Supplemental California Consumer Privacy Act Privacy Policy

In this Supplemental California Consumer Privacy Act Privacy Policy (“CCPA Privacy Policy”), we, NuMedis Publishing, disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018 (“CCPA”) and supplement the disclosures in our other privacy notices. We use the term “Services” to mean the websites, mobile applications and newsletters that we operate. This CCPA Privacy Policy is effective January 1, 2020. 

I. Who and what information is subject to this CCPA Privacy Policy?

California residents are protected as “consumers” by the CCPA with respect to personal information. A number of statutory exceptions apply under the CCPA. As a result, this CCPA Privacy Policy does not apply to the following:

  1. (1)

    personal information reflecting a written or verbal communication or a transaction between the business and the consumer, where the consumer is a natural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency and whose communications or transaction with the business occur solely within the context of the business conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, non-profit, or government agency;

  2. (2)

    personal information that is collected by a business about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the natural person’s personal information is collected and used by the business solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of that business;

  3. (3)

    personal information that is collected by a business that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of having an emergency contact on file; and

  4. (4)

    personal information that is necessary for the business to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of administering those benefits.

II. How can an individual with a disability access this CCPA Privacy Policy?

Individuals who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this document.

III. Supplemental CCPA Disclosures

We provide additional disclosures about consumer rights and our personal information handling practices in the preceding twelve months.

  1. Right to Know About Personal Information Collected, Disclosed, or Sold

We describe here the personal information we generally collect, use, disclose and sell about California residents. You have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (“right to know”). To submit a request to exercise the right to know, please submit an email request to privacy@numedis.com and include “California Request to Know” in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.

We will ask that you provide certain information to verify your identity, such as a code sent to an email address we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

  1. Our Personal Information Handling Practices in 2019

We have set out below the categories of personal information we have collected about California residents in the preceding 12 months and, for each category of personal information collected, the categories of sources from which that information was collected, the business or commercial purposes for which the information was collected, and the categories of third parties with whom we shared the personal information.

Category of personal information

We collected such personal information for the following purposes:

We collected such personal information from the following categories of sources:

We shared such personal information with the following categories of third parties:

Identifiers such as a real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address or other similar identifiers.

● Upon request, create an account for you for the Services;

● Respond appropriately to your inquiries;

● Update you regarding your account;

● Provide you with, maintain, secure and improve our Services;

● Provide you with a customized experience in connection with our Services;

● Improve the accuracy and relevance of the results you see when you interact with the search engine and the search engine's integrated chat-bot functionality that is part of our Services;

● Discharge our contractual obligations to you;

● Comply with any legal obligations that apply to us; and

● Send you communications according to your preferences.

● Directly from the consumer;

● Where permitted by applicable law, we may also collect information about your specialty, hospital affiliation, and academic or scientific publications from public resources.

● We may share your personal information with affiliated and non-affiliated service providers to help us fulfill the purposes set forth in this Privacy Policy;

● If you participate in a medical education activity that we publish and thereby obtain a continuing medical education or similar certificate, we may disclose the fact that you participated in the activity to the medical school or institute that accredited the activity for the purposes of complying with professional accreditation recordkeeping requirements;

● If we publish an activity from another medical education provider, and thereby obtain a continuing medical education or similar certificate, we may disclose the fact that you participated in the activity to the medical education provider for the purposes of complying with professional accreditation recordkeeping requirements;

● We may disclose your personal information to government entities as required by applicable law or necessary to protect against harm

● If you respond to a market research survey, we do not share your personal information with the third parties on whose behalf we are conducting such research except with your consent or where required by applicable law.

Any categories of personal information described in subdivision (e) of Section 1798.80: “Personal information” means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, address, telephone number, education, employment, employment history.

Same as above

Same as above

Same as above

Internet or other electronic network activity information, including, but not limited to, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.

● Upon request, create an account for you for the Services;

● Update you regarding your account;

● Provide you with, maintain, secure and improve our Services;

● Provide you with a customized experience in connection with our Services;

● Improve the accuracy and relevance of the results you see when you interact with the search engine and the search engine's integrated chatbot functionality that is part of our Services;

● Discharge our contractual obligations to you; and

● Comply with any legal obligations that apply to us.

Directly from the consumer

Same as above

Electronic or similar information.

We collect and store personal information electronically for the purposes described in this Privacy Policy

Directly from the consumer

Same as above

Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics.

● Provide you with a customized experience in connection with our Services; and

● Send you communications according to your preferences.

Directly from the consumer

Same as above

  1. Disclosures of Personal Information; No Sale

Over the preceding 12 months, we disclosed certain categories of California residents’ personal information to the categories of third parties as shown in the table above. 

We do not and will not sell California residents’ personal information. We do not sell the personal information of minors under 16 years of age without affirmative authorization.

  1. Right to Request Deletion of Personal Information

You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please submit an email request to privacy@numedis.com and include “California Request to Delete” in the subject line. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA.

We will ask that you provide certain information to verify your identity, such as a code sent to an email address we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once we have verified your identity, we will ask you to confirm that you wish to have your personal information deleted. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

  1. Right to Opt-Out of the Sale of Personal Information

You have the right to opt-out of the sale of your personal information by a business. We do not, and will not, sell your personal information.

  1. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You may not be discriminated against because you exercise any of your rights under the CCPA.

  1. Authorized Agent

You can designate an authorized agent to make a request under the CCPA on your behalf if:

  • The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
  • You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described in Sections 1 and 4 above:

  • Mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf to privacy@numedis.com; and
  • Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

  1. Contact for More Information

If you have questions or concerns regarding our Privacy Policy or practices, you may email us at privacy@numedis.com