CCPA Point of Collection Notice

The California Consumer Privacy Act of 2018 (the “CCPA”) provides California residents certain rights regarding their Personal Information (as defined below) that we, Vituity® (Vituity is the trade name for CEP America, LLC and each of its member partnerships and subsidiaries, MedAmerica, Inc., and MedAmerica Billing Services, Inc.), collect about you or the Consumer (as defined below).

For the purposes of the CCPA and this Point of Collection Notice (the “Notice”), a Consumer is defined as an individual residing in the State of California including visitors to our website, visitors to a Vituity site and those who are acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of Vituity (the “Consumer”).

The CCPA defines Personal Information as information that identifies, describes, or could reasonably be linked with the Consumer (“Personal Information”). Vituity is committed to safeguarding the privacy of our Consumers and this Notice serves to inform you of the categories of Personal Information that we collect and the purposes for which those categories of Personal Information are used.

The CCPA does not apply to the following categories of information:

Medical information governed by:
- Confidentiality of Medical Information Act (CMIA)
- Health Insurance Portability and Accountability Act (HIPAA)
- Health Information Technology for Economic and Clinical Health Act (HITECH)
- Genetic Information Nondiscrimination Act (GINA)
Privacy data covered by other regulations including:
- US Gramm-Leach-Bliley Act
- US Driver’s Privacy Protection Act
- California Financial Information Privacy Act
Information collected by government entities

Categories of Personal Information Collected by Vituity

The categories of Personal Information collected by Vituity within the past 12 months may include:

Category	Examples	Collected? Yes / No
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	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, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.	Yes
C. Characteristics of protected Classification under California or federal law	Race, color, religion (includes religious dress and grooming practices), sex/gender (includes pregnancy, childbirth, breastfeeding and/or related medical conditions), gender identity, gender expression, sexual orientation, marital status, medical condition, military or veteran status, national origin, ancestry, disability, genetic information, request for family care leave, request for leave for an employee’s own serious health condition, request for Pregnancy Disability Leave, Retaliation for reporting patient abuse in tax-supporting institutions, Age (40 or older).	Yes
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information	An individual’s physiological, biological, or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	Yes
F. Internet or other electronic network activity	Activity including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.	Yes
G. Geolocation data	Physical location or movements	Yes
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	No
I. Professional or employment-related information that is not publicly available.	Current or past job history or performance evaluations.	Yes
J. Education Information	Information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).	Yes
K. Inferences	Information drawn from any of the personal information categories referenced above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes

Purposes for Collecting Personal Information

Vituity collects your Personal Information for recruitment, employment, personnel related and other business purposes.

How Vituity Obtains Personal Information

Vituity may obtain Personal Information either directly from you (forms you complete through our website or through other online communications with Vituity), or indirectly from you (by tracking actions you take on our website). We may also obtain Personal Information from third-party vendors who perform business services on our behalf.

Sharing Personal Information

Vituity may disclose your Personal Information to third-parties, with your consent when required by federal and state law, including consumer reporting agencies for employment background checks, service providers with whom the Consumer directs us to share such Personal Information, and service providers that fulfill a specific business purpose (i.e. payroll companies, health/benefits/wellness providers, human resource consultants, staffing agencies, etc.).

Right to Amend Point of Collection Notice

This Notice supplements the information contained in the Website Privacy Policy and the CCPA Privacy Policy. Vituity may update this Notice from time to time. When we do, we will post the Notice and revise the date at the bottom of this page. We encourage you to frequently check this page to stay informed about how we are helping to protect the Personal Information we collect. You acknowledge and agree that it is your responsibility to review this Point of Collection Notice periodically and become aware of any modifications.

If you have any questions about this Notice, please contact us at:

Vituity
1-800-600-6339
compliance@vituity.com

Last updated: March 3, 2021