Privacy Notice for California Residents

Last Updated: December 18, 2023

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This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in the Claimant Medical Data Solutions, LLC Privacy Policy (the “Privacy Policy”) made available on the website located at www.cmdatasolutions.com (the “Site”). The Site is owned and operated by Claimant Medical Data Solutions, LLC (“Company,” “we,” “us” or “our”). This Privacy Notice applies solely to residents of the State of California (“CA Users”). We adopt this Privacy Notice in compliance with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”). Any terms defined in the CCPA and/or CPRA have the same meaning when used in this Privacy Notice. CA Users with disabilities who wish to access this Privacy Notice in an alternative format can contact us by emailing us at: privacy@cmdatasolutions.com; by calling us at: (888) 757-4011; or sending us U.S. Mail to: Claimant Medical Data Solutions, 890 Winter Street, Suite 230 Waltham, MA 02451.

Categories of Information We Collect

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 CA User or device (“personal information“). In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, postal address, telephone number, passport number, driver’s license or State identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a CA User’s interaction with a website, application or advertisement. YES
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO
L. Sensitive Personal Information (Cal. Civ. Code §1798.140(ae)). A Social Security number, driver’s license number, state identification card number, or passport number. Account log-in information, financial account, or debit or credit card number used in combination with any required security code, access code, password, or log-in credentials necessary to access an account. Precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership. The contents of a consumer’s U.S. mail, electronic mail, or text messages unless the business is the intended recipient, and a consumer’s genetic data. YES

Personal information does not include:

  • Publicly available information from government records.
  • Information that we believe has been lawfully made public by the consumer or from widely distributed media or from disclosure to a third party by the consumer where the consumer did not limit disclosure to a specific audience.
  • De-identified or aggregated CA User information.
  • 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; and
  • 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.

We obtain the categories of personal information listed above (including the information set forth in the “Personal Information that We Collect” section above) from the following categories of sources (with the specific categories of personal information indicated in parenthesis):

  • Directly from our CA Users. For example, from online Surveys and/or registration forms that our CA Users submit to us in connection with the products and/or services that we offer by and through the Site. (Categories A, B, C and L)
  • Indirectly from our CA Users. For example, through information we collect from our CA Users in the course of providing our products and/or services to them. (Categories A, B, C and F)
  • Directly and indirectly from activity on the Site. This includes the type of browser that the CA User uses (e.g., Safari, Chrome, Internet Explorer), CA User IP address, the type of operating system used by the CA User (e.g., Windows or iOS) and the domain name of the CA User’s Internet Service Provider. In addition, we obtain certain Site usage details and analytics as same are collected automatically by us and our third party partners. (Category F)
  • From third-parties that interact with us in connection with the products and/or services that we offer to our CA Users. For example, third party entities that assist us in sending direct and electronic mail, removing duplicate information from CA User lists, analyzing data and providing marketing analysis. (Categories A, B, C and F)

Retention of Personal Information and Sensitive Personal Information

We retain all categories of your personal information and sensitive personal information (including the information set forth in the “Personal Information that We Collect” section above) that we collect for the maximum period permitted by applicable law. We may also use certain criteria to determine whether and when to delete certain categories of collected personal and sensitive personal information including:

  • Date of collection.
  • Frequency of consumer interaction with us.
  • Last interaction the consumer had with us.
  • Whether the purpose of collection has been completed.

Use of Personal Information

We may use the personal information that we collect (including the information set forth in the “Personal Information that We Collect” section above) for one or more of the following business purposes (with the specific categories of personal information indicated in parenthesis):

  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with your purchase of products and/or services, we will use that information to process your order. (Categories A, B, C, F and L)
  • To provide you with information, products or services that you request from us. (Categories A, B, C, F and L)
  • To create, maintain, customize and secure your account with us. (Categories A, B, C and F)
  • To provide you with e-mail, direct mail and telemarketing messages concerning certain Company products and/or services, as well as third-party products and/or services, that we believe may be of interest to you. (Categories A, B, C and F)
  • To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (Categories A, B, C and F)
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Site’s Terms and Conditions. (Categories A, B, C, F and L)
  • To improve the Site and better present its contents to you. (Categories A, B, C and F)
  • For customer service purposes and to respond to inquiries from you. (Categories A, B and C)
  • For testing, research, analysis and product development. (Categories A, B, C and F)
  • As necessary or appropriate to protect our rights, property or safety, and that of our clients and/or others. (Categories A, B, C, F and L)
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Categories A, B, C, F and L)
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA and/or CPRA. (Categories A, B, C, F and L)
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred. (Categories A, B, C, F and L)

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 with notice.

Sharing Personal Information

Subject to your right to opt-out of such sharing/sale, we may share, rent and/or sell your personal information from Categories A, B, C and F (but not Sensitive Information from Category L) ((including the information set forth in the “Personal Information that We Collect” section above)): (i) with/to third parties for marketing purposes; and (ii) for the other business purposes set forth above.

When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from CA Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of CA Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of CA Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months.

In the preceding twelve (12) months, we have disclosed the following categories of personal information ((including the information set forth in the “Personal Information that We Collect” section above)) for a business purpose:

Category A Identifiers.
Category B California Customer Records personal information categories.
Category C Protected classification characteristics under California or federal law.
Category F Internet or other similar network activity.
Category L Sensitive Personal Information (disclosed solely as required in connection with facilitating your request for SSDI benefit-related products and/or services).

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates. (Categories A, B, C and F)
  • Service providers. (Categories A, B, C, F and L)
  • Third parties who provide the products and/or services featured on the Site. (Categories A, B, C and F)
  • Third parties who purchase and/or license your personal information for marketing purposes, including: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers. If a third party purchaser of your personal information wants to resell it, that purchaser is required by law to provide you with explicit notice and an opportunity to opt-out of further sales, unless the right to resell it was secured by us at the point of collection. (Categories A, B, C and F); provided, however, that we do not share Sensitive Information with third parties for this purpose.
  • Third parties to whom you authorize us to disclose your personal information in connection with the products and/or services that we provide to you. (Categories A, B, C, F and L)

In the preceding twelve (12) months, we have sold the following categories of personal information (including the information set forth in the “Personal Information that We Collect” section above, but not the Sensitive Information, other than as required in connection with facilitating your application for SSDI benefits) to third parties:

Category A Identifiers.
Category B California Customer Records personal information categories.
Category C Protected classification characteristics under California or federal law.
Category F Internet or other similar network activity.

In the preceding twelve (12) months, we have sold the above referenced categories of personal information (including the information set forth in the “Personal Information that We Collect” section above, but not the Sensitive Information) to the third parties who purchase and/or license your personal information for marketing purposes, as well as the third parties who provide the products and/or services featured on the Site.

Your Rights and Choices

The CCPA and CPRA provide CA Users (California residents) with specific rights regarding their personal information. This section describes your CCPA and CPRA rights and explains how to exercise those rights.

Opt-Out from the Sale or Sharing of Your Personal Information

You have the right to opt-out of our sale of your personal information (including sensitive information) to third parties. To exercise any or all of these rights to limit our use of your personal information, please submit a verifiable User request to us by either:

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.

Opt-Out from the Sharing of Your Personal Information

You have the right to opt-out of our sharing your personal information with third parties. To exercise your right to opt-out of our sharing your personal information with third parties, please submit a verifiable CA User request to us by either:

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.

Opt-Out from the Use and/or Sharing of Your Sensitive Personal Information

You have the right to limit our use of your sensitive personal information, including any sensitive information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law) and/or Category L (Sensitive Personal Information), to those uses which: (i) are necessary to perform the services or provide the goods requested by you; (ii) help us to ensure security and integrity of your personal information to the extent the use of your sensitive personal information is reasonably necessary and proportionate for these purposes; (iii) are short-term, transient uses including, but not limited to, non-personalized advertising shown as part of your then-current interaction with the Site, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the then-current interaction with the Site; (iv) involve performing services on behalf of Company, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of Company; and (v) include activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by, Company, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by, Company.
You also have the right opt-out of our sharing your sensitive personal information with third parties, including any sensitive information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law) and/or Category L (Sensitive Personal Information).

To exercise your right to limit our use of your sensitive personal information and/or opt-out of our sharing your sensitive personal information with third parties, please submit a verifiable CA User request to us by either:

We endeavor to act on all such requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable CA User request, we will 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 have shared that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Right to Request Correction of Inaccurate Personal or Sensitive Personal Information

You have the right to request correction of inaccurate personal and/or sensitive personal information that we collect. Upon receiving a verifiable consumer request for correction, we will make commercially reasonable efforts to correct information identified as inaccurate.

Right to Request Deletion of Personal and/or Sensitive Personal Information

You have the right to request that we delete any of your personal information and/or sensitive information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech rights, ensure the right of another CA User to exercise her/his free speech rights or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, but only if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with CA User expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability and Deletion Rights

To exercise your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by either:

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information.

You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must:

  • Provide sufficient information that allows us to reasonably verify that you are: (1) the person about whom we collected personal information; or (2) an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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 that the personal information relates to you. Making a verifiable CA User request does not require that you create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures that we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response that we provide will also explain the reasons that we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable CA User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

How to Submit an Appeal
You may appeal our decision with respect to a request you have submitted by going to our Internal Dispute Notice.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA and/or CPRA rights. Unless permitted by the CCPA and/or CPRA, 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; and/or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We reserve the right to amend these Privacy Provisions in our discretion and at any time. When we make changes to these Privacy Provisions, we will notify you by email or through a notice on the Site’s homepage.

Contact Information

If you have any questions or comments about these Privacy Provisions, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either: