Privacy Policy for California Residents
Effective Date: May 6, 2024
This Privacy Policy for California Residents (“CCPA Privacy Policy”) applies to SQ Care Management, LLC processing of personal information of California residents to the extent the information is subject to the California Consumer Privacy Act of 2018 (“CCPA”). This CCPA Privacy Policy does not apply to personal information collected pursuant to: (i) the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act; or (ii) certain medical and health information covered by HIPAA. This CCPA Privacy Policy supplements and does not replace our website Privacy Policy and Terms and Conditions.
Categories of Personal Information We Collect, Use, or Disclose
SQ Care Management, LLC collects 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 (“Personal Information”).
In general, within the last twelve (12) months SQ Care Management, LLC has collected consumers’ Personal Information so we can provide you with products and services and satisfy our legal obligations. Further, we share consumers’ Personal Information with other businesses who provide services to us, and with government agencies and regulators so that we can provide our products and services to consumers. We may also share a consumer’s Personal Information with our affiliates or in the event of a business transfer. Additional detail on how SQ Care Management, LLC processes Personal Information of consumers is set forth below.
Category of Personal Information
Identifiers
Examples: Real name, postal address, email address, Social Security number, driver’s license number, or other similar identifiers. In addition, through online facilities or services, (e.g., our website) we collect the following identifiers: Internet Protocol address.
Categories of Sources of Personal Information: Directly from you, for example when you fill out an application or file a claim, from your transactions with us, and from third parties that interact with us in connection with the products and/or services we provide as permitted by law, as well as our service providers.
As a result of your use of our website or other online services, and from third parties such as website analytics providers.Business or Commercial Purpose(s) for which Used: We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
○ Providing you with the services that you request, such as by completing transactions, processing registration, processing claims, or processing your application for one of our products, or
○ Communicating with you, for example to respond to inquiries, or
○ To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations.
We use this information to provide services to you and to maintain our website or other online services, such as:
○ To help maintain the safety, security, and integrity of our website, information systems, databases and other technology assets, or
○ To personalize the website experience and to deliver content and product and service offerings relevant to your interests, or
○ To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations.Categories of Third Parties with Whom Personal Information is Shared, if any: We share Personal Information as permitted or required by law in connection with performance of our services and for our business operations, including:
○ Administrative service providers, or
○ Our affiliates, pursuant to a business transfer, or
○ Government agencies if required by law, or
○ Advertising or social media networks, to direct content to consumers.
We may share this information as described above as well as with third parties providing:
○ Application and security services,
○ Website or other online hosting services, or
○ Information technology services.
Our website may provide links to content or services controlled or owned by third parties. When website visitors interact with such third-party content or services, they may be sharing their Personal Information with such third parties.
Categories of Personal Information Identified in the California Customer Records Statute (Note: Some Personal Information included in this category may overlap with other categories)
Examples: A person’s name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, employment, bank account number, credit card number, or debit card number.
Categories of Sources of Personal Information: We collect this information from the categories of sources of Personal Information listed next to “Identifiers” above.We collect this information from the categories of sources of Personal Information listed next to “Identifiers” above.
As a result of your use of our website or other online services, and from third parties such as website analytics providers.
Business or Commercial Purpose(s) for which Used: We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
○ Providing you with the services that you request, such as by completing transactions, processing claims, or processing your application for one of our products, or
○ Communicating with you, for example to respond to inquiries, or
○ To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations.Categories of Third Parties with Whom Personal Information is Shared, if any: We may share Personal Information as permitted or required by law in connection with performance of our services, and for our business operations, such as:
○ Administrative service providers, or
○ Our affiliates, pursuant to a business transfer, or
○ Government agencies if required by law, or
○ Advertising or social media networks, to direct content to consumers.
Characteristics of protected classifications under California or federal law
Examples: Age, citizenship, marital status, medical condition, physical or mental disability, sex (including pregnancy).
Categories of Sources of Personal Information: Directly from you, for example when you fill out an application or file a claim, from your transactions with us, and from third parties that interact with us in connection with the products and/or services we provide as permitted by law, as well as our service providers.
Business or Commercial Purpose(s) for which Used: We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
○ Providing you with the services that you request, such as by completing transactions, processing registration, processing claims, or processing your application for one of our products, or
○ To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations.Categories of Third Parties with Whom Personal Information is Shared, if any: We may share Personal Information as permitted or required by law in connection with performance of our services and for our business operations, including:
○ Administrative service providers, or
○ Our affiliates, pursuant to a business transfer, or
○ Government agencies if required by law, or
○ Advertising or social media networks, to direct content to consumers.
Internet or other electronic network activity information
Examples: Browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement.
Categories of Sources of Personal Information: As the result of your use of our online services, such as our website, consumer portals or mobile applications (if any), including through the use of cookies, Web beacons, embedded scripts, and other recognition and/or tracking technologies.
Business or Commercial Purpose(s) for which Used: We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
○ To provide access to our website and the information about our products and services contained therein, or
○ For the security of our website and information systems, or
○ Providing you with information, including communications about products that may be of interest to you, or
○ To support, personalize, improve our website, products or services, or
○ To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations.
Categories of Third Parties with Whom Personal Information is Shared, if any: We may share Personal Information as permitted or required by law in connection with performance of our services, and for our business operations, such as:
○ Administrative service providers, or
○ Our affiliates, pursuant to a business transfer, or
○ Government agencies if required by law, or
○ Advertising or social media networks, to direct content to consumers.
Professional or employment-related information
Examples: Current employment-related information.
Categories of Sources of Personal Information: Directly from you, for example when you fill out an application or file a claim, from your transactions with us, and from third parties that interact with us in connection with the products and/or services we provide as permitted by law, as well as our service providers.
Business or Commercial Purpose(s) for which Used: We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
○ Providing you with the services that you request, such as by completing transactions, processing registration, processing claims, or processing your application for one of our products, or
○ To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations.Categories of Third Parties with Whom Personal Information is Shared, if any: We may share Personal Information as permitted or required by law in connection with performance of our services, and for our business operations, such as:
○ Administrative service providers, or
○ Our affiliates, pursuant to a business transfer, or
○ Government agencies if required by law, or
○ Advertising or social media networks, to direct content to consumers.
Disclosure or Sale of Personal Information for a Business or Commercial Purpose
Our disclosures of Personal Information for business or commercial purposes in the preceding twelve (12) months are disclosed above.
In the preceding twelve (12) months, we have not sold any California resident’s personal information.
Your Privacy Rights
Right to Know
You have the right to request that we disclose to you the Personal Information we collect, use, or disclose about you.
You can visit our form or call (833) 613-2111 to make a disclosure request. You may make up to two requests in any 12-month period.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
Making a verifiable consumer request does not require you to create an account with us. We do, however, consider requests made through a password-protected account that is sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make 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.
Right to Request Deletion
You have the right to request that we delete your Personal Information. You may make such a request by visiting our form or calling (833) 613-2111.
You should be aware, however, that California law allows us to retain your Personal Information under certain conditions, even if you have asked us to delete it, such as when retaining your Personal Information is necessary for us to complete a transaction with you or provide you with a good or service you have requested. We will notify you of any denial of your deletion request and the reason for such denial.
Non-Discrimination
We will not discriminate against you for exercising your rights under the CCPA. Unless otherwise 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 a different level or quality of goods or services, or
Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Using an Authorized Agent
You may use an authorized agent to submit a “request to know” or “request to delete.” To use an authorized agent, you will need to (i) provide written instruction to your agent, and verify your identity to us, or (ii) provide a power of attorney pursuant to California Probate Code Sections 4000 to 4465.
Contact Us
If you have questions about this CCPA Privacy Policy, please contact us at SQ Care Management, LLC by writing us at 6800 W. 115th Street, Suite 2511, Overland Park, KS 66211, or by calling us at (833) 613-2111.
