Privacy Policy

Last Updated/Effective Date: May 11, 2023

1. Introduction
CentraCare (“CentraCare,” “us,” “our,” or “we”) is committed to ensuring that your privacy is protected. This Privacy Notice describes the types of Personal Information CentraCare may collect: (a) when you visit, access, or use our websites (the “Websites”); or (b) as a part of any other services to which this Privacy Notice is posted (collectively, “Services”). It also describes CentraCare’s practices for collecting, using, maintaining, protecting, and disclosing your Personal Information.

To the extent we collect or process protected health information, as defined by the Health Insurance Portability and Accountability Act (“HIPAA”), please see our Notice of Privacy Practices.

Please note that we may modify this Privacy Notice at any time. All changes will be effective immediately upon posting on the applicable Websites and Services. Material changes will be conspicuously posted or otherwise communicated to you in accordance with applicable law.

2. Personal Information We Collect
We may collect a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you.

The types of Personal Information we collect may include:

• Identifiers, such as your name, physical address, email address, telephone number, account name, and device identifiers.
• Commercial information, such as information about purchases you have made, products and services you have shown interest in, payment processing information, and other commercial information.
• Location Data – While navigating our Websites your mobile device or browser may share your location data, both through WiFi and GPS. We will collect this information based on the settings of your phone and browser.
• Device information, consisting of information from devices you connect to or use with our Websites, including your mobile device, connected devices, and wired and wireless sensors. The information we receive from these devices may include IP address and similar unique device identifiers.
• Internet or other electronic network activity information, such as browsing history, search history, device and browser information, and information about your interactions with and use of our products, services, and social media.
• Inferences drawn from the information we collect about you to create a profile about you reflecting your preferences.
• Communications, such as the contents of your communications with us, whether via e-mail, chat functionality , social media, telephone or otherwise, and inferences we may make from other personal information we collect. Where permitted by applicable law, we may collect and maintain records of calls and chats with our agents, representatives, or employees via message, chat, post, or similar functionality.

3. How We Collect Your Personal Information
• We May Collect Your Personal Information Directly From You – For example, if you request information from us, submit a question, send us a message or live chat with us through our Websites, or register for our other Services.
• We May Also Collect Personal Information From Third Parties – For example, we may work with business partners, service providers, advertising networks, and analytics providers, who may provide us with Personal Information.
• Through Online Tracking Technologies and Analytics– We may use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect certain Personal Information about you. For more information about the trackers and analytics tools that we use, please see Section 4 of this Privacy Notice. Please note that some of our service providers or plug-ins may use cookies or other methods to gather information regarding your use of the Websites and may combine the information in these cookies with any Personal Information about you that they may have. The use of such tracking information by a third party depends on the privacy notice of that third party. For more information on cookie choices and controls, please see Section 4 of this Privacy Notice.

4. Cookies and Other Technologies
We process the information collected through cookies and tracking technologies to allow you to access certain features of the Websites; to help authenticate users, prevent fraud, and secure the Websites; to understand how you interact with our Websites in order to help improve them and understand what you are most interested in; and to help personalize your experience. For more information on the specific tracking technologies we use and their purposes, please see below:

Cookies. We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Websites, pages visited, referring URL, language preferences, and other aggregated traffic data. We use the data for security purposes, to facilitate navigation, to display data more effectively, to collect statistical data, to personalize your experience while using the Websites and Services, and to recognize your computer to assist your use of the Websites and Services. We also gather statistical data about use of the Websites and services to continually improve design and functionality, understand how it is used and assist us with resolving questions.

Pixel Tags and Other Similar Technologies. We collect data from pixel tags (also known as web beacons and clear GIFs), which are used to, among other things, track the actions of users of the Websites and Services, measure the success of our marketing campaigns, and compile statistics about usage of the Websites and Services.

Analytics. We collect data through Google Analytics and Google Tag Manager, which use cookies and technologies to collect and analyze data about use of the Websites and Services. These services collect data regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://policies.google.com/technologies/partner-sites and opt out by downloading the Google Analytics opt out browser add-on, available at https://tools.google.com/dlpage/gaoptout.You can learn more about Adobe and opt out by visiting http://www.adobe.com/privacy/opt-out.html.

You can use our cookie preference page to decide which of the above technologies you wish to enable when you use our Websites . Most browsers provide you with the ability to block, delete, or disable cookies and similar technologies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Websites may not be available, or some functionality may be limited or unavailable.

We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.

Blocking or rejecting cookies will not stop all of the tracking described in this Privacy Notice. These features and options are browser and device specific and are not uniform. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful, or you can use the help option in your browser for more details:
• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari web and iOS

To find out more on how to manage and delete cookies, visit www.allaboutcookies.org. For more details on your choices regarding use of your web browsing activity for interest-based advertising you may visit the following websites:
• networkadvertising.org
• optout.aboutads.info
• youradchoices.com
• youronlinechoices.eu

On a mobile device, you may also be to adjust your settings to limit ad tracking.

5. How We Use the Personal Information Collected
To the extent permitted by applicable law, we may use Personal Information to:
• operate the Websites and Services and provide support to our business functions;
• fulfill your requests;
• provide our Websites and Services, along with customer support;
• protect against criminal activity, claims and other liabilities;
• send you information about our company, products, services, and promotions;
• respond to reviews, comments, or other feedback provided to us;
• support and personalize the Websites and Services and our advertising efforts;
• protect the security and integrity of the Websites and Services;
• the extent required for benchmarking, data analysis, audits, developing new products, enhancing the Websites, facilitating product, software and applications development, improving the Websites or our Services, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes;
• meet our contractual requirements;
• comply with applicable legal or regulatory requirements and our policies;
• market, advertise, and provide the Websites and our Services; and
• the extent necessary for any other lawful purpose for which the Personal Information is collected.

6. Disclosure of Personal Information
We may disclose your Personal Information in the following circumstances:

• To Business Partners – We may share Personal Information with our trusted business partners. For example, we may share your Personal Information with a company for marketing purposes, such as when we co-sponsor a product or service. These partners and affiliates may use your Personal Information to, among other things, send you information or contact you about their services and products.
• For Legal Obligation or Safety Reasons – When we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Use, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of CentraCare, its users, or the public against harm.
• In the Case of a Merger or Sale – If we are involved in a merger, acquisition, or any form of transfer or sale of some or all of its business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal Information may be transferred along with the business. Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer.
• To Service Providers – When we hire a service provider to help operate the Websites, Services, or our business, we may give access to Personal Information as necessary to perform such services. This may include service providers that operate our Websites and Services, send our communications, manage our customer relations, or assist us in providing our services.
• To Affiliates – We may share Personal Information with our affiliated companies, for example where we share services and for administrative purposes.

7. How Long Do We Keep Your Personal Information
We will retain your Personal Information for as long as necessary to fulfill the purposes for which it has been collected, as outlined in this Privacy Notice, or any longer retention period required by law. If you are a California resident, please see the section below titled California Residents for additional information about how long we retain your Personal Information.

8. How We Protect Your Personal Information
We use our commercially reasonable efforts to protect the confidentiality and security of Personal Information we process. However, despite these efforts to store Personal Information in a secure operating environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information.

9. Your Choices and Controls
Depending on where you live, you may have the following rights with respect to your Personal Information:

• Access
• Data portability
• Erasure
• Correction
• Out of sales of Personal Information

For a broader description of these rights, please see the applicable chart in Section 13 of this Privacy Notice. In addition, you may have the right to opt out of targeted advertising and profiling, to the extent that profiling makes decisions that produce legal or similarly significant effects concerning you. To exercise any of these rights available to you, see Section 14 below.

To opt out of marketing emails, you can use the unsubscribe link found in the email communication you receive from us. You may also use the “Contact Us” option within the relevant service to opt out and elect not to receive further emails from us. Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law. Additionally, if you choose not to provide certain Personal Information, we may be unable to provide some or all of our Services to you.

10. International Use of the Websites
Our Websites and Services are hosted in the United States. If you are visiting our Websites from outside of the United States, please note that by providing your Personal Information it is being transferred to, stored, collected, or processed in the United States, where our data center and servers are located and operated.

11. Children’s Privacy
• We do not knowingly collect or solicit any Personal Information from children under the age of 16. In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at privacyline@centracare.com or contact us using the information listed in Section 16.

12. Links to Third-Party Websites
We are not responsible for the practices employed by any websites or services linked to or from the Website, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s Privacy Notice.

13. California Residents
This Section applies to our collection and use of Personal Information if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (the “CCPA”), where “Personal Information” has the definition set forth in the CCPA. This Section describes (1) the categories of Personal Information collected and disclosed by us, subject to CCPA, (2) your privacy rights under CCPA, and (3) how to exercise your rights.

If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact us using the information provided below.

CentraCare makes the following disclosures regarding the Personal Information CentraCare has collected within the 12-month period preceding the effective date of this Privacy Notice:

Sources of Personal Information. We collect Personal Information from the categories of sources detailed in Section 3 above: (i) directly from you; (ii) data collected automatically through tracking technologies; and (iii) third parties.

Use of Personal Information. We collect Personal Information for the business and commercial purposes detailed in Section 5 above.

Disclosure of Personal Information. The categories of third parties to which we disclose personal information for a business or commercial purpose or to whom we sell or share personal information are summarized in the chart below. We do not sell or share your Personal Information. We also do not knowingly sell or share the personal information of minors under the age of 16.

We will retain each category of your Personal Information for as long as necessary to fulfill the purposes described in the “How We Use the Personal Information Collected” section above, unless otherwise required by applicable laws. Criteria we will use to determine how long we will retain your information include whether: we need your information to provide you with products or services you have requested; we continue to have a relationship with you; you have requested information, products, or services from us; we have a legal right or obligation to continue to retain your information; we have an obligation to a third party that involves your information; our retention or recordkeeping policies and obligations dictate that we retain your information; we have an interest in providing you with information about our products or services; and we have another business purpose for retaining your information.

Subject to certain exceptions, if you are a resident of California, you may have the following rights:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child.

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

Other California Privacy Rights
• California Civil Code Section 1798.83 permits visitors to our Websites and Services who are California residents and who have an existing business relationship with us to request certain information regarding our disclosure of personal information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please send an email with the subject heading “California Privacy Rights” to us at privacyline@centracare.com, or you may write to us at the address below.

14. Exercising Your Individual Privacy Rights
You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Privacy Notice which means we will not deny goods or services to you, provide different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.

To exercise your privacy rights under applicable data protection law, please submit a request to us by one of the following methods:

• Calling us toll free at 800-835-6652
• E-mailing us at privacyline@centracare.com
• Submitting a request through our web form

Verification: We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. We will only use Personal Information provided in a request to verify the requestor’s identity. If you are an authorized agent making a request on behalf of a California consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.

We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our written response electronically.

We do not charge a fee to process or respond to your 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.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us.

We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes

Appeals: If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you may submit your appeal via our web form.

15. Changes to this Privacy Notice
It is CentraCare’s policy to post any changes to the Privacy Notice on this page. The date the Privacy Notice was last updates is identified at the top of the page. We may provide you with an updated Privacy Notice if material changes are made, if required by law. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to this page or through another mechanism, if required by law. Please refer back to this Privacy Notice on a regular basis.

16. Contact Us
For questions about this Privacy Notice and CentraCare’s privacy practices, contact us at the email or mailing address listed below. Please keep in mind we may request additional information from you to verify your identity.

Email: privacyline@centracare.com

Or

CentraCare
Attn: Privacy Officer
1406 Sixth Avenue North
St. Cloud, MN 56303
Phone: 800-835-6652 or 320-251-2700, ext. 53046