Privacy Notice

Last Updated: 31 December 2019

MODERNIZING MEDICINE: PRIVACY NOTICE FOR CALIFORNIA RESIDENTS SEEKING EMPLOYMENT WITH MODERNIZING MEDICINE, INC.

INTRODUCTION

If you are a California resident who has applied for or sought employment with Modernizing Medicine, Inc. (the “Company”, “we”, “us”, or “our”), this Privacy Notice applies to you (“Prospective California Employees” or “you”).

SCOPE

  1. This notice is intended to describe our practices as required by the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice. This Privacy Notice supplements information contained in our Privacy Policy and takes precedence over the Privacy Policy with respect to CCPA Personal Information for Prospective California Employees if there is a conflict between the two.
  2. In this Privacy Notice, when we talk about “CCPA Personal Information”, we mean information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Prospective California Employee.
  3. You should be aware that CCPA Personal Information does not include:
    1. Publicly available information from government records.
    2. De-identified or aggregated consumer information.
    3. Information excluded from the CCPA’s scope, like:
      1. Protected Health Information under HIPAA, information subject to the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or
      2. Personal 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 WE COLLECT FROM PROSPECTIVE CALIFORNIA EMPLOYEES

We have collected the following categories of personal information from Prospective California Employees within the last twelve (12) months:

CategoryExamples
IdentifiersA real name, alias, postal address, unique personal identifier, online identifier, or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))A name, signature, address, telephone number, education, employment or employment history. Some personal information included in this category may overlap with other categories.
Protected classification characteristics under California or federal lawAge (40 years or older), race, color, ancestry, national origin, citizenship, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation or veteran or military status.
Professional or employment-related informationCurrent or past job history, performance evaluations.
Inferences drawn from other personal informationProfile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

USE OF PERSONAL INFORMATION

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

  1. To consider or process an application for employment or to verify information provided to us in connection with the pre-employment process;
  2. To effectively process expense reimbursement requests;
  3. To comply with state and federal law requiring employers to maintain certain records;
  4. As necessary or appropriate to protect the rights, property, or safety of us, our clients or others, including conducting appropriate security and related reviews of our systems;
  5. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations, including garnishments, withholdings or similar requests or proceedings; and
  6. As described to you when collecting your personal information or as otherwise set forth in the CCPA.

    7. 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.

SALES OF PERSONAL INFORMATION

In the preceding twelve (12) months, we have not sold personal information of our Prospective California Employees and will not sell personal information of our Prospective California Employees.

CHANGES TO THIS PRIVACY NOTICE

We may change this Privacy Notice at any time. Unless we say otherwise, changes will be effective upon the last updated date at the top of this Privacy Notice. Please check this Privacy Notice regularly to ensure that you are aware of any changes. We may try to notify you of material changes to this Privacy Notice, which if we do so may be by sending an email notification (if you have provided your email address to us), or by other reasonable methods.

CONTACT INFORMATION

If you have any questions or comments about this Privacy Notice, including how we collect and use your CCPA Personal Information or your choices and rights regarding such use, or if you wish to exercise your rights under California law, please contact us by either:

  1. Calling us at 1-866-799-2146 and asking to speak with the Privacy Officer;
  2. Emailing privacy@modmed.com; or
  3. Writing us at:

    4. Modernizing Medicine, Inc.
    4850 T-Rex Avenue, Suite 200
    Boca Raton, Florida 33431
    Attention: Privacy Officer
    1-866-799-2146

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