CCPA Policy – Advanced Practice Nursing Specialists

Last updated August 24th, 2024

This policy explains the rights of California residents regarding the collection, use, sale, and sharing of their personal information under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We may update and make changes to this policy, so we encourage you to review it periodically.

1. Key Terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our: Another Way Holdings, LLC; Advanced Practice Nursing Specialists, LLC
Compliance officer: David Memmoli, david.memmoli@advancedpracticenursingspecialists.com
Affiliate Sites: https://www.athenahealth.com, https://yosi.health
Personal information: Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household.
Sensitive personal information: Personal information revealing a consumer’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer’s health, sex life, or sexual orientation, contents of a consumer’s mail, email and text messages where the business is not the intended recipient, genetic data, and biometric information.
Biometric Information: An individual’s physiological, biological, or behavioral characteristics, including information pertaining to an individual’s DNA, that is used or intended to be used to establish individual identity. This includes imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings from which an identifier template can be extracted, as well as keystroke patterns, gait patterns, and sleep, health, or exercise data containing identifying information.

2. Personal Information We Collect About You

In the preceding 12 months, we may have collected the following categories and specific types of consumer personal information:

Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or similar identifiers): Real name, postal address, online identifier, email address, government issued ID
Information identifying a particular individual (e.g., name, signature, social security number, physical characteristics, address, telephone number, passport number, driver’s license or state ID number, insurance policy number, education, employment history, bank account number, credit or debit card number, financial information, medical information, or health insurance information): Legal name, address, telephone number, government issued ID, insurance policy number, health insurance information, and credit card number
Characteristics of protected classifications under California or federal law: As above
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies): N/A
Biometric information: Height and weight
Internet or other electronic network activity information (e.g., browsing history, search history, interactions with a website, application, or advertisement): N/A
Geolocation data: Geolocation data
Audio, electronic, visual, thermal, olfactory, or similar information: Electronic or visual information provided by patients as part of clinical care
Professional or employment-related information: Employment history if appropriate depending on clinical context
Education information, as defined by FERPA: N/A
Inferences drawn from any of the information above to create a profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes: N/A
Sensitive Personal Information: Protected health information, personal identifiable information as above, and demographic data as above

3. How Your Personal Information Is Collected

We collect most of this personal information directly from you — in person, by telephone, text, or email, and/or via our website. However, we may also collect information from the following categories of sources:

Publicly accessible sources (e.g., property records)
Third parties (e.g., sanctions screening providers, credit reporting agencies, customer due diligence providers, advertising networks, internet service providers, social networks, data analytics providers, government entities, and data brokers)
Third parties with your consent (e.g., your bank)
Cookies on our website
Automated information collection
Our IT systems, including:
- Door entry systems and reception logs
- Automated monitoring of our websites and other technical systems, such as computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems

4. Why We Use Your Personal Information

We collect, and may sell and/or share, consumer personal information for the following business purposes:

Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
Helping to ensure security and integrity to the extent reasonably necessary and proportionate for these purposes
Debugging to identify and repair errors that impair existing intended functionality
Short-term, transient use, including non-personalized advertising shown as part of a consumer’s current interaction, provided the information is not disclosed to another third party or used to build a profile or alter the consumer’s experience outside that interaction
Performing services on behalf of the business, including maintaining or servicing accounts, customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, analytic services, storage, or similar services
Providing advertising and marketing services, except for cross-context behavioral advertising
Undertaking internal research for technological development and demonstration
Verifying or maintaining the quality or safety of a service or device owned, manufactured, or controlled by the business, and improving, upgrading, or enhancing it
Complying with our legal and regulatory obligations
Performance of our contract with you or to take steps at your request before entering into a contract
Our legitimate interests or those of a third party
Where you have given consent

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

To provide high quality healthcare to you: For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or the company and its associates: For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity: Screening for financial and other sanctions or embargoes
Complying with professional, legal, and regulatory obligations (e.g., health and safety regulation or professional regulator rules): To comply with our legal and regulatory obligations
Gathering and providing information for audits, enquiries, or investigations by regulatory bodies: To comply with our legal and regulatory obligations
Ensuring business policies are adhered to (e.g., security and internet use policies): For our legitimate interests or those of a third party
Operational reasons such as improving efficiency, training, and quality control: For our legitimate interests or those of a third party
Ensuring the confidentiality of commercially sensitive information: For our legitimate interests or those of a third party
Statistical analysis to help manage our business (e.g., financial performance, customer base, product range): To comply with our legal and regulatory obligations
Preventing unauthorized access and modifications to systems: For our legitimate interests or those of a third party
Updating and enhancing customer records: For the performance of our contract with you or to take steps at your request before entering into a contract
Statutory returns: To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration, and assessments: To comply with our legal and regulatory obligations and for our legitimate interests
Marketing our services to existing/former customers and interested third parties: For our legitimate interests, i.e., to promote our business
Credit reference checks via external agencies: For our legitimate interests, i.e., to ensure customers can pay for our products and services
External audits and quality checks (e.g., accreditations, audit of accounts): For our legitimate interests and to comply with legal and regulatory obligations

5. With Whom We Share Your Personal Information

In the preceding 12 months, we have sold or shared consumers’ personal information with:

Our affiliates, including companies within Advanced Practice Nursing Specialists and associated medical groups
Service providers we use to help deliver our products and/or services, such as payment service providers, partner pharmacies, revenue cycle management contractors, and delivery companies
Other third parties we use to help run our business, such as marketing agencies or website hosts
Third parties approved by you, including linked social media sites or third-party payment providers
Credit reporting agencies
Our insurers and brokers (HPSO)
Our banks (U.S. Bank, Wells Fargo)
External auditors

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect it. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

6. Categories of Personal Information We Sold or Shared

In the preceding 12 months, we have sold or shared the following categories of personal information:

Identifiers
Information identifying a particular individual (as described above)
Characteristics of protected classifications under California or federal law
Commercial information
Biometric information
Internet or other electronic network activity information
Geolocation data
Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
Education information (as defined by FERPA)
Inferences drawn to create a consumer profile
Sensitive personal information

7. Categories of Personal Information We Disclosed for a Business Purpose

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

Identifiers
Information identifying a particular individual (as described above)
Characteristics of protected classifications under California or federal law
Commercial information
Biometric information
Internet or other electronic network activity information
Geolocation data
Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
Education information (as defined by FERPA)
Inferences drawn to create a consumer profile
Sensitive personal information

8. How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints, or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

9. Your Rights Under the CCPA/CPRA

You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge the rights below.

Disclosure of Personal Information We Collect About You

You have the right to know, and request disclosure of:

The categories of personal information we have collected about you, including sensitive personal information;
The categories of sources from which the personal information is collected;
Our business or commercial purpose for collecting, selling, or sharing personal information;
The categories of third parties to whom we disclose personal information, if any; and
The specific pieces of personal information we have collected about you.

Please note that we are not required to:

Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information is not retained;
Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
Provide the personal information to you more than twice in a 12-month period.

Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose

In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

The categories of personal information about you that we sold or shared and the categories of third parties to whom it was sold or shared; and
The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed.

You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise this right, we will refrain from selling or sharing your personal information unless you subsequently provide express authorization for the sale or sharing of your personal information.

To opt-out of the sale or sharing of your personal information, visit our homepage and click on the Do Not Sell or Share My Personal Information link here: [URL].

Right to Limit Use of Sensitive Personal Information

You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:

Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;
Perform the following services: (1) helping to ensure security and integrity to the extent reasonably necessary and proportionate; (2) short-term, transient use, including non-personalized advertising, provided the information is not disclosed to another third party or used to build a profile or alter the consumer’s experience outside that interaction; (3) performing services on behalf of the business, such as maintaining accounts, customer service, processing orders and transactions, verifying customer information, processing payments, financing, analytic services, or storage; and (4) verifying or maintaining the quality or safety of a service or device, and improving, upgrading, or enhancing it; and
As authorized by further regulations.

You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

Delete your personal information from our records;
Direct any service providers or contractors to delete your personal information from their records; and
Direct third parties to whom we have sold or shared your personal information to delete it, unless this proves impossible or involves disproportionate effort.

Please note that we may not delete your personal information if it is reasonably necessary to:

Complete the transaction for which it was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or otherwise perform a contract between you and us;
Help to ensure security and integrity to the extent reasonably necessary and proportionate;
Debug to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise free speech, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act;
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest, when deletion would impair such research and we have obtained your informed consent;
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
Comply with an existing legal obligation; or
Otherwise use your personal information internally, in a lawful manner compatible with the context in which you provided it.

Right of Correction

If we maintain inaccurate personal information about you, you have the right to request that we correct it. Upon receipt of a verifiable request, we will use commercially reasonable efforts to correct the inaccurate personal information.

Protection Against Retaliation

You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:

Deny goods or services to you;
Charge different prices or rates for goods or services, including through discounts, other benefits, or penalties;
Provide a different level or quality of goods or services to you; or
Suggest that you will receive a different price, rate, level, or quality of goods or services.

Please note that we may charge a different price or rate, or provide a different level or quality of goods and/or services, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs, or payments as compensation, for the collection, sale, or retention of personal information.

10. How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Policy, you can do so by emailing support@getzealthy.com.

Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us, you will need to provide us with:

Enough information to identify you (e.g., your full name, address, and customer or matter reference number);
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

11. Contact Information

Please contact us with any questions or concerns regarding this Agreement at:

Email: info@advancedpracticenursingspecialists.com
Address: Advanced Practice Nursing Specialists, 9205 W Russell Rd, Suite 305, Las Vegas, NV 89148