Supplemental State Privacy Notice

1. Introduction

This Supplemental State Privacy Notice (“Notice”) applies only to personal information collected by Veradigm LLC (“Veradigm”, “we”, “our”, or “us”).

This Notice describes our practices regarding the collection, use, and disclosure of Personal Information while using our solutions and visiting our websites and provides instructions for submitting privacy requests. This Notice supplements the information in Veradigm’s Privacy Policy (“Privacy Policy”) and should be read in conjunction with our Privacy Policy. 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.

2. Definitions Specific to this Notice

“Consumer” means a natural person. 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 or as an applicant for employment.

“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 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 Connecticut Data Privacy Act shall apply to you if used in this Notice.

3. Personal Information We Collect and Process

We, and our Vendors, may have collected and processed the following categories of Personal Information about you within the last twelve (12) months:

Identifiers, such as your name, email address, mailing address, IP address, online identifiers, and account information. We typically collect this information directly from you to provide you with access to certain information on our website.
Internet or other Electronic Activity Information, such as your browsing history, search history, browser information, and online activity over time and across different devices and websites. We typically collect this information using cookies, pixels, web beacons, and other data collection technologies to help us market our products and services to you, design our website, identify popular features, and for other managerial purposes.
Commercial Information, such as products and services purchased from us and inferences drawn from our interactions with you. We typically collect this information directly from you to fulfill your transactions and provide you with customer service.
Professional or Employment-Related Information, such as your current and previous employment, education history, and other information included on your resume. We typically collect this information directly from you or from third parties, including background check providers, previous employers, and references, in order to manage our recruitment processes.
Inferences drawn from your Information, such as information about your preferences and characteristics. We typically infer this information from the information we collect directly from you or via cookies and similar tracking technologies to tailor our services and communications to you.

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 may include:

Maintaining and servicing your account, including managing your preferences.
Administering and improving our services, including running analytics, assessing the quality of our website, and for other related internal business purposes.
Communicating with you and responding to inquiries you send to us.
Sending you messages promoting our products and services.
Evaluating applications for employment and conducting interviews and background checks.
Complying with our legal, regulatory, and risk management obligations, including establishing, exercising, and/or defending legal claims.
Detecting, preventing, or addressing fraud, security, or technical issues.
Protecting against harm to the rights, property, or safety of our users, Veradigm, or the public, as required or permitted by law.
Engaging in a merger, acquisition, reorganization, or sale of all or a portion of Veradigm assets.

4. Sensitive Personal Information

Although 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.

5. Retention of Your Personal Information

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 may disclose each of the categories of Personal Information we collect with Third Parties as described in our Privacy Policy.

Veradigm does not sell Personal Information to Third Parties in exchange for money unless we have obtained your consent. However, within the past twelve (12) months we may have disclosed your Personal Information with our affiliates and trusted partners in arrangements that may meet the broad definition of “sale” under certain state privacy laws. In these arrangements, use of the information we “sell” is limited by policies, contracts, or similar restrictions.

Veradigm may share Personal Information with Advertising Partners for targeted advertising purposes. These Advertising Partners 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: Identifiers; Internet and other Electronic Activity Information; Commercial Information; and Inferences drawn from your Information.

We do not have actual knowledge that we sell or share Personal Information of Consumers under 16 years of age.

7. Your Privacy Rights

If you are a resident of California, Colorado, or other states that have a comprehensive privacy law, you may be entitled to some or all the below-listed privacy rights

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.
Right to Opt-Out of the Sale or Sharing of Your Personal Information for Targeted Advertising You have the right to direct us not to sell your Personal Information or share your Personal Information for targeted advertising purposes. You may opt out by clicking the “Your Privacy Choices” link at the bottom of our Veradigm 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 Opt-Out of Profiling and Automated Decision-Making You have the right to opt out of processing for the purposes of certain types of profiling and automated decision-making.
Right to Appeal If we deny your request to exercise certain rights, you may have the right to appeal that denial.
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

Shine the Light – Third Party Marketing. You may request and obtain from Veradigm once per calendar year information about any of your Personal Information shared with Third Parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information.

You can find more details about the rights you specifically are entitled to by referencing the state privacy law that applies to you, or you may contact us using the information in Section 8 below.

8. How to Exercise Your 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 or email us at privacy@veradigm.com.

We may need to verify your identity to comply with your privacy 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.

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.

9. Contact Information

Veradigm
Attn: Privacy Officer
222 Merchandise Mart Plaza
Suite 2024
Chicago, Illinois 60654
Privacy@Veradigm.com

10. Updates

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 try to 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: November 15, 2024