CCPA Privacy Policy

Last Updated: October 29, 2021

This California Consumer Privacy Act (“CCPA”) privacy policy (this “CCPA Policy”) is included in our Privacy Policy and applies to SPI Healthcare (“AIS,” “we,” “us,” or “our”)’s processing of personal information of California consumers (as the terms “personal information” and “consumer” is defined under the CCPA) (collectively, “Consumers,” “you,” or “your”). Any capitalized terms or other terms not defined herein shall have the meaning ascribed to them in the Privacy Policy or, if not defined herein or in the Privacy Policy, the CCPA. To the extent of any conflict between this CCPA Policy and the rest of our Privacy Policy, this CCPA Policy shall control only with respect to Consumers and their personal information. If you are located elsewhere, please see our Privacy Policy here.

Personal Information We May Collect The following chart shows the categories of personal information that we have collected, the sources of such information, and the business or commercial purposes for which we may use such information. For all categories of personal information collected, we disclose data to our service providers and other third parties to help us accomplish the business purposes described below.

For the table below, the list of examples for each category is intended to be illustrative and not exhaustive.

Categories of Personal Information	Sources of Personal Information	Business and Commercial Purposes
Identifiers (e.g., name, address, e-mail address, account name(s))	Websites or services (information collected directly from user) Third-party advertisers/promoters Industry Affiliates Vendors	Account activation and administration Customer support and feedback Process, fulfillment, and maintenance of benefits/plan Delivery of marketing communications Analytics
Commercial Information (e.g., products or services purchased, obtained, or inquired about)	Websites or services (information collected directly from user) Third-party advertisers/promoters Industry Affiliates Vendors	Customer support and feedback Process, fulfillment, and maintenance of benefits/plan Delivery of marketing communications Analytics
Internet or Network Activity (e.g., IP address, browser and operating system, referral URL, pages viewed, date/time of visit)	Websites or services (information collected directly from user) Third-party advertisers/promoters Vendors	Delivery of marketing communications Analytics
Geolocation (physical location of device)	Websites or services (information collected directly from user) Third-party advertisers/promoters Vendors	Customer support and feedback Process, fulfillment, and maintenance of benefits/plan Delivery of marketing communications Analytics
Inferences drawn from any of these personal information categories (e.g., interest in services, such as based on feedback and customer support)	Websites or services (information collected directly from user) Third-party advertisers/promoters Industry Affiliates Vendors	Customer support and feedback Process, fulfillment, and maintenance of benefits/plan Delivery of marketing communications Analytics
Financial Information (e.g., credit card information, bank account information)	Websites or services (information collected directly from user) Vendors	Account activation and administration Process, fulfillment, and maintenance of benefits/plan

Your CCPA Rights

Access

You may request access to the personal information that we have collected and maintained about you (along with information regarding its use and disclosure) over the past twelve (12) months upon appropriate verification. You may only make such requests twice (2) per every twelve (12) months.

Deletion

You have the right to request that we delete personal information collected and maintained about you, subject to certain exceptions. Once your request is verified and we have determined that we are required to delete that information in accordance with applicable law, we will delete your personal information accordingly. Your request to delete your personal information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA. Please note that a record of your deletion request may be kept pursuant to our legal obligations.

Exercising Your Rights

To exercise the access and deletion rights described above, please submit a request to us by either:

• Utilizing the “Do Not Sell My Personal Information” button located at the bottom of each page, or
• Utilizing the “Exercise Your Rights” button located at the bottom of each page.

Please note that Consumers have a right to not receive discriminatory treatment for the exercise of their rights under the CCPA.

Verifying Your Request

Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verifiable before we can fulfill such request.

Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf (e.g., previous transactions of person to whom request relates).

We will only use the personal information that you have provided in a verifiable request in order to verify your request. As stated above, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority.

Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded.

Your California Privacy Rights under the ``Shine the Light`` Law

Pursuant to Section 1798.83 of the California Civil Code (a separate law from the CCPA), residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact us via email at [email protected].

Do Not Track

We currently do not respond to any Do Not Track signals or similar signals.

Contacting Us

If you have any questions regarding our privacy practices as it relates to this CCPA Policy, please contact us via email at [email protected] with the subject line, ” CCPA Policy.”