This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

supplements the information contained in the Privacy Policy of prIME Oncology LLC (“prIME Oncology” or “we,” “us,” or “our”) and applies solely to our users who are residents of the State of California (“consumers” or “you”) in relation to your use of our services, products, websites and other communications (collectively, the “Services”).

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in our Privacy Policy or in the CCPA have the same meaning when used in this notice.

Information we collect.

We have collected the following categories of information from consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers. 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. Yes
B. Personal information listed under 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. Yes
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).
D. Commercial Information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes
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. No
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes
G. Geolocation data. Physical location or movements. Yes
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No
I. Professional or employment-related information. Current or past job history or performance evaluations. Yes
J. Non-public education information. 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. No
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes

Certain information that we collect identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”).

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
    • Information included in categories D and G is collected and used in a de-identified and/or aggregated manner.
  • 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; or
    • 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.

Categories of sources from which information is collected.

As described in our Privacy Policy, we may obtain the categories of information listed above from the following sources:
Directly from you, such as when you register with us.

  • Indirectly from you, such as information we may collect in the course of providing the Services.
  • Directly and indirectly from your activity on our website, as described below under Cookies.
  • From third parties that interact with us in connection with the Services, such as from business partners or third party vendors.

Cookies

We use cookies to collect information about your use of the Services. “Cookies” are small data files assigned to your browser when you visit our Site. Specifically, we use the following cookies:

Functional cookies
Functional cookies ensure that our website works properly, and enable us to recognize you when you return to our website and to remember your preferences. We also use functional cookies to track down misuse of our website and services, such as by registering the number of consecutive failed login attempts.

Analytical cookies
These cookies allow us to recognize and count the number of visitors, the duration of their visits, their browsing behavior, and other information that helps us to improve the use of our website. Analytical cookies can give us a better view on which parts of our website are the most relevant to our visitors and which content is the most popular, so that we can enhance our website for our visitors.

Tracking cookies
Tracking cookies enable us to follow your online behavior and make personalized offers to you. These offers may include offers from third parties, directly or indirectly. Examples of tracking cookies are advertising cookies and social media plug ins.

Advertising cookies include web beacons, pixels, and tags, which help us to provide relevant information to you more effectively. This information may include information from third parties, such as third-party network servers.

For more information about our how cookies and other tracking technologies are used in connection with the Services, please read our Cookie Policy.

Use of personal information.

The personal data included in each of categories A, B, C, F, I and K described above may be used for the following business purposes:

  • Provision of the Services. We may use your personal information to provide you with the information and Services that you expect and/or request from us. This may be access to (online) events, meetings, presentations, and publications, as well as receipt of newsletters and emails that inform you about our business activities. Whenever you register for one of our events or other services, we use your personal data to meet our obligations to provide you with the information and services you asked for. Whenever this includes billing or reimbursement, we use the billing data you provided to exercise our financial rights and obligations.
  • Internal Business Purposes. Your personal data is also used for our internal business purposes, such as improving our Services and communications, enhancing our website, and monitoring the use of our website.
  • Marketing. Your personal data such as name and e-mail address may be used for direct marketing purposes.
  • Personalize the Services. We may use your personal information to personalize the Services and to provide relevant information to you more effectively.
    Verification Purposes. We may use your information in conjunction with information from third parties to recognize you as a registered member when you visit our website and to verify your identity and/or professional credentials. We may require you to provide proof of your identity, including that you are a healthcare professional, and if you are unable to do so to our reasonable satisfaction, we reserve the right to deny you access to the Services.
  • Account Management. We may use your information to administer your account, respond to your inquiries, fulfill your requests and send you administrative communications about the Services.
  • Investigations. We may use your information to detect, investigate and defend against fraudulent or unlawful activity, violations of our Terms of Use and to otherwise establish, exercise and defend our legal rights.

Sharing your personal information

Personal information disclosed for a business purpose

  • Service Providers. We work with third party service providers to help us provide the Services and to otherwise assist us in the operation of our website, including in the areas of email management and deployment, analytics, marketing, market research, identity and professional credential validation, customer service, payment fulfillment, event logistics, hotel booking, website maintenance and data storage and security. We may provide these service providers with personal information about users of our Services so that they can fulfill their responsibilities to us, and we require that they agree to limit their use of this personal information to the fulfillment of these responsibilities.
  • Consent. We may disclose your personal information to a third party in a manner not addressed by this Notice subject to your consent at such time.
  • Aggregated Information. We may provide aggregated information about users of our Services to third parties as we deem appropriate in our sole discretion.
  • Business Transfers and Affiliates. We may share your information with any member of our group of companies (meaning our subsidiaries, our ultimate holding company and its subsidiaries) for their use for the purposes set forth in this Notice, including to market to you through a variety of channels as described herein, subject to applicable law.
  • Legal Requirements. We may release personal information when we believe release (i) is required to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order and to meet national security or law enforcement requirements; or (ii) is reasonable in response to a physical threat to you or others, to protect property or defend or assert legal rights of us or others.

In the preceding twelve (12) months, we may have disclosed the personal information included in categories A, B, C, F, I and K described above for each of the business purposes described above depending on your use of the Services described herein.

Personal information “sold” to third parties

We do not offer an opt-out from the sale of personal information because prIME Oncology does not engage in the sale of personal information as contemplated by the CCPA.

Your rights

The CCPA provides California consumers 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 we 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, 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 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 disclosed your personal information for a business purpose, two separate lists containing disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

Deletion request rights

You have the right to request that we 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, 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 providers 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 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 request to us by either:

  • Calling us at (866) 967-1410.
  • Clicking here.

By calling the toll-free number or using the above link, you will be asked to provide certain identifying information, such as name, email, residency and date of birth, which we will only use to process or verify your request. You will be asked to validate your request by clicking a validation link in an email that will be sent to the email address provided.

You may also be asked to provide further verifying documentation, such as proof of residency and identity.

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.

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. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide proof of written authorization to do so, and you must verify your identity directly with us, unless such authorized agent provides proof of a power of attorney pursuant to Probate Code sections 4000 to 4465.

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. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will cover a period of no less than 12 months preceding the receipt of a verifiable consumer request. 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.

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.

Non-Discrimination

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.

We may provide a different level of Services if the difference is reasonably related to value provided by your data.

Changes to this privacy notice

We reserve the right to change or modify this privacy notice and any of our Services at any time and any changes will be effective upon being posted unless we advise otherwise. By continuing to use the Services after changes are made to this privacy notice, you agree to such changes. We encourage you to periodically review this privacy notice for the latest information on our privacy practices.

Contact information

If you have any questions about this Notice, please contact our Privacy Office at the address below:

prIME Oncology LLC
Attn: Office of Privacy
1201 Peachtree Street, NE
400 Colony Square, Suite 2100
Atlanta, GA 30361

Effective Date: January 1, 2020