Last Updated: February 14, 2023
The information in this Supplemental Privacy Statement describes how we collect, use, disclose and otherwise process personal information of California and Virginia residents, and how to exercise your rights under the California Consumer Privacy Act and the Virginia Consumer Data Protection Act. We call those laws collectively the "U.S. Privacy Laws."
Unless otherwise expressly stated, all terms in this Supplemental Privacy Statement have the same meaning as defined in our Privacy Statement or as otherwise defined in the U.S. Privacy Laws.
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal data”), some of which may be considered sensitive personal data. In particular, we have collected one or more data types in the following categories of personal data from consumers within the twelve (12) months preceding the effective date of this Privacy Statement:
|Category||One or More Data Types Collected?||Disclosed in the path twelve months?|
|A.||Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.||Yes||Yes|
|B.||Any personal data described in Cal. Civ. Code § 1798.80(e), such as name, physical characteristics or description, address, telephone number, credit card number, debit card number, or any other financial information, medical information.||Yes||Yes|
|C.||Characteristics of protected classifications under state or federal law, such as racial or ethnic origin, or union membership.||Yes||Yes|
|D.||Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes||No|
|E.||Sleep, health, or exercise data that contain identifying information.||Yes||No|
|F.||Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet web site, application, or advertisement.||Yes||Yes|
|H.||Audio, electronic, visual, thermal, olfactory, or similar information.||Yes||Yes|
|I.||Professional or employment-related information.||No||No|
|J.||Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Yes||Yes|
For additional information, see Information We Collect About You.
We obtain the categories of personal data listed above from the following categories of sources:
For additional information, see Information We Collect About You.
We use the personal data we collect for our operational purposes or other purposes set out in our Privacy Statement (See How We Use Your Information). Those purposes may include:
We also use the personal data we collect for our commercial or economic purposes, such as attracting consumers to buy, subscribe to, provide, or exchange products, goods, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.
For information on where we share personal data, see How we share your information.
In the 12 months preceding the effective date of this Privacy Statement, we have exchanged contact information with our promotional and marketing partners, which would constitute a “sale” as defined under the CCPA. In addition, as is common practice among companies that operate online, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services, delivering ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. For more information about how to opt out of personal information sharing that constitutes a “sale” under the CCPA, please refer to the Consumer Rights Under the U.S. Privacy Laws section below.
The rights in this section apply only to residents of California or Virginia.
Right to Request Disclosure. If you are a California or Virginia consumer, you have the right to request, free of charge, that we disclose information about our collection and use of your personal information over the past twelve (12) months, including:
For more information on how to request information about our collection, use, and disclosure of your personal information, please see the Submitting a Request under the U.S. Privacy Laws section below.
Right to Request Correction or Deletion. You have the right to request the correction or deletion of your personal information that we collected. For more information on how to request correction or deletion, please see the Submitting a Request under the U.S. Privacy Laws below. Once we receive your deletion request and verify your identity, we will review your request to see if an exception allowing us to retain the information applies. We will delete or de-identify personal information not subject to an applicable exception from our records and will direct our service providers to take similar action.
You do not need to create an account with us to exercise your correction or deletion rights. We will only use personal information provided in a deletion request to review and comply with the request.
Right to Request Opt-Out of the Sale of Your Personal Information. If you are age 16 or older, you have the right to direct us to not sell your personal information at any time. We do not sell the personal information of consumers we actually know are less than 16 years old.
To exercise the right to opt-out, you or your authorized representative may submit an opt-out request by following the procedures specified in the Submitting a Request under the U.S. Privacy Laws section below. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorized personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Right of Non-Discrimination. You have the right to be free from discriminatory adverse treatment for exercising these rights. We will not discriminate against you for exercising any of your rights under the U.S. Privacy Laws.
We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent, where your identity cannot be confirmed, or where we must retain your information to comply with legal obligations.
Although some of the information we collect and process about you may be considered sensitive personal information, we only process such information for purposes authorized by law, such as to provide services you request from us or to verify your information.
Depending on the jurisdiction in which you live, you may have the right to appeal our refusal to take action on your request. You may indicate your intention to appeal in the manner through which your request was originally processed.
Requests to Know or Delete. To exercise your rights to know or delete described above, you may submit a request by contacting us through one of the following methods:
Requests to Opt-Out of Sales of Your Personal Information. To exercise your right to opt-out of sales of your personal information, you may submit a request form via our website at: https://preferences.takecareof.com/dont_sell. You may also submit a request by emailing us at email@example.com with the subject line “Opt-Out of Sale.”
Verification of Requests. Only you, or an individual legally authorized to act on your behalf, may make a request to know, correct, delete, or opt-out related to your personal information. To designate an authorized agent, please contact us by using the contact information above.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
We may request information from you in order to verify your identity. Additionally, we may require that authorized agents provide proof of their authorization. We cannot respond to your request or provide you with personal information if we are unable to verify your identity, your authority to make a request on behalf of another person, or if we cannot confirm that the personal information relates to you. In general, we will verify your request and your identity by matching certain information you provided with the information we have in our records.
You do not need to create an account with us to submit a request to know, or to submit a request to delete your personal information or opt-out of sales of your personal information.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. In order to facilitate these rights, we do not disclose personal information of California residents to third parties for their direct marketing purposes, as defined under California’s “Shine the Light” law, where the resident opts out of such sharing. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law, please fill out the following Right to Opt Out form at: https://preferences.takecareof.com/dont_sell, filling in your first name, last name, and email address, which we need in order to process your request and safeguard your data.
PLEASE NOTE: To opt-out of all disclosures to third parties for direct marketing purposes, you must provide your personal information to be added to our suppression list.
We will update this Supplemental Privacy Statement from time to time. When we make changes to this Supplemental Privacy Statement, we will change the "Last Updated" date at the beginning of this Statement. All changes shall be effective from the date of publication unless otherwise provided in the notification.
If you have any questions or requests in connection with this Supplemental Privacy Statement or other privacy-related matters, please send an email to firstname.lastname@example.org with “Supplemental Privacy Privacy Statement” in the subject line. Alternatively, inquiries may be addressed to:
NoHo Health Inc.
850 3rd Ave
Suite 601 ATTN: Care/of
Brooklyn, NY 11232