Information We Collect
We 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”). In particular, we have collected the following sensitive personal data (“SPI”) categories of personal information from consumers within the last twelve (12) months:
A. Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Collected: YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Collected: YES
C. Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: YES
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected: YES
Examples: Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and
voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: YES
F. Internet or other similar network activity.
Examples: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Collected: YES
G. Geolocation data.
H. Sensory data.
I. Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: YES
K. Inferences drawn from other personal information.
Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: YES
Personal information does not include:
- Publicly available information from government records.
- 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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following
categories of sources:
- Directly from our clients or their agents. For example, from documents that our
clients provide to us related to the services for which they engage us. - Indirectly from our clients or their agents. For example, through the information
we collect from our clients in the course of providing services to them. - Directly and indirectly from activity on our website (empowerme.com). For
example, submissions through our website portal or website usage details are
collected automatically. - From third parties that interact with us in connection with the services we
perform. For example, from government agencies.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the
following business purposes
- To fulfill or meet the reason for which the information is provided. For example, if
you provide us with personal information for us to process your employment
application. - To provide you with information, products, or services that you request from us.
- To provide you with email alerts, text messages, event information, and other
notices concerning our services and events or news, that may be of interest to
you. - To carry out our obligations and enforce our rights arising from any contracts
entered into between you and us, including for billing and collections. - To improve our website and present its contents to you.
- For testing, research, and analysis.
- As necessary or appropriate to protect the rights, property, or safety of us, our
clients, or others. - To respond to law enforcement requests and as required by applicable law, court
order, or governmental regulations. - As described to you when collecting your personal information or as otherwise
set forth in the CCPA.
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.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose.
When we disclose personal information for a business purpose, we enter a contract that
describes the purpose and requires the recipient to both keep that personal information
confidential and not use it for any purpose except performing the contract. We will not
sell and share personal information regarding minors without any parental or guardian
consent.
In the preceding twelve (12) months, we have disclosed the following categories of
personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under CA or federal law.
Category D: Professional or employment-related information
We disclose your personal information for a business purpose to the following
categories of third parties
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with services we provide to you.
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their
personal information. This section describes your CCPA rights and explains how to
exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request a “look back” that we disclose certain information to you
about our collection and use of your personal information over the past 12 months.
Once we receive and confirm your verifiable consumer request, we will disclose to you
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal
information. - Limit or disclose SPI “sensitive personal information.” The SPI includes the following points: biometric and genetic data, social security, driver’s license, passport number, state identification card, passwords, debit and credit card numbers, racial, ethnic origins, or religious details, union membership, and location.
- The categories of third parties with whom we share or sell that personal information and the ability to request to “opt-out” of any profiling with third parties.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- Sales, identifying the personal information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
You have the right to request that we correct any inaccurate personal data, including
personal identifiable information (PII) and sensitive personal data (SPI) that we
collected from you and retained, subject to certain exceptions. Once we receive and
confirm your verifiable consumer request, we will correct (and direct our service
providers to correct) your personal information to our records, unless an exception
applies.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we
collected from you and retained, subject to certain exceptions. Once we receive and
confirm your verifiable consumer request, we will delete (and direct our service
providers to delete) your personal information from our records, unless an exception
applies.
We may deny your deletion request if retaining the information is necessary for us or
our service providers to:
- 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 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 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 achievement of the research if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
To exercise the access, data portability, and deletion rights described above, please
submit a verifiable consumer request to us by either
- Call us at 844-502-7996.
- Email us at [email protected]
- Visit empowerme.com
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.
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.
We cannot respond to your request or provide you with personal information if we
cannot verify your identity or authority to make the request and confirm the personal
information relates to you. Making a verifiable consumer request does not require you
to create an account with us. We will only use personal information provided in a
verifiable consumer request to verify the requestor’s identity or authority to make the
request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt.
period in writing. If you have an account with us, we will deliver our written response to
that account. If you do not have an account with us, we will deliver our written response
by mail or electronically, at your option. 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.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless
permitted by the CCPA, we will not
- Deny you services.
- Charge you different rates for services, including through granting discounts or other benefits, or imposing penalties.
- Provide you with a different level or quality of services.
- Suggest that you may receive a different price or rate of services or a different level or quality of services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
Contact Information
If you have any questions or comments about this notice, our California Privacy Statement, the ways in which we collect and use your personal information, 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: 844-502-7996
Website: empowerme.com
Email: [email protected]
Postal Address:
EmpowerMe Wellness
Attn: Compliance Dept.
1135 Strassner Dr.
St. Louis, MO 63144