Privacy Policy for California Residents

Effective: June 12, 2020

This Privacy Policy for California Residents (“CCPA Privacy Policy”) applies to Shadow Health, Inc.’s (including our subsidiaries and affiliates, “Shadow Health,” “we,” “us,” or “our”) processing of personal information of California residents to the extent the information is subject to the California Consumer Privacy Act of 2018. This CCPA Privacy Policy supplements and does not replace our Web site Privacy Policy and Terms of Use.

We do not sell consumers' Personal Information (defined below).

Personal Information We Collect, Use, or Disclose

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). Within the last twelve (12) months, we have collected the following categories of Personal Information from the sources identified below for the business and commercial purposes indicated, and shared such categories of Personal Information with the specified categories of third parties:

Category of Personal Information Examples Sources of Personal Information Business or Commercial Purpose(s) for Which Used Third Parties Shared With, If Any
Identifiers Real name, alias, postal address, unique personal identifier, or other similar identifiers. Directly from you, for example when register at the Web site, from your transactions with us, and from your educational institution. We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
• Providing you with the services that you request;
• To contact you regarding your use of the services;
• To create, maintain, customize, and secure your account;
• To investigate and address user concerns, and to monitor and improve our responses; or
• To process requests, purchases, transactions.
We share Personal Information as permitted or required by law in connection with performance of our services and for our business operations, including to:
• Government agencies;
• affiliates or your academic institution using our services;
• Administrative service providers.
Identifiers (continued) In addition, through online facilities or services, (e.g., our Web site) we collect the following identifiers: online identifier, Internet Protocol address, email address, account name. Directly from you, for example when set up an online account, and as a result of your use of our Web site or other online services, and from third parties such as your academic institution and Web site analytics providers. We use this information to provide services to you and to maintain our Web site or other online services, such as:
• To contact you regarding your use of the services;
• To help maintain the safety, security, and integrity of our Web site, information systems, databases and other technology assets;
• To create, maintain, customize, and secure your account; or
• For testing, research, analysis, and product development, including to develop and improve our Web site, products and services.
We share Personal Information as permitted or required by law in connection with performance of our services and for our business operations, including to:
• Government agencies;
• affiliates or your academic institution using our services; and
• Administrative service providers.
Categories of Personal Information Identified in the California Customer Records Statute A name, signature, address, telephone number Directly from you, for example when you set up an online account, and as a result of your use of our Web site or other online services. We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
• Providing you with the services that you request;
• To contact you regarding your use of the services;
• To create, maintain, customize, and secure your account;
• To investigate and address user concerns, and to monitor and improve our responses; or
• To process requests, purchases, transactions.
We share Personal Information as permitted or required by law in connection with performance of our services and for our business operations, including to:
• Government agencies;
• affiliates or academic institutions using our services;
• Administrative service providers.
Internet or other electronic network activity information Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. Directly from you, for example when you set up an online account, and as a result of your use of our Web site or other online services, and from third parties such as Web site analytics providers. We use this information to provide services to you and to maintain our Web site or other online services, such as:
• To contact you regarding your use of the services;
• To help maintain the safety, security, and integrity of our Web site, information systems, databases and other technology assets;
• To create, maintain, customize, and secure your account; or
• For testing, research, analysis, and product development, including to develop and improve our Web site, products and services.
We share Personal Information as permitted or required by law in connection with performance of our services and for our business operations, including to:
• Government agencies;
• affiliates or your academic institution using our services; and
• Administrative service providers.
Non-public education information (as defined in the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)) Education records, files, documents, and other materials directly related to a student maintained by an educational agency or institution or by a person acting for such an agency or institution, such as assignment scores, class lists, and student identification codes. Directly from you, for example when you set up an online account, and as a result of your use of our Web site or other online services, and from third parties such as Web site analytics providers. We use this information to provide services to you and to maintain our Web site or other online services, such as:
• To provide users with information, products, or services that they request from us;
• To provide, support, personalize, and develop our Web site;
• To create, maintain, customize, and secure your account and permit your institution to conduct the course you are taking; or
• For testing, research, analysis, and product development, including to develop and improve our Web site, products and services.
We share Personal Information as permitted or required by law in connection with performance of our services and for our business operations, including to:
• Government agencies;
• affiliates or your academic institution using our services; and
• Administrative service providers.

Disclosure or Sale of Personal Information for a Business or Commercial Purpose

Our disclosures of Personal Information for business or commercial purposes in the preceding twelve (12) months are disclosed above.

We do not sell consumers’ Personal Information.

Your Privacy Rights

Right to Know

You have the right to request that we identify to you the Personal Information we collect, use, or disclose about you.

You can visit our website https://support.shadowhealth.com or call 1-800-860-3241 to make a disclosure request. You may make up to two requests in any 12-month period.

We do not sell your Personal Information.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

Making a verifiable consumer request does not require you to create an account with us. We do, however, consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account.

To verify the identity of the requestor and authority to make the request, you will be required to provide your name, email address and other unique information that we may determine is required in order to connect you to the information that we retain (e.g., phone number associated with your account or prior courses you have enrolled in with Shadow Health).

We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

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.

Right to Request Deletion

You have the right to request that we delete your Personal Information. You may make such a request by visiting our website https://support.shadowhealth.com or by calling 1-800-860-3241.

You should be aware, however, that California law allows us to retain your Personal Information under certain conditions, even if you have asked us to delete it, such as when retaining your Personal Information is necessary for us to complete a transaction with you or provide you with a good or service you have requested. We will notify you of any denial of your deletion request and the reason for such denial.

Right to Non-Discrimination for Exercise of Consumer Privacy Rights

We will not discriminate against you because you have chosen to exercise any of your privacy rights described above.

If you have questions about this CCPA Privacy Policy, please contact us at the following:

Phone: 1-800-860-3241

Website: https://support.shadowhealth.com

Email: privacy@shadowhealth.com

Address:

Shadow Health, Inc.
Attn: Data Privacy Officer
201 SE 2nd Ave, Ste. 201
Gainesville, FL 32601

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