Effective Date: January 1, 2020

This Privacy Notice for California Residents supplements the information contained in Life Line’s Privacy & Cookie Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals (see California Employee Privacy Notice).

Information We Collect

We collect 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 consumer, household, or device (“personal information“). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from its consumers within the last twelve (12) months:

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.
• OTHER SOURCE CATEGORY: Third party service entities for the purpose of analyzing and modeling data to provide potential targets for marketing.This information is not sold but we do receive other consideration, namely potential other acquisition target data.

Use of Personal Information

We may use, [sell,] or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request an appointment for screening or if you have a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery or scheduling. We may also save your information to facilitate new product orders or for future appointments.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• [For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.]
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights)]. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. [The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.]

We share your personal information with the following categories of third parties:

• Service providers.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company may have disclosed the following categories of personal information for a business purpose:

• Identifiers
• California Customer Records personal information categories
• Internet or other similar network activity
• Geolocation data

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers.

Sales of Personal Information

In the preceding twelve (12) months, Company may have disclosed and received something of value for the following categories of personal information:

• Identifiers
• California Customer Records personal information categories
• Internet or other similar network activity
• Geolocation data

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Life Line Screening, Attn: Privacy Officer
901 South Mopac Expressway
Barton Oaks Plaza 2, Suite 130 Austin, TX 78746

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:

See Do Not Sell My Information

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by:

Opt me back in

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please mail us at:

Life Line Screening, Attn: Privacy Officer
901 South Mopac Expressway
Barton Oaks Plaza 2, Suite 130 Austin, TX 78746

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Life Line collects and uses your information described here or in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Life Line Screening, Attn: Privacy Officer
901 South Mopac Expressway
Barton Oaks Plaza 2, Suite 130 Austin, TX 78746

California Employee Privacy Notice

Effective Date: January 1, 2020

The California Consumer Privacy Act of 2018 (“CCPA”) imposes specific obligations on businesses processing personal information of California residents. Pursuant to the CCPA, Life Line Screening of America, Ltd. and its related companies (“Life Line”, “we” or “us”) is required to provide its employees who are California residents (“California Persons”) a notice, used at or before the point of collection of such personal information, that identifies the categories of personal information that may be collected and why Life Line collects such information.

This California Employee Privacy Notice (“Notice”) is intended to provide California Persons with the CCPA required notice.

1. Updates

This Notice will be updated at least once every twelve (12) months to reflect changes in our business, legal or regulatory obligations, so please check this Notice periodically for changes by visiting (hyperlink for where this will be posted). Life Line will not collect additional categories of your personal information or use your personal information already collected for additional purposes without providing you with a notice of our intent to do so. Any changes to this Notice will be effective from the date they are communicated to you. If we make any material changes to this Notice, we will notify you by email before such changes are effective at the email address you have provided to us.

2. Definitions

2.1 “Personal information” has the meaning as defined in the CCPA, and includes information that is collected by Life Line about you in the course of employment for employment related purposes and encompasses any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

2.2 “Process”, “processed” or “processing” means any operation or set of operations which is performed on personal information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal information.

2.3 “Employees”, “employee” or “you” means an identified or identifiable natural person who is a California resident and who is acting as a Life Line job applicant, employee, or contractor. In this context “job applicant” refers to any person who has submitted his or her candidacy with Life Line; “employee” refers to any person who is employed at Life Line as a full-or part-time employee or temporary worker, and “contractor” means a natural person who provides any service to a business pursuant to a written contract.

3. Personal Information We Collect About You

Listed below are the categories of personal information that Life Line may process about employees:

3.1 Identifiers, including real name, alias, postal address, unique personal identifiers, email, account name, social security number, driver’s license number, passport number or other similar identifiers. In this context, a “unique personal identifier” means a persistent identifier that can be used to recognize an employee, or a device that is linked to an employee, over time and across different services, including, but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, or similar technology; unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers.

3.2 Characteristics of Protected Classifications Under California or Federal Law, including the following: race, skin color, national origin, religion (includes religious dress and grooming practices), sex/gender (includes pregnancy, childbirth, breastfeeding and/ or related medical conditions), gender identity, gender expression, sexual orientation, marital status, medical condition (such as genetic characteristics, cancer or a record or history of cancer), disability (such as mental and physical including HIV/AIDS, or cancer), military or veteran status, request for family care leave, request for leave for an employee’s own serious health condition, request for pregnancy disability leave, and age.

3.3 Internet or Other Electronic Network Activity Information, including browsing history, search history, application access location and information regarding an employee’s interaction with an internet website, application or advertisement, time and geolocation data related to use of an internet website, application or physical access to a Life Line office location.

3.4 Professional or Employment-related Information, including job related data, maintained as part of the employment relationship that is present in: a job application or resume; an employment contract; a contractor agreement; a performance review; a disciplinary record; photos; biometric data, including imagery of your fingerprint, face, and voice recordings; information from employee expenses; browsing and search history; payroll and benefits related data; internal and external contact information; or information captured from video, audio, systems, or other forms of monitoring or surveillance.

3.5 Education Information, including information about an employee’s educational background, such as education records, report cards, and transcripts that is not publicly available.

3.6 Inferences, including any information drawn from any of the personal information categories referenced above to create a profile about an employee reflecting the employee’s characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

4. Purposes for Collecting Your Personal Information

Life Line collects the personal information identified in Section 3 above for the reasons listed below.

4.1 To Recruit Employees, including to conduct employment related background screening and checks.

4.2 To Administer Benefits, such as medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management and provision of online total reward information and statements.

4.3 To Pay and Reimburse for Expenses, including salary administration, payroll management, payment of expenses, to administer other compensation related payments, including assigning amounts of bonus payments to individuals, administration of departmental bonus pools and administration of stock option payments.

4.4 To Conduct Performance-Related Reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff re-structuring.

4.5 To Monitor Work-Related Licenses and Credentials, including provisioning software licenses for use in the course of an employee’s work-related responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies.

4.6 To Provide Our Employees with Human Resources Management Services, including providing employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration.

4.7 To Administer International Assignments, including relocation services, documenting assignment terms and conditions, obtaining relevant immigration documents, initiating vendor services, fulfilling home/host country tax administration and filing obligations, addressing health requirements and populating the International Mobility global system.

4.8 To Maintain Your Contact Information, including altering your details across relevant entities within the Life Line group of companies (for example personal, other employment and transferring roles).

4.9 To Assist You in Case of Emergency, including maintenance of contact details for you, and your dependents in case of personal or business emergency.

4.10 To Monitor Eligibility to Work in the U.S., which means monitoring and ensuring compliance of employees’ ability to work in the U.S.

4.11 To Conduct Healthcare-Related Services, including conducting pre-employment and employment-related medical screenings for return to work processes and medical case management needs; determining medical suitability for particular tasks; identifying health needs of employees to plan and provide appropriate services, including operation of sickness policies and procedures; and providing guidance on fitness for travel and fitness for expatriation.

4.12 To Facilitate Better Working Environment, which includes conducting staff surveys, providing senior management information about other employees, and conducting training.

4.13 To Ensure a Safe and Efficient Working Environment, which includes Life Line actions relating to disciplinary actions, and code of conduct processes and investigations.

4.14 To Maintain Security on Life Line Websites and Internet Connected Assets, which includes hosting and maintenance of computer systems and infrastructure; management of Life Line’s software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access.

4.15 To Comply with Applicable Law or Regulatory Requirements, such as legal (state and federal) and internal company reporting obligations, including headcount, management information, demographic and Health, Safety, Security and Environmental reporting.

5. Further Information

If you have any questions about this statement, please contact the Life Line Privacy Officer at Privacy@llsa.com.