Effective Date: December 22, 2023
This Supplemental State Privacy Notice (“Notice”) applies only to information collected by Veradigm LLC (“Veradigm”, “we”, “our”, or “us”) about California, Virginia, Colorado, Connecticut, and Utah consumers. It provides information required under the following laws: California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (collectively, the “CPRA”); Virginia Consumer Data Protection Act of 2021 (the “VCDPA”); Colorado Privacy Act of 2021 (the “CPA”); Connecticut Data Privacy Act (“CDPA”); and Utah Consumer Privacy Act of 2022 (the “UCPA”) (collectively, “State Privacy Laws”).
This Notice describes our practices regarding the collection, use, and disclosure of Personal Information while visiting our website and provides instructions for submitting data subject requests. This Notice supplements the information in Veradigm’s Privacy Notice (“Privacy Notice”) and should be read in conjunction with our Privacy Notice. Some sections of this Notice apply only to consumers of particular states. In those instances, we have indicated where such language applies only to those consumers.
“Consumer” means a natural person who resides in California, Virginia, Colorado, Connecticut, and Utah and to whom we offer information, goods, or services. For purposes of this Notice, this term includes natural persons who reside in California and engage with us as part of business-to-business transactions.
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with, directly or indirectly, a particular Consumer or household. Personal Information includes “personal data,” as that term is defined in the applicable State Privacy Law. Personal Information includes “Sensitive Personal Information,” as defined below, except where otherwise noted.
“Sensitive Personal Information” means Personal Information that reveals a Consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious beliefs, or union membership; contents of email or text messages; or genetic data. Sensitive Personal Information also includes the processing of biometric information for the purpose of uniquely identifying a Consumer and Personal Information collected and analyzed concerning a Consumer’s health, sexual activity, or sexual orientation. Sensitive Personal Information also includes “sensitive data,” as that term is defined by the applicable State Privacy Law.
“Third Party” means a person or organization which is not a Consumer, Vendor, or an entity owned or controlled by us and as defined by the applicable State Privacy Law.
“Vendor” means a “service provider,” “contractor,” or “processor” that collects, stores, or otherwise handles data for us, as those terms are defined by the applicable State Privacy Law.
These definitions apply regardless of whether the terms are capitalized in this Notice. Other terms used in this Notice may be defined under the State Privacy Laws and shall have the meanings given to them under those statutes. If there are variations in definitions among the State Privacy Laws, you will be covered by the definition that applies in your state. For example, if you are a Connecticut Consumer, terms defined in the CDPA shall apply to you if used in this Notice.
We, and our Vendors, may have collected and processed the following categories of Personal Information about you within the last twelve (12) months:
In addition to the purposes for collection described above, we have collected each of the above categories of Personal Information for the purpose of performing services for you and managing our relationship with you, which typically includes:
Although some Veradigm products advertised on this website may be utilized to collect Sensitive Personal Information by our customers, Veradigm does not purposely collect Sensitive Personal Information on this website. Please refrain from sending us your Sensitive Personal Information if you use this website to contact us regarding our products.
Veradigm retains your Personal Information only for as long as necessary to fulfill the purpose for which it was collected, or a related and compatible purpose consistent with the average consumer’s expectation, and to comply with applicable laws and regulations or our legal obligations.
Veradigm does not sell Personal Information about California, Virginia, Colorado, Connecticut, or Utah consumers to Third Parties unless we have obtained your consent. Veradigm may share the categories of Personal Information we collect with Third Parties as described in our Privacy Notice. For example, we contract with third-party advertising networks that may track your activity over time and across different channels, including our websites, email activity, and other websites and applications that display advertisements. They may use this tracking information to understand and predict your interests, to display an advertisement for Veradigm on another website, or email you with a marketing communication for a Veradigm product. Specifically, in the preceding twelve (12) months, we have disclosed the following categories of Personal Information to Third Parties: Direct Identifiers; Internet Activity Information; Commercial Information; and Profile Information. If we change our practices, we will update this Notice in accordance with Section 10.
Disclosure for California Consumers
Unless specifically stated, we have not sold or shared Personal Information about California Consumers to Third Parties for their own use. Relatedly, we do not have actual knowledge that we sell or share Personal Information of California Consumers under 16 years of age. However, within the past twelve (12) months we may have shared your Personal Information with our affiliates and trusted partners in arrangements that may meet the broad definition of “sale” or “share” under California law. In these arrangements, use of the information we share is limited by policies, contracts, or similar restrictions.
For purposes of the CPRA, a “sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
Disclosure for Virgina, Colorado, Connecticut, and Utah Consumers:
Unless specifically stated, we do not sell or share Personal Information to Third Parties for their own use. However, we may share or process one or more of the above categories of Personal Information with our affiliates and trusted partners in arrangements for purposes of targeted advertising, as the terms “sell,” “share,” “process,” and “targeted advertising” are defined in the CPA, VCDPA, UCPA, and CDPA. In these arrangements, the use of the information we share is limited by policies, contracts, or similar restrictions.
If you are a resident of California, Virginia, Colorado, Connecticut, or Utah, you may be entitled to some or all the below-listed data subject rights. You can find more details about the rights you specifically are entitled to by referencing the State Privacy Law that applies to you. However, please be advised that we will need to verify your identity to comply with your data subject request. If you have an account with us, we will use our existing account authentication practices to verify your identity. If you do not have an account with us, we may request additional information about you to verify your identity. You may use an authorized agent to submit a request; however, when we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that you have authorized them to act on their behalf. Also, in some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.
Right to Notice Before or at the time we collect Personal Information from you, you have the right to receive notice of the Personal Information to be collected and the purposes for which we will use it. This Notice is intended to satisfy this requirement.
Right to Know You have the right to request the following: (i) the specific pieces of Personal Information we have about you; (ii) the categories of Personal Information we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of your Personal Information that we sold or disclosed in the last 12 months; (v) the categories of Third Parties to whom your Personal Information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling Personal Information. This right includes the right to receive a copy of the information we have about you in a readily available format.
Right to Deletion and/or Correction of Your Personal Information You have the right to request that we delete or correct inaccurate Personal Information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. Certain exceptions under applicable state law may allow Veradigm to retain and use certain Personal Information notwithstanding your deletion request. If we deny your request for deletion or correction, we will let you know the reason for the denial.
Right to Opt-Out of the Sale or Sharing of Your Personal Information You have the right to direct us not to share, disclose or sell your Personal Information. You may opt out by clicking the “Your Privacy Choices” link at the bottom of our website and selecting your preferences on that page. You may also opt out by broadcasting an opt-out preference signal like the Global Privacy Control (GPC), but please note that this signal will be linked to your browser only. If you wish to learn more about GPC and how to use a browser or browser extension incorporating the GPC signal, you can visit the GPC website here.
Right to Limit the Use of Your Sensitive Personal Information You have the right to opt out of the use and disclosure of your Sensitive Personal Information for certain purposes related to the offering of goods or services as listed in your applicable State Privacy Law.
Right to Opt-Out of Targeted Advertisements and Profiling You have the right to opt out of any targeted advertising that we may direct toward you. As described in Section 3 above, Veradigm may use targeted or advertising cookies for our marketing efforts and to reach potential customers across the web. Depending on your jurisdiction (for example, if you are a California resident), you have the right to opt-out of the sale or sharing of your Personal Information by us as a business. You may opt out by clicking the “Your Privacy Choices” link at the bottom of our website and selecting your preferences.
Right to Equal Service If you choose to exercise any of these rights that apply to you, Veradigm will not discriminate against you in any way. However, if you choose to exercise certain rights, understand that you may be unable to use or access certain features of Veradigm’s website.
Additional California Privacy Rights
To exercise any of the above-listed privacy rights that apply to you, contact us at 1-800-334-8534 or 1-844-903-7567 (for Practice Fusion customers) or email us at privacy@veradigm.com. We will respond to your verified request as soon as reasonably practicable or in the timeframe required by applicable State Privacy Law. If circumstances cause any delay in our response, we will notify you promptly and provide a date for our response.
Veradigm
Attn: Privacy Officer
222 Merchandise Mart Plaza
Suite 2024
Chicago, Illinois 60654
Privacy@Veradigm.com
We may update this Notice from time to time. If we make any changes to this Notice that materially relate to any consents that you have given, we will notify you before they take effect either through the website or by sending you a notification. Unless otherwise noted, any changes we make to this Notice will become effective immediately once posted on this page. Please see the date noted below for the latest revision date. Unless otherwise noted, any changes we make to this Notice will become effective immediately once posted on this page. Your continued use of the website following any changes to this Notice indicates that you have read and understood the practices described in the revised Notice.
Date of Last Update: December 22, 2023