This Privacy Notice for California Residents supplements the information contained in Greenway Health’s (“Greenway,” “we,” or “us”) Privacy Statement and applies solely to the extent the CCPA applies to you (”consumer” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act, and as may be further amended (collectively “CCPA”), and any terms defined in the CCPA have the same meaning when used in this notice.

  1. OVERVIEW

The CCPA provides California residents (“consumers” as defined by the CCPA) with certain rights regarding their personal information, but it also includes limitations as to when those rights apply. This notice provides details about what personal information we may collect, use, and share. It also describes your rights and how you may exercise them. 

California consumers have the right to:

  • Knowledge, access, correction, and deletion of their personal information 

  • Opt-out of the sale or sharing of their personal information 

  • Limit how their sensitive information is used

  • Not be discriminated against for exercising any of these rights

A few notes that you should be aware of as they may impact your CCPA rights:

  • Certain of your rights (like the request to delete information) are limited by the CCPA based on our need to continue to use your personal information for various reasons (including, to be able to continue to provide you with products and services that you use, or for other legal/regulatory reasons)

  • Greenway Health is a provider ofsoftware solutions and services to healthcare providers. Therefore, if the reason we have your personal information is because we are providing those solutions and services to your healthcare provider, then your direct relationship, and main point of contact, is your provider (in this situation, your healthcare provider is the “business” under the CCPA, and we are the “service provider.”) In order to pursue your rights, you generally would need to start with the business under the CCPA that you have a direct relationship with (here, your healthcare provider). If we are providing solutions or services on behalf of your healthcare provider (we would be the “service provider”), then we often are not legally allowed to comply with your requests, as your request should be directed to your healthcare provider.   

  • PHI is exempt from the CCPA

  1. INFORMATION WE COLLECT

Greenway Health may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). Greenway Health has collected the following categories of personal information (each an “Information Type”) from consumers within the last twelve (12) months:

  • Identifiers, such as your name, address, phone number, and IP address.

  • Customer records information, such as your name, address, phone number, credit card number, or government issued identification numbers.

  • Protected information under California Law, such as demographic information, financial information, or other identifying information.

  • Internet or other network activity information, such as how you interact with Greenway’s websites, applications, or advertisements, and which may include your preferences and/or characteristics.

  • Inferences, which may include creating a profile about you, reflecting personal preferences, characteristics, and behavior. 

  • Geolocation data, such as your broad location information that is derived from your IP address.

  • Professional or employment related information, such as work history or performance evaluations. 

  • Sensitive Information, such as personal identification numbers (driver’s license, passport), account log-in information, financial information combined with any security or access code, religious beliefs, and racial origin.

Personal information does not include:

  • Publicly available information.

  • De-identified or aggregated consumer information.

  • Information excluded from the CCPA’s scope, like:

    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.

    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994 

  1. How WE collect your information

Greenway Health may obtain the personal information described above from the following categories of sources:

  • Directly from you. For example, from forms, or other information, you submit to Greenway, Greenway products and services you purchase, phone calls, live chats, emails, in-person events.

  • Indirectly from you. For example, from observing your actions on our websites, or from (or about) devices you use in accessing our websites.

  • From third parties. For example, from data analytics providers, or 3rd party data brokers. 

  • From your representative. For example, someone may register an account on your behalf, or otherwise provide us with information about you. 

  1. Why we collect, USE, and disclose PERSONAL INFORMATION

We may use, or disclose, the personal information we collect, as noted above, for one or more of the business purposes described below. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose for sharing the information, and requires the recipient to both: keep that personal information confidential, and not use or further disclose it for any purpose except performing the contract. In the past 12 months we may have used or disclosed personal information (to the extent applicable to a consumer):

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

  • To provide, support, personalize, and develop, our websites, products, and services.

  • To create, maintain, customize, and secure your account with us.

  • To process your requests, purchases, transactions, and payments, and prevent transactional fraud.

  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

  • To help maintain the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.

  • To personalize your experience on our websites or applications and to deliver content relevant to your interests, which may include targeted offers and ads through our websites, third-party sites, or via email or text message (with your consent, where required by law). 

  • For testing, research, analysis, and product development, including to develop and improve our websites, products, and services.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. For example, to verify your right to work lawfully in the United States, and perform our contracts.

  • In our capacity as an employer, to satisfy our legal obligations, provide employment benefits, and as necessary for Greenway’s reasonable business purpose in our capacity as your employer. 

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.

  • As otherwise described to you when collecting your personal information or as otherwise set forth in the CCPA.

Greenway Health will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes, without providing notice or obtaining your consent (as required by the CCPA).

  1. disclosing your information to third parties

As set forth in this notice, we may disclose or share your personal information (which may include one or more of the Information Types set forth in Section 2 above) with the following categories of third parties:

  • Service Providers. We may share any personal information we collect about you with our third-party service providers and vendors that assist us with the provision of our solutions and services. This includes service providers and vendors that provide us with IT support, data hosting, website development and operation, and related services; payment processing, customer service, and related services.

  • Business Partners. We may provide personal information to business partners to provide you with the solutions or services you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

  • Affiliates. We may share personal information with our affiliated corporate entities.

  • Advertising and Marketing Partners. We may share your personal information with third-party advertising and marketing partners. These advertising and marketing partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements for Greenway to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. 

  • Third Parties in Order to Comply with Law or Otherwise Protect Our Interest or Those of Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’, rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

  • Third Parties in the Event of the Analysis of, or for Conducting, a Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

  1. SHARING PERSONAL INFORMATION

Under the CCPA, the term “share” means “the disclosure of personal information to a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration.”

Pursuant to the CCPA, Greenway Health has the right to sell or share your personal information, subject to your right to opt-out of those sales (as set forth below). The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We may share your personal information with the following categories of third parties:

  • Advertising and marketing partners

The personal information we share, or otherwise may be used for these purposes, may include any of the Information Types set out in Section 2 above. 

  1. SALE OF PERSONAL INFORMATION

Under the CCPA, the term “sale” means “the disclosure of a consumer’s personal information to a third party for monetary or other valuable consideration.”

In the preceding twelve (12) months, Greenway Health has not sold personal information for any purpose.

  1. how we protect, and retain, PERSONAL INFORMATION

We are committed to keeping your information secure, and we take reasonable precautions to protect your personal information from loss, misuse, or alteration. We maintain your information using reasonable administrative, physical, and technical safeguards. We keep your personal information as long as we need it to provide our services, comply with legal obligations, or protect ours or others’ interest. We decide how long we keep each category of personal information on a case-by-case basis, and retention periods are set forth in our internal records retention policy. 

  1. YOUR RIGHTS AND CHOICES

The CCPA provides consumers (California residents) with specific rights regarding their personal information and sensitive information. This section describes your CCPA rights and explains how to exercise those rights.

  • your right to ACCESS SPECIFIC INFORMATION, along with your DATA PORTABILITY RIGHTS

You have the right to request that Greenway Health disclose certain information to you about our collection, use, and disclosure of your personal information over the preceding 12 months. You have the right to request that the information is provided to you in a portable and readily useable format, to the extent technically feasible (“data portability"). Depending on your request, and once we verify your request (as set forth below), we may disclose to you:

  • The categories of personal information and sensitive information we collected about you.

  • The categories of sources for the personal information and sensitive information we collected about you.

  • Our business or commercial purpose for collecting, using, or disclosing that personal or sensitive information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information we collected about you.

  • If we sold your personal information, the categories of third parties to whom we sold that personal information, and the categories of personal information sold.

  • If we disclosed your personal information for a business purpose, the categories of third parties to whom we disclosed that personal information, and the categories of personal information disclosed. 

  • The planned retention period, or criteria used for retention.

     

  • your DELETION REQUEST RIGHTS

You may have the right to request that Greenway Health delete your personal information that we collected and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and/or direct our service providers to delete) your personal information from our records, unless an exception applies, and we will inform you of such actions taken or not taken.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s). Some of the reasons for denying your request could include the need to:

  • Properly verify the request. If we cannot properly verify your request, we have the right to deny your request. 

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or attempt to prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

  • Retain such information based upon other laws or exemptions from the CCPA (with PHI, pursuant to HIPAA, being one example).

  • Comply with another legal obligation. 

We do not provide deletion rights for personal information (defined pursuant to HIPAA as protected health information (PHI)) that is stored or otherwise used by our clients that are healthcare providers or otherwise deemed to be Covered Entities (as that term is defined in HIPAA). You may directly contact your healthcare provider if you have questions about these rights with respect to information about you that is stored or otherwise used by them.

  • Your Right to Limit use, and disclosure, of sensitive personal information

You have the right to request us to limit our use and disclosure of your sensitive personal information to only those uses that are necessary to provide you with Greenway goods and services. However, we only collect, use and disclose sensitive personal information in accordance with applicable federal and state privacy laws, including: performing reasonably expected services, ensuring Greenway’s security and legal compliance, and for quality purposes.  For the avoidance of doubt, Greenway does not collect, use, or disclose sensitive personal information for any purpose not permitted by relevant privacy laws. For more information on this, please see our State Privacy Law Notice [LINK].

  • Your right to have your personal information corrected or updated

You have the right to request we correct inaccurate, or otherwise update, personal information we maintain about you.  Once we receive a verified request, we will use commercially reasonable efforts to correct or update the information as directed by you and applicable law.

  • Your right to opt-out or opt-in to the selling or Sharing of your personal information

If you are 16 years of age or older, you have the right to direct us to not “sell” or “share” your personal information or use your personal information for “targeted advertising” (as those terms are defined under the CCPA) at any time (the “right to opt-out”). We do not “sell” or “share” the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales or sharing may opt-out of future sales or sharing at any time.

To exercise the right to opt-out, you or your authorized representative may submit a request to us by visiting the following Internet Web page link:

DO NOT SELL or share MY PERSONAL INFORMATION

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales or sharing. However, you may change your mind and opt back into personal information sales or sharing at any time. We will only use personal information provided in an opt-out request to review and comply with the request.

  • your NON-DISCRIMINATION Rights                                                     

We will not discriminate or retaliate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

  • Retaliate against an employee, applicant for employment, or independent contractor.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

  1. how you may EXERCise your RIGHTS

To exercise any of the rights described above, please submit a verifiable consumer request to us via any of the following methods:

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.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 

The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

  • AUTHORIZED AGENT

If an authorized agent makes a request on your behalf, we may require the authorized agent to provide proof of signed permission, and we may also require you to verify your own identity and/or directly confirm to Greenway that you provided the authorized agent with permission to submit the request.

  • RESPONSE TIMING AND FORMAT

For deletion, correction, or access, requests, we endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time (up to 90 calendar days), we will inform you of the reason and extension period in writing.

For requests to opt-out or limit the use of sensitive information, we endeavor to respond to a verifiable consumer request within fifteen (15) business days of its receipt. 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

  1. OTHER CALIFORNIA PRIVACY RIGHTS

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please use the contact methods outlined in Section 10 of this document.

  1. Third party websites

Our website may provide, or third parties may provide, links to other websites or online resources. This notice solely applies to our website. It does not apply to services offered by third parties, including websites and other online services to which our website may display links. When you click on such links, you may be visiting websites or interactive services operated by third parties who have their own information collection practices. We do not have control over how any third party collects or uses information, so we recommend that you review their privacy policies to learn about their practices.

  1. CHANGES TO OUR PRIVACY NOTICE

Greenway Health reserves the right to amend this notice at our discretion and at any time. Unless otherwise noted, any such changes will be immediately incorporated into this notice, and the “Date Last Updated” below will show when the latest changes were made. You should review the page often to ensure you have the most up-to-date information. Your continued use of our website following any changes indicates your consent to the terms and practices described in the most-current version of this notice.

  1. CONTACT INFORMATION

If you have any questions or comments about this notice, the ways in which Greenway Health collects and uses your information described below and in the Privacy Statement, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-855-343-7202
Website: http://greenwayhealth.com
Web Form link: https://www.greenwayhealth.com/consumer-privacy-request 
Postal Address:
Greenway Health
Attn: Privacy Officer
4301 West Boy Scout Blvd, Suite 800
Tampa, Florida 33607

Privacy Notice for California Residents

Date Last Updated: February 4, 2025