CentraCare Wayfinding Privacy Notice
Effective Date: February 9, 2023
CentraCare (“we” or “us”) is committed to protecting
the privacy of all individuals (“you” or “your”)
who utilize our App (as defined in the
End User License Agreement ). Please read the following statement to understand how we collect, use,
and safeguard the information you may provide to us via the App.
1. WHAT INFORMATION DOES CENTRACARE COLLECT FROM YOU?
CentraCare may collect certain information related to your use of the App.
We collect personal information and non-personal information. When we
use the term “personal information” in this Privacy Notice,
we mean information about you that is personally identifiable to you.
We collect the following personal information from you:
• Your precise geolocation within CentraCare’s facilities.
As stated above, we also collect information that does not identify you
(“non-personal information”). Personal information and non-personal
information may be collectively referred to as “information”
throughout this Privacy Notice. The information we collect is limited
to technical information. When you access the App from a mobile device,
we may collect non-personal information from your use of the mobile device,
including:
• The date and time you started and stopped using the App;
• The route taken while using the App;
• Your mobile device manufacturer, model, and operating system and version;
• Any errors detected while using the App;
• Any wi-fi signal observed (if using an Android device); and
• The version of the App and map you are using;
In order to collect some of the above information, we, or our service providers
(such as Purple Wifi), utilize certain indicators in order to provide
functionality in the App. These indicators include your BLE (Bluetooth
Low Energy) beacon strength, surrounding WiFi networks (Android Only),
and motion/orientation sensors. The processing of information from these
indicators takes place on your device, and this information does not leave
your device.
2. HOW IS YOUR INFORMATION USED?
We collect, retain, and use your personal information for the following purposes:
• To provide you the Services and products you requested;
• To operate and improve the App;
• To respond to an inquiry from you;
• To create aggregated, non-personal information, or to create de-identified
information;
• To comply with applicable laws, regulations or legal process;
• To comply with requests of relevant regulatory and law enforcement
and/or other governmental agencies or authorities; and
• To enforce our End User License Agreement; and/or to protect the
rights, property, or safety of CentraCare and other users of the App.
We may use any non-personal information for any purposes as appropriate
and subject to applicable law, since non-personal information cannot identify
you as an individual. For example, we may use non-personal information
collected to monitor visitor traffic patterns and App usage and to improve
our App. We may also use non-personal information in the aggregate to
create summary statistics that help us analyze App usage trends, determine
technical design specifications, arrange our App in a user-friendly way,
and identify system performance or problem areas. We also use non-personal
information to protect the security and integrity of the App.
3. WHEN WE SHARE YOUR INFORMATION?
We share your information in the following circumstances:
Service Providers. We may share your information with affiliated and unaffiliated
companies (such as Purple Wifi) that perform tasks on our behalf related
to our business. Such tasks include analyzing usage data, fixing errors
in the App, and protecting the security and integrity of the App. Third-party
service providers receive your information as necessary to perform their
role, and we instruct them not to use your information for any other purposes.
As Required by Law. We will disclose your information as necessary or appropriate,
including as required by law, regulation, subpoena, court order, legal
process or government request; to enforce our
End User License Agreement , including investigations of potential violations thereof; to detect,
prevent or otherwise address fraud, security or technical issues; when
we believe in good faith that disclosure is necessary to protect your
safety or the safety of others; to protect our rights, to investigate
fraud, or to respond to a government request.
Business Transfers. CentraCare may, in the future, sell or otherwise transfer
some or all of its assets to a third party. The information we obtain
from you via the App may be disclosed to any potential or actual third-party
purchasers of such assets and/or may be among those assets transferred
in accordance with applicable law.
4. YOUR PRIVACY CHOICES
Depending on where you live, you may have the following rights with respect
to your personal information, to the extent applicable to the App:
• Access
• Data portability
• Erasure
• Correction
• Opt out of sales of personal information
For a description of these rights, please see the applicable chart in Section
10 of this Privacy Notice. In addition, you may have the right to opt
out of targeted advertising and profiling, to the extent that profiling
makes decisions that produce legal or similarly significant effects concerning
you. To exercise any of these rights available to you, see Section 12 below.
5. CHILDREN
The App does not permit children under 13 to become users, and we do not
collect information from children. By using the App, you represent that
you are not under the age of 13. Any information we receive from users
we believe to be under the age of 13 will be purged from our database.
6. THIRD PARTY WEBSITES
CentraCare may reference or provide links to third party websites or CentraCare’s
other websites. You should review the privacy notices posted on such sites,
as those privacy notices will control once you are directed to those websites.
Please be aware that CentraCare does not control, nor are we responsible
for, the privacy notices or information practices of third parties or
their websites.
7. RETENTION
We have policies and procedures relating to the retention of personal information
based upon a classification scheme consisting of business functions and
process areas, and the classification and types of data and records. We
retain personal information for as long as we reasonably require it for
business and legal purposes. In determining data retention periods, we
consider contractual and legal obligations, and the expectations and requirements
of customers, vendors, suppliers and others who disclose their personal
information with us. When we no longer need personal information, we securely
delete or destroy it.
8. SECURITY
CentraCare and its service providers employ security systems to protect
the information we receive from you from unauthorized disclosure. We make
commercially reasonable efforts to keep your information secure using
appropriate technical, physical and organizational measures to prevent
against unlawful use, alteration, unauthorized access accidental destruction
and loss. No transmission of data over the internet is guaranteed to be
completely secure. Due to the nature of the internet, we cannot guarantee
that information, during transmission through the internet or while stored
on its system or otherwise in its care, will be absolutely safe from intrusion
by others, such as hackers. Because security is important to both CentraCare
and you, we will always make reasonable efforts to ensure the security
of our systems.
9. UPDATES
We may update this Privacy Notice from time to time to reflect changes
to our information practices. We will provide you with advance notice
of a major change prior to your access of any portion of the App. For
example, we may (i) require that you re-accept the updated version of
this Privacy Notice, (ii) send you an electronic notification advising
of the update to this Privacy Notice, or (iii) include a notice on our
App. We do not ordinarily provide advance notice of a minor change.
We encourage you to periodically review this page for the latest information
on our privacy practices. You can tell when changes have been made to
the Privacy Notice by referring to the “Effective Date” legend
on top of this page.
10. CALIFORNIA RESIDENTS
This section supplements the information above and applies solely to California
residents whose personal information is subject to California Consumer
Privacy Act, as amended by the California Privacy Rights Act and its regulations
(“CCPA”).
During the last twelve (12) months, CentraCare collected the following
categories of personal information from California consumers:
• Geolocation data; and
• Sensitive personal information, including precise geolocation.
CentraCare collects the categories of personal information listed above
from the following categories of sources:
• Directly from you; and
• Our service providers.
CentraCare collects the categories of personal information listed above for the following business and/or commercial purposes:
• Providing the requested services, such as operating our App or responding
to inquiries;
• Enhancing your user experience;
• Monitoring and maintaining the security and functionality of the App; and
• For compliance and legal obligations, and to exercise our legal rights.
During the last 12 months, CentraCare has disclosed personal information
in accordance with the below chart:
|
Categories of Personal Information We Collect |
Categories of Third Parties to Which We Disclose Personal Information for a Business or Commercial Purpose |
Categories of Third Parties to Which We May Sell or Share Personal Information |
|
Geolocation data |
Service providers |
We do not sell or share personal information. |
|
Sensitive personal information, including precise geolocation |
Service providers |
We do not sell or share personal information. |
Please see Section 7 with regard to our data retention practices.
We will not collect additional categories of personal information or use the personal information collected for materially different, unrelated, or incompatible purposes without providing notice to the California consumer, unless required or permitted by applicable laws.
We also do not knowingly sell or share personal information of consumers under the age of 16.
Subject to certain exceptions, if you are a resident of California, you may have the following rights:
|
Privacy Right |
Description |
|
Notice |
The right to be notified of what categories of personal information will be collected at or before the point of collection and the purposes for which they will be used and shared. |
|
Access |
The right to request the categories of personal information that we collected in the previous twelve (12) months, the categories of sources from which the personal information was collected, the specific pieces of personal information we have collected about you, and the business purposes for which such personal information is collected and shared. You may also have the right to request the categories of personal information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your personal information. |
|
Data Portability |
The right to receive the personal information you have previously provided to us. |
|
Erasure |
The right to have your personal information deleted. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required or permitted to retain your personal information for one or more of the following categories of purposes: (1) to complete a transaction for which the personal information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); or (4) to otherwise use your personal information internally, in a lawful manner that is compatible with the context in which you provided it. |
|
Correction |
You have the right to request that we correct any incorrect personal information that we collect or retain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see below), we will correct (and direct any of our service providers that hold your data on our behalf to correct) your personal information from our records, unless an exception applies. We may deny your correction request if (a) we believe the personal information we maintain about you is accurate; (b) correcting the information would be impossible or involve disproportionate; or (c) if the request conflicts with our legal obligations. |
|
Automated Decision Making |
You have the right to request information about the logic involved in automated decision-making and a description of the likely outcome of processes, and the right to opt out. CentraCare does not currently engage in any automated decision-making practices. |
|
To Opt Out of Sales or Sharing of Personal Information |
CentraCare does not sell or share your personal information. If we did, you would have the right to opt-out of the sale and sharing of your personal information. When you opt-out of sales, we will not share your personal information with our advertising vendors or marketing partners. However, for personal information already shared, you will need to submit your access, deletion, and opt-out requests to each partner individually. When you opt out of sharing, we will not share your personal information with third parties for purposes of cross-context behavioral advertising. |
|
Limit Use of Sensitive Personal Information |
CentraCare does not use or disclose sensitive personal information other than to provide our services to you. However, if we used or disclosed sensitive personal information for other purposes, you would have the right to opt out. |
Only you or a person who is authorized to act on your behalf (“Authorized
Agent”) may make a request related to your personal information.
Requests may also be made on behalf of a minor child. Requests must:
• Provide sufficient information that allows CentraCare to reasonably
verify the requestor is the person about whom the Personal Information
is collected or an Authorized Agent and
• Describe the request with sufficient detail that allows CentraCare
to properly understand, evaluate, and respond to it.
You, or your Authorized Agent, may submit requests to CentraCare by sending
an email to CentraCare at
CCISServiceDesk@CentraCare.com.
CentraCare cannot respond to requests or provide personal information if
it is unable to verify a requestor’s identity or authority to make
the request and confirm the personal information relates to the requestor.
Making a request does not require you to create an account with CentraCare.
Personal information provided for identity verification for such requests
will only be used to verify your identity or authority to make the request.
Identity Verification Requirements. In order to verify your identity, you
may need to submit certain information. CentraCare will match this information
against information CentraCare has previously collected about you to verify
your identity. If an Authorized Agent is being utilized for a request,
CentraCare will require proof of the Authorized Agent’s authority.
If we are unable to verify your identity, your request may be denied.
Depending on the nature of the personal information which is the subject
of your request, our verification process may include using existing authentication
practices or matching two or three additional data points, and may also
include submitting a declaration.
Non-Discrimination. CentraCare will not discriminate against you for exercising
any rights under applicable privacy law.
Appeals: If you are not satisfied with the resolution of your request and
would like to submit an appeal, please submit your appeal using the information
provided above.
1. USERS FROM OUTSIDE THE UNITED STATES
Our App is hosted in the United States and are governed by United States
law. If you are using the App from outside the United States, please be
aware that your information may be transferred to, stored, and processed
in the United States where our (or our service provider’s) servers
are located. The data protection and other laws of the United States and
other countries might not be as comprehensive as those in your country.
By using the App, you consent to your information being transferred to
our facilities and to the facilities of those third parties with whom
we share it as described in this Privacy Notice.
2. QUESTIONS REGARDING THIS PRIVACY NOTICE
Questions regarding this Privacy Notice should be directed to CentraCare at
privacyline@CentraCare.com. CentraCare may also be contacted directly at the following address and
phone number:
CentraCare
Attn: Privacy Officer
1406 Sixth Avenue North
St. Cloud, MN 56303
Email:
privacyline@CentraCare.com
Phone: 800-835-6652 or 320-251-2700, ext. 53046