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CCPA Privacy Notice

Effective July 8, 2020 

Privacy Notice for California Residents

This Privacy Notice for California Resident supplements the information contained in the Privacy Statement (available at https://www.blinkhealth.com/legal/privacy-policy) as applicable to Blink Health, Inc. and its subsidiaries engaged in e-commerce transactions (collectively, referred to in this CCPA Privacy Notice as “Blink,” “we,” “us,” and “our”)   and applies solely to those visitors, users, and others who reside in the State of California whose Personal Information is subject to CCPA (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. 

How Personal Information may be used 

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer (“Personal information”). In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Categories and Examples

A. Identifiers.  Examples include name, address, personal identifier, IP/email address, account name.
B.  Personal information categories listed in the California Consumer Records statue (Cal. Civ. Code § 1798.80(e)). Examples include name, signature, physical characteristics or descriptions, telephone number, address, insurance policy number, or bank account number, credit card number debit card number, or any other financial information, medical information, or health insurance information.
C. Characteristics of protected classifications under California or federal law.  Examples include age, marital status, medical condition, physical or mental disability, sex. 
D.  Commercial Information. Examples include records of products, services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E.  Internet or other electronic network activity. Examples include browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement.
F.  Geolocation data. Examples include physical location or movements.
G.  Sensory data. Examples include audio, electronic, visual, thermal, olfactory, or similar info, such as a voice recording.
H. Inferences drawn from other personal information. Examples include a profile about a consumer reflecting the consumer’s preferences and behaviors.


For each of the above categories of Personal Information we collect, we may use it for one or more of the following purposes:  To fulfill or meet the reason for which the information is provided, including providing support, respond to inquiries, investigate concerns; to facilitate new services and product orders or process returns; to monitor and improve our responses; to communicate with you and others concerning our products or services; to improve our website and present its contents to you; for testing, research, analysis and product development; to protect the rights, property or safety of you and others; to personalize, advertise, and market our products and services; to undertake quality and safety assurance measures; to conduct risk and security control and monitoring; to detect and prevent fraud; to perform accounting, audit, and other internal functions; to comply with law, legal process, and internal policies; to exercise and defend against legal claims; and as otherwise described to you when collecting your personal information or as otherwise set forth in the CCPA.


We may disclose your Personal Information to a third party, such as a vendor, for business purposes.  In the preceding twelve (12) months, we may have disclosed Personal Information for a business purpose in each of categories A-H above. We may disclose your Personal Information for business purposes to the following categories of third parties:

  • Our affiliates
  • Service providers
  • Third parties to whom you, your agents, or applicable law authorize us to disclose your Personal Information in connection with products or services we provide to you

CCPA requires that we disclose any ‘sale’ of your Personal Information.  The term ‘sale’ may include the releasing or disclosing Personal Information to a third party, such as a vendor, and that party using the Personal Information for their own purposes. In the preceding twelve (12) months, we may have engaged in this type of sale of Personal Information, from categories A, C, D, or E above.  We do not engage in the type of sale of Personal Information that involves the receipt of monetary payment in exchange for Personal Information.

 

Individual Rights and Request

The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

A. Right to Know and Right to Delete

You have the right to request that we (a) disclose certain information to you about our collection and use of your Personal Information over the past 12 months (the "Right to Know"), and (b) delete Personal Information collected from you over the past 12 months (the "Right to Delete") . To exercise the rights described above, please submit a request to us by either:

Once we receive and confirm your request, we will, as applicable:

  1. 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 
  2. Delete Personal information we collected from you

To exercise the Right to Know or the Right to Delete please submit a request to us by either:

For each request, we will ask you:

  • To describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • To provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of that person, we will ask you to provide the following information:
    • Your full name, date of birth, and prescription shipping address; and 
    • As to your most recent prescription received through Blink Health: 
      • The drug name;
      • The name of the pharmacy from which your drug was picked up or delivered; and 
      • Your Blink member ID (which starts with "B" and is followed by seven numbers).


B. Right to Opt Out of Sale 

You also have the right to opt-out of sale of your Personal Information by one of the following methods:

Authorized Agent

You may designate another person (“Authorized Agent”) to act on your behalf with regard to CCPA requests under this Notice.  Requests made by an Authorized Agent will be required to verify your identity as described above.

If you designate an Authorized Agent to act on your behalf with regard to a CCPA request described in this Notice, you must provide us with legal authorization documenting the Authorized Agent’s representation. Examples of acceptable forms of legal authorization would be a fully executed Power of Attorney or a notarized affidavit that indicates the authority to represent you as it pertains to your CCPA request.  This documentation should be provided to Privacy@BlinkHealth.com


Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights; this means 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

 

 

 

 

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