Date Privacy Policy Last Modified: May 22, 2024.
INTRODUCTION
Sevita and its affiliated entities (“Sevita”, “us”, “our” or “we”) respect your privacy and are committed to protecting your Personal Information (as defined below) through our compliance with this Privacy Policy (“Policy”).
This Policy will inform you about our practices for collecting, using, maintaining, and disclosing information which identifies, relates to or is reasonably capable of being associated with a particular individual or household (“Personal Information”) when you visit any of our websites (our “Website”) or otherwise interact with us (collectively, the Website and our services are referred to as the “Services”), and certain rights you may have regarding your Personal Information and how to exercise those rights.
1. SCOPE
Please read this Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. This Policy is incorporated into and made a part of our Website Terms and Conditions of Use (“Terms”). By accessing or using our Services, you agree that you have read and agree with the terms of this Policy. If you do not agree with our Policy, your choice is to not access or use our Services.
If you are an employee or job applicant, this Policy does not address information we collect and process in the applicant or employment. Our employee and applicant data privacy notice is available by request using the contact information listed below.
STATE SUPPLEMENTAL LAWS. PRIVACY LAWS VARY BY STATE, AND YOU MAY HAVE ADDITIONAL OR DIFFERENT PRIVACY RIGHTS DEPENDING UPON WHERE YOU LIVE. IF YOU ARE A RESIDENT OF CALIFORNIA OR VIRGINIA, PLEASE SEE THE CALIFORNIA PRIVACY RIGHTS OR THE VIRGINIA PRIVACY RIGHTS SECTION OF THIS POLICY BELOW FOR ADDITIONAL DISCLOSURES AND INFORMATION REGARDING YOUR PRIVACY RIGHTS.
This Policy does not apply to protected health information (“PHI”). PHI is governed by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and its subsequent amendments and regulations and applicable state law. “PHI” is defined under HIPAA to include individually identifiable health information about your past, present or future physical or mental health or condition, the provision of health care to you or the past, present or future payment for such care. It is important to note, however, that HIPAA does not necessarily apply to an entity or person simply because there is health information involved, and HIPAA may not apply to any or all of your transactions or communications with us. For any PHI that we do collect, our of Privacy Practices (“NPP”) , and not this Privacy Policy, will apply. If you have questions about which policy applies to the information you have submitted, please do not hesitate to contact using the contact information listed below.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES.
We may modify this Policy at any time. All changes will be effective immediately upon posting to the Website. The date the Policy was last updated is identified above. Historic versions are available upon request to the contact listed below. If we make material changes to how we treat Personal Information, we will notify you through a notice on the Website home page or by sending an email to the email address you provided to us. YOUR CONTINUED USE OF OUR SERVICES FOLLOWING THE POSTING OF CHANGES CONSTITUTES YOUR ACCEPTANCE OF SUCH CHANGES TO OUR PRIVACY POLICY.
It is important that the Personal Information, and importantly, the contact information we hold about you is accurate and current. If you provide your e-mail address to us, you are responsible for ensuring we have a current e-mail address for you, and for periodically visiting our Website and this Policy to check for any changes.
2. THE PERSONAL INFORMATION WE COLLECT
The types of Personal Information we collect from you may include, without limitation:
- contact information such as your first name, last name, email address, age, and general geographic location data such as your zip code, city, and state;
- internet and network activity information, including, but not limited to IP address and information regarding your interaction with our Website or Services; and
- technical and device data, including information about your device, system, and browser type, peripherals and other data related to your interactions with our Website.
3. HOW PERSONAL INFORMATION IS COLLECTED
We collect Personal Information from the following sources:
- Direct interactions. You may give us your Personal Information by filling in forms or by corresponding with us by mail, phone, email or otherwise. This includes Personal Information you provide when you:
- Use our Services;
- Request marketing or other information be sent to you;
- Fill out a form or contact our representatives; or
- Give us feedback; or
- Report a problem with our Services.
- Automated technologies or interactions. As you interact with our Services, we may automatically collect Personal Information about you through scripts, pixels, cookies, web beacons, and other technologies. Information collected automatically includes your browser type and operating system, web pages you view, links you click, your IP address, your internet service provider, device ID, approximate geographic location, the referring URL that led you to the Site, data related to how and when you use the Site, the pages visited, and average time spent on the Site. While we do not collect Personal Information automatically, we may tie automatically collected information to Personal Information about you that we collect from other sources or that you have previously provided to us, including, where applicable, your account information and other Personal Information.
- Cookies. Certain features of the Website are only available through the use of cookies. A cookie is a small file placed on the hard drive of your computer, which stores your preferences or other records and enable Sevita to (a) collect information about your use of the Site, (b) understand general Website usage and volume statistical information, (c) improve the Services, experience, content and offerings on the Website, (d) enable advertising and analytics functionality by tracking your interaction with the Website and Services and collecting information about how you use the Website and Services, and (e) allow for customized use and experience of the Website and Services. Most browsers automatically accept cookies. You may refuse to accept browser cookies by deactivating this function through the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. You cannot disable all cookies, such as cookies that are essential to the functioning of the Website.
- Third Party Ad Networks and Other Tracking Technologies.
We use third-party ad networks (including Google, Facebook, YouTube, Instagram, LinkedIn, and X (formerly Twitter) to deliver ads to you on our behalf across the internet. Through these ad networks, we can track your online activities over time by collecting information through automated means, including through the use of third-party cookies, web server logs, pixels and web beacons and other technologies. The ad networks use this information to provide you with interest-based (behavioral) advertising or other targeted content. The information our ad networks may collect includes data about your visits to websites, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Website and on third-party websites that participate in these ad networks. We do not control these third-party websites or their privacy practices, and are not responsible for their privacy statements/notices. When you leave our Services (including the Website), we encourage you to read the privacy notice of every website you visit and application you use. - Analytics. Our Website uses analytics tools to collect information about your use of our Website. Your web browser automatically sends this information to our analytics vendors, such as the web address of the page that you visit and your IP address. Our analytics vendor may also set cookies or read preexisting cookies. This information may be stored on the vendor´s servers. Our analytics vendors may then use this information to provide us with reports about traffic to our Site and your visit to our Site (such as the domain from which you access the internet, the web address of the website from which you linked to our Site, the time and date of your visit to the web pages that you view and click-through). We will use this data to improve our Website structure and content. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. Our analytics providers include:
- Google Analytics. We use Google Analytics to collect and process information about your use of the Website. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google may also use this data in accordance with its Privacy Policy, which can be found at http://www.google.com/policies/privacy. For more detailed information on how Google uses your data through our Site, please visit http://www.google.com/policies/privacy/partners. You may opt-out of our use of Google Analytics by visiting the Google Analytics opt-out page and installing the Google Analytics browser add-on, currently made available by Google at https://tools.google.com/dlpage/gaoptout.
4. HOW WE USE PERSONAL INFORMATION
We may use information that we collect about you or that you provide to us, including your Personal Information for the following purposes:
- To fulfill or meet the reason you provided the information.
- To create, maintain, customize, and secure your account with us.
- To process and respond to your requests, questions, comments, or complaints.
- 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 provide you with updates and marketing communications about services and offers that may be relevant to you.
- To personalize your experience and to deliver content and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, services, databases and other technology assets and business.
- For testing, analysis, and product development, including to develop and improve our Website, Services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Services, or to other users of the Services. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests.
- We may also use Personal Information as requested or consented to by you.
- As described to you when collecting your Personal Information.
- To enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
5. DISCLOSING YOUR PERSONAL INFORMATION
We may disclose your Personal Information to the following categories of parties:
- Employees and affiliates who have a need to know the information for our business purposes.
- Service Providers and third parties that provide services for us and with whom we have contracted with to protect any such Personal Information. For example, we may disclose Personal Information with vendors to help us host and manage the Website; provide targeted advertising and other marketing; improve the content and functionality of the Website; perform data analysis and statistical analysis; troubleshoot problems with the Website; provide payment processing services and online storefronts; and support or provide the security of the Website.
- Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Sevita or any other party.
- Professional Advisors. We may disclose Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Sevita.
- Change in Ownership. In the event Sevita is the subject of a change of control or in the event the Website changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s).
- Other. We may disclose Personal Information with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
6. CHILDREN AND PRIVACY
Our Website and Services are not intended for children under the age of 16 and we do not knowingly collect, use, disclose or sell Personal Information from children under age 16. If you know or suspect that your child has submitted Personal Information to us and you would like to request that such information be removed, you may do so by contacting us at the address listed below in the Contact Information section.
7. INTERNATIONAL TRANSFER
If you are located in a province, country, or other government jurisdiction outside of the United States, and if you choose to provide your Personal Information to the Sevita through our Services, please be aware that your Personal Information will be transferred to and maintained on computers located in the United States and the applicable US privacy laws may not be as protective as those in your jurisdiction.
8. DATA SECURITY
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. We also limit access to Personal Information to those employees, agents, contractors, and other third parties who have a business need to know. These individuals will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of the data transmitted to or through our Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
9. DATA RETENTION AND NON-PERSONAL INFORMATION
We may maintain or store your Personal Information and may keep such information for the period necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
We may de-identify, anonymize or aggregate your Personal Information so that it can no longer be associated with you, in which case, it is no longer considered Personal Information. We may use that information for any purpose, including for research or statistical purposes, in which case we may collect, use, disclose, transfer, and otherwise process this information indefinitely without further notice to you. Sevita is the sole and exclusive owner of such de-identified, anonymized, and aggregated information.
Sevita may also collect, use, disclose, transfer, and otherwise process public information, including information you share or upload to social media platforms. We may post (or re-post) on the Website and our social media pages any comments or content that you post on social media platforms. Your use of social media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.
10. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We have various mechanisms to provide you with the following control over your information:
- Updates and Promotional Offers from the Sevita. If you do not wish to have your e-mail address used by the Sevita to promote or provide updates about our own or third parties’ services, you can opt-out by sending us an e-mail stating your request to the e-mail address provided below in the Contact Information section. If we have sent you a marketing or promotional e-mail, you may click an unsubscribe link within the e-mail or contact us by e emailing the email address provided in the Contact Information section below asking to be omitted from future e-mail distributions. This opt-out does not apply to communications with Sevita as a result of a service experience or other transactions.
- Opting out of Receiving Targeted Ads. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) by visiting the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting out of targeted advertising does not opt you out of all ads, just those targeted to you.
11. CONTACT INFORMATION
If you have a general inquiry about our privacy practices or would like to request changes to your information, or unsubscribe from an e-mail subscription, please contact us in one of the following methods.
E-mail: [email protected]
Toll-Free Telephone: 800-245-3860
Mail: 6600 France Avenue South, Suite 350, Edina, MN 55435
Attn: Compliance Officer
State Specific Supplemental Privacy Notices
1. CALIFORNIA PRIVACY RIGHTS NOTICE
THIS SECTION PROVIDES ADDITIONAL PROVISIONS APPLICABLE ONLY TO RESIDENTS OF CALIFORNIA. If any information in this section conflicts with the main body of this Policy above, the information in this section shall control.
Capitalized terms used in this California-specific section but that are not defined in this Policy have the meanings set forth in the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 and its implementing regulations (collectively, “CCPA“).
Categories of Personal Information. In the last twelve (12) months, we have collected the following categories of Personal Information:
- Identifiers consisting of: real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (“IP”) address, email address, or other similar identifiers.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code section 1798.80(e)) such as name, signature, address, telephone number, education, employment, employment history.
- Internet or other similar network activity such as browsing history, search history, information on a consumer’s interaction with a website, application or advertisement.
- Geolocation Data: Approximate GPS geolocation and IP address, depending in part on your device.
Categories of Sources From Which Personal Information is Collected. The categories of sources from which your Personal Information is collected is described in Section 2 above (The Personal Information We Collect).
Purposes for Collecting Personal Information. Our purposes for collecting your Personal Information are described in Section 4 (How We Use Personal Information).
Categories of Personal Information Disclosed For a Business Purpose. In the last 12 months we disclosed the following categories of Personal Information for our or one of our service provider’s operational purposes:
- Identifiers
- Customer Records
- Internet Activity
- Internet or other similar network activity
- Geolocation Data
The categories of third parties and / or service providers with whom we disclosed Personal Information in the last 12 months are described above in Section 5 Section 5 (Disclosing Your Personal Information).
Categories of Personal Information Sold or Shared. In the last 12 months we have not sold Personal Information for monetary compensation. However, we have “sold” or “shared the following categories of Personal Information (as defined by CCPA) for cross-contextual behavioral advertising. See the section above titled “Categories of Personal Information We Collect” for more detail on the type of Personal Information in each category. You have the right to opt-out of the Sale or Sharing of your Personal Information.
- Internet Activity
- Geolocation Data
We do not have any actual knowledge that we have sold or shared information of any individual under the age of 16 for monetary compensation or for cross-context behavioral advertising.
Sensitive Personal Information. We have not used or disclosed Sensitive Personal Information for any reason other than the reasons for which it was provided to us. We do not use Sensitive Personal Information to infer characteristics about individuals.
Your California Consumer Rights
Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, as a California resident, you may exercise the following rights with regard to your Personal Information:
Right to Request Disclosure of Categories. You have a right to request access to the following information: (a) the categories of personal information we collected from you in the 12 month period prior to your request, (b) the categories of sources from which the personal information was collected, (c) the business or commercial purpose for collecting your personal information(d) the categories of third parties with whom we disclosed your personal information; and (e) the categories of personal information we disclosed in the 12 month period prior to your request. You also have a right to access a list of categories of personal information we sold or disclosed for a business purpose in the last 12 months, if any.
Right to Request Access. You have a right to request that we disclose to you the specific pieces of Personal Information that we have collected about you in the 12-month period prior to your request and to have this delivered, either (a) by mail or (b) electronically in a portable format and, to the extent technically feasible, in a readily useable format.
Right to Request Deletion. You have the right to request that we delete Personal Information we collected from you. We will comply with such requests, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.
Right to Opt-Out of the Sale or Sharing of Your Personal Information. You have the right to request that we do not Sell or Share any Personal Information sold or shared by us in the prior 12 months. You may submit your opt-out request by following this link: Do Not Sell or Share My Personal Information.
We also respond to Global Privacy Control browser signals as opt-out of sale/sharing requests.
Right to Request Correction of Inaccurate Personal Information. You have the right to request that we correct inaccurate Personal Information that we maintain about you.
Right to Limit Use and Disclosure of Sensitive Personal Information. Sevita does not use or disclose sensitive personal information for purposes that, under applicable law, require us to offer consumers a “Right to Limit” the use or disclosure of sensitive personal information.
Right to Non-Discrimination. You have a right to not receive discriminatory treatment for exercising any of your rights under the CCPA. Should you wish to exercise any of your rights as detailed above, we will not discriminate against you by offering you different Services based solely upon your exercise of the above rights.
How to Exercise Your Rights
To exercise your rights described in this Policy, you, or your authorized agent, may submit your request to us by contacting us at any of the following:
E-mail: [email protected]
Toll-Free Telephone: 800-245-3860
Mail: Attn: Compliance Officer
6600 France Avenue South
Suite 350
Edina, MN 55435
Verifiable Consumer Request. You must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.
When we receive your rights request (i) we will acknowledge receipt of your request; (ii) we will try to match the information you provide in making the request with information we already maintain about you; (iii) if required to verify your identity, we may ask you to provide additional information, which may include Personal Information; and (iv) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.
We will only use Personal Information we collect during the verification process for the purpose of verifying your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.
We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.
Authorized Agents. You have a right to submit requests to exercise your rights using an authorized agent, in which case you must still verify your identity directly with us. We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf. Furthermore, a parent or legal guardian may make a request on behalf of their child.
CALIFORNIA’S “DO-NOT-TRACK” REQUIREMENT. WE CURRENTLY DO NOT HONOR “DO NOT TRACK” REQUESTS.
2. VIRGINIA PRIVACY RIGHTS NOTICE
THIS SECTION PROVIDES ADDITIONAL PROVISIONS APPLICABLE ONLY TO RESIDENTS OF VIRGINIA. If any information in this section conflicts with the main body of this Policy above, the information in this section shall control.
Capitalized terms used in this Virginia-specific section but not defined in this Policy have the meanings set forth in the Virginia Consumer Data Protection Act (“VCDPA”).
A. Virginia Consumer Rights
Subject to exceptions permitted by applicable law and verification of your identity, Virginia residents have the following rights with regard to their Personal Data:
Right to Request Access. You have the right to confirm whether or not we are processing your Personal Data and to access such Personal Data.
Right to Request Data Portability. You have the right to obtain a copy of your Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without hindrance, where the processing is carried out by automated means.
Right to Request Correction. You have the right to request to correct inaccuracies in your Personal Data, considering the nature of the Personal Data and the purposes of the processing of such Personal Data.
Right to Request Deletion. You have the right to request deletion of Personal Data provided by or obtained about you.
Right to Opt-Out. You have the right to opt-out of the processing of Personal Data for purposes of (i) Targeted Advertising, (ii) the Sale of Personal Data, or (iii) Profiling in furtherance of decisions that produce legal or similarly significant effects on you. To opt-out online, please use contact information below.
B. How to Exercise Your Virginia Consumer Rights
To exercise your rights described in this Policy, you may submit your request to us by contacting us at any of the following:
E-mail: [email protected]
Toll-Free Telephone: 800-245-3860
Mail: Attn: Compliance Officer
6600 France Avenue South
Suite 350
Edina, MN 55435
We are not required to comply with a rights request if we are unable to authenticate the request using commercially reasonable efforts. In such event, we will either deny the request or request more information from you to help us authenticate the request.
If we reject or deny your request, you have the right to appeal our decision by submitting an appeal to [email protected]. This appeal request must be submitted within a reasonable time period following our rejection of your request. If we deny your appeal, you may submit a complaint to the Attorney General of Virginia by using the contact information found here: https://www.oag.state.va.us/contact-us/contact-info
C. Deidentified Data Commitment
We will not attempt to re-identify any de-identified data that we maintain and use.