California Consumer Privacy Act

Information We Collect

Under the California Consumer Privacy Act (“CCPA”), we are required to notify California consumers about our collection, use, and disclosure of their personal information (whether collected through this website or offline). In this section of our Policy, and in accordance with the CCPA, “personal information” includes any information 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, including the categories identified in the table below to the extent they identify, relate to, describe, are capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.

To submit a data rights request click here.

This Policy does not apply to applicants for positions at Bulletin Healthcare or Bulletin Media.

Below please find the categories of personal information about California residents that we collect, sell, and/or disclose to third parties or service providers for a business purpose.

Categories of personal information	Do we collect?	Do we disclose for business purposes?	Do we sell?
Category A – Identifiers Examples: Name, email address, physical address, NPI, ME Number, telephone number, IP address, and unique personal identifier.	Yes	Yes	Yes
Category B – Personal Information Categories Listed in the California Customer Records Statute (Cal. Civ Code Sec. 1798.80(e)) Examples: Name, telephone number, address, education, and employment.	Yes	Yes	Yes
Category C – Protected Classification Characteristics Under California or Federal Law Examples: Race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.	Yes	No	No
Category D – Internet or Other Similar Network Activity Examples: Interaction with our email news briefings; including whether you have opened a briefing, or clicked on a link within the briefing.	Yes	Yes	Yes
Category E – Professional or Employment- Related Information Examples: Professional life cycle, title, current employment, institution	Yes	No	No
Category F – 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 Level	Yes	No	No
Category G – Commercial Customer Records: Examples: Paper and electronic customer records containing personal information, such as name, signature, work email address, and work contact details.	Yes	No	No
Category H – Commercial Customer purchase history and tendencies: Examples: Commercial information, products or services purchased, obtained, or considered, or other purchasing histories or tendencies.	Yes	No	No
Category I – Biometric Information: Examples: physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	No	No	No
Category J – Gelocation Data: Examples: Precise geographic location information about a particular individual or device	Yes	Yes	Yes
Category K – Audio Or Visual Data	No	No	No

Personal Information Does Not Include

• Publicly available information from government records
• De-identified or aggregated consumer information
• Information excluded from the scope of CCPA

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our association partners
• From reputable data providers
• Directly and indirectly from readers via interactions with our briefings
• Cookies and web trackers. For more information, go here.

Purposes for Collecting and Using Personal Information
Generally, we may use or disclose the personal information we collect for the following business purposes:

• To provide the delivery of our briefings
• To target relevant advertisements to our readers
• To provide you with information that you request from us
• To improve our briefing deliverability
• To improve our briefing content
• To improve the advertisements readers may see
• For testing, research, analysis, and product development
• As necessary to protect the rights of our partners, readers, and others
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Sharing of Personal Information

We may use or disclose your personal information to a third party for a business purpose. We will only disclose personal information for a business purpose to third-parties with whom we have a contractual relationship. Those third-parties are bound to keep your personal information confidential and may not use that information for any purpose other than as described by our contracts.

In the preceding (12) months we have disclosed the following categories of personal information for a business purpose.

• Category A – Identifiers
• Category B – California Customer Records-Related Information
• Category D – Internet or Other Similar Network Activity
• Category E – Professional or Employment-Related Information

We disclose your personal information for a business purpose to the following categories of third parties.

• Our association partners
• Service providers
• Our affiliates
• Advertisers

In the preceding twelve (12) months, we have sold personal information.

California Residents’ Rights
California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below. California consumers have the right to request that we disclose what personal information we collect, use, disclose, and sell about you. Any California Resident may inquire about the personal information we collect about them, request deletion of personal records, and/ or seek to opt out of sales of their personal information through the Do Not Sell provision listed below in this section.

Do Not Sell My Personal Information. California residents have the right to opt-out of our sale of their personal information.

Opt-out rights can be exercised via our Do-Not-Sell options: email info@bulletinhealthcare.com or call toll-free 877-297-8921.

Verifiable Requests for Copy, Deletion and Right to Know. Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months. Please see Submitting Requests section below for instructions about how to exercise your rights:

Deletion: The right to request deletion of personal information that we have collected about you, subject to certain exemptions, and to have such personal information deleted, except where necessary that we maintain such personal information in order to:

• Where appropriate, complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business's ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
• 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 businesses' deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
• Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer's relationship with the business.
• Comply with a legal obligation.
• Otherwise use the consumer's personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

Copy: The right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months.

Right to Know (Collection): Where we have collected their personal information, the right to request that we disclose certain information about how we have handled their personal information in the prior 12 months, including: the categories of personal information collected; categories of sources of personal information; business and/or commercial purposes for collecting and selling their personal information; and the categories of third parties/with whom we have disclosed or shared their personal information.

Right to Know (Disclosure and Sale): Where we have sold or disclosed for a business purpose their personal information, the right to request that we disclose certain information about how we have handled your personal information in the prior 12 months, including: the categories of personal information collected; categories of third parties to whom the consumer's personal information has been sold and the specific categories of personal information sold to each category of third party; categories of third parties to whom personal information has been disclosed; and the categories personal information that we have disclosed or shared with a third party for a business purpose.

Submitting Requests

You may exercise your rights by doing one of the following:

• Emailing us at info@bulletinhealthcare.com (if you are emailing from an address different than the address that appears on the bottom of your briefing, please add that email address to the body of your request)
• Contacting us at 877-297-8921 (toll free)

We will respond to your Data Request within 45 days.

When you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the personal information we maintain about you. As part of our verification process, we may ask you to submit additional information, or use identity verification services to assist us. Please understand that, depending on the type of request you submit, to protect the privacy and security of your personal information, we will only complete your request when we are satisfied that we have verified your identity to a reasonably degree of certainty.

Authorized Agents. The CCPA allows California consumers to designate an authorized agent to exercise their rights under CCPA. If Bulletin receives a request from an agent, then Bulletin has the right to verify with the data subject that the data subject indeed wants to take the action requested by the agent and will do so by contacting the data subject directly.

Incentives and Discrimination. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California residents related to their personal information.

Discrimination: If consumers exercise their rights under CCPA, businesses may not discriminate against them including by denying or providing a different level or quality of goods or services or charging or suggesting that a business will charge different prices or rates or impose penalties, unless doing so is reasonably related to the value provided to the consumer by the consumer's data. However, a deletion request that includes a request to delete your email address will prevent Bulletin Healthcare from being able to deliver a briefing to your inbox.

Disclosure of Incentives: If businesses offer any financial incentives for the collection, sale or deletion of their personal information, residents have the right to be notified of any financial incentives offers and their material terms, the right not be included in such offers without prior informed opt-in consent, and the right to be able to opt-out of such offers at any time. Businesses may not offer unjust, unreasonable, coercive or usurious financial incentives. We do not offer any incentives at this time.

California Privacy Rights under California’s Shine-the-Light Law
Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. California residents who would like to make such a request may submit a request in writing to Privacy@cision.com or through our Resident Rights page here.

The request should attest to the fact that the requester is a California resident, and provide a current California address.

Contact Us
If you have questions about our privacy practices or would like to make a complaint, please contact us at info@bulletinhealthcare.com

This privacy notice was last updated on 1st November, 2021.