Notice of Data Security Incident by Shields Healthcare
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Welcome to The StayWell Company, LLC or Krames LLC (sometimes referred to herein as “us”, “our” or “we”) Web site (the “Site”). Protecting your privacy is important, and we’re committed to clearly explaining how we treat your personal information.
The Information We Collect and How We Collect It
Calculators, quizzes, and risk assessments
Calculators, quizzes, and risk assessments available on SCHL or Krames CHL do not collect any Personally Identifiable Information or track who is using the tool.
Information from Children
This Site is not designed or intended to attract children, and we do not collect or maintain information from individuals who we actually know are under the age of 13 years. If you are under 13, please do not attempt to register or send any information about yourself to us, including but not limited to your name, address, telephone number, or email address. No one under age 13 may provide any personal information to us. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at the address below.
Information We Collect through Cookies
How We Use Your Information
We may use or aggregate your non-personal information with the non-personal information of our other users or other non-personal information collected offline. We may use some or all of this information to support our commercial activities such as for general statistical purposes, site tracking, or for any other purpose. Any personal information that we collect is used solely to provide services or products to you that you have requested or authorized, to respond to your questions, to provide better functionality to you, to help us manage our Site, and to comply with applicable law or valid legal process. We do not sell or share the information with any other entity for marketing purposes.
We Use Your Account Holder Information to:
Send you information about your orders;
Fulfill your orders;
Process and collect your payments;
Customize, analyze, adjust and improve our services and products to better meet your needs;
Enforce our agreements with you;
Prevent fraud and other prohibited or illegal activities; and
Comply with requests of law enforcement or data protection agencies.
Third Party Service Providers
We may employ other companies and individuals to perform functions on our behalf, such as but not limited to, as applicable, fulfilling orders, delivering packages, sending postal mail and e-mail, serving ads on our behalf, providing search results and links, processing credit card payments and other services to support our business. These third-party service providers may have access to Account Holder Information needed to perform their functions but may not use it for any other purpose.
California Privacy Rights
This section is provided pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”). This section applies solely to Site visitors and Account Holders of our Site who are California residents as defined under the CCPA.
Information We Collect
Within the last twelve (12) months, we have or may have collected the following categories of information from our Site visitors and Account Holders: identifiers; personal information listed under Cal. Civ. Code § 1798.80(e); commercial information; internet or other similar network activity; geolocation data; professional or employment-related information; and inferences drawn from any of the information identified in this section.
Categories of Sources from Which Information is Collected
As described in the “The Information We Collect and How We Collect It” section above, we obtain the categories of personal information listed above from the following categories of sources: directly from you; and directly and indirectly through cookies and other technologies.
Using and Sharing of Personal Information
The personal information described in the categories above may be used for the business purposes listed in the “How We Use Your Information” section above.
We disclose your personal information for a business purpose to the following categories of third parties: (a) service providers and (b) third parties to whom you authorize or direct us to disclose your personal information in connection with our products and services. In the preceding twelve (12) months, we have disclosed the personal information described in the categories listed above for the business purposes listed in the “Third party Service Providers” section above. We may also share your personal information for any other purpose(s) disclosed to you at the time we collect your information or with your consent.
Personal Information “Sold” to Third Parties
In the preceding twelve (12) months, we have not sold your personal information to third parties.
We do not sell the personal information of Site visitors or Account Holders that we know are minors under 16 years of age without affirmative authorization as required under the CCPA.
Your Rights under the CCPA
As of January 1, 2020, California residents, as defined under the CCPA, may take advantage of the following rights:
You may request, up to two (2) times each year, that we disclose to you, once we receive and confirm your verifiable consumer request: (1) categories and specific pieces of personal information that we have collected about you; (2) categories of sources from which your personal information is collected; (3) business or commercial purpose for collecting your personal information; (4) categories of personal information that we disclosed for a business purpose; (5) categories of personal information that we sold about you; (6) categories of third-parties with whom we have shared your personal information; and (7) business or commercial purpose for selling your personal information.
Subject to certain exceptions and up to two (2) times each year, you may request that we delete any of your personal information that we collected from you. Once we receive and confirmed your verifiable consumer request for deletion, we will delete (and direct our service providers to delete) such personal information from our records, unless an exception applies.
To exercise the access and deletion rights described above, please contact us through the address or email listed under the “How to Contact Us” section below.
You will be asked to provide certain identifying information, such as your name, email, and residency. While processing your request, we may ask you to provide further verifying documentation. We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request. Only you, or a person registered with the California Secretary of State that you authorize 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. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide proof of written authorization to do so, and you must verify your identity directly with us, unless such authorized agent provides proof of a power of attorney pursuant to Probate Code sections 4000 to 4465.
We will not discriminate against you for exercising any of your rights under the CCPA. Accordingly, and unless permitted by the CCPA, we will not: deny you services; charge you different prices or rates for services; provide you a different level of service; or suggest that you may receive a different price or rate for services or a different level for services. We may charge a different price or rate or provide a different level of service if the difference is reasonably related to the value provided by your personal information.
Advertising and Marketing
StayWell or Krames does not accept any advertising of third parties on our Site nor do we receive income from marketing sponsors or advertisers. Any mention of a particular service is not an endorsement and is provided for solely for your convenience.
Note to Site Visitors and Account Holders Outside of the United States
Additional Information for Visitors from the European Economic Area (EEA) and the UK
The EU General Data Protection Regulation and UK General Data Protection Regulation (together the “GDPR”) require certain information to be provided to data subjects located in the EEA and the UK, and grant them certain rights regarding their personal information. This section applies solely to the processing activities that are governed by the GDPR.
Data Controller and EEA Representative
StayWell is the controller of the personal information provided to, collected by or for, or processed in relation with, the Site and Services. StayWell has appointed Aptus Health International France SAS as its representative in the EEA. StayWell’s Data Protection Officer can be contacted at firstname.lastname@example.org.
Legal Bases for Processing
Where we rely on your consent to process your personal information, you have the right to decline consent or withdraw your consent at any time. Where we rely on our legitimate interests to process your personal information, you have the right to object.
Your Rights Under the GDPR
If you are a Site visitor or Account Holder in the EEA, you can: (i) access personal information we have about you (we will try to provide information within 30 days of your request); (ii) have your personal information corrected or deleted (in most cases you can correct personal information you have submitted to us through your account); (iii) in certain circumstances, you can object to our processing of your personal information and we will discontinue such processing unless we have compelling legitimate grounds to continue; (iv) withdraw consent previously provided (including, in limited circumstances, the right to ask us to stop processing your personal information, with some exceptions, by contacting us); or (v) if you believe that we have not complied with applicable data protection laws, you may lodge a complaint with your local supervisory authority. If you wish to inquire as to whether we maintain any of your personal information and if so, whether you wish to exercise any of those rights that are available to you with respect to such personal information, you may contact us as described in the “How to Contact Us” section below. We will respond to your request within a reasonable timeframe.
Transfers Outside the EEA and the UK
We are located in the United States. Accordingly, as the controller, we process your personal information in the United States. We may also transfer your personal information outside the United States to service providers with operations in other countries. For more information, please refer to the “Note to Site Visitors and Account Holders Outside of the United States” section above.
Automated Decision Making
We do not make automated decisions that create legal effects or otherwise significantly affect you.
How to Contact Us
- or -
The StayWell Company, LLC800 Township Line Rd, Suite 100Yardley, PA 19067Attn: Legal Department
Registering complaints or general inquiries
Please email StayWell or Krames at email@example.com or call 877-330-3796 and select Option #1 for, but not limited to, the following reasons:
Formal complaints about the functionality of SCHL or Krames CHL
Questions about StayWell or Krames policies
Privacy concerns about SCHL or Krames CHL
Additional information about StayWell, Krames, and their products
We respond to clients within 24 hours on business days.
Address for StayWell
StayWell800 Township Line RoadYardley, PA 19067Tel: 267-685-2800www.staywell.com
Address for Krames
Krames800 Township Line RoadYardley, PA 19067Tel: 267-685-2800www.krames.com
Reviewed and Approved by the Quality Oversight Committee: July 2021
Revised: July 2021