Last Updated: September 30, 2021
This Privacy Notice for California Residents (“Notice”) applies to consumers who reside in the State of California (“consumers”, “you”) and supplements the privacy statements issued by Ginger.io, Inc., Ginger.io of California Medical P.C. and its affiliates and subsidiaries (collectively “Ginger”, “we”). We adopt this Notice to comply with the California Consumer Privacy Act (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Notice.
PERSONAL INFORMATION WE COLLECT
We may collect certain information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer, household, or device, whether collected online or offline (as further defined in the CCPA, “Personal Information”).
Much of the Personal Information that Ginger collects in the course of delivering our behavioral health services (“Services”) and related healthcare operations is not subject to the CCPA. Personal Information for the purposes of the CCPA does not include: protected health information (“PHI”) that is subject to the Health Insurance Portability and Accountability Act (HIPAA) or medical information as defined in the California Confidentiality of Medical Information Act (CMIA); clinical trial data; or publicly available information from government records. Personal Information also does not include de-identified or aggregated consumer information.
The following is the list of categories of Personal Information which may have been collected from consumers by Ginger within the twelve (12) months prior to the effective date of this Notice:
- Identifiers: such as your name, address, email address, or IP address
- Customer records information listed in Cal. Civ. Code § 1798.80(e): such as your name, address, telephone number, or credit card number
- Protected classifications under California or federal law: such as your age, race, sexual orientation, or marital status
- Online Activity: such as information about your interactions with our website or mobile application.
- Professional or employment-related information: such as your current or past company name, dates of employment, and information that you may provide in a job application
- Education information: such as a student identification number and related data defined in the Family Educational Rights and Privacy Act (FERPA)
- Inferences: inferences drawn from the above to create a profile about you reflecting your preferences, characteristics, trends, or behavior
SOURCES OF PERSONAL INFORMATION
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from our customers or their authorized agents. For example, information our customers provide to us to provision the Ginger Services.
- Directly from you. For example, through information we ask from you when visit our Ginger website, download content, apply for a position, or attend a webinar
- Social networks. For example, Facebook, Instagram, and Twitter, when you share or interact with our content on those platforms
- Other third-party sources. For example, data analytics partners, recruiters, and employment websites
- Directly and Indirectly from you when you use our Services, use our mobile app, or visit our website. For example, usage details collected automatically in the course of your interaction with the Ginger website or mobile application
USE OF PERSONAL INFORMATION
We may use or disclose the Personal Information we collect for one or more of the following business purposes:
- To provide you with the information, products, or services that you request from us.
- To send you with email and text alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you
- To operate and improve our apps and websites, and to present content to you
- To detect, investigate, and respond to security incidents, and potentially malicious, deceptive, fraudulent, or illegal activity
- To carry out our legal and regulatory obligations
- To protect the rights, property or safety of you, us, our customers, or others
- To respond to law enforcement requests and as required by applicable law, court order, or government regulation
- For technical product research, analysis, and development
- To support employment, benefits, and human resources management
- To process a corporate transaction such as a merger, acquisition, reorganization, or sale of company assets
- As described to you when collecting your Personal Information
We will not collect additional categories of personal information or use the Personal Information we have collected for materially different, unrelated, or incompatible purposes without providing you notice.
SHARING OF PERSONAL INFORMATION
During the twelve (12) month period prior to the effective date of this Notice, we may have shared your Personal Information with the following categories of third parties:
- Ginger Affiliates and Subsidiaries
- Service Providers under restrictive contracts
- Government authorities and law enforcement agencies
RIGHT TO KNOW
You have the right to know and request information about the categories and specific pieces of Personal Information we have collected about you within the last twelve (12) months, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed your Personal Information.
RIGHT TO REQUEST DELETION
You have the right to request the deletion of your Personal Information. If we deny your request for certain exceptions, we will explain the reason, such as when your data is required to maintain your health record, for employment activities, to comply with a legal obligation, or when required to complete the transaction for which we collected the information.
EXERCISING YOUR RIGHTS
To exercise the access and deletion rights described above, submit a request to us by email to privacy@ginger.io.
When receiving a request, we will verify that the individual making the request is the resident to whom the Personal Information subject to the request pertains. California residents may exercise their rights themselves or may use an authorized agent to make the request. We may need to obtain additional information in order to verify or otherwise fulfill your request.
We will respond to a verifiable consumer request within forty-five (45) days of receipt. We will deliver our written response to your request via email.
NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny your use of our Services
- Provide you a different level or quality of Services
WE DO NOT SELL YOUR PERSONAL INFORMATION
Ginger does not sell Personal Information, including the Personal Information of minors.
CHANGES TO THIS NOTICE
We reserve the right to amend this Notice at our discretion and at any time. The date this Privacy Notice was last updated is identified at the top of the Notice. You are responsible for periodically visiting the Ginger website and this Notice to check for any changes.
CONTACT INFORMATION
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, you may contact us via email at privacy@ginger.io.
