Effective Date: July 31, 2023

e4health Privacy Notice for California Residents

Please note, this Privacy Notice for California Residents is available at e4.health and its related domains and subdomains, including, but not limited to, https://e4.services.com, https://intellisiq.com/ and https://education.intellisiq.com/ (each the “Website” as applicable). e4health maintains other privacy notices to address specific use cases applicable to e4health, which are available at the following locations:

For our Privacy Notice, visit https://www.e4.health/privacy-policy.
If you are a user of the e4health Intellis IQ Education Center, please refer to https://education.intellisiq.com/privacy-policy/ for the IQ Education Center Privacy Notice relating to the e4health training platform for Subscribers and partners.

Introduction

e4 Services, LLC, dba e4health, respects your privacy, and we are committed to protecting your personal information. To that end, we have put together this Privacy Notice for California Residents (“Privacy Notice”) to describe the rights of consumers under the California Consumer Privacy Act of 2018 (“CCPA”). This Privacy Notice applies solely to visitors and users of the Website, recipients of marketing communications from e4health, personnel of e4health, and users of the e4health Intellis IQ Education Center, who reside in the State of California (“consumers” or “you”) to the extent that e4health collects and processes their personal information as a business or service provider (as those terms are defined in the CCPA).

For purposes of this Privacy Notice:

The term “personal information” means any information that identifies, relates to, describes, references are reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal information excludes:
Publicly available information from government records
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, such as the following:
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; and
Personal information is covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Please take the time to read this Privacy Notice and the related statements in their entirety to ensure you are fully informed. If you have any questions or concerns about your rights under the CCPA, please contact us.

Personal Information We Collect

We have collected the following categories of personal 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 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. 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). YES
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. 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. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. YES
I. Professional or employment-related information. Current or past job history or performance evaluations. YES
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. 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

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you if you provide your personal information to us.
Directly and indirectly from activity on e4health websites. For example, from your submissions through our websites’ forms or your website usage details that are collected automatically.
Directly from our prospects, customers, or their agents.
Indirectly from our prospects, customers, or their agents. For example, through information, we collect from our customers in the course of providing services to them.
Personal Information We Use

We may use or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information.
To provide, support, personalize, and develop our websites, 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 websites, products, and services, other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our websites, products, and services.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and e4health, including, but not limited to, our Website Terms of Use.
To notify you about changes to our Website or obtain any required consent.
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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
For other lawful or legitimate purposes, which may be reasonably required for day-to-day operations.
We 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 and if required by law, seeking your consent.

Personal Information We Share

e4health takes care to allow your personal information to be accessed only by those who need to know to perform their tasks and duties and to third parties who have a legitimate business purpose for processing or accessing it. 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. As such, we may share your personal information as described in this Privacy Notice.

Notice to the following categories of recipients:

To our subsidiaries, affiliates, or their or our successors or assigns.
To our private equity investors, affiliates, contractors, service providers, and other third parties which will process the personal data on the basis of its legitimate interests in overseeing the administration, research, and business operations of e4health.
To our contractors, business partners, service providers, and other third parties who require the data to assist us in supporting our business (e.g., third-party hosting facilities) or third parties with products, services, or positions that may be of interest to you, provided such parties provide at least the same level of privacy protection as is required of e4health. These companies are authorized to use your personal data only as necessary to provide these services to us.
To a potential buyer (and its agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our assets (including in the event of a reorganization, dissolution, or liquidation), in which case, personal data held by us about you will be among the assets transferred to the buyer or acquirer.
A third-party under the following circumstances where we, in good faith,: (i) believe we are compelled by applicable law or regulation, judicial request from a court of competent jurisdiction, or another legal process or government authority; (ii) find it necessary to exercise, establish or defend our legal rights; (iii) seek to enforce or apply our Website Terms of Use or terms of any other agreement; (iv) seek to protect e4health’s rights or property; (v) seek to protect e4health, our other customers, or the public from harm or illegal activities; (vi) seek to respond to an emergency which we believe, in good faith requires us to disclose data to prevent harm; or (vii) rely on your consent.
Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Identifiers.
California Customer Records personal information categories.
Protected classification characteristics under California or federal law.
Internet or other similar network activity.
Sensory data.
Professional or employment-related information.
Sales of Personal Information

In the preceding 12 months, e4health has not sold any personal information.

Cookies and Similar Technologies

For information about the cookies and other tracking technologies used by our Website and how to manage your settings for these cookies and technologies, please see our Cookie Notice.

Your CCPA Privacy Rights

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 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 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 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 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 using the contact details under the “Contact Information” heading below.

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

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. 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 forty-five (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.

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.

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 Rights

You have the right to direct us not to sell your personal information at any time. However, we do not sell (as defined in the CCPA) your personal information (and will not sell it without providing a right to opt-out).

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.
Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websites 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 contact us by using the contact details under the “Contact Information” heading below.

How We Treat Do Not Track Signals

Various browsers allow a “do not track” (DNT) setting, which sends a signal to websites visited by an individual about their browser DNT setting. At this time, there is no general agreement on how companies like e4health should interpret DNT signals. Therefore, we do not currently commit to responding to DNT signals. We will continue to monitor developments around DNT browser technology and the implementation of a standard.

Changes to this Notice

e4health reserves the right to update or change this Cookie Notice from time to time. If we make material changes to this Cookie Notice, we will post it to our Website home page prior to or at the time of the change becoming effective. We ask that you review the Cookie Notice periodically to stay informed about any updates or changes that we may have made. You can see when this Cookie Notice was last updated by checking the “Effective Date” displayed at the top of this Cookie Notice.

Contact Information

To ask questions or comment about this Cookie Notice and our privacy practices or if you need to update, change, or remove your personal data or exercise any other rights, please contact us.