion, including to contact you regarding programs, distributed products, services, and topics that may be of interest or useful
- To engage in joint marketing initiatives
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- To comply with legal and regulatory obligations
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and to:
- Service providers, including those who analyze data on our behalf and who help execute programs
- Our lawyers, accountants, and consultants
- Third parties with whom we have joint marketing and similar arrangements
- Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
- Legal and regulatory bodies and other third parties as required by law
Internet and Online/Electronic Technical Information
Category and Sources of Personal Information
We collect this type of information from:
- You and from your computer or devices when you interact with our platforms, websites and applications; for example, when you visit our websites, our server logs record your IP address and other information
- Automatically, via technologies such as cookies, web beacons, when you visit our website or other websites
- Third parties, including computer security services and advertising partners
- We also associate information with you using unique identifiers collected from your devices or browsers
- Third parties who provide website and online security services
Representative Data Elements
Data elements in this category include:
- IP Address
- MAC Address, SSIDs or other device identifiers or persistent identifiers
- Online user ID
- Password
- Device characteristics (such as browser information)
- Web Server Logs
- Application Logs
- Browsing and search history
- Viewing Data (site and app usage)
- First Party Cookies
- Third Party Cookies
- Web beacons, clear gifs and pixel tags
- Internet service provider
- Referring/exiting URL Request/response date and time
- Clickstream data
- Ads and web pages viewed
- Time spent on a web page or mobile app
- Other information regarding your interactions with our websites, applications, emails, and advertisements
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- For system administration, technology management, including optimizing our websites and applications
- For information security and cybersecurity purposes, including detecting threats
- For recordkeeping, including logs and records that are maintained as part of Transaction Information
- For online targeting and advertising purposes
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To conduct internal business analysis and market research
- To engage in joint marketing initiatives
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To comply with legal and regulatory obligations
- To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, distributed products, services, and advertisements for such purposes
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and to:
- Service providers including companies who assist with our information technology and security programs, including companies such as network security services who retain information on malware threats detected
- Service providers who assist with fraud prevention, detection, and mitigation Third party advertising network companies
- Our lawyers, accountants, and consultants
- Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
- Legal and regulatory bodies and other third parties as required by law
Audio Visual Information
Category and Sources of Personal Information
We collect this type of information from:
- You
- Automatically, such as when we record calls to our call center and use video cameras in our facilities
- Companies conducting research such as market research companies
- Third parties that provide access to information you make publicly available, such as social media
Representative Data Elements
Data elements in this category include:
- Photographs
- Video images
- Video recordings
- Call center recordings and call monitoring records
- Voicemails
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- For internal business purposes, such as call recordings used for training, coaching or quality control
- For relationship purposes, such as use of photos and videos for social media purposes
- For premises security purposes and loss prevention
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Service providers, including companies who assist with our information technology and security programs, and our loss prevention programs
- Service providers, including companies who conduct market research on our behalf Our lawyers, accountants, and consultants
- Other third parties as required by law
Financial Information
Category and Sources of Personal Information
We collect this type of information from:
- You
- Third parties that provide access to information you make publicly available, such as social media
- Third parties that provide information that helps us understand our customers, including data aggregators and public records providers
- Consumer reporting agencies and third parties who assist with fraud prevention, detection, and mitigation
- Payment processors and other financial institutions
- Other third parties who facilitate, process, and complete transactions for us, such as resellers, sales agents, and program partners
Representative Data Elements
Data elements in this category include:
- Bank account number and details
- Payment card information and details
- Debit or credit card number
- Payment and reimbursement amounts
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- To better understand you and to understand our customers generally
- To design distributed products, services, and programs, including subscription and special offer programs
- To communicate with you regarding our programs, distributed products, and services.
- To fulfill our business relationship with you, including processing payments, issuing refunds and collections
- For recordkeeping and compliance, including dispute resolution
- For internal business purposes, such as finance, audits, training, reporting and analytics
- For risk management, fraud prevention and similar purposes
- To determine and verify program, product, and service eligibility and coverage
- To enroll you in our programs and provide our distributed products and services to you
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To issue invoices and collect payments
- Reimburse customers, satisfy warranty obligations, and fulfill payment obligations
- To procure vendor/supplier distributed products and services, including to manage and satisfy related vendor/supplier contractual obligations
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To comply with legal and regulatory obligations
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Service providers, including payment processors, financial institutions and others as needed to complete the transactions and for authentication, security, and fraud prevention
- Our lawyers, accountants, and consultants
- Customers, in connection with their audits of Company
- Third parties who provide program enrollment, and product fulfillment services in connection with our distributed products and services
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
- Third Party Advertising partners
- Other third parties as necessary to complete transactions and provide our distributed products/services
- Consumer reporting agencies
- Legal and regulatory bodies and other third parties as required by law
Electronic and Sensor Data
Category and Sources of Personal Information
We collect this type of information automatically when you use our internet-enabled distributed products such as mobile apps and connected devices from:
- You
- When you contact or visit us (automatically), such as when we record calls to our call center or use video cameras in our facilities
- Your mobile devices and other internet-connected devices and applications (automatically)
- Third parties that provide access to information you make publicly available, such as social media platforms
Representative Data Elements
Data elements in this category include:
- Smart device records
- Health values and sensor readings data, such as steps taken, movement information, data collected by our mobile apps, blood glucose levels, heart rate, and blood pressure
- Recording of a customer service call
- Recording from a video camera in our facilities
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- To enable product functionality
- For internal business purposes, such as program development, security, and quality control
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To analyze and better understand your needs, preferences, and interests, as well as those of other consumers
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To provide access to, monitor, and secure our facilities, equipment, and other property
- To comply with legal and regulatory obligations
- To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, distributed products, services, and advertisements for such purposes
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and to:
- Service providers, including companies who host our data, assist with our information technology and security programs, including network security services and cybersecurity
- Service providers, including companies who assist with fraud prevention, detection, and mitigation
- Third party network advertising partners
- Our lawyers, accountants, and consultants
- Healthcare providers, health insurance companies (health plans), other payors and others as needed to provide the contemplated services or transactions involving the data, such as for processing health care payments
- Authorized/legal representatives, family members, and caregivers
- Third parties who provide program enrollment, and product fulfillment services in connection with our distributed products and services
- Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
- Third parties who assist with our information technology and security programs
- Third parties who assist with fraud prevention, detection, and mitigation
- Other third parties as necessary to complete transactions and provide our distributed products/services
- Other third parties as required by law
Geolocation Data
Category and Sources of Personal Information
We may collect this type of information automatically from your mobile device and computer when you visit or interact with our websites, applications, and online platforms.
Representative Data Elements
Data elements in this category include:
- Precise location data
- Geofencing data
Purpose for Collecting and Sharing the Personal Information
We may use this type of information:
- To provide the information, distributed products or services requested
- For information security and fraud prevention
- For our everyday business purposes
- To administer, manage, analyze, and improve our programs, distributed products, and services
- To conduct internal business analysis and market research
- For advertising and product promotion, including to contact you regarding programs, distributed products, services, and topics that may be of interest or useful
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To comply with legal and regulatory obligations
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Third parties who assist with our information technology and security programs
- Third parties who assist with fraud prevention, detection, and mitigation
- Our lawyers, accountants, and consultants
- Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors
- Legal and regulatory bodies and other third parties as required by law
Compliance Data
Category and Sources of Personal Information
We collect this type of information from:
- You
- Third parties, including companies that help us conduct internal investigations
- Third parties, such as consumer reporting agencies and data aggregators who conduct background screening for us
Representative Data Elements
Data elements in this category include:
- Compliance program data, including signed consent forms, data subject request forms, customer screening records, and other records maintained to demonstrate compliance with applicable laws
- Occupational and environmental safety records
- Records relating to complaints and internal investigations, including compliance hotline reports
- Records of privacy and security incidents, including any security breach notifications
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- To comply with and demonstrate compliance with applicable laws
- For legal matters, including litigation and regulatory matters, including for use in connection with civil, criminal, administrative, or arbitral proceedings, before regulatory or self-regulatory bodies, including service of process, investigations in anticipation of litigation, execution or enforcement of judgments and orders
- For internal business purposes, such as risk management, audit, internal investigations, reporting, analytics
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Our lawyers, accountants, and consultants
- Customers, in connection with their audits of our business
- Other third parties (including government agencies, courts and opposing law firms, consultants, process servers and parties to litigation) in connection with legal matters
Professional Information
Category and Sources of Personal Information
We collect this type of information from:
- You
- Our business partners and other third parties that provide access to information you make publicly available, such as social media platforms
- Third parties who provide us with supplemental data or data analytics and market research services, such as data aggregators
- Your employer or principal
Representative Data Elements
Data elements in this category include:
- Employer and job title
- Medical license
- Employer location
- Information from a resume or CV, including education and certification credentials Information included in an IRS W-9 form, etc.
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- To provide you with our Products and Services To communicate with you
- To administer our relationship with your organization
- To send you updates
- To administer and manage your registration and participation at events
- To fulfill business relationships with you, including processing payments and notifying you of your order status or any associate order status issues
- To identify and authenticate you
- To ensure the appropriate use of our Products and Services
- To improve our Products and Services and our Online Services
- For short-term, transient use
- For administrative purposes
- For quality assurance
- For marketing, internal research, and development
- To customize content for you
- To procure vendor/supplier distributed products and services, including to manage and satisfy related vendor/supplier contractual obligations
- Advertising and product promotion, including to contact you regarding programs, distributed products, services, and topics that may be of interest or useful
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To determine and verify program, product, and service eligibility and coverage
- To conduct internal business analysis and market research
- To comply with legal and regulatory obligations
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Third parties who provide benefit verification, program enrollment, and product fulfillment services in connection with our distributed products and services
- Our lawyers, accountants, and consultants
- Other Healthcare Providers
- Your patients
- Third parties who assist with fraud prevention, detection, and mitigation
- Third parties who assist with our information technology and security programs
- Partners that assist us in providing the Products and Services or help us improve our marketing or administration
- Legal and regulatory bodies and other third parties as required by law
FOR CALIFORNIA JOB APPLICANTS
The following provides detail for residents of California who interact with us applicants for jobs, with respect to the category of Personal Information collected, the source of that information, the purposes for collection and sharing/disclosure, and the categories of third parties to whom the category of Personal Information is shared
Contact Information
Category and Sources of Personal Information
We may collect this type of information from:
- You
- Your employer or principal
- Service providers such as companies that provide employment recruiting services to us, including third parties that provide access to information you make publicly available, such as via social media platforms
- Consumer reporting agencies and other third parties who verify the information you provide
- Third parties who help us maintain the accuracy of our data and data aggregators that help us complete and enhance our records
Representative Data Elements
Data elements in this category include:
- Full name, or unique pseudonym
- Honorifics and titles, preferred form of address
- Postal address
- Email address
- Phone number
- Fax number
- Contact information for related persons, such as authorized users of your account
- Company ID number (e.g., customer number, account number, subscription number)
- System identifiers (e.g., usernames or online credentials)
Purpose for Collecting and Sharing the Personal Information
We may use this type of information:
- To identify you and communicate with you
- For our internal business, administrative, and candidate recruiting and employment-related purposes
- For record-keeping and reporting, including for data matching, metrics, and analytics
- To conduct marketing of the company and market research
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- If you visit our physical sites, to provide access to, monitor, and secure our facilities, equipment, and other property
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Service providers such as companies who help manage recruiting events and activities Third parties who deliver our communications, such as the postal service and couriers
- Other third parties (including government agencies) as required by law, such as pursuant to legally binding subpoenas, court orders, and similar instruments
- Service providers, including those who host our data centers, help administer our call center hosting platforms and phone systems, and provide parts of our physical and electronic infrastructure
- Third Party Advertising companies (see Third Party Advertising below)
- Third parties who assist with fraud prevention, detection, and mitigation
- Other third parties as necessary to complete transactions and provide our distributed products/services, including delivery companies, agents, and manufacturers
- Service providers who provide employment recruiting services, data analytics services, and third parties such as business and social media platforms used to deliver our ads, website/email optimization providers, and email marketing vendors
- Consumer reporting agencies
- Our lawyers, accountants, and consultants
- Other Unique Identifiers
Category and Sources of Personal Information
We may collect this type of information from:
- You
- Your employer or principal
- Service providers such as companies that provide employment recruiting services to us, including third parties that provide access to information you make publicly available, such as via social media platforms
- Consumer reporting agencies and other third parties who verify the information you provide
- Third parties who help us maintain the accuracy of our data and data aggregators that help us complete and enhance our records
Representative Data Elements
Data elements in this category include:
- Government issued identifiers, such as Social Security Numbers, Birth Certificate Number, Driver’s or Operator’s license number, Passport Number, Alien Number or I-94 Number
- Customer number
- IP address
- Service Request ID number
- Cookie ID
- Online User ID
Purpose for Collecting and Sharing the Personal Information
We may use this type of information:
- To identify you and communicate with you
- For our internal business, administrative, and candidate recruiting and employment-related purposes
- For record-keeping and reporting, including for data matching, metrics, and analytics
- To conduct marketing of the company and market research
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- If you visit our physical sites, to provide access to, monitor, and secure our facilities, equipment, and other property
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Service providers such as companies who help manage recruiting events and activities Third parties who deliver our communications, such as the postal service and couriers
- Other third parties (including government agencies) as required by law, such as pursuant to legally binding subpoenas, court orders, and similar instruments
- Service providers, including those who host our data centers, help administer our call center hosting platforms and phone systems, and provide parts of our physical and electronic infrastructure
- Third Party Advertising companies (see Third Party Advertising below)
- Third parties who assist with fraud prevention, detection, and mitigation
- Other third parties as necessary to complete transactions and provide our distributed products/services, including delivery companies, agents, and manufacturers
- Service providers who provide employment recruiting services, data analytics services, and third parties such as business and social media platforms used to deliver our ads, website/email optimization providers, and email marketing vendors
- Consumer reporting agencies
- Our lawyers, accountants, and consultants
Characteristics or Description of Individuals
Category and Sources of Personal Information
We may collect this type of information from:
- You
- Service providers such as companies that provide employment recruiting services to us, including third parties that provide access to information you make publicly available, such as via social media platforms
- Third parties who help us maintain the accuracy of our data and data aggregators that help us complete and enhance our records
Representative Data Elements
Data elements in this category include:
- Height
- Weight
- Hair & eye color
- Age/Date of Birth
- Gender
- Race and Ethnicity
- Citizenship Status
- Religion
- Information concerning sexuality or sex life
- Disability
- Personal characteristics and preferences, marital and family status , shopping/ product preferences, languages spoken
- Other similar data elements
Purpose for Collecting and Sharing the Personal Information
We may use this type of information:
- If you visit our physical site, to help manage emergency incidents that occur on campus or involve company property
- To determine and verify program eligibility
- For our internal business, administrative, and candidate recruiting and employment-related purposes
- To analyze and better understand your needs, preferences, and interests
- For our company marketing and market research purposes
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To conduct internal business analysis and market research
- To comply with legal and regulatory obligations
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Emergency personnel
- Service Providers which use the data only to assist in incident management and reporting
- Service providers, including those who help administer our call center hosting platforms and phone systems
- Service providers, including those who host websites, and companies who assist with our information technology and security programs
- Service providers who provide employment recruiting services, data analytics services, and third parties such as business and social media platforms used to deliver our ads, website/email optimization providers, and email marketing vendors.
- Our lawyers, accountants, and consultants
- Legal and regulatory bodies and other third parties as required by law
Inferred and Derived Information
Category and Sources of Personal Information We collect this type of information from:
- Inferred and derived data elements we create by analyzing our relationship and transactional information
- We draw inferences from the information we collect from and about you, such as your preferences, characteristics, attributes, and abilities
- Third parties who provide digital marketing, and analytics services for us
Representative Data Elements
Data elements in this category include:
- Propensities, attributes and/or scores generated by internal analytics programs and used for marketing
- Propensities, attributes and/or scores generated by internal analytics programs and used for information security and fraud purposes
- Preferred language
- Inferences reflecting a consumer’s wellness, health, preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, or other inferred data
Purpose for Collecting and Sharing the Personal Information
We combine inferred data with other relationship information and use this type of information:
- For company marketing and market research purposes, such as quality control, training, and analytics
- For our internal business and administrative purposes, candidate recruiting and employment-related purposes
- To analyze and better understand your needs, preferences, and interests, as well as those of other applicants
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- For internal business purposes, such as quality control, training, and analytics
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- To comply with legal and regulatory obligations
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and to:
- Service providers, including those who analyze data on our behalf and who help execute programs
- Our lawyers, accountants, and consultants
- Service providers who provide employment recruiting services, data analytics services, and third parties such as business and social media platforms used to deliver our ads, website/email optimization providers, and email marketing vendors
- Legal and regulatory bodies and other third parties as required by law
Internet and Online/Electronic Technical Information
Category and Sources of Personal Information
We collect this type of information from:
- You and from your computer or devices when you interact with our platforms, websites and applications; for example, when you visit our websites, our server logs record your IP address and other information
- Automatically, via technologies such as cookies, web beacons, when you visit our website or other websites
- Third parties, including computer security services and advertising partners
- We also associate information with you using unique identifiers collected from your devices or browsers
- Third parties who provide website and online security services
Representative Data Elements
Data elements in this category include:
- IP Address
- MAC Address, SSIDs or other device identifiers or persistent identifiers
- Online user ID
- Password
- Device characteristics (such as browser information)
- Web Server Logs
- Application Logs
- Browsing and search history
- Viewing Data (site and app usage)
- First Party Cookies
- Third Party Cookies
- Web beacons, clear gifs and pixel tags
- Internet service provider
- Referring/exiting URL Request/response date and time
- Clickstream data
- Ads and web pages viewed
- Time spent on a web page or mobile app
- Other information regarding your interactions with our websites, applications, emails, and advertisements
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- For system administration, technology management, including optimizing our websites and applications
- For information security and cybersecurity purposes, including detecting threats
- For recordkeeping, including logs and records that are maintained as part of Transaction Information
- For online behavioral advertising purposes and general advertising and company promotion
- For our internal business, administrative, and candidate recruiting and employment-related purposes
- For company marketing and market research purposes
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements
- To comply with legal and regulatory obligations
- To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, distributed products, services, and advertisements for such purposes
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Service providers including companies who assist with our information technology and security programs, including companies such as network security services who retain information on malware threats detected
- Service providers who assist with fraud prevention, detection, and mitigation
- Third party advertising network companies
- Our lawyers, accountants, and consultants
- Service providers who provide employment recruiting services, data analytics services, and third parties such as business and social media platforms used to deliver our ads, website/email optimization providers, and email marketing vendors
- Legal and regulatory bodies and other third parties as required by law
Audio Visual Information
Category and Sources of Personal Information
We collect this type of information from:
- You
- Automatically, such as when we record calls to our call center and use video cameras in our facilities
- Companies conducting research such as market research companies
- Service providers such as companies that provide employment recruiting services to us, including third parties that provide access to information you make publicly available, such as via social media platforms
Representative Data Elements
Data elements in this category include:
- Photographs
- Video images video recordings
- Call center recordings and call monitoring records
- Voicemails
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- For internal business purposes, such as call recordings used for training, coaching or quality control
- To identify and authenticate you
- For relationship purposes, such as use of photos and videos for social media purposes
- For premises security purposes and loss prevention
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Service providers, including companies who assist with our information technology and security programs, and our loss prevention programs
- Service providers, including companies who conduct market research on our behalf
- Our lawyers, accountants, and consultants
- Other third parties as required by law
Professional Information
Category and Sources of Personal Information
We collect this type of information from:
- You
- Your employer or principal
- Service providers such as companies that provide employment recruiting services to us, including third parties that provide access to information you make publicly available, such as via social media platforms
Representative Data Elements
Data elements in this category include:
- Employer and job title
- Medical license Employer location
- Information included in an IRS W-9 form, etc.
Purpose for Collecting and Sharing the Personal Information
We use this type of information:
- For our internal business, administrative, and candidate recruiting and employment-related purposes
- To identify and authenticate you
- For company marketing, market research purposes
- To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal
- To comply with legal and regulatory obligations
- For our everyday business purposes
Categories of Third Parties to Whom This Type of Personal Information Is Shared or Disclosed for a Business Purpose
We may disclose this type of information to our Affiliates and Service Providers and to:
- Service providers such as companies who help manage recruiting events and activities Third parties who deliver our communications, such as the postal service and couriers
- Other third parties (including government agencies) as required by law, such as pursuant to legally binding subpoenas, court orders, and similar instruments
- Service providers, including those who host our data centers, help administer our call center hosting platforms and phone systems, and provide parts of our physical and electronic infrastructure
- Third Party advertising companies (see Third Party Advertising below)
- Third parties who assist with fraud prevention, detection and mitigation
- Service providers who provide employment recruiting services, data analytics services, and third parties such as business and social media platforms used to deliver our ads, website/email optimization providers, and email marketing vendors
- Consumer reporting agencies
- Our lawyers, accountants, and consultants
- Legal and regulatory bodies and other third parties as required by law
Mergers and Acquisitions. In addition to the uses set forth above, in certain circumstances, we will use and disclose your Personal Information to facilitate a merger, consolidation, transfer of control or other corporate reorganization in which MDD Options participates, or pursuant to a financial arrangement undertaken by MDD Options and your Personal Information will be disclosed to the buyer, assignee, or transferee.
Data Retention. We will retain your Personal Information for as long as needed or permitted to fulfill the purpose(s) for which it was collected or obtained, and as outlined in this Privacy Statement. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject that affects the Personal Information; and (iii) whether retention is determined to be necessary or advisable for MDD Options due to applicable statutes of limitations, litigation, or other legal or regulatory obligations. We take reasonable steps to dispose of Personal Information upon the expiration of retention periods taking into consideration these litigation, legal, or regulatory obligations.
De-Identification. We may de-identify your Personal Information, which means it will remove certain data from your Personal Information, such as Contact Information, such that the resulting data would not be able to identify you or anyone else as the subject of the data. The de-identified data will no longer be Personal Information and may no longer be subject to data protection laws. We will not attempt to re-identify you or anyone else from this de-identified data and if we disclose it to third parties, we will require that they commit to not attempting to re-identify you or anyone else from the de-identified data. We will use de-identified data for our business purposes.
THIRD PARTIES
Third Party Advertising:
We disclose Personal Information about you (as set forth above) to third-party advertising network companies. We use third-party advertising network companies to place ads on other websites, including network advertising companies with whom we work who place their own cookies on your browser when you visit our Site. This enables these third-party advertising network companies to collect and use data from their cookie on your browser, which may include information about your visits to this and other websites. These advertising companies use and further disclose this information in order to deliver advertisements about our distributed products and services to you when you are on other websites. These advertisements will often be tailored to you. These advertisers may in turn disclose the information about you collected from their cookies to other advertisers to allow those advertisers to display ads to you as well.
In some jurisdictions, these cookies are disabled until you opt-in; in others, these are enabled by default, but you may have the right to opt out. You may opt out of our disclosure of your Personal Information for these purposes by sending an email to privacy [at] mddoptions.com.
For additional information about how else we use cookies and other digital technologies, please see the Digital Advertising, Cookies and Other Data Collection Technologies section of the Privacy Statement.
Service Providers:
Service providers acting on our behalf must execute agreements requiring them to maintain confidentiality and to process Personal Information as necessary to perform their functions in a manner consistent with this Statement, other applicable privacy notices, and as explicitly permitted or required by applicable laws, rules, and regulations.
Combination of Data with Data Received from Third Parties:
We may combine information we collect, including Personal Information, with Personal Information that we may obtain from third parties.
Links to Other Websites:
Our Products and Services may contain links to other websites, applications, distributed products, or services that are not owned or operated by MDD Options, such as social media websites and applications like Facebook and X. You should carefully review the privacy policies and practices of other websites, products, and services as we cannot control and are not responsible for privacy policies, notices, or practices of third-party websites, applications, products, and services.
Do Not Track Signals and Global Privacy Control
Some web browsers incorporate other "do-not-track" (“DNT”) or similar features that signals to websites with which the browser communicates that a visitor does not want to have their online activity tracked. As of the Effective Date, not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, MDD Options Sites along with many other digital service operators do not respond to all DNT signals.
Certain web browsers and other programs may transmit “opt-out” signals, such as the Global Privacy Control (or GPC) signal (we refer to these as “GPC Signals”), to websites with which the browser communicates. In most cases you will need to change your web browser’s settings or add an application to your web browser to enable your browser to send a GPC Signal. Our websites will recognize GPC Signals for website users differently based on the location of the user when they access our websites. For users that access our websites from U.S. states that have laws requiring recognition of GPC Signals, we will recognize and apply the GPC Signal to inactivate all but essential cookies for that website. (Essential cookies are necessary for the website to operate).
Please note that in many circumstances, we cannot effectively do business with you without processing some Personal Information about you (e.g., your contact information). For example, when you contact our customer service representatives, we may require you to provide information to authenticate your identity to assist you with your request. If you are unable to provide this information, we may be unable to process your request.
To the extent that the state in which you live has a data protection law that requires us to offer some or all of the following rights to you, we will provide the following rights to you based on your state’s law:
- To opt-out of sharing your Personal Information for cross-context behavioral advertising or, in other states, to opt-out of targeted advertising,
- To request access to and a copy of your Personal Information and/or your Sensitive Personal Information, including a request to provide a copy directly to another organization (i.e., a right to data portability),
- To request to confirm or know about the Personal Information we process about you or, in other states, to request to acknowledge our processing of your Personal Information,
- To request that we correct your Personal Information,
- To request that we delete your Personal Information (and notify any affiliates, processors, contractors, or other third parties with which we shared to delete it as well),
- To request that we limit the processing of your Sensitive Personal Information,
- To opt-out of processing of Sensitive Personal Information,
- To withdraw consent to the collection or sharing of your Sensitive Personal Information,
- To appeal the denial of a request, and
- To lodge a complaint with the data protection authority in your jurisdiction.
To learn which rights are provided in the state in which you live and to exercise any of these rights with respect to your Personal Information, please see the following section on How to Submit a Data Privacy Rights Request. We will not discriminate against you for exercising any of the rights described above, although we may not be able to continue to provide you Products and Services, or it may otherwise affect the way we are able to interact with you.
How to Submit a Data Privacy Rights Request
To submit a request to opt-out of targeted advertising, you may submit your request to privacy [at] mddoptions.com.
To submit a request pursuant to your data privacy rights under U.S. state privacy laws, we have designated the following two options for you to submit a data privacy rights request:
- Submit your request by email to privacy [at] mddoptions.com.
- Contact us at +1 (984) 355-0399.
We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. We may, after receiving your request, require additional information from you to honor your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.
You may designate an authorized agent to assist you in exercising any of your rights stated above. When you use an authorized agent to submit a request to exercise your rights, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.
In the event you wish to make a complaint about how we process your Personal Information or appeal a response to your request, please contact us by email to privacy [at] mddoptions.com, and we will handle your request as soon as possible in accordance with applicable laws. Even if you make a complaint to us, you may always lodge a complaint with the relevant authority in your location.
When we receive your Personal Information from our customers and process your Personal Information on their behalf, we do so at their request and subject to their instructions. We do not have control over our customers’ privacy and security practices and processes. If your Personal Information has been submitted to us by an MDD Options customer and you wish to exercise any of the above-mentioned rights, please contact the relevant customer directly.
Right of Non-Discrimination for Exercise of Your Privacy Rights
We or MDD Options will not discriminate against any person exercising his or her rights under applicable state data protection laws, as described above. Discrimination, in this context, includes that, as a result of exercising any of your data privacy rights, you are denied goods or services, charged different prices for goods or services, or provided a different level of quality.
Residents of U.S. states with comprehensive privacy laws who are unable to review or access this Supplemental U.S. Privacy Statement due to a disability may contact us to request access to this Statement in an alternative format. Please contact us by email to privacy [at] mddoptions.com.
Nevada Residents
MDD Options’ does not sell Covered Information as defined under Nevada law. If you would like to make a further inquiry regarding the selling of your Covered Information as defined under Nevada law, please send an email to privacy [at] mddoptions.com.
To exercise any rights you might be entitled to under applicable privacy laws, please utilize the designated mechanisms provided in the Supplemental European Privacy Statement or the Supplemental U.S. Privacy Statement . If you have any questions or concerns about this Privacy Statement or about your Personal Information, you may contact us as follows:
Privacy Team
MDD Options
355 Cedar Lane Farm Ln,
New Hill, NC 27562
Or by email to privacy [at] mddoptions.com
Or by telephone +1 (984) 355-0399
If you wish to receive a response by email, please be sure to include your name, postal address, and email address. If we do not receive an email address, we will respond by postal mail.
Changes to Our Privacy Statement
We may update this Privacy Statement from time to time. When we do update it, for your convenience, we will make the updated statement available on this page. Our intention is to use Personal Information in accordance with the Privacy Statement in place at the time the information was collected.
