Last Reviewed: December 1, 2020
Effective Date: December 1, 2020

Sutter Health (collectively, “we”, “us”, or “ours”) is committed to the protection of your personal information. This privacy notice discloses the privacy practices for our website (KeepingOurCareConnected.org).

This privacy policy (“Privacy Policy”) explains how we collect, use and share your Personal Information in connection with our Service, and this website. (“Service”). 
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 INFORMATION WE COLLECT
We may collect a variety of Personal Information from you or about you or your devices from various sources, as described below. 

A.    Personal Information
When you engage us for our Service or use our Service, we may collect different types of Personal Information depending on the Service and your relationship with us. Categories of Personal Information collected include:
●      Usage Data

B.    Usage Data
To help us understand how you use our Service and to help us improve them, we automatically collect usage data about your interactions with our Service.

Usage Data may include, but is not limited to, information such as:
●     Your Device’s Internet Protocol address (e.g. IP address)
●     Browser type
●     Browser version
●     The pages of our Service that You visit
●     The time and date of Your visit
●     The time spent on those pages
●     Unique device identifiers
●     Other diagnostic data.
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 TRACKING TECHNOLOGIES AND COOKIES
We and third-party service providers use various processes and technologies to collect and store information, including cookies, pixel tags, clickstream data or similar technologies.  We and our third-party service providers, such as, analytics and advertising partners, to collect and track information and to improve and analyze our Service.

A cookie is a small file containing a string of characters that is sent to your device when you visit a website. You can configure your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or Service may not function properly without cookies. Learn more about cookies here.

What do we use cookies for? Cookies fall into one or more of the categories set out below. This website uses cookies that fall into all the categories. Also, we use data from targeting cookies placed on your computer by third parties when you have visited other websites.

1.   Strictly necessary cookies – These cookies enable Service you have specifically asked for.  These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies certain Service you have asked for cannot be provided.

2.   Performance cookies – These cookies collect information on the pages visited. These cookies collect information about how users use a website, for instance which pages users go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. They are only used to improve how the website works.

3.   Functionality cookies – These cookies remember choices you make to improve your experience.  These cookies allow the website to remember choices you make and provide enhanced, more personal features. The information these cookies collect may be anonymized and they cannot track your browsing activity to other websites.

4.   Targeting cookies or advertising cookies – these cookies collect information about your browsing habits in order to make advertising relevant to you and your interests

You have options to remove or disable cookies from your browser at any time. Please click here to learn more about how you can manage cookies for your browser.

DETAILED INFORMATION ON THE PROCESSING OF YOUR PERSONAL INFORMATION
Third-party service providers have access to your Personal Information only to perform their tasks on our behalf and are obligated not to disclose or use it for any other purpose.

A.    Analytics
We may use third-party service providers to monitor and analyze the use of our Service.

Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google Service. Google may use the collected data to contextualize and personalize the ads of its own advertising network.You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

B.    Advertising
We may use advertising Service to advertise on third party websites to you after you visited our Service. We and our third-party service providers use cookies to inform, optimize and serve ads based on your past visits to our Service.

Twitter
Twitter advertising service is provided by Twitter Inc. You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

Facebook
Facebook advertising service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

Bing Ads
Bing Ads advertising service is provided by Microsoft Inc. You can opt-out of Bing Ads interest-based ads by following their instructions: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

You can learn more about the privacy practices and policies of Microsoft by visiting their Privacy Policy page: https://privacy.microsoft.com/en-us/PrivacyStatement

Google Ads
Google Ads advertising service is provided by Google Ads Inc. You can find instructions on how to block Google Ads interest-based ads by following their instructions: https://support.google.com/ads/answer/2662922?hl=en

You can learn more about the privacy practices and policies of Microsoft by visiting their Privacy Policy page: https://policies.google.com/technologies/ads

LinkedIn Ads
LinkedIn Ads advertising service is provided by LinkedIn Corporation. You can opt-out of LinkedIn Ads interest-based ads by following their instructions: https://www.linkedin.com/help/linkedin/answer/62931/manage-advertising-preferences

You can learn more about the privacy practices and policies of LinkedIn by visiting their Privacy Policy page: https://www.linkedin.com/legal/privacy-policy 

HOW WE USE INFORMATION WE COLLECT
We use the information we collect from you or about you or your devices:
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●     To provide, maintain, improve, and enhance our Service;
●     For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you, including interest-based ads and targeted ads;
●     To de-identify and aggregate information collected through our Service and use it for lawful purpose;
●     To comply with our legal obligations and enforce our legal rights, such as, among other things, to exercise contractual rights, to comply with financial reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law;
●     To detect, investigate and prevent potentially prohibited or illegal activities, including fraud, and respond to trust and safety issues that may arise;
●     For any purpose with your consent.

SECURITY
We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the personal information. The personal information processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.  

THIRD PARTY WEBSITES:
Our Service may contain links to other sites for news and other information. Our Privacy Policy only applies to our Service, and we are not responsible for the privacy practices or the content of other websites that we do not operate. You should check the privacy policies of such other sites before providing your personal data to them. 
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 RETENTION TIME
 
Your information shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:
●     Personal information collected for purposes related to the performance of a contract between us and you shall be retained until such contract has been fully performed.
●     Personal information collected for the purposes of our legitimate interests shall be retained as long as needed to fulfill such purposes. You may find specific information regarding the legitimate interests pursued us within the relevant sections of this document or by contacting us through the information under the Contact Us section in this Privacy Policy below.

Once the retention period expires, your personal information shall be either deleted or anonymized. 

California residents may have additional rights and choices. Please see Your Rights Under California Privacy Law section below for more information.

YOUR RIGHTS UNDER CALIFORNIA PRIVACY LAW / ONLY FOR CALIFORNIA RESIDENTS
This section is adopted to comply with the California Consumer Privacy Act of 2018 (CCPA) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this section. For the purpose of this section, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

A.    Your Rights and Choices
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 immediately preceding the Effective Date of this Privacy Policy:
●     The categories of Personal Information we have collected about you.
●     The categories of sources for the Personal Information we have collected about you.
●     Our business or commercial purpose for collecting or selling your Personal Information.
●     The categories of third parties with whom we share your Personal Information.
●     The specific pieces of Personal Information we have collected about you (also referred to as data portability).
●     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.

B.    Information We Collect
In the past twelve (12) months, we collected the following categories of Personal Information regarding California residents:
●     Usage Data
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We obtain the categories of Personal Information listed above from the following categories of sources:
●     From third-party service providers such as analytics and advertising services.

C.    Use of Personal Information
In the twelve (12) months immediately preceding the Effective Date of this Privacy Policy, we have disclosed the following categories of Personal Information for a business purpose:
●     To improve our website and present its contents to you.
●     For testing, research, analysis and product development.
●     For targeted marketing

We do not sell your Personal information. 

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, 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 providers to:
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1.   Complete the transaction for which we collected the Personal Information, fulfill the terms of a written warranty or product recall conducted with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, 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 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:
●     Emailing us at [email protected].

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

Non-Discrimination
We will not discriminate against you for exercising any of your California privacy rights. Unless permitted by the CCPA, we will not:
●     Deny you goods or Service.
●     Charge you different prices or rates for goods or Service, including through granting discounts or other benefits, or imposing penalties.
●     Provide you a different level or quality of goods or Service.
●     Suggest that you may receive a different price or rate for goods or Service or a different level or quality of goods or Service.
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ADDITIONAL RIGHTS UNDER CALIFORNIA’S SHINE THE LIGHT LAW / ONLY FOR CALIFORNIA RESIDENTS
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits 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 contact us from the details under the Contact Us section in this Privacy Policy.
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 ADDITIONAL INFORMATION ABOUT INFORMATION COLLECTION AND PROCESSING
 
Legal action
Your Personal Information may be used for legal purposes by us in Court or in the stages leading to possible legal action arising from improper use of our Service.
You declare to be aware that we may be required to reveal Personal Information upon request of public authorities.

 HOW “DO NOT TRACK” REQUESTS ARE HANDLED
We do not support “Do Not Track” requests and signals.
To determine whether any of the third-party Service it uses honor the “Do Not Track” requests, please read their privacy policies.

CHANGES TO THE PRIVACY POLICY
We may modify this Privacy Policy from time to time by posting updates on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the top. If we materially change the ways in which we use or share personal information previously collected from you through the Service, we will notify you through the Service, by email, or other communication, 
Should the changes affect processing activities performed on the basis of your consent, we shall collect new consent from you, where required.
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CONTACT US
If you have any questions or comments about this Privacy Policy contact us at: [email protected]

If you would like to review Sutter Health’s Privacy Policy, please click here.