August 1, 2022
Last Reviewed on: August 1, 20221
Information We Collect
The Company provides access to and use of providerscience.com, including any content, functionality, and services offered through providerscience.com (collectively, the “Website”). Therefore, the Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, the Website has collected the following categories of personal information from its consumers within the last twelve (12) months:2
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||No|
|D. Commercial information.||
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|E. Biometric information.||
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
|F. Internet or other similar network activity.||
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
|G. Geolocation data.||
Physical location or movements.
|H. Sensory data.||
Audio, electronic, visual, thermal, olfactory, or similar information.
|I. Professional or employment-related information.||
Current or past job history or performance evaluations.
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
|K. Inferences drawn from other personal information.||
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
The Company obtains the categories of personal information listed above from the following categories of sources:3
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions via the Website.
Use of Personal Information
We may use, sell, or disclose the personal information we collect for one or more of the following business purposes:4
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide, support, personalize, and develop our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
The Company will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
The Company may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
We share your personal information with the following categories of third parties:
- Service providers.
- Data aggregators.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company [has not disclosed personal information for a business purpose/ [OR] has disclosed the following categories of personal information for a business purpose]:5
- [Category A: Identifiers.]
- [Category B: California Customer Records personal information categories.]
- [Category I: Professional or employment-related information.]
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
Sales of Personal Information
In the preceding twelve (12) months, Company has not sold personal information:6
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that the Company disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights7
You have the right to request that the Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:8
- Calling us at 800-705-2910
- Visiting providerscience.com
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to forty-five (45) days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically electronic delivery.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights9
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting your account profile in the BetterShifts application.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information on your account profile page.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or write us at: 550 Reserve Street, Suite 480, Southlake, TX 76092.
Changes to Our Privacy Notice
The Company reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Attn: Privacy Officer
550 Reserve Street, Suite 4280
Southlake, TX 76092
1The policy should identify the date it was last revised and optionally, the date it was last reviewed. The CCPA requires PROVIDERSCIENCE to review and update the privacy notice’s content at least every 12 months. If the annual review does not cause the business to change or alter the policy, it should add the optional “last reviewed” clause. This confirms that the required annual review took place but did not lead to changes requiring a new effective date.
2When disclosing the personal information categories that PROVIDERSCIENCE collects about consumers, the CCPA expects the privacy notice to reference and use the 11 categories listed in its personal information definition that most closely describe the personal information collected. This chart, where PROVIDERSCIENCE affirmatively states whether it has or has not collected that type of personal information provides the required information in a clear, easy-to-understand format. It also helps PROVIDERSCIENCE comply with the requirement to produce individualized lists by category on request. The company should carefully review and categorize the personal information it collects to complete the chart.
3The CCPA requires the business to identify the categories of sources from which it collects personal information. While it does not elaborate on or provide examples of the source categories a business should use, PROVIDERSCIENCE should describe them with sufficient detail to provide clear and meaningful disclosures about where acquired personal information originates.
4Under the CCPA, PROVIDERSCIENCE must disclose its purposes for collecting or selling personal information. This section provides optional clauses describing several common commercial or business purposes for using personal information. However, the Company should carefully review how and why it uses the personal information it collects to provide clear and accurate disclosures. The CCPA’s purpose limitation clause prohibits using collected personal information for purposes not listed in the privacy notice or uses unrelated to those purposes (Cal. Civ. Code § 1798.100(b)). Therefore, the business should ensure that the provided list comprehensively describes both current and reasonably anticipated use cases.
5The CCPA requires that PROVIDERSCIENCE to provide a statement on its personal information disclosures for a business purpose during the preceding 12 months that either: (a) States that no disclosures occurred OR (b) provides the categories of personal information disclosed, using the 11 categories listed in the personal information definition that most closely describe the personal information.
PROVIDERSCIENCE should carefully review the types of personal information it discloses for a business purpose to identify which categories it should list in the privacy notice.
6The CCPA requires PROVIDERSCIENCE to provide a statement on its personal information sales during the preceding 12 months that either (a) states that no sales occurred OR (b) provides the categories of personal information sold, using the 11 categories listed in the personal information definition that most closely describe the personal information.
The company should carefully review the types of personal information it sold to identify which categories it should list in the privacy notice.
7The CCPA notice must disclose the consumers’ right to request deletion of their personal information and requires PROVIDERSCIENCE to delete personal information from its records after receiving a verifiable consumer request, unless one of nine statutory exceptions allow the business to retain it. PROVIDERSCIENCE must also instruct its service providers to delete any information that the CCPA requires it to delete under this consumer right.
8The CCPA only requires PROVIDERSCIENCE to honor a consumer’s access, data portability, and deletion rights if the person makes a verifiable consumer request that allows the business to reasonably verify the requester’s identity and requires PROVIDERSCIENCE to provide consumers with at least two methods for making verifiable requests to exercise these CCPA rights. The methods must include at least:
(a) A toll-free telephone number; and
(b) A website address.
9Under the CCPA, a business selling a consumer’s personal information must provide notice of the consumer’s opt-out and opt-in rights by:
(a) Creating an internet webpage with the title “Do Not Sell My Personal Information” that enables a consumer (or other authorized person) to opt-out of personal information sales.
(b) Clearly and conspicuously linking to that page from either its: (1) public internet home page; or (2)a California-specific public internet home page, if it takes reasonable steps to direct all California consumers to that California home page instead of the general one.
(c) Including both a description of the right and a separate link to the “Do Not Sell My Personal Information” page in: (1) its online privacy policies, if they exist; and (2) any California-specific description of consumers’ privacy rights.