One Health Link Chatbot CCPA Privacy Notice

Effective:       1/1/24

Last Updated 9/1/24

Version         1.1.1

Because RxAnte Pharmacy Services, LLC, dba Mosaic Pharmacy Services (“we,” “us” or “our”) uses a third party service provider, One Health Link and its subsidiaries (collectively, “One Health Link,” or “OHL”),  to provide Chatbot services, the following One Health Link CCPA Privacy Notice or PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Mosaic Pharmacy Services Chatbot Privacy Policy and applies solely to One Health Link Chatbot users who are residents of the State of California ("consumers" or "you") in relation to your use of One Health Link’s owned and operated websites that are intended for use by consumers (non-professionals) for non-commercial personal, family or household purposes, and including the mobile optimized versions of these sites (OHL refers to these sites collectively as the "One Health Link Sites"). One Health Link provides a service that enables users to engage in automated digital conversation sessions about their health, health plan, and health-related activities. These automated, interactive conversation sessions are referred as the “chat”. We and OHL refer to the One Health Link Sites, along with the information and chat services made available to you through the One Health Link Sites as the "Services".

 

This notice is adopted to comply with the California Consumer Privacy Act of 2018 ("CCPA") and other California privacy laws. Any terms defined in our Chatbot Privacy Policy or in the CCPA have the same meaning when used in this notice.

Information OHL collects.

OHL has collected the following categories of information from consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

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.

Yes

B. Personal information listed under Cal. Civ. Code § 1798.80(e).

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.

Yes

C. Protected classification characteristics under California or federal law.

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).

Yes

D. Commercial Information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

E. Biometric Information.

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.

No

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Yes

G. Geolocation data.

Physical location or movements.

Yes

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

No

I. Professional or employment-related information.

Current or past job history or performance evaluations.

No

J. Non-public education information.

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.

No

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Yes

Certain information that OHL collects identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information").

 

Personal information does not include:
  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • 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; or
    • 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.

 

Categories of sources from which information is collected.

As described in the Mosaic Chatbot Privacy Policy, we and OHL may obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you, such as when you opt in to use the One Health Link
  • Indirectly from you, such as information we may collect in the course of providing the
  • Directly from your activity on our Sites, as described below under Collection of General

 

OHL may collect information provided to us by your direct input into our site or your browser, including the website you came from, the type of browser you use, the time and date of access, and other information that does not personally identify you. One Health Link may use tracking technology (known as 'cookies') that deposits certain bits of information on your hard drive.

Cookies allow OHL to track and target your interests to tailor sites to suit your needs better.

 

Use of personal information.

Your personal information included in each of categories A, B, C, D and F described above may be used for the following business purposes:

 

  • Communication with individual users about health management, care management, member service and clinical services on behalf of a One Health Link Customer (such as Mosaic Pharmacy Service), which may be a healthcare provider, insurer, employer, or other entity.
  • Providing health education to individual
  • Providing assistance to individual users to find health-related and health plan information they needed.

 

Sharing your personal information.

Personal information disclosed for a business purpose.

 

OHL may share your information with its subsidiaries, affiliates and companies acquired by or merged with it and its affiliates.  OHL will also share your information with Mosaic Pharmacy Service and its affiliates and companies acquired by or merged with it and its affiliates.

 

In the preceding twelve (12) months, OHL has disclosed your personal information included in each of categories A, B, C, D, F, G and K only to its customer (Mosaic Pharmacy Service) and for a pre-defined business purpose on behalf of you, their member or customer.

 

OHL only discloses your personal information for a business purpose to the following categories of third parties: (i) service providers, and (ii) third parties to whom you or your agents authorize us to disclose your personal information in connection with the Services.

 

Personal information "sold" to third parties

We and One Health Link do not and will not sell your personal information.

 

Your rights

The CCPA provides California consumers 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 that we OHL disclose certain information to you about its collection and use of your personal information over the past 12 months. Once OHL receives and confirm your verifiable consumer request, OHL will disclose to you:

 

    • the categories of personal information collected about
    • the categories of sources for the personal information collected about
    • our business or commercial purpose for collecting that personal
    • the categories of third parties with whom we share that personal
    • the specific pieces of personal information collected about you (also called a data portability request).
    • if your personal information is disclosed by \ OHL 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 may only make a verifiable consumer request for access or data portability twice within a 12-month period.

 

Deletion rights

You have the right to request that OHL  delete any of your personal information collected from you and retained, subject to certain exceptions. Once OHL receives and confirms your verifiable consumer request,  OHL will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

 

OHL may deny your deletion request if retaining the information is necessary for us, OHL or their or our service providers to:

    • complete the transaction for which OHL 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
    • 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 research's achievement, 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
    • make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

 

Exercising access, data portability, and deletion rights

To exercise the access, data portability and deletion rights described above, please submit a request to us by:

Emailing here: compliance@onehealthlink.com

By using the above email, you will be asked to provide certain identifying information, such as name, email, residency and date of birth, which we will only use to process or verify your request. You may be asked to validate your request by clicking a validation link in an email that will be sent to the email address provided.

 

The verifiable consumer request must:

  • Provide sufficient information that allows OHL 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 OHL o properly understand, evaluate, and respond to it.
  • You may be asked to provide further verifying documentation, such as proof of residency and identity.

 

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. If you are

making a request through an authorized agent acting on your behalf, such authorized agent must provide proof of written authorization to do so, and you must verify your identity directly with us, unless such authorized agent provides proof of a power of attorney pursuant to Probate Code sections 4000 to 4465.

 

OHL cannot respond to your request or provide you with personal information if it 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 or OHL. OHL 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

OHL endeavor to respond to a verifiable consumer request within 45 days of its receipt. If OHL requires more time (up to 90 days), we and/or OHL will inform you of the reason and extension period in writing. Any disclosures provided will cover a period of no less than 12 months preceding the receipt of a verifiable consumer request. The response we provide will also explain the reasons  OHL cannot comply with a request, if applicable. For data portability requests,  OHL 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.

 

OHL does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If OHL determines that the request warrants a fee, OHL will tell you why it made that decision and provide you with a cost estimate before completing your request.

 

Non-Discrimination

OHL will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, OHL will not:

  • Deny you goods or
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

OHL may provide a different level of Services if the difference is reasonably related to value provided by your data.

 

Changes to this privacy notice

We and OHL each reserve the right to change or modify this privacy notice and any of our Services at any time and any changes will be effective upon being posted unless we advise otherwise. By continuing to use the Services after changes are made to this privacy notice, you agree to such changes.  We encourage you to periodically review this privacy notice for the latest information on our privacy practices.

 

Contact information

If you have any questions or concerning this Chatbot CCPA Privacy Policy, you may contact One Health Link at: privacy@onehealthlink.com or One Health Link, Inc. at 8 Linden Lane, Avon, Connecticut, 06001, US  or Mosaic Pharmacy Service at privacy@mosaicpharmacy.com  or Mosaic Pharmacy Service at 45999 Center Oak Plaza, Suite 120, Sterling, VA 20166.

 

We or OHL will respond to your request within a reasonable timeframe.