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The following California Consumer Privacy Act Disclosures (“CCPA Disclosures”) supplement the WRS Health Privacy Policy in order to disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018 (“CCPA”). These CCPA Disclosures are effective July 1, 2020.

All defined terms in the WRS Health Privacy Policy shall have the same meaning in these CCPA Disclosures.

I. Who We Are and Scope of these CCPA Disclosures

California residents are protected as “consumers” by the California Consumer Privacy Act of 2018 with respect to personal information.

Certain categories of personal data are statutorily excluded from the CCPA and these CCPA Disclosures, including the following: (a) personal information reflecting a written or verbal communication or a transaction between a business and a 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; (b) 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; (c) 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 (d) 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 a consumer with a disability access these CCPA Disclosures?

Consumers 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 notice. You may also contact privacypolicy@wrshealth.com if you wish to obtain a copy of these CCPA Disclosures in an alternative format.

III. CCPA Notice at Collection Online

WRS addresses “at collection” disclosure requirements (see Section I., “Who We Are and Scope of these CCPA Disclosures”).

IV. CCPA Privacy Policy

Beyond the disclosures in the preceding “CCPA Notice at Collection Online” section, WRS is providing additional disclosures about consumer rights and our personal information handling practices in the preceding twelve (12) months, as required by the CCPA.

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

This CCPA Privacy Policy describes the personal information WRS generally collects, uses, and discloses about California residents. You have the right to request that WRS disclose what personal information we collect, use, and disclose about You specifically (“right to know”). To submit a request to exercise the right to know or for information on self-service procedures (where available), please visit our WRS Health Support portal here, call our toll-free phone number at (866) 977-4367 or submit an email request to privacypolicy@wrshealth.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.

WRS may ask that You provide certain information to verify Your identity. If You have a password-protected account with WRS, we may verify Your identity through our existing authentication practices for Your account. The information that WRS asks You to provide to verify Your identity will depend on Your prior interactions with us and the sensitivity of the personal information at issue. WRS will respond to Your request in accordance with the CCPA. WRS will explain any request denial.

2. WRS Personal Information Handling Practices in 2020

We have created a table listing the categories of personal information we have collected about California residents in the preceding twelve (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 WRS shared the personal information.

Please click here to review the table listing our personal information handling practices.

3. Disclosures of Personal Information; No Sale

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

WRS has not sold California residents’ personal information over the preceding twelve (12) months and do not do so. This includes the personal information of minors under sixteen (16) years of age.

4. Right to Request Deletion of Personal Information

You have a right to request the deletion of personal information that WRS collects or maintains about You. To submit a request to delete personal information or for information on our self-service data deletion procedures (where available), please visit our WRS Health Support portal here or submit an email request to privacypolicy@wrshealth.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 deleted, which can be all of Your personal information as required by the CCPA.

WRS may ask that You provide certain information to verify Your identity. If You have a password-protected account with us, we may verify Your identity through our existing authentication practices for Your account. The verification information that we ask You to provide will depend on Your prior interactions with WRS and the sensitivity of the personal information at issue. Once we have verified Your identity, we will ask You to confirm Your deletion request. Once confirmed, we will respond to Your request in accordance with the CCPA. We will explain any denial of such a request.

5. 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. WRS has not and does not sell Your personal information.

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

You may not be discriminated against because of exercising any of Your rights under the CCPA.

7. 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 above:

• Mail Your written declaration authorizing the authorized agent to act on your behalf, certified by a California notary public, to Attn: CCPA Request (WRS Health), Catania, Mahon & Rider, PLLC, 641 Broadway, Newburgh, NY 12550 with an e-mail cc: to privacypolicy@wrshealth.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 WRS and the sensitivity of the personal information at issue.

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

8. Contact for More Information

If you have questions or concerns regarding these CCPA Disclosures, our Privacy Policy or practices, You may contact us using the following details:

Email address: privacypolicy@wrshealth.com

Postal address: Attn: WRS Health, 2004 Rt. 17M, Goshen, NY 10924 with an e-mail cc: to privacypolicy@wrshealth.com