CCPA Privacy Policy / Notice of Collection

The California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA”) provides California residents certain rights regarding their Personal Information (as defined below) that we, Vituity® ("Vituity" is the trade name for CEP America, LLC and each of its member partnerships and subsidiaries, MedAmerica, Inc., and MedAmerica Billing Services, Inc.), collect about you the Consumer (as defined below).

For the purposes of this CCPA Privacy Policy/Notice of Collection ("CCPA Privacy Policy"), a Consumer is defined as an individual residing in the State of California including visitors to our website, visitors to a Vituity site and those who are acting as a job applicant to Vituity, and an employee of, owner of, director of, officer of, medical staff member of, or contractor of Vituity (“Vituity Workforce Member”) (collectively the “Consumer”).

The CCPA defines Personal Information as information that identifies, describes, or could reasonably be linked with the Consumer (“Personal Information”). Vituity is committed to safeguarding the privacy of our Consumers and this CCPA Privacy Policy serves to inform you of the categories of Personal Information that we collect, at or before the time of collection, and the purposes for which those categories of Personal Information are used. The CCPA Privacy Policy also provides consumers with a description of Vituity’s online and offline practices regarding the collection, use, and disclosure of Personal Information and the rights of Consumers regarding their Personal Information pursuant to the CCPA. This page is intended to provide the Notice at Collection required under the CCPA.

The CCPA does not apply to the following categories of information:

Medical information governed by:
- Confidentiality of Medical Information Act (CMIA)
- Health Insurance Portability and Accountability Act (HIPAA)
- Health Information Technology for Economic and Clinical Health Act (HITECH)
- Genetic Information Nondiscrimination Act (GINA)
Privacy data covered by other regulations including:
- US Gramm-Leach-Bliley Act
- US Driver’s Privacy Protection Act
- California Financial Information Privacy Act
Information collected by government entities

Categories of Personal Information Collected by Vituity

Personal Information may be received by our Service providers and user-directed entities. We may retain your information for a period of time consistent with the original purpose of collection. We also may retain your information during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements. The categories of Personal Information collected by Vituity within the past 12 months include the following:

Category	Examples	Collected? Yes / No Source of personal data	Purpose for Collection	Recipients
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 Interactions with Consumers	Provide our products and services; respond to customer questions, marketing	Service providers and Consumer-directed entities
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.	Yes Interactions with Consumers	Provide our products and services; authentication of accounts	Service providers and Consumer-directed entities
C. Characteristics of protected Classification under California or federal law	Race, color, religion (includes religious dress and grooming practices), sex/gender (includes pregnancy, childbirth, breastfeeding and/or related medical conditions), gender identity, gender expression, sexual orientation, marital status, medical condition, military or veteran status, national origin, ancestry, disability, genetic information, request for family care leave, request for leave for an employee’s own serious health condition, request for Pregnancy Disability Leave, Retaliation for reporting patient abuse in tax-supporting institutions, Age (40 or older).	Yes Interactions with Consumers	Provide services and products	Service providers and Consumer-directed entities
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information	An individual’s physiological, biological, or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	Yes Interactions with Consumers	Provide services and products; support Vituity Workforce Members	Service providers and Consumer-directed entities
F. Internet or other electronic network activity	Activity including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.	Yes Interactions with Consumers	Provide services and products; marketing	Service providers and Consumer-directed entities
G. Geolocation data	Physical location or movements	Yes Interactions with Consumers	Provide services and products; support Vituity Workforce Members	Service providers and Consumer-directed entities
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	No
I. Professional or employment-related information that is not publicly available.	Current or past job history or performance evaluations.	Yes Interactions with Consumers and organizations that represent consumers	Provide services and products; support Vituity Workforce Members; marketing	Service providers and Consumer-directed entities
J. Education Information	Information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).	Yes Interactions with Consumers and organizations that represent consumers	Provide services and products; support Vituity Workforce Members; marketing	Service providers and Consumer-directed entities
K. Inferences	Information drawn from any of the personal information categories referenced above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes Interactions with Consumers and organizations that represent consumers	Provide services and products; support Vituity Workforce Members; marketing	Service providers and Consumer-directed entities

Sensitive Information

Subject to your privacy settings and our Website Privacy Policy, and depending on the products and services you use and your choices, we may collect or disclose certain Personal Information that qualifies as “sensitive information” under applicable U.S. state data privacy laws. Sensitive information is a subset of Personal Information. In the list below, we outline the categories of sensitive information we collect, the sources of the sensitive information, our purposes of processing, and the categories of third-party recipients to whom we disclose the sensitive information.

Category	Source of Personal Data	Purpose for Collection	Recipients
(L) Sensitive Personal Information
A. A consumer’s social security, driver’s license, state identification card, or passport number.	Interactions with users and Vituity workforce	Provide products and services and manage Vituity Workforce Members	Service providers
B. A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.	Interactions with users and Vituity workforce	Provide products and services and manage Vituity Workforce Members	Service providers
C. A consumer’s precise geolocation;	Interactions with users and Vituity workforce	Provide service requested; some attributes may be disclosed to third parties to provide the service	Users and service providers
D. A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.	Communications with users and Vituity workforce	Conduct research to better understand how our products and services are used and perceived for the purposes of improving Vituity services and Vituity Workforce Member environment	Service providers
E. The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.	Users’ interactions with products and services	Provide our products and services; improve our product and service experience; safety	Service providers
F. A consumer’s genetic data.	Interactions with users and Vituity workforce	Provide products and services and manage Vituity Workforce Members	Service providers

How Vituity Obtains Personal Information

Vituity collects your Personal Information for recruitment, employment, personnel related and other business purposes. Vituity may obtain Personal Information either directly from you (forms you complete through our website or through other online communications with us) or indirectly from you (by tracking actions that you take on our website). We may also obtain Personal Information from third-party vendors who perform business services on our behalf.

Sharing Personal Information

Vituity may use or disclose Personal Information we collect for one or more of the following business purposes: to fulfill the reasons for which you provided the information; to provide, support and develop our website and services; to maintain the safety and security of our website and services; to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; and as described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

Vituity may disclose your Personal Information to third-party service providers for business purposes including personnel-related functions such as payroll, benefits, recruiting and maintaining personnel records. We may also share your Personal Information with vendors to improve functionality across our websites. You have the right to direct us not to “share” your Personal Information. (See Personal Information Sales Opt-Out below.)

Sale of Personal Information

In the preceding twelve (12) months, Vituity has not “sold” Personal Information for any business or commercial purpose.

Your Rights and Choices

The CCPA provides 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 access to your Personal Information that Vituity has collected over the past 12 months.

Delete and Correct my Personal Information

You have the right to request that Vituity delete any of the Personal Information and to correct any Personal Information that we have collected from you subject to certain exceptions.

If we cannot comply with your request, we will explain the reasons why in our response.

Exercising Access, Data Portability, and Deletion Rights

Only you, or someone legally authorized to act on your behalf, may make a verifiable Consumer request related to your Personal Information. If using a legally authorized agent, we reserve the right to require verification of your authorized agent’s identity and authority. 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 their authorized representative. This may include proof of valid government-issued identification, attestation under penalty of perjury that you are a California resident, or other proof of identity acceptable to us at our sole discretion.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to 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. We will only use Personal Information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.

Personal Information Sales and Share Opt-Out

We do not sell your Personal Information. You have the right to direct us not to share your Personal Information at any time (the “Right to Opt-Out”). You may indicate your choice to opt-out of the sharing of your personal data with third parties for personalized advertising by visiting our Website Privacy Policy.

Timing and Format for Vituity’s Response

Vituity will respond to a verified Consumer request within forty-five (45) days of its receipt. If we require more time to respond (up to 90 days), we will inform you in writing of the reason we need the extension period. All disclosures we provide will only cover the 12-month period preceding the receipt of the verified Consumer request. We do not charge a fee for verified Consumer requests, except for as provided by the CCPA.

You may submit a Consumer request by clicking here. You may also submit a Consumer request by calling us at (855) 550-0007.

Children

Vituity does not knowingly collect Personal Information from children under the age of 13. If Vituity is made aware of collecting information from a child under 13, we will delete this information.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Vituity will not charge you different prices for services, deny you services, provide you with different level of quality of service, or suggest that you receive a different price or rate for services or a different level of quality of service.

Right to Amend CCPA Privacy Policy

This CCPA Privacy Policy supplements the information contained in the Website Privacy Policy. Vituity reserves the right to amend this CCPA Privacy Policy at our own discretion and at any time. When we do, we will post the updated CCPA Privacy Policy and revise the date at the bottom of this page. We encourage you to frequently check this page to stay informed about how we are helping to protect the Personal Information we collect. You acknowledge and agree that it is your responsibility to review this CCPA Privacy Policy periodically and become aware of any modifications.

Emily Wang Zahn, SVP and Chief Compliance Officer and Chief Privacy Officer, Vituity

Vituity

(855) 550-0007
compliance@vituity.com

Last updated: May 31, 2023