Noho Health Inc. California Privacy Notice
Last Updated: April 11, 2020
This California Privacy Notice (the “CA Notice”) supplements the information contained in our Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you”).
This CA Notice provides additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).
Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.
When we use the term “personal information” in this CA Notice, we mean 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.
For the purposes of this CA Notice, personal information does not include:
Publicly available information from government records.
Deidentified, aggregated or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you.
Information excluded from the CCPA’s scope, such as 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 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.
Information relating to our employees, contractors and other personnel.
Collection and use of Personal Information
In the last 12 months, we have collected the following categories of personal information from the categories of sources and for the purposes set forth below, which reference the personal information, sources and purposes described in the ‘Information We Collect and/or Receive’ and ‘How We Use and Share Information’ sections of our Privacy Notice:
|Category of Personal Information Collected||Collected||Commercial or Business Purpose||Categories of Sources|
|Identifiers, including your name, address, phone number, email address, date of birth or other similar identifiers.||✅||
|California Customer Records (Cal. Civ. Code § 1798.80(e)), such as birthdate, contact information and payment information.||✅||
|Protected Classification Characteristics, including your age, race, veteran status, and gender.||✅||
|Commercial Information, including shopping and purchase history.||✅||
|Internet/Network Information, including device information, logs and analytics data.||✅||
|Geolocation Data, including precise location information from your device or generated based on IP address.||✅||
|Sensory Information, including recordings of phone calls with us, where permitted by law.||✅||
|Professional/Employment Information, including your employment history, educational history, and degree relevant to your job application (applicants only).||✅||
|Other Personal Information, including loyalty program data, information you post on our social media pages or otherwise provide to us.||✅||
|Inferences, including predictions about your interests and preferences.||✅||
Disclosure of and Recipients of Personal Information
As described in the ‘How We Use and Share Information’ section in our Privacy Notice, we have disclosed personal information within Noho Health and with a variety of third parties for business purposes. In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose:
- All of the categories of personal information we collect, explained in the table above.
We may from time to time, and we have in the last 12 months, exchanged contact information (Identifiers and CA Customer Records) we maintain for contact information our promotional and marketing partners maintain, which would constitute a “sale” as defined under the CCPA. In addition, as is common practice among companies that operate online, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services, delivering ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. For more information about how to opt out of personal information sharing that constitutes a “sale” under the CCPA, please refer to the ‘Your California Consumer Rights’ section below.
Your California Consumer Rights
California Consumer Rights
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
|The Right to Know||
You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
|The Right to Request Deletion||You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.|
|The Right to Opt Out of Personal Information Sales||You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.|
|The Right to Non-Discrimination||
You have the right not to receive discriminatory treatment for exercising these rights.
However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.
How to Exercise your California Consumer Rights
To Exercise Your Right to Know or Right to Request Deletion
To exercise your Right to Know or your Right to Request Deletion, please submit a request by filling out our Privacy Request Form here, and selecting ‘Download’ or ‘Delete’ as the request type, or by calling our toll-free number: 1 (877) 227-3631.
We will need to verify your identity before processing your request. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems.
To Exercise Your Right to Opt Out of Personal Information Sales
To initiate your request to opt-out, please fill out following form here, or email us at email@example.com with the subject line “California Opt-Out” . We need your name and email address in order to process your request and safeguard your data. To the extent that our third-party advertising and analytics providers’ collection of information from users of our websites and other online services constitutes a “sale” under the CCPA, please refer to the ‘Third-Party Analytics & Advertising’ disclosures in the ‘Information We Collect and/or Receive’ section of our Privacy Notice for more information about the choices and opt-out options you have in relation to those practices. By visiting www.privacyrights.info, you can also opt out from “sales” of this type of personal information by businesses that participate in the DAA’s CCPA Opt-Out Tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices.
Minors Under Age 16
We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at firstname.lastname@example.org to inform us if you, or your minor child, are under the age of 16.
California’s “Shine the Light” Law
California’s “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. In order to facilitate these rights, we do not disclose personal information of California residents to third parties for their direct marketing purposes, as defined under California’s “Shine the Light” law, where the resident opts out of such sharing. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law, please fill out the following Right to Opt Out form here, filling in your first name, last name, and email address, which we need in order to process your request and safeguard your data.
PLEASE NOTE: To opt-out of all disclosures to third parties for direct marketing purposes, you must provide your personal information to be added to our suppression list.
Updates to This CA Notice
We will update this CA Notice from time to time. When we make changes to this CA Notice, we will change the “Last Updated” date at the beginning of this CA Notice. All changes shall be effective from the date of publication unless otherwise provided in the notification.
If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to email@example.com with “California Privacy Notice” in the subject line.
Alternatively, inquiries may be addressed to:
NoHo Health Inc.
75 Varick St.
9th Fl ATTN: Care/of
New York, NY 10013