This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the
its subsidiaries (collectively, “we,” “us,” or “our”) and applies
solely to visitors, users, and others who reside in the State of
California (“consumers” or “you”). We adopt this notice to comply
with 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.
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
consumer or device (“personal information”). In particular, we may
have collected the following categories of personal information
from consumers within the last twelve (12) months:
||Examples of Data
A real name, email address, telephone number, postal
address, online identifier, user ID, device ID, domain
server, type of device/operating system, browser used to
access our services, Internet Protocol address, account
name, driver's license number, passport number, or other
B. Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A real name, email address, telephone number, postal
address, passport number, driver's license or state
identification card number, insurance information (including
insurance carrier, insurance plan, member ID, group ID,
payer ID), education, employment, employment history,
medical information, or health insurance information. Some
personal information included in this category may overlap
with other categories.
C. Protected classification characteristics under California
or federal law.
Age, race, ethnicity, color, ancestry, national origin,
citizenship, zip code, 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).
|D. Commercial information.
Records of personal property, products or services
purchased, obtained, or considered, or other purchasing or
consuming histories or tendencies.
|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 or exercise data.
|F. Internet or other similar network activity.
Browsing history, search history, information on a
consumer's interaction with a website, application, or
advertisement, referring webpage/source through which you
access our services, non-identifiable request IDs, and
statistics associated with the interaction between device or
browser and our services.
|G. Geolocation data.
Approximate location (city and state) of the device from
which you access out services.
|H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar
|I. Professional or employment-related information.
||Current or past job history.
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.
|K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics,
psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.
|L. Medical Data
Medical history and health information you provide us,
including health conditions, healthcare providers visited,
reasons for visit, dates of visit, booking and appointment
data (including appointment date/time, provider information,
appointment procedure, whether or not user is a new patient
for a particular provider).
M. Other Identifying Information That You Voluntarily Chose
Personal Data in emails, letters or online forms that you
send or submit to us.
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
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;
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 from
the following categories of sources:
Directly from our clients or their agents. For example, from
information that our clients provide to us related to the
services for which they engage us.
Indirectly from Physician Providers or their agents. For
example, through information we collect from Physician
Providers in the course of providing services to them.
Directly and indirectly from activity on our website
(kalypsys.com). For example, from submissions through our
website portal or website usage details collected
From third-parties that interact with us in connection with
the services we perform.
Use of Personal Information
We may use or disclose the personal information we collect for one
or more of the following business purposes:
To fulfill or meet the reason for which the information is
provided. For example, if you provide us with personal
information in order for us to provide you with a selection of
healthcare providers relevant to the criteria you input, we
will use that information to prepare and submit to you a
selection of such healthcare providers.
To provide you with information, products or services that you
request from us.
To provide you with email alerts and other notices concerning
our products or services, or events or news, that may be of
interest to you.
To carry out our obligations and enforce our rights arising
from any contracts entered into between you and us, including
for billing and collections.
- To improve our website and present its contents to you.
For testing, research, analysis and development of service
As necessary or appropriate to protect the rights, property or
safety of us, our clients or others.
To respond to law enforcement requests and as required by
applicable law, court order, or governmental regulations.
As described to you when collecting your personal information
or as otherwise set forth in the CCPA.
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
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
Sharing Personal Information
We may disclose your personal information to a third party for a
business purpose. When we disclose personal information for a
business purpose, we enter a contract that describes the purpose
and requires the recipient to both keep that personal information
confidential and not use it for any purpose except performing the
In the preceding twelve (12) months, we have or may have disclosed
the following categories of personal information for a business
California Customer Records personal information categories.
Protected classification characteristics under California or
||Internet or other similar network activity.
||Professional or employment-related information.
Other Identifying Information That You Voluntarily Chose to
We disclose your personal information for a business purpose to
the following categories of third parties:
- Our affiliates.
- Service providers, including Physician Providers.
Third parties to whom you or your agents authorize us to
disclose your personal information in connection with products
or services we provide to you.
In the preceding twelve (12) months, we have not sold any personal
Your Rights and Choices
The CCPA provides consumers (California residents) with specific
rights regarding their personal information. This section
describes your CCPA rights and explains how to exercise those
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 12 months. Once we receive and confirm your
verifiable consumer 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 share that
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
Deletion Request Rights
You have the right to request that we delete any of your personal
information that we collected from you and retained, subject to
certain exceptions. Once we receive and confirm your verifiable
consumer request, we will delete (and direct our service providers
to delete) your personal information from our records, unless an
We may deny your deletion request if retaining the information is
necessary for us or our service providers to:
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 contract with you.
Detect security incidents, protect against malicious,
deceptive, fraudulent, or illegal activity, or prosecute those
responsible for such activities.
Debug products to identify and repair errors that impair
existing intended functionality.
Exercise free speech, ensure the right of another consumer to
exercise their free speech rights, or exercise another right
provided for by law.
Comply with the California Electronic Communications Privacy
Act (Cal. Penal Code § 1546 seq.).
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, if you previously
provided informed consent.
Enable solely internal uses that are reasonably aligned with
consumer expectations based on your relationship with us.
- Comply with a legal obligation.
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 the access, data portability, and deletion rights
described above, please submit a verifiable consumer request to us
Only you or a person registered with the California Secretary of
State that you authorize 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
You may only make a verifiable consumer request for access or data
portability twice within a 12-month period. The verifiable
consumer request must:
Provide sufficient information that allows us to reasonably
verify you are the person about whom we collected personal
information or a legally 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 the personal information relates to you.
Making a verifiable consumer request does not require you to
create an account with us. We will only use personal information
provided in a verifiable consumer request to verify the
requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45
days of its receipt. If we require more time (up to 90 days), we
will inform you of the reason and extension period in writing. If
you have an account with us, we will deliver our written response
to that account. If you do not have an account with us, we will
deliver our written response by mail or electronically, at your
option. Any disclosures we provide will only cover the 12-month
period preceding the verifiable consumer request's receipt. The
response we provide will also explain the reasons 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
consumer 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.
We will not discriminate against you for exercising any of your
CCPA rights. In that regard, we will not take the following
actions in response to your exercising of your CCPA rights, unless
permitted by the CCPA:
- Deny you goods or services.
Charge you different prices or rates for goods or services,
including through granting discounts or other benefits, or
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
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our
discretion and at any time. When we make changes to this privacy
notice, we will notify you by email or through a notice on our
website homepage. You will also be able to determine the date that
the CCPA policy has become effective, by viewing the Effective
Date at the top of this document.
If you have any questions or comments about this notice, our
Privacy Statement, 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 at:
c/o Wilson Elser
Attn: Neil Prupis
200 Campus Drive
Florham Park, NJ 07932