Privacy notice for California residents
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy and applies solely to individuals residing in California (“consumers”) from whom we, Spark Health Partners (“Spark,” “we,” “our”), collects Personal Information (defined below).
Personal information we collect
The CCPA defines Personal Information as data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Our collection of Personal Information is generally not subject to the CCPA, however, since the law does not apply to:
- Publicly available information from government records;
- De-identified or aggregate consumer information; and
- Other Personal Information excluded from the CCPA’s scope, such as:
- 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; and
- 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.
This website is intended for use by our business partners, potential business partners, and those interested in seeking employment with Spark.
In general, we may collect the following categories of Personal Information: Identifiers, personal information as defined in the California customer records law, commercial information, internet activity information, geolocation data, and audio, electronic, or similar information. If you are seeking employment with Spark, we may also collect the following information: Characteristics of protected classifications under California or federal law, professional or employment-related information, education information, and sensitive personal information. Please note that we do not use or disclose sensitive personal information for purposes other than those specified in Section 7027(m) of the CCPA regulations. We collect Personal Information from the following categories of sources:
- Directly from you and from our clients or their agents.
- Indirectly from you and from our clients or their agents.
- Indirectly from you when you browse our website (Spark Health Partners).
- Business inquiries on our website (Spark Health Partners).
- From third parties that interact with us in connection with the services we perform.
Cookies and other tracking technologies
We and our service providers may use cookies and similar technologies such as pixels, web beacons, and local storage to collect usage and browser information about how you use our website. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of our website, to enhance your experience through personalization, and to help us better understand the features of our website that you and other users are most interested in.
We use analytics services, including Google Analytics, to assist us with analyzing our website traffic. These services utilize cookies and other technologies that collect your Personal Information. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ websites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.
Most browsers provide you with the ability to block, delete, or disable cookies, 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 our services may not be available, or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings. We respond to Do Not Track (“DNT”) signals sent to us by your browser.
Use and disclosure of information
We may use the Personal Information that we collect for the following purposes:
- To contact representatives of prospective clients through the regular course of marketing/sales activities.
- To allow us to better service you in providing you with information, products or services that you request from us.
- To provide you with email alerts, event/webinar registrations, advertising, and other notices concerning our products or services, or events or news, that may be of interest to you.
- To send periodic emails regarding your order or other products and services.
- 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, analysis and product development.
- To manage and administer a prospective employment relationship with you if you are seeking employment with Spark.
- 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.
Disclosure of personal information
The categories of third parties to which we disclose Personal Information for a business or commercial purpose are summarized in the chart below. We do not knowingly sell or share (as those terms are defined under the CCPA) Personal Information, including Personal Information of minors under the age of 16.
Categories of data
Categories of recipients to which we disclose personal information for a business or commercial purpose
Identifiers
- Affiliates and subsidiaries
- Service providers
- Business partners
- For legal, security and safety purposes
- In connection with a corporate transaction
- Entities to which you have consented to the disclosure
Personal information, as defined in the California customer records law
- Service providers
Commercial information
- Not applicable
Biometric information
- Not applicable
Characteristics of protected classifications under California or Federal Law
- Not applicable
Internet or other similar network activity
- Service providers
Geolocation data
- Service providers
Audio, electronic, visual, thermal, olfactory or similar information
- Not applicable
Inferences drawn from other personal information
- Not applicable
Professional or employment-related information
- Service providers
Non-public education information (per the Family Education Rights and Privacy Act [20 U.S.C. Section 1232g, 34 C.F.R. Part 99])
- Not applicable
Sensitive personal information
- Service providers
CCPA rights
Description of rights
You may have the following rights with respect to your Personal Information:
- Access – You may have the right to know what Personal Information we have collected about you and to access such data.
- Data portability – You may have the right to receive a copy of your information in a portable and readily usable format.
- Deletion – You may have the right to delete your Personal Information that we have obtained, subject to certain exceptions.
- Correction – You may have the right to correct inaccuracies in your Personal Information.
- Opt out of certain processing – You may have the right to: (a) opt out of the sale or sharing (as defined under the CCPA) of your Personal Information; (b) limit the use of your Sensitive Personal Information (if applicable), and (c) opt out of the processing of your Personal Information for purposes of profiling.
To exercise any of these rights available to you, see the Exercising Your Individual Privacy Rights section below.
Exercising your individual privacy rights
To exercise any of the privacy rights afforded to you under the CCPA, please submit a request to us by one of the following methods:
- Calling us toll free at 844-429-7466
- Emailing us at sparkhealthpartners@spark.com
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.
Only you, or an authorized agent 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.
We must verify your identity before fulfilling your requests, and 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. 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 consumer, we will also need to verify your identity. To make a request on behalf of an Spark consumer, an Authorized Agent must first provide a copy of either (a) a letter signed by the consumer authorizing the agent to submit a CCPA request on his or her behalf, or (b) a valid power of attorney issued pursuant to California Probate Code sections 4000 to 4465. An Authorized Agent must email one of these documents to sparkhealthpartners@spark.com and include a phone number where the agent may be reached during regular business hours. 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.
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.
We do not charge a fee to process or respond to your requests unless it is excessive or repetitive. 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 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.
How long do we keep your personal information?
We will retain each category of your Personal Information for as long as necessary to fulfill the purposes described above, unless otherwise required by applicable laws. Criteria we will use to determine how long we will retain your Personal Information include whether we need your Personal Information to provide you with our services you have requested; we continue to have a relationship with you; you have requested information or services from us; we have a legal right or obligation to continue to retain your Personal Information; we have an obligation to a third party that involves your Personal Information; our retention or record keeping policies and obligations dictate that we retain your Personal Information; we have an interest in providing you with Personal Information about our services; and we have another business purpose for retaining your Personal Information.
California Shine the Light Law
Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of Personal Information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please contact us using the information below. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.
How we protect personal information
We use 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.
International use of our services
Our website is hosted in the United States. If you are visiting our website 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.
Links to third-party websites
We are not responsible for the practices employed by any websites or services linked to or from our services, 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.
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 sparkhealthpartners@spark.com or contact us using the information listed below.
Changes to this privacy notice
Please note that we may modify or update this Privacy Notice from time to time, so please review it periodically. We will notify you if material changes are made. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to our website.
Contact us
If you have any questions about our practices or this Privacy Notice, please contact us as follows:
Mailing Address:
Spark Health Partners
11511 Reed Hartman Hwy
Blue
Ash, OH 45241
704-765-3715
844-429-7466
Last updated Jan. 25, 2024