Easy Healthcare California Notice at Collection and Privacy Notice

Last revised: August 30th, 2023

This Easy Healthcare California Notice at Collection and Privacy Notice (“California Privacy Notice”) is only applicable to California residents (“you”). It supplements the information contained in our Easy Healthcare Privacy Policy. It is delivered on behalf of Easy Healthcare Corporation and our relevant affiliates (collectively, “Easy Healthcare,” “we,” “us,” and “our”) and governs certain personal information we collect from or about you.

We have adopted this California Privacy Notice to comply with the California Consumer Privacy Act, Cal. Civ. Code §§ 1798.100 et seq. (“CCPA”). Please take the time to read and understand this California Privacy Notice.

Scope

This California Privacy Notice covers personal information collected from or processed about you when you use our websites, www.premom.com and healthcare-manager.com (“Sites”) and the Premom mobile application (“App”) (the Sites and App together are called the “Services”).

There is other personal information that this California Privacy Notice does not cover. In some cases, that personal information may not be subject to the CCPA. In other cases, a different privacy notice may apply. Accordingly, this California Privacy Notice and/or the California privacy rights set out herein may not apply to you or to all of your personal information. For example, Personal information we may have from California residents in their capacity as current or former employees, personnel, or independent contractors of Easy Healthcare is not covered by this California Privacy Notice.

The following is not personal information for purposes of the CCPA: (i) publicly available information; (ii) lawfully obtained, truthful information that is a matter of public concern; (iii) deidentified consumer information about California residents; and (iv) aggregate consumer information about California residents (in each case, as those terms are used in the CCPA). This California Privacy Notice does not apply to such information.

Notice at Collection and Collection, Use and Disclosure of Personal Information

The CCPA requires us to give you specific information about the categories of personal information we collect about you, the sources from which we have obtained that information, the purposes for which we collect it and the categories of entities to whom we disclose it. The table below sets out our relevant practices. Our collection, use and disclosure of personal information depends on your relationship with us and your interaction with us.

Category of Personal Information

Categories of Sources From Which We May Collect Personal Information

Business or Commercial Purpose for Collecting Personal Information

Categories of Entities To Whom We May Disclose

Identifiers and Categories in Cal. Civ. Code 1798.80(e), such as name, unique personal identifier, online identifier, IP address, email address

· Directly from you or otherwise at your direction, such as when you use the Services, register to create an account, become a subscriber, communicate with us, or purchase products

· Automatically, such as via cookies and other tracking technologies that may be used to collect information about your device and activities while using the Services

· Via companies we engage to act on our behalf

· Integrated sign-in partners, such as Google Sign-In

 

· To provide you with the Services

· To communicate with you

· For analytics purposes

· To engage in marketing and advertising

· For compliance with law, to enforce our rights and manage our business

· To prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or required by law, including for auditing, fraud and security monitoring purposes

· Other uses about which we notify you

· Our affiliates

· To our vendors, such as those who help us perform tasks on our behalf, process orders and payments, respond to your technical support questions, provide customer support or otherwise help us provide the Services

· To vendors who help us promote our business, including for marketing and advertising purposes and to conduct audience engagement and analytics related to the Services

· To monitor for fraud

· To comply with legal requirements and enable protection of rights, such as at the request of law enforcement or government agencies, or as otherwise required by law

· As otherwise described to you or with your consent

· In connection with a business transaction, such as the sale of all or part of our business

 

 

 

Commercial information, such as records of products or services purchased, obtained or considered, or other purchasing or consuming histories of tendencies

 

· Directly from you or otherwise at your direction, such as when you use the Services, register to create an account, become a subscriber, communicate with us, or purchase products

· Automatically, such as via cookies and other tracking technologies that may be used to collect information about your device and activities while using the Services

· Via companies we engage to act on our behalf

 

· To provide you with the Services

· To communicate with you

· For analytics purposes

· To engage in marketing and advertising

· For compliance with law, to enforce our rights and manage our business

· To prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or required by law, including for auditing, fraud and security monitoring purposes

· Other uses about which we notify you

· Our affiliates

· To our vendors, such as those who help us perform tasks on our behalf, process orders and payments, respond to your technical support questions, provide customer support or otherwise help us provide the Services

· To vendors who help us promote our business, including for marketing and advertising purposes and to conduct audience engagement and analytics related to the Services

· To monitor for fraud

· To comply with legal requirements and enable protection of rights, such as at the request of law enforcement or government agencies, or as otherwise required by law

· As otherwise described to you or with your consent

· In connection with a business transaction, such as the sale of all or part of our business

 

 

 

Internet or other electronic network activity information, such as browsing history, search history or information regarding interaction with our website, app or services

 

· Directly from you or otherwise at your direction, such as when you use the Services, register to create an account, become a subscriber, communicate with us, or purchase products

· Automatically, such as via cookies and other tracking technologies that may be used to collect information about your device and activities while using the Services

· Via companies we engage to act on our behalf

· Integrated sign-in partners, such as Google Sign-In

 

· To provide you with the Services

· To communicate with you

· For analytics purposes

· To engage in marketing and advertising

· For compliance with law, to enforce our rights and manage our business

· To prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or required by law, including for auditing, fraud and security monitoring purposes

· Other uses about which we notify you

· Our affiliates

· To our vendors, such as those who help us perform tasks on our behalf, process orders and payments, respond to your technical support questions, provide customer support or otherwise help us provide the Services

· To vendors who help us promote our business, including for marketing and advertising purposes and to conduct audience engagement and analytics related to the Services

· To monitor for fraud

· To comply with legal requirements and enable protection of rights, such as at the request of law enforcement or government agencies, or as otherwise required by law

· As otherwise described to you or with your consent

· In connection with a business transaction, such as the sale of all or part of our business

 

 

 

Geolocation data, such as the state or country associated with your IP address

 

· Directly from you or otherwise at your direction, such as when you use the Services, register to create an account, become a subscriber, communicate with us, or purchase products

· Automatically, such as via cookies and other tracking technologies that may be used to collect information about your device and activities while using the Services

 

· To provide you with the Services

· To communicate with you

· For analytics purposes

· To engage in marketing and advertising

· For compliance with law, to enforce our rights and manage our business

· To prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or required by law, including for auditing, fraud and security monitoring purposes

· Other uses about which we notify you

· Our affiliates

· To our vendors, such as those who help us perform tasks on our behalf, process orders and payments, respond to your technical support questions, provide customer support or otherwise help us provide the Services

· To vendors who help us promote our business, including for marketing and advertising purposes and to conduct audience engagement and analytics related to the Services

· To monitor for fraud

· To comply with legal requirements and enable protection of rights, such as at the request of law enforcement or government agencies, or as otherwise required by law

· As otherwise described to you or with your consent

· In connection with a business transaction, such as the sale of all or part of our business

Audio, electronic, visual, thermal, olfactory or similar information, such as a photo associated with your account

· Directly from you or otherwise at your direction, such as when you use the Services, register to create an account, become a subscriber, communicate with us, or purchase products

· Integrated sign-in partners, such as Google Sign-In

 

· To provide you with the Services

· To communicate with you

· For compliance with law, to enforce our rights and manage our business

· To prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or required by law, including for auditing, fraud and security monitoring purposes

· Other uses about which we notify you

· Our affiliates

· To our vendors, such as those who help us perform tasks on our behalf, process orders and payments, respond to your technical support questions, provide customer support or otherwise help us provide the Services

· To monitor for fraud

· To comply with legal requirements and enable protection of rights, such as at the request of law enforcement or government agencies, or as otherwise required by law

· As otherwise described to you or with your consent

· In connection with a business transaction, such as the sale of all or part of our business

Inferences

· Directly from you or automatically when you Use the App  

· Automatically, such as via cookies and other tracking technologies that may be used to collect information about your device and activities while using the Services

· Via companies we engage to act on our behalf

 

 

· To provide you with the Services

· To communicate with you

· For analytics purposes

· To engage in marketing and advertising

· For compliance with law, to enforce our rights and manage our business

· To prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or required by law, including for auditing, fraud and security monitoring purposes

· Other uses about which we notify you

· Our affiliates.

· To our vendors, such as those who help us perform tasks on our behalf, process orders and payments, respond to your technical support questions, provide customer support or otherwise help us provide the Services

· To vendors who help us promote our business, including for marketing and advertising purposes and to conduct audience engagement and analytics related to the Services

· To monitor for fraud

· To comply with legal requirements and enable protection of rights, such as at the request of law enforcement or government agencies, or as otherwise required by law

· As otherwise described to you or with your consent

· In connection with a business transaction, such as the sale of all or part of our business

Information that may be sensitive personal information, such as information about your health and well-being

· Directly from you or otherwise at your direction, such as when you use the Services, register to create an account, become a subscriber, communicate with us, or purchase products

· Via companies we engage to act on our behalf

 

 

· To provide you with the Services

· To communicate with you

· For analytics purposes

· For compliance with law, to enforce our rights and manage our business

· To prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or required by law, including for auditing, fraud and security monitoring purposes

· Other uses about which we notify you

· Our affiliates

· To our vendors, such as those who help us perform tasks on our behalf, process orders and payments, respond to your technical support questions, provide customer support or otherwise help us provide the Services

· To comply with legal requirements and enable protection of rights, such as at the request of law enforcement or government agencies, or as otherwise required by law

· As otherwise described to you or with your consent

· In connection with a business transaction, such as the sale of all or part of our business

 

Data Retention:

We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. To determine the appropriate retention period for your personal information, we will consider the amount, nature, and sensitivity of the personal information, the potential risk from unauthorized use or disclosure, the purposes for which we process personal information and whether we can achieve those purposes through other means, and applicable legal requirements.

If you choose to delete the App from your device (note that deletion of the App does not mean that your account is deleted – please contact us at support@premom.com if you wish to delete your account) or your account becomes inactive, we will retain your Personal Information for a period of five (5) years in case you decide to re-activate the Services or re-install the App. We have determined that this retention period is appropriate taking into account the factors described above and based on our experience with our App users, in order to secure your smooth experience with our App functions.

You may delete your account and erase your personal information at any time by contacting us at support@premom.com. Please note that if you choose to do this, your personal information will not be recoverable should you later create another account.

Please note that, in all cases, we may need to retain personal information for a longer period where we are subject to legal or regulatory requirements to do so.

How We Disclose Personal Information

We disclose each of the categories of personal information listed above for business purposes, as set out above.

Sales of Personal Information

We do not sell your personal information.

Sharing Personal Information for Cross-Context Behavioral Advertising

We do not share your personal information for purposes of cross-context behavioral advertising:

Minors Under the Age of 16

We do not have actual knowledge that we sell or share the personal information of minors under the age of 16.

Your Rights as a California Resident

As a California resident, you may have certain rights in relation to your personal information.

Right to Know

You may have the right to know how we have collected, used and disclosed your personal information. Specifically, you may have the right to know:

  • The categories of personal information we have collected about you.
  • The categories of sources from which we have collected your personal information.
  • The business or commercial purpose for which we collect, sell or share your personal information.
  • The categories of third parties to whom we have disclosed your personal information.
  • The categories of personal information that we have sold or shared about you and the categories of third parties to whom it was sold or shared.
  • The categories of personal information we have disclosed about you for a business purpose and the categories of persons to whom we have disclosed it.

In addition, you may have the right to know the specific pieces of personal information we have collected about you. Subject to certain limitations, you may request that we provide this information dating back to January 1, 2022.

Right to Make a Deletion Request

You may have the right to request that we delete your personal information that we have collected or received. Subject to certain exceptions, we must delete your personal information and direct our service providers and contractors to delete your personal information.

Right to Correct Inaccurate Personal Information

You may have the right to request that we correct inaccurate personal information about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Right to Opt-Out of Sales of Personal Information

You may have the right to opt-out of the sale of your personal information.

Right to Opt-Out of Sharing of Personal Information

You may have the right to opt-out of us sharing your personal information for cross-context behavioral advertising purposes.

Right to Limit Use and Disclosure of Sensitive Personal Information

Subject to certain exceptions, you may have the right to limit our use and disclosure of your sensitive personal information.

Right to Non-Discrimination

You have the right not to be discriminated against by us for choosing to exercise your rights under the CCPA.

Other Rights: Notice to California Consumers

You have other rights under California’s “Shine the Light” law. California Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. We do not disclose personal information to third parties for those third parties’ direct marketing purposes.

Notice of Financial Incentives

From time to time, we may run certain offers and promotions that may be deemed “financial incentives” in relation to our collection of personal information under the CCPA. For example, we may offer you a discount in exchange for providing us with your email address or signing up for certain products or services. You can make a request to delete your data in order to withdraw from such a program by following the instructions under the “How to Exercise Your California Privacy Rights” section of this California Privacy Notice. The value of such a program to Easy Healthcare is related to the value of your information to us and the costs associated with offering the program. The value of your data to Easy Healthcare may be calculated based on a number of factors, such as whether and to what extent you take advantage of any of our paid product or service offerings. 

How to Exercise Your California Privacy Rights

If you wish to exercise your right to know, access specific pieces of personal information we have about you, delete or correct inaccuracies in your personal information, please submit a request to us by, clicking here or contacting us at support@premom.com, or service@healthcare-manager.com.

“Do Not Track” Signals

We do not currently take steps to recognize “do not track” signals.

Information for Authorized Agents

You can authorize a person (“Authorized Agent”) to exercise your California privacy rights on your behalf. To submit a request to Easy Healthcare on behalf of another person as an Authorized Agent, please submit a request to us by clicking here, or contacting us at support@premom.com or service@healthcare-manager.com.

Verifying Your Requests

We only respond to your requests to know, access the specific pieces of personal information we have about you, delete and correct inaccurate personal information when we can verify that you are a California resident exercising your rights regarding your personal information. 

We may need to ask you for personal information to verify your request so we can match it to the personal information we already have about you. We may also need to obtain additional information about you that we do not already have. If you provide us with new personal information that we do not already have about you, we will use it solely for the purpose of verifying your request. We will let you know via email if we need more information from you to verify your request. Please reply to our requests promptly.

We will communicate with you about your requests via email. We will use the email address you provided when submitting your request.

If we cannot verify your identity, we will let you know.

Responding To Your Requests

We aim to promptly verify and respond to your requests within 45 days of receipt but may require a total of up to 90 days to respond to your requests. If we require additional time beyond the initial 45 days after we receive your request, we will let you know within the first 45 days.

We do not ordinarily charge a fee for our response to your requests. However, we may do so to the extent your request(s) are excessive, repetitive, or manifestly unfounded. If we determine that charging a fee is warranted, we will let you know and will provide you with an estimate of the associated costs of responding to your request(s).

If we determine that we cannot or will not take the action that you requested, we will let you know. We will inform you of our reasons for not taking action and any rights you may have to appeal the decision.

Unless you tell us that you would like to receive a response via postal mail, we will respond to you via email regarding your requests to know and to access the specific pieces of personal information we have about you. We will contact you at the email address you provided when submitting your request(s). If you would like to receive responses to a request to know or access personal information via postal mail rather than email, please let us know when submitting your request(s).

Limitations
We are only required to respond to certain requests twice in any twelve-month period. We are not required to provide you access to specific pieces of personal information more than twice in any twelve-month period. Similarly, we are not required to comply with your “requests to know” more than twice in any twelve-month period.

Changes to Our California Privacy Notice

From time to time, Easy Healthcare may update or revise this California Privacy Notice. If there are changes to the terms of this California Privacy Notice, documents containing the revised policy on the relevant webpage and/or or application page will be updated.

How to Contact Us

If you have any questions or concerns about this California Privacy Notice, please contact us at support@premom.com or service@healthcare-manager.com.