PRIVACY

 

The details in this Privacy Notice will tell you about how FocusOne Solutions, L.L.C.. and its affiliates and subsidiary entities (referred to collectively herein as, "FocusOne Solutions" "our" "us" or "we") handle personal information. 

 

This Privacy Notice applies to any individuals who are (1) FocusOne Solutions job applicants, (2) current FocusOne Solutions employees and/or independent contractors, (3) former FocusOne Solutions employees and/or independent contractors, (4) dependents or beneficiaries of current FocusOne Solutions employees, and/or (5) dependents or beneficiaries of former FocusOne Solutions employees, (6) visitors of FocusOne Solutions' locations, and/or (7) visitors to FocusOne Solutions websites.  Where you provide FocusOne Solutions with the personal information of third parties (i.e., dependents, beneficiaries and/or emergency contacts) for employment purposes, it is your responsibility to notify such third party of the limited purpose for which you provided FocusOne Solutions their personal information and inform them of this Privacy Notice as applicable.  This Privacy Notice does not cover how FocusOne Solutions' clients or subcontractors will handle your personal information; they will have separate notices regarding their personal information handling practices, and who can refer to their websites or policies for more details.

 

In this Privacy Notice, we will tell you how we handle your personal information—both online and offline—when you apply for a job, through the course of your employment, or if you visit our website or are one of FocusOne Solutions' clients.  We want to be clear with you about the following:

 

1. The personal information we collect about you: when, what, why, and from whom
2. Which information we collect automatically about you online
3. The legal categories of personal information we collect about you
4. Why we share your personal information with others (including with whom we share it and why)
5. Required Disclosures
   1. California Residents
   2. Colorado Residents
   3. Virginia Residents
6. How to contact us with questions about your personal information
7. How we protect your personal information
8. Changes we make to our privacy practices
9. Personal Information Privacy Chart

 

1. PERSONAL INFORMATION WE COLLECT ABOUT YOU

 

Your privacy is important to us.   This section will describe the "who, what, when, and why" of the personal information we collect about you. 

 

Job Applications

• When: When you apply for employment.
• What: We may collect at minimum your name, alias, email, phone number, Social Security number, driver's license number, date of birth, physical address, criminal history, education information, employment history information, self-assessment of skills and qualifications, skills checklist, health records, license and certification information, core competency information, and name and contact information of references from you and from information available as a result of a background check.  Should you provide it, we may also collect EEO information including gender, disability status, veteran status, race and ethnicity. We may also combine information we collect from you with information we obtain or purchase from third parties.
• Why: To complete the application process, to determine your qualifications for different opportunities, to ensure we meet our obligations as an employer, and to manage our relationship with you.
• From Whom: We will collect this information directly from you when you fill out an application or onboarding forms.  Sometimes you might authorize someone else, like the company performing your background check or assessments, to share information with us.

 

Employment

• When: Throughout your employment with FocusOne Solutions.
• What: We may collect at minimum your name, address, phone number, email, gender, age, information for employment related taxes, education transcripts, Social Security number, citizenship information, veteran status and information, driver's license number, I-9 information, emergency contact information, any information you provide when you submit a request under the FMLA or another leave, disability, or benefits law, and any other information you have chosen to provide to FocusOne Solutions.  We may also combine information we collect from you with information we obtain or purchase from third parties. 
• Why: To determine your qualifications for different opportunities, to ensure we meet our obligations as your employer, and to manage our relationship with you, including, without limitation, to customize incentives or rewards.
• From Whom: We will collect this information directly from you when you fill out an application or onboarding forms.  Sometimes you might want someone else, like your doctor or your previous school, to provide information to us as well.

 

Travel

• When: When you book travel through FocusOne Solutions.
• What: We may collect your name, address, email, phone number, birth date, passport number, driver's license or government-issued ID number, ticket/document number, and other related travel information.
• Why: To book travel for you or on your behalf as part of your employment.
• From Whom: We will usually collect this information directly from you.

 

Payroll and Benefits

• When: When we are providing you with payroll and benefits services.
• What: We may collect your name, address, birth date, age, marital status, Social Security number, email address, phone number, dependent information, beneficiary information, and bank account number, routing number, and account type.
• Why: To pay you for your employment, or to provide you with benefits like insurance and retirement savings.
• From Whom: We will collect this information directly from you.

 

Licenses, Credentials, Certifications and Education History

• When: When we track and maintain your licenses, credentials, certifications, and education history.
• What: We may collect your name, license number, license type, license state, email, phone number, work address, birth year, and last 4 digits of your Social Security number from you; and from state licensing authorities we may collect the status of your licenses, credentials, certifications, and education history. We may also collect publicly available information from third-parties (for example, Nursys) and co-mingle such information with information we collect from you.
• Why: To make sure your professional licenses, credentials, and certifications are current and to help you stay up to date when we can. To ensure your education history is complete and accurate.
• From Whom: We will collect information from you or from a third-party source that we will use to identify your relevant credentials and track their status, and we will obtain information about the status of your credentials from the accrediting organization (for example, the state licensing board).

 

Background and Qualification Checks

• When: When we conduct background checks, drug tests, and occupational health checks.
• What: We may collect your full name, alias, Social Security number, date of birth, address, phone number, address history, driver's license number, and signature from you, and we may collect your drug test status, criminal history, and physical information from the third party completing the inquiries.
• Why: Depending on your position, we might need to get background checks, drug tests, occupational health tests, and competency exam information for you.  We may need to do this when you first apply for a job or around that time, and we may also need to update the information throughout your employment with FocusOne Solutions.
• From Whom: We will collect information from you that we will use to identify you to the vendors that are handling different checks, and we will obtain information about the results of these checks from the vendors who handle them on our behalf.

 

Providing Client Services

• When: When we provide staffing services to our clients.
• What: We may collect your email address, phone number, communications logs, and company Form W-9, including your name, business name, type of business, address, Social Security number or Employer Identification number, bank account and routing number, signature, and method of payment.
• Why: We collect this information so you can pay us for services and so that we can make necessary filings with the Internal Revenue Service.
• From Whom: We will collect information directly from you.

 

Audits

• When: When we need to audit for legal, regulatory, or another type of compliance.
• What: We may collect any of the information we described in this Privacy Notice.
• Why: There are different requirements we must comply with as your employer and as a company that employs medical professionals, as well as more generally.  Sometimes, we are asked to prove we are doing the right things and that we are doing them correctly.
• From Whom: We will collect information from you and from the other companies we described in this section of this Privacy Notice.

 

Website

• When: When you interact with our website.

• What: We may automatically collect your browser type, device type, operating system information, CPU speed, reference or exit webpages, click patterns, session ID, your computer's IP address and general geolocation, and demographics such as age or age range.  We may also collect general information about use of our website, such as what pages visitors access, the number of visits, average time spent on the website, website activity and flow, entrance and exit pages, and other similar factors.  This information is generally collected in aggregate form, without identifying any user individually, although IP addresses and Session ID in relation to downloads may be tracked as part of our fraud prevention efforts. For more information about information automatically collected through the use of our website, see Section 2, "DETAILS ABOUT INFORMATION WE COLLECT ABOUT YOU ONLINE."
• Why: To determine whether and how well our website is working, to learn more about visits and visitors to our website, to improve our website, and to prevent fraud.
• From Whom: This information is collected automatically from the device you use to access our website.

 

Technology Monitoring

• When: When you use our systems or applications.
• What: We may collect your session actions, page visits, and specific user actions you take.
• Why: To maintain the security of our systems, networks, and information.
• From Whom: We collect this information automatically from your device and use of our systems.

 

Marketing

• When: When we send you information about our services or potential opportunities.
• What: We may collect your name, email, credentials, address and phone number.
• Why: To provide you with information about our services or potential opportunities that is relevant to you.
• From Whom: We collect this from you and from third parties. 

When we use your personal information for marketing purposes, you can withdraw your consent at any time using the unsubscribe link in our emails, or by phone, email, or regular mail.

 

Security

• When: When on site at an office location.
• What: We may collect and retain for limited periods video surveillance in order to ensure safety at our office locations.
• Why: As a security measure to monitor and protect our office locations and staff.
• From Whom: We may use cameras or other security surveillance to ensure the safety and security of the office. We may contract with third-parties to store or otherwise maintain videos we capture for a period of time.

 

2. DETAILS ABOUT INFORMATION WE COLLECT ABOUT YOU ONLINE

 

This section gives you more specific details about the information we collect automatically from your device(s) online.  We'll tell you about cookies and different online technologies that automatically collect information, what types of information we collect automatically, and how we use online information we collect automatically from you.

 

Here, have a cookie!  A "cookie" is a small text file that websites send to your computer, device, or other Internet-connected device you are using.  We use cookies to identify your browser or to store information or settings in the browser to improve your experience with our website(s).

 

Web beacons.  A "web beacon" links web pages to web servers and the cookies and may be used to transmit information collected through cookies back to a web server.  You might have heard of a web beacon that was called something else, like an Internet tag, pixel tag or clear GIF.

 

What information do our websites collect from you?  Our sites use cookies, web beacons, java scripts, and similar technologies to collect certain information about your activity relating to our websites.  These technologies collect your Internet Protocol (IP) address, device type, age or age range, network location, and information about how you interact with our websites. 

 

How do we use cookies and other automatically collected information?  We use data collected automatically through our website to analyze trends, administer our sites, track visitors' movements through our websites, and gather demographic information about our visitors as a whole.  We may receive reports based on these technologies on an aggregated basis.

 

We use cookies to keep track of advertisements and compile aggregate data about website traffic and website interaction, so we can offer better website experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our website visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.  We also use third-party analytics services on our websites, including Google Analytics.  To learn more about Google Analytics, visit: https://policies.google.com/technologies/partner-sites.

 

What you can do about cookies. Your Internet browser may let you restrict or disable certain types of cookies.  Without cookies, you may not be able to use all of the options on our websites.

 

We may also use JavaScript to help our websites, especially pictures, function better.  You can turn JavaScript on or off in your browser functions, but if you turn it off, you may not be able to use all of the options on our websites.

 

Sometimes we use technology to collect the information that your browser uses to auto-fill your contact or other information that you may enter.  We use this to tell you if there is a mistake in registration or if the registration cannot be submitted.  You can stop this technology by turning it off in your browser, and you will still be able to use all of the options on our websites.

 

Where we share personal information with third parties about our visitors of our website, we only do so for the purposes outlined in Section 1 and based on your third party permissions. For more information on who we share personal information with, see Section 4, "SHARING YOUR PERSONAL INFORMATION." Below are links to our third parties opt out pages for your convenience:

 

• You may opt out of Google’s use of cookies by visiting the Google advertising opt-out page.

 

• You may also opt out of other third-party online advertising vendors’ use of cookies by visiting the Network Advertising Initiative opt out page.

 

• We also use remarketing services, including but not limited to (1) Google’s Remarketing services, which are delivered in two ways: (a) Remarketing Dynamic Ads, which you may opt out of by visiting here; and (b) DoubleClick, which uses remarketing pixels, which you may opt out of by visiting the DoubleClick opt-out pageor the Network Advertising Initiative opt out page; and (2) AdRoll, which you may opt out of here.

 

Do Not Track Signals. Some web browsers allow you to turn on Do Not Track ("DNT"), which sends signals to websites you visit, telling those sites that you do not want your online activities to be tracked. Our websites currently are not designed to respond to DNT signals received from web browsers.

 

3. "LEGAL CATEGORIES" OF PERSONAL INFORMATION WE COLLECT

 

The law requires us to tell you about the personal information we collect about you in a certain way – specifically, we need to tie it back to "legal categories" of personal information that are listed in the law.  To do this, we bundled up the information we gave you in Section 1 of this Privacy Notice and matched the different types of personal information we collect about you with the legal category.  To make things easier to understand, we've put this information in a chart that shows you four things:

 

1. The legal category of personal information,
2. The types of personal information we collect about you for each legal category,
3. The purpose for why we collect and use your personal information for each legal category; and
4. The business purposes for which we share your personal information and with whom.

 

We've included the chart at the end of this Privacy Notice as Appendix A. At the end of the Personal Information Privacy Chart, we also included a list of Information We Disclose for a Business Purpose.

 

4. SHARING YOUR PERSONAL INFORMATION

 

This section will tell you about how we share your personal information with others.  First, we will tell you how we use and share your personal information for marketing purposes.  Then, you'll learn about how we share your personal information for business purposes.  We'll take the "legal categories" of information from Appendix A and match them up with what we share and who we share it with.

 

Follow-Up Marketing.  Once you've given us your name, phone number, and email address, we may use those three things to contact you with information or potential opportunities that are relevant to you.  To send you these marketing messages, we may need to share your personal information with potential employers so they can contact you.  If you don't want to receive follow-up marketing from us, you can opt out at any time.

 

Sharing for Business Purposes.  Except for follow-up marketing, we only share your personal information for our business purposes.  Put another way, we only share your personal information to operate our business and for the purposes we've described for you in this Privacy Notice (to accomplish the "why" in Section 1). 

 

Clients, Facilities, Potential Employers: We may share your personal information with our clients, facilities, and potential employers to present you for employment opportunities and to manage your employment relationship. 

 

Our "Family" Companies: We may share your personal information with any company that is owned by or affiliated with FocusOne Solutions or our parent companies.  If we share your personal information, we will take reasonable steps to make sure that our companies take prudent steps to protect your personal information.  We may share not just information that you provide to us, but also information we obtain from third parties (all of which may be combined or comingled).

 

Service Providers: Other companies sometimes provide certain services to us or on our behalf (e.g., payroll services, leave and absence management services, maintenance or IT support, audits, analysis, and benefits).  Unless we tell you differently or as described elsewhere in this Privacy Notice, our service providers are not permitted to use your personal information except to assist us. 

 

Third Parties with Whom You Direct Us to Share Your Personal Information:  If you direct us to share your personal information with a third party, we will share only the information that is needed to complete your request.

 

Other Third Parties, such as consumer reporting agencies when we perform employee background checks. 

 

Compliance with Legal Obligations: We may need to disclose certain information to auditors, government authorities, law enforcement, regulatory agencies, our legal counsel, third party litigants and their counsel, or other authorized individuals to comply with laws that apply to us, subpoenas, discovery requests, or other legal obligations such as contractual requirements. 

 

Changes in Business Structure/Ownership: We may disclose or transfer your personal information to a third party in the event of any reorganization, merger, sale, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of FocusOne Solutions' business, assets, or ownership interest (including through bankruptcy or similar proceedings). 

 

We've provided a list of all the legal categories of information we share for a business purpose after the chart in Appendix A.

 

FocusOne Solutions does not sell applicants' or employees' personal information to anyone and FocusOne Solutions does not share applicants' or employees' personal information with third parties for those parties' commercial use.  The law also requires us to explicitly state that we do not sell the personal information of minors under 16 years old.

 

5. REQUIRED DISCLOSURES

 

In certain circumstances, we may chose to or may be required to provide additional or different disclosures to residents of different countries or states. Below are the disclosures that may be applicable to you.

 

Privacy Rights: Some privacy laws require that we disclose to you the privacy rights that you have regarding personal information. We have defined the various privacy rights below. to see which rights apply to you, refer to the "Privacy Rights Chart" immediately following this subsection.

• The right to know what categories of personal information we collect about you, and what categories of personal information is sold or shared about you and to whom
• The right to know how we share your personal information,
• The right to deletion of your personal information,
• The rights to access and portability grants you the right to obtain access about the personal information about you in a readily usable format,
• The right to limit use and disclosure of your sensitive personal information,
• The right to opt out of sale or sharing of your personal information or profiling
• The right to non-retaliation following opt out or exercise of other rights, or the right to equal service and price even when you exercise your privacy rights, and
• The right to correct certain personal information we have about you if you believe it is inaccurate
• The right to have an authorized agent exercise your rights on your behalf.

These rights may be subject to certain limitations or exceptions depending on your state of residency and the purpose for which we process personal information about you. For example, if you are engaging with FocusOne Solutions as part of a future, current or past employment relationship, your privacy rights may not apply.

 

 

 

Privacy Rights Chart:

 

	Right to Know	Right to Access	Right to Portability	Right to Limit Sensitive Personal Information	Right to Opt Out of the Sale or Sharing	Right to Non-Retaliation	Right to Correction	Right to Deletion
California Residents	✅	❌	❌	✅	✅	✅	✅	✅
Virginia Residents	✅	✅	✅	✅	✅	✅	✅	✅
Colorado Residents *	✅	✅	✅	✅	✅	✅	✅	✅
Connecticut Residents *	✅	✅	✅	✅	✅	✅	✅	✅
Utah Residents	✅	✅	✅	✅	✅	✅	❌	✅

 

 

How to Make a Request: If you wish to exercise any of the rights we've described above, please contact us using any of the methods in the Contact Us section below.  FocusOne Solutions will verify your identity prior to fulfilling your request. Be ready to provide your name and email address, and if you have authorized an agent to make a request on your behalf, we will need you to provide the agent's name and email address, as well as your written authorization or a valid power of attorney appointing the agent to make a request on your behalf.   Additional verification information may be required taking into account the type of request as well as the type, risk and value of the personal information involved.

You can contact us to make a request by email, phone, or regular mail.

 

Responding to Requests: Your request will be evaluated to determine whether the requested change meets legal regulatory requirements and does not risk making our other data less secure or changing our other data.  If we aren’t able to honor any part of your request, we will tell you that in our response, as well as the reason(s) we cannot do so.

 

Verifying Your Identity: To protect you and your information, we will ask you to confirm certain information before we honor your request.  For example, if you make a request, we will ask you to confirm your email address and phone number.  For certain requests, we will use a combination of your email address, phone number, zip code, and/or birth date to verify your identity, so that we can help protect your information.  If you designate an authorized agent to make a request on your behalf, we will require you to verify your identity and provide the information outlined in “How to Make a Request” above.

 

 

6. CONTACT US

 

If you would like to make a request or have any questions or concerns about this Privacy Notice, you can contact us via phone, email, and regular mail.  Alternative formats of this Privacy Notice are available to individuals with a disability.  Please contact us for assistance.

 

• Phone: 866.633.3548
• Email: Privacy@medicalsolutions.com
• Postal Address:
  FocusOne Solutions
  Attn: Privacy Team
  1010 N. 102 Street

Omaha, NE 68114

 

7. HOW WE PROTECT YOUR PERSONAL INFORMATION

 

Your privacy is important to us, and we strive to take appropriate security measures to help safeguard your personal information from unauthorized access, disclosure, alteration, or destruction.  For example, only authorized employees are allowed to access personal information, and they may only access it for permitted business functions.  We also use technology to protect your personal information, including encrypting confidential personal information that is transferred to or from our systems and implementing physical security measures to protect electronic and hard copy information. 

 

In general, we keep your personal information for as long as we need it to carry out the purposes described in this Privacy Notice, and as necessary to comply with our records-management policies and laws that apply to us. We also keep your personal information when we need to comply with other legal obligations we might have, such as in connection with a lawsuit, complaint, or investigation.

 

While we cannot guarantee that loss, misuse, or alteration will never occur, we use reasonable efforts to prevent it.  When you send your personal information to us over the internet, please keep in mind that no method of storage or transmission over the Internet is completely secure, so your provision of information to us is at your own risk.

 

8. PERSONAL INFORMATION PRIVACY CHART

 

Legal Category*	Types of Information Collected	Source	Purpose for Collection and Use	Sharing of Information for Business Purposes
A. Identifiers.	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, video or pictures or other similar identifiers.	• Directly from you • From Third Parties • Automatically from your devices	• Job Applications • Employment • Travel • Payroll and Benefits • Licenses, Credentials, and Certifications • Background and Qualification Checks • Providing Client Services • Audits • Website • Technology Monitoring • Marketing • Security	• Clients, Facilities, Potential Employers • Our “Family” Companies • Service Providers • Third Parties with Whom You Direct Us to Share Your Personal Information • Other Third Parties • Compliance with Legal Obligations • Changes in Business Structure/Ownership
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, images and videos or any other financial information. Some personal information included in this category may overlap with other categories.	• Directly from you • From Third Parties	• Job Applications • Employment • Travel • Payroll and Benefits • Licenses, Credentials, and Certifications • Background and Qualification Checks • Providing Client Services • Audits • Website • Marketing • Security	• Clients, Facilities, Potential Employers • Our “Family” Companies • Service Providers • Third Parties with Whom You Direct Us to Share Your Personal Information • Other Third Parties • Compliance with Legal Obligations • Changes in Business Structure/Ownership
C. Protected classification characteristics under California or federal law.	Age (40 years or older), national origin, citizenship, marital status, and veteran or military status.	• Directly from you • From Third Parties	• Job Applications • Employment • Travel • Payroll and Benefits • Licenses, Credentials, and Certifications • Background and Qualification Checks • Audits • Website	• Clients, Facilities, Potential Employers • Our “Family” Companies • Service Providers • Third Parties with Whom You Direct Us to Share Your Personal Information • Other Third Parties • Compliance with Legal Obligations • Changes in Business Structure/Ownership
D. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement, device type.	• Automatically from your device(s)	• Audits • Website • Technology Monitoring	• Our “Family” Companies • Service Providers • Third Parties with Whom You Direct Us to Share Your Personal Information • Compliance with Legal Obligations • Changes in Business Structure/Ownership
E. Geolocation data.	Physical location or movements.	• Automatically from your device(s)	• Audits • Website	• Our “Family” Companies • Service Providers • Third Parties with Whom You Direct Us to Share Your Personal Information • Compliance with Legal Obligations • Changes in Business Structure/Ownership
F. Professional or employment-related information.	Current or past job history or performance evaluations.	• Directly from you • From Third Parties	• Job Applications • Employment • Licenses, Credentials, and Certifications • Background and Qualification Checks • Audits	• Clients, Facilities, Potential Employers • Our “Family” Companies • Service Providers • Third Parties with Whom You Direct Us to Share Your Personal Information • Other Third Parties • Compliance with Legal Obligations • Changes in Business Structure/Ownership
G. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	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.	• Directly from you • From Third Parties	• Job Applications • Employment • Licenses, Credentials, and Certifications • Background and Qualification Checks • Audits	• Clients, Facilities, Potential Employers • Our “Family” Companies • Service Providers • Third Parties with Whom You Direct Us to Share Your Personal Information • Compliance with Legal Obligations • Changes in Business Structure/Ownership
H. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	• Directly from you • Automatically from your device(s)	• Audits • Website	• Our “Family” Companies • Service Providers • Third Parties with Whom You Direct Us to Share Your Personal Information • Other Third Parties • Compliance with Legal Obligations • Changes in Business Structure/Ownership
I. Sensitive Personal Information	Social Security number, driver’s license, state ID card, passport number, account login, financial account, debit/credit card number (w/access code), credentials allowing access to an account, precise geolocation, race or ethnic origin, religious or philosophical beliefs, or union membership, contents of personal communications, genetic data, biometric data health data, and sex life or sexual orientation	• Directly from you • From Third Parties (including but not limited to Nursys)	• Employment • Travel • Payroll and Benefits • Background and Qualification Checks • Providing Client Services	• Affiliates • Clients • Service Providers, Suppliers • Compliance with Legal Obligations • Changes in Business Structure/Ownership

 

* We may also collect your personal information to comply with laws or regulations or with legal requests that don't fit into one of the categories we've described for you. 

 

We share the following categories of information about you for business purposes:

 

1. Identifiers
2. California Customer Records Categories
3. Protected Classifications
4. Internet and Network Activity
5. Physical Location or Movements
6. Professional or Employment Records
7. Education Records
8. Inferences Drawn from Other Personal Information
9. Sensitive Personal Information

 

9. CHANGES TO OUR PRIVACY PRACTICES

 

We may need to adapt to changes to continue to protect your personal information, so we may make changes to our privacy practices at any time, and we will review our practices at least every 12 months.  If we make a change to the privacy practices, we will update this Privacy Notice on our website.

 

This policy was last updated on August 28, 2023.

 

 

 

* Colorado and Connecticut residents will have the rights outlined above on and after July 1, 2023 but not before.