Privacy Notice for California Residents

This Privacy Notice for California Residents (“CA Notice”) supplements the information contained in the Privacy Policy of Twomagnets LLC dba Clipboard Health (“Clipboard,” “we,” or “us”) and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”).  This CA Notice describes how we collect, use, disclose, and otherwise process Personal Information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (“CCPA”). Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Policy or as otherwise defined in the CCPA.

Information We Collect

Sometimes we collect Personal Information, including sensitive personal information, automatically when an individual interacts with our Services, and sometimes we collect the Personal Information directly from an individual. For example, many important features of our app require you grant the app “Always” and “Precise Location” permissions with respect to your device’s location data. At times, we may collect Personal Information about an individual from other sources, even before our first direct interaction with that individual. To learn more about the types of Personal Information we collect and the sources from which we collect or receive Personal Information, please refer to the Clipboard’s Collection of Personal Information section of our Privacy Policy.

Use of Personal Information

We may use, or disclose the Personal Information we collect for a variety of purposes. For example, we use Personal Information to communicate with customers about our Services, to provide our Services, to process payments, and to otherwise operate our business. To learn more about the purposes for which we use Personal Information, please refer to the Clipboard’s Use of Personal Information section of our Privacy Policy.

Sharing Personal Information

We may disclose your Personal Information to third parties in connection with providing Services. Additionally, subject to your right to opt out, we may use services that help deliver interest-based ads to you and may transfer Personal Information to business partners for their use. Making Personal Information (such as online identifiers or browsing activity) available to these companies may be considered a “sale” under the CCPA. To learn more about our disclosure of Personal Information, please refer to the Clipboard’s Disclosure of Personal Information and Third-Party Data Collection and Online Advertising sections of our Privacy Policy. To learn more about your opt-out rights, please refer to the Control Over Your Information section of our Privacy Policy and, if you are a California resident, our Do Not Sell My Personal Information page.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Clipboard has disclosed all of the categories of Personal Information described in the Clipboard’s Disclosure of Personal Information section of our Privacy Policy to third parties for a business purpose.

Sales of Personal Information

In the preceding twelve (12) months, we may have “sold” the following categories of Personal Information to third parties, subject to your settings and preferences, and your right to opt out of those sales: (i) commercial information, (ii) browsing history and online identifiers, (iii) internet/network information, and (iv) geolocation data.

In addition, please see the Third-Party Data Collection and Online Advertising section of our Privacy Policy to learn how third-party advertising networks, social media companies, and other third-party entities collect and disclose your Personal Information directly from your browser or device through cookies or other data collection technologies when you visit or interact with our Services or otherwise engage with us.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information (subject to certain limitations at law):

The Right to Access/Know

You have the right to request any or all of the following information relating to your Personal Information we have collected and disclosed in the last 12 months, upon verification of your identity:

• The specific pieces of Personal Information we have collected about you;
• The categories of Personal Information we have collected about you;
• The categories of sources of the Personal Information;
• The categories of Personal Information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
• The categories of Personal Information we have sold about you (if any), and the categories of third parties to whom the information was sold; and
• The business or commercial purposes for collecting or, if applicable, selling the Personal Information.

The Right to Request Deletion

You have the right to request the deletion of Personal Information we have collected from you, subject to certain exceptions.

The Right to Opt Out of Personal Information Sales

You have the right to direct us not to sell Personal Information we have collected about you to third parties now or in the future.

If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.

The Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising these rights.

However, please note that if the exercise of these rights limits our ability to process Personal Information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner

“Shine the Light”

California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code §1798.83).

Exercising Your Right to Access, Right to Know, or Right to Deletion

To exercise your Right to Access, Right to Know, or Right to Deletion as described above, please submit a verifiable consumer request to us by:

• Calling us at (408) 837-0116; or
• Emailing us at privacy@clipboardhealth.com with the subject line, “California Rights Request”

Only you, or someone legally authorized 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 minor child.

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional Personal Information from you, including, but not limited to, your email address, phone number, and/or date of last transaction on our Services.

In certain circumstances, 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.

Personal Information Sales Opt-Out and Opt-In Rights

To exercise the right to opt-out, please visit our Do Not Sell My Personal Information page.

Alternatively, you may submit a request to us by submitting a request titled “Do Not Sell My Personal Information” to privacy@clipboardhealth.com.

If you change your mind and want to opt back in to Personal Information sales, you may submit a request by emailing privacy@clipboardhealth.com.

Authorized Agents

In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in this CA Notice where we can verify the authorized agent’s authority to act on your behalf.

For requests to access, know or delete Personal Information, we require the following for verification purposes:

• a power of attorney valid under the laws of California from you or your authorized agent; or
• sufficient evidence to show that you have: (1) provided the authorized agent signed permission to act on your behalf; and (2)verified your own identity directly with us pursuant to the instructions set forth in this CA Notice; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

For requests to opt-out of Personal Information “sales”, we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

Minors Under 16

We do not sell the Personal Information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.  Please contact us at privacy@clipboardhealth.com to inform us if you, or your minor child, are under the age of 16.

Financial Incentives

We may offer you financial incentives for the collection, sale, retention, and use of your Personal Information as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs, and/or their terms by posting notice on the program descriptions and terms, so check them regularly.

Each financial incentive or price or service difference related to the collection and use of Personal Information is based upon our reasonable, good-faith determination of the estimated value of such information to our business, taking into consideration the value of the offer itself and the anticipated revenue generation that may be realized by rewarding brand loyalty. We calculate the value of the offer and financial incentive by using the expense related to the offer.

Changes to Our Privacy Notice

We reserve the right to amend this CA Notice at our discretion and at any time.  When we make changes to this CA Notice, we will post the updated CA Notice on the Site and update the CA Notice’s effective date.  

Contact Information

If you have any questions or comments about this CA Notice, the ways in which Clipboard collects and uses your information described here and in the Privacy Policy, or your choices and rights regarding such use, please do not hesitate to contact us at:

• Phone: (408) 837-0116
• Website: https://www.clipboardhealth.com
• Email: privacy@clipboardhealth.com