Privacy Notice for California Residents
We include this section for residents of California in order to comply with the California Consumer Privacy Act of 2018, and its amendment, the California Privacy Rights Act of 2020 (together, the “CCPA”). This section is intended to comply with the CCPA by supplementing the information provided elsewhere in the Privacy Policy.
California Privacy Disclosure
This disclosure supplements the information contained in our Privacy Policy by providing additional information about our personal information processing practices relating to individual residents of California.
For the purposes of this disclosure, personal information does not include publicly available information or deidentified, aggregated, or anonymized information that is maintained in a form that is not capable of being associated with or linked to you. Personal information under CCPA does not include health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data. Additionally, this disclosure does not describe our practices when we process customer data as a service provider on behalf of our clients in accordance with our contractual agreements with our customers or when we process customer data on behalf of Providers who are individuals providing services to patients.
Your California Privacy Rights
Subject to applicable law, consumers have the following rights:
- Right to Know: You have the right to submit a verifiable request up to twice in a 12-month period for specific pieces of your personal information and for information about Company’s collection, use, and disclosure of your personal information.
Please note that the CCPA’s right to obtain “specific pieces” does not grant a right to the whole of any document that contains personal information, but only to discrete items of personal information. Moreover, consumers have a right to know categories of sources of personal information and categories of external recipients to which personal information is disclosed, but not the individual sources or recipients.
- Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that you have provided to Company.
- Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by Company, taking into account the nature of the personal information and the purposes of processing the personal information.
How to Exercise Your Rights
Company will respond to requests to know, delete, and correct in accordance with applicable law if it can verify the identity of the individual submitting the request. You can exercise these rights in the following ways:
We match personal information that you provide us against personal information we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of personal information), the more items of personal information we may request to verify your identity. If we cannot verify your identity to a sufficient level of certainty to respond securely to your request, we will let you know promptly and explain why we cannot verify your identity.
You may designate an authorized agent to exercise your right to know, to correct, or to delete. If an authorized agent submits a request on your behalf, the authorized agent must submit with the request another document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you or your authorized agent to follow the applicable process described above for verifying your identity.
In the alternative, you can provide a power of attorney compliant with the California Probate Code.
Company will not unlawfully discriminate or retaliate against you for exercising your rights under the California Privacy Rights Act.
Disclosure of Personal Information
Company does not sell or “disclose” (disclose for cross-context behavioral advertising) your personal information. In addition, we have no actual knowledge that we sell or disclose the personal information of individuals of any age, including the personal information of children under 16. To learn more about the disclosure of your personal information, please refer to the “How We Share Personal Information” section of our Privacy Policy.
Disclosures for Business Purposes
Company may disclose each of the categories of personal information listed in the “Categories of Personal Information We Collect About You” section for the following business purposes:
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.
- Debugging to identify and repair errors that impair existing intended functionality.
- Short–term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
- Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.
- Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers that the service provider or contractor receives from, or on behalf of, the business with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.”
Cal. Civ. Code § 1798.140(e).
Company may disclose each of the categories of personal information to the third parties listed below:
- Service providers: Company may disclose to service providers any of the categories of personal information listed in the “Categories of Personal Information We Collect About You” section, for the business purpose of performing services on Company’s behalf and, in particular, for the specific purposes described in the “Disclosures for Business Purposes” section, above.
- Auditors, lawyers, consultants, and accountants engaged by Company: Company may disclose the categories of personal information listed in the “Categories of Personal Information We Collect About You” section, to these service providers or contractors for the business purpose of auditing compliance with policies and applicable laws, in addition to performing services on the Company’s behalf.
- Affiliated companies: Company may disclose any of the categories of personal information listed in the “Categories of Personal Information We Collect About You” section to other companies within its managed services organization (MSO) group, presently including SUD Specialty Group – CA; Mental Health Specialty Group, P.A.; Mental Health Specialty Group NJ, PC; and Mental Health Specialty Group KS, P.A., and also including any future medical professional corporations that may become a part of Company’s MSO group, for the business purposes of (a) auditing compliance with policies and applicable laws, (b) helping to ensure security and integrity, (c) debugging, (d) short-term transient use, (e) internal research, and (f) activities to maintain or improve the quality or safety of a service or device.
Additional Information for Applicants or HR Individuals
To review supplemental information that describes the additional personal information we collect when you apply for a position with us, please refer to
California Applicant Privacy Notice. To review supplemental information that describes the additional personal information we collect from (a) employees, (b) independent contractors, interns, volunteers, owners, board members, and other individuals who perform work for Company (collectively “Non-Employee Workers”), or (c) employees’ and Non-Employee Workers’ dependents, emergency contacts, and beneficiaries (“Related Contacts”), (all collectively, “HR Individuals”), please refer to
California HR Individuals Privacy Notice.
Updates
Path CCM reserves the right to update this Privacy Policy from time to time. Non-material changes to this Privacy Policy become effective when the revisions are posted on the website. For material changes, Rula will email users and post on the website. We suggest you review the Privacy Policy on our website to stay informed about how we may collect, store, use and disclose your personal information.
Contact Us
If you have any questions about our Privacy Policy, you may contact us via email at privacy@pathccm.com or at (323) 205-7088.
