State Privacy Disclosures

Last revised: August 19, 2024

These State Privacy Disclosures (“State Disclosures”) supplement our Privacy Policy by providing additional information about our personal information processing practices for residents of the States of California and Colorado. For a detailed description of how we collect, use, disclose, and otherwise process personal information in connection with our Services, please visit our Privacy Policy. Unless otherwise expressly stated, all terms defined in our Privacy Policy have the same meaning when used in these State Disclosures.

1. Additional Disclosures – Collection, Use and Disclosure of Personal Information.

 

  • Username and password
  • Disclosure of personal information. We share personal information with third parties for the business purposes described in our Privacy Policy. The categories of third parties to whom we disclose your personal information for a business purpose include: 
    • Practices that participate in our ACOs
    • Our service providers
    • Marketing and strategic partners
    • Advertising and analytics partners 
    • Social networks 
    • Government authorities

We have sold or shared the following categories of personal information for the purposes described in our Privacy Policy, subject to your settings and preferences and your “Right to Opt Out”: 

  • Personal identifiers
  • Commercial information
  • Preferences
  • Internet, network, and device information, such as IP address and advertising ID

The categories of third parties to whom we may sell or share the personal information –
excluding your mobile phone number – include: 

  • Advertising and analytics partners

To learn more about how we disclose personal information to third parties, please refer to the Personal Information We Collect, How We Collect Personal Information and How We May Use Personal Information sections of our Privacy Policy. 

  • De-identified data. We may at times receive, or process personal information to create, de-identified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain de-identified data, we will maintain and use the data in de-identified form and not attempt to reidentify the data except as required or permitted by law. 

2. Your Privacy Rights. 

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

The Right to Know

The right to confirm whether we are processing personal information about you and – under California law only – to obtain certain personalized details about the personal information we have collected about you, including the:

  • categories of personal information collected;
  • categories of sources of the personal information;
  • purposes for which the personal information were collected; 
  • categories of personal information disclosed to third parties (if any), and the categories of recipients to whom the personal information were disclosed;
  • categories of personal information shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for those purposes; and
  • categories of personal information sold (if any), and the categories of third parties to whom the personal information were sold.

The Right to Access & Portability

The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

The Right to Correction

The right to correct inaccuracies in your personal information, considering the nature of the personal information and the purposes of the processing of the personal information.

The Right to Control Over Sensitive Information

The right to exercise control over our collection and processing of certain sensitive information.

The Right to Deletion

The right to have us delete the personal information we maintain about you. After receiving and appropriately verifying a request to delete, we will delete the personal information we have collected about you, except for situations where specific information is necessary for us to: 

  • provide you with a good or service that you requested; 
  • perform a contract we entered into with you; 
  • maintain the functionality or security of our systems; or 
  • comply with or exercise rights provided by the law. 

In addition, the law permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided it to us or that are reasonably aligned with your expectations based on your relationship with us.

Right to Opt Out of Sales or Sharing of Personal information

The right to direct us not to (a) “sell” your personal information to third parties for monetary or other valuable consideration, or (b) “share” your personal information with third parties for cross-context behavioral advertising purposes and targeted advertising purposes.

Non-discrimination / Non-retaliation. Depending on your state of residency, you have the right to not receive retaliatory or discriminatory treatment if you exercise any of the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

3. How to Exercise the Right to Opt-Out of “Sales” or “Sharing” of Personal Information. 

As is common practice among companies that operate online, we do allow certain advertising networks, social media companies and other third-party businesses to collect your personal information directly from your browser or device through Cookies when you visit or interact with our websites and otherwise engage with us online. For example, they may collect Internet, network and device information, such as an IP address, cookie ID or advertising ID and Website usage to infer preferences from your browsing history and interactions with our Service as well as other sites and services. 

These third parties use this personal information to display relevant ads on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third-party businesses may use such data for their own purposes in accordance with their own privacy statements, which may include reselling this data to additional third parties, including other advertising networks. Please see the Advertising and Analytics section of our Privacy Policy for more information about how third parties use Cookies to collect data automatically on our Services, and the choices you may have in relation to those practices.

To opt out of the “sales” or “sharing” of your personal information for the purposes of targeted advertising, or any potential future “sales” or “sharing” of your personal information, please complete the following steps.

  • Website or App. To opt out of advertising Cookies on the Website or App, navigate to your browser’s settings and clear your cache and delete all cookies stored on your browser.  Then, please re-visit the Website or App. You will be provided with, and can exercise, an option to decline all advertising cookies involved in the “sale” or “sharing” of personal information. Please note that this opt-out is device- and browser-specific and will not be effective on your visits to the Website or App from other devices or browsers. Please note that deleting and opting out of some cookies may result in an inability to take full advantage of the services.
  • Other Potential Future “Sales” and Sharing. For other potential future “sales” and sharing for targeted advertising, you may submit a request to opt-out and to be added to our suppression list by:
    • Emailing us at privacy@aledade.com with the subject line “Consumer Opt-Out Request” and sufficient information in the content of the message to identify you in our records; or 
    • Contacting us at 866-252-0873.

4. How to Exercise Your Right to Know, Access, Portability, Correction or Deletion. 

To exercise any other privacy rights described in the Your Privacy Rights section above, either email us at privacy@aledade.com or contact us at 866-252-0873. Depending on the nature of your request, we may ask you for additional information to verify your request and identity. 

We will need to verify your identity before processing your request. To verify your identity, we will generally either require the matching of sufficient information about you to the information we maintain about you in our systems or the successful login to your account. Although we try to limit the personal information collected in connection with requests, certain requests may require us to obtain additional personal information from you for added certainty, such as your email address, mailing address, and/or date of last interaction with us. In certain circumstances, we may decline a request to exercise the right to know and delete, particularly where we are unable to verify your identity.

We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. 

Authorized agents. In certain circumstances, you may designate an agent to submit requests on your behalf. The agent can be a natural person or a registered business entity. For security purposes, we may need to verify your identity and confirm directly with you that you have provided the authorized agent permission to submit the request, and it may take additional time to fulfil agent-submitted requests. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf.  Please note that for privacy and security reasons, we will direct future communications to the data subject on whose behalf the request was made.

If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process. Please contact us at privacy@aledade.com or 866-252-0873 for more information.

5. Contacting Us.

Questions. If you have questions on the processing of your personal information or are unhappy with how we’ve handled your personal information, please contact us at: 

Mail: Aledade, Inc.
Attn: Privacy Officer
4550 Montgomery Avenue, Suite #950N
Bethesda, MD 20814 

Email: privacy@aledade.com

Appealing Privacy Rights Decisions.  Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted using by email at privacy@aledade.com with the subject line “Consumer Rights Request,” or by calling 866-252-0873.

Colorado Residents: If your appeal is denied, you may contact the Colorado Attorney General to address your concerns here.