Prime Therapeutics – Privacy Notice for California Residents
Last updated: January 1, 2021
Prime Therapeutics LLC (“Prime,” “we,” or “us”) understands the importance of your privacy and takes our responsibility to protect your information seriously. To that end, this privacy notice (the “Notice”) provides information regarding the categories of information we collect from California residents, how we use and share that information, and certain rights and obligations relating to that information, as required by the California Consumer Privacy Act of 2018 (the “CCPA”). This Notice applies to the personal information we collect from California residents that use our websites—primetherapeutics.com and myprime.com—including applicants for job openings with Prime.
Personal Information We Collect and How We Collect It
As defined by the CCPA, “personal information” includes any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or device. Personal Information does not include HIPAA-protected health and patient information that Prime Therapeutics may receive as a business associate, as that information is excluded from the requirements of the CCPA. It also does not include publicly available information from government records or information that has been de-identified or aggregated.
In the past 12 months, we have collected the following categories of personal information from California residents through our websites and from job applicants.
|Category||Examples||Do We Collect?|
|Legally protected classification characteristics||Race, color, national origin, citizenship, marital status, sex, age (40 years or older), gender, military status, medical condition, pregnancy, physical or mental disability||Yes, but only for job applicants.|
|Personal information categories in California’s Consumer Records statute||Name, social security number, physical characteristics, address, telephone number, education, employment, employment history, signature||Yes, but only for job applicants.|
|Identifiers||Name, alias, postal address, unique personal identifiers, IP address, other online identifier, email address, social security number,||Yes; SSNs are only collected from job applicants|
|Internet or similar network activity||Information relating to your interaction with our website or applications, browsing history, search history||Yes|
|Commercial information||Purchasing or consuming histories, records of personal property, products and services purchased||No|
|Geolocation information||Information regarding physical location, movement, and movement patterns||No|
|Biometric information||Physiological, biological, or behavioral characteristics, such as DNA sequence, finger prints, iris or retina scans, voice recordings, keystroke rhythm or gait, face or palm patterns, vein patterns, and sleep, health, or exercise data that contain identifying information||No|
|Sensory information||Audio, electronic, visual, thermal, or similar information||No|
|Professional or employment-related information||Prior employment history, performance information, resume or similar information||Yes, but only for job applicants|
|Non-public education information||Education records directly related to a student that are maintained by an educational institution pursuant to the Family Educational Rights and Privacy Act,||Yes, but only for job applicants|
|Inferences from other personal information||Inferences drawn from the categories listed above to create a profile about an individual that reflects the individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes||No|
We collect the information above directly from job applicants when they choose to provide it to us in connection with the application for a job and when if they create an online careers account with us. We collect the information above directly from website users when they choose to provide it to us by filling out forms on our website and registering to receive emails or information from us. We also collect certain categories of information from website users indirectly—including identifiers (such as IP addresses), information describing your internet connection, information about the equipment you use to access our website, and website usage data—when they visit, use, and navigate across our website. We do so by using the following technologies:
- Flash Cookies. Certain features of our website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
How We Use Your Personal Information
We use the personal information that you provide us, or that we collect about you, for the following business or commercial purposes:
- To present our website and its contents to you.
- To consider you for current or future employment opportunities and to process your employment application.
- To provide you with information, products or services that you request from us or that we are contracted to provide through your applicable health plan or employer group.
- To fulfill any other purpose for which you provide it, such as subscribing you to an e-mail newsletter.
- To provide you with notices about your account and status.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our website or any products or services we offer or provide through it.
- To notify you about any of the benefits or services you may be eligible to receive offered through us by your health plan.
- To allow you to participate in interactive features on our website, if any.
- To contact you regarding any of our services you have accessed, whether through our website or otherwise.
- To comply with applicable laws, regulations, and legal process.
- In any other way we may describe when you provide the information.
- To keep a record of our transactions and communications.
- As otherwise necessary or useful for us to conduct our business, provided the use is permitted by law. Specific examples include: Analyzing our audience and use patterns from the websites; storing information about your preferences and allowing us to direct or customize specific content to you; recognizing you when you return to our websites.
- For the protection of our operations or those of any of our affiliates, or to protect our rights, privacy, safety or property, or that of our affiliates, you, or other parties.
- For any other purposes with your consent.
Disclosure and Sale of Personal Information
- Governmental agencies, as may be required by law;
- Consumer reporting agencies, as necessary to conduct pre-employment background screening; and
- HRIS vendor and, for job applicants, pre-employment assessment vendors/administrators, including drug and alcohol testing vendors.
During the past 12 months, Prime has disclosed the following categories of personal information relating to job applicants for a business purpose: identifiers, professional and employment-related information, non-public education information, legally protected classification characteristics, and personal information categories as identified in California’s Consumer Records statute. All of these categories have been shared with our HRIS vendor and pre-employment assessment vendors/administrators. Only identifiers, and personal information categories from California’s Consumer Records statutes have been shared with consumer reporting agencies. No information has been shared with governmental agencies.
Prime has not sold any categories of personal information to third parties in the past 12 months and does not sell personal information of minors under 16 years of age.
Please note that we may also use, disclose, or transfer your information in connection with the sale, merger, dissolution, restructuring, divestiture, or acquisition of our company or its assets. We may also disclose your personal information in response to a court order, subpoena, search warrant, law, or regulation.
Your Rights Under the CCPA
The CCPA provides California residents with the rights discussed below. For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable.
- Right to Request Access Information. You have the right to request that we disclose certain information about our collection and use of your personal information during the past 12 months. Specifically, you may request that we disclose:
o The categories of personal information we collected about you;
o The categories of sources for the personal information we collected about you;
o The business and commercial purposes for collecting your personal information;
o The categories of third parties with whom we shared your personal information;
o The specific pieces of personal information we collected about you; and
o If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party.
- Right to Data Portability. You have the right to request that we provide copies of the specific pieces of personal information we collected about you. If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically. If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible.
- Right to Request Deletion. You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.
To exercise the rights described above, you—or someone authorized to act on your behalf—must submit a verifiable consumer request to us by filling out and submitting a request form here. Alternatively, you may call us at 888.849.7840 or submit a request via email to Privacy@primetherapeutics.com. Please be prepared to provide the information required in the request form, including your name, phone number, email address, physical address, and the nature of your relationship to Prime. If you are an authorized agent submitting a request on behalf of a consumer, we may request confirmation of your authorization, including a signed permission from the consumer. This information is necessary to reasonably verify that you are the individual regarding whom we collected the personal information or an authorized representative, and to ensure that we can understand and respond to your request. We reserve the right to request additional information as necessary to verify and act upon your request. You may only submit requests for access or data portability twice within any 12-month period. As indicated above, please be aware that the CCPA provides certain limitations and exception to the foregoing rights, which may result in us denying or limiting our response to your request.
The CCPA requires us to respond to a verifiable consumer request within 45 days, but permits us to extend that period by an additional 45 days, provided we notify you of the reason for the extension in writing. We will endeavor to acknowledge our receipt of a consumer request within 10 days and, if applicable, provide information regarding how we will process the request. In general, we will not charge a fee to respond to a verifiable request, unless it is excessive, repetitive, or unfounded.
Our Commitment Not to Discriminate
If a California resident exercises the rights discussed above, consistent with the CCPA, we will not discriminate against that resident by denying goods or services, charging different prices or rates for goods or services, providing different levels or quality of goods or services, or suggesting that the resident will receive a different price, rate, or quality of goods or services.
Changes to this Notice
Please note that we may change this Notice from time to time. We will post changes here and update the “Last Updated” date at the top of this document. Continued use of this website after any changes is deemed to be acceptance of those changes. Please check this Notice periodically for updates.
Our Contact Information
To contact us regarding this Notice, your rights under the CCPA, or to exercise those rights, please contact us using the information below.
Prime Therapeutics LLC
Attn: Privacy Officer
P.O. Box 64812
St. Paul, MN 55164-0802