Compliance and Privacy

This Careers Privacy Notice (“Privacy Notice”) supplements any other notice received and applies solely to Versant Health employees, contracted personnel and job applicants (“consumer” or “you”) of Versant Health, Inc. and its affiliates (the “Company”, “we”, “our”) who are California residents.

The purpose of this Privacy Notice is to inform you about our online and offline practices regarding the collection, use, sharing, and retention of your personal information, and the rights available to you..

This Privacy Notice is intended to comply with all applicable laws, such as the California Privacy Rights Act (“CPRA”). If any provision below conflicts with a legal requirement, then the Company will comply with the applicable law.

Personal Information We Collect

We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or a member of your household.

We may have collected the following categories of Personal Information about you in in the last twelve (12) months:

• Identifiers, such as name, alias, postal address, unique personal identifier, Internet Protocol (IP) address, email address, telephone number, passport number, date of birth Social Security number, driver’s license number, or other similar identifiers.
• Additional data subject to (Cal. Civ. Code § 1798.80(e)), such as signature, physical characteristics or description, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
• Characteristics of protected classes under California or federal law, such as age, race, national origin, citizenship, religion, marital status, veteran or military status, medical condition, disability, sex, gender, gender identity, gender expression, and medical conditions.
• Online activity, Internet or other electronic network activity information, such as browsing history, search history, interaction with web sites, applications, or advertisements.
• Geolocation data, such as IP Address.
• Sensory information, audio, electronic, visual, thermal, olfactory or similar information, such as Voice recordings, CCTV, photographs and videos.
• Professional or employment-related information such as resumes, references, compensation, benefits and payroll information (e.g., salary-related information, tax-related information, benefits elections and details regarding leaves of absence), information relating to your position (e.g., job title and job description), performance-related information (e.g., evaluations and training), talent management information (e.g., resume information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, and pre-employment screening and background check information, including criminal records information), and emergency contact information.
• Education information, such as degrees, grades, certificates, licenses and education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
• Inferences drawn from any of the information we collect, such as to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• Sensitive Personal Information, such as Social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card or credit card number; geolocation data such as IP address; racial or ethnic origin, union membership; health information.

We may have collected personal information about you from the following categories of sources:

• Directly from you
• From your devices, such as when you visit our websites and mobile applications
• Our affiliates
• Social networks
• Data brokers / data analytics providers
• Attorney / Legal counsel
• Other individual(s) associated with an insurance policy
• Beneficiaries of insurance policies
• Adverse parties (related to a claim under a policy)
• Brokers/Agents
• Consumer Report / Credit Reporting Agencies
• Court orders or legally binding documents
• Employers, Group Policyholders, Plan Sponsors, and Employer’s Administrators
• Factoring companies
• Government agencies or regulators
• A financial institution of a policyholder
• A prior insurance carrier
• Medical professionals / paramedical vendors
• Versant Health’s service providers

How We Use Personal Information

We may use your personal information for the purposes described in the “How We Use

Your Personal Information” section of other applicable Company Privacy Notices that you may have received in an employment relationship and/or as a job applicant and for one of more of the following business purposes, including as specified in the CPRA.

• Enable you to express interest in and/or allow you to apply for employment.
• Verify your identify and consider your candidacy and suitability for employment.
• Conduct a background investigation, which may include, but not limited to, criminal record check, criminal history and/or FBI background search, Social Security number and name verification, and other searches applicable to the position for which you applied, in accordance with applicable laws.
• Open and maintain your employee records, communicate with you for internal business purposes or emergencies, maintain an internal employee directory and grant you access to internal systems.
• Manage our human resources operations, including performing analytics.
• Career planning, assessing your personal and professional development, benefits and other awards, job moves, conflict of interest reporting, and to fulfill our obligations to regulators.
• Conduct equal opportunity and diversity monitoring where permitted or required by law.
• Arrange or reimburse travel, contact you during travel, as necessary with travel service providers, or in an emergency situation.
• Maintain safety and security controls and features, including workplace safety, electronic systems and digital properties, and to comply will applicable laws.
• Monitor your compliance with our internal policies and procedures, to investigate security breaches and misuse of computer equipment and systems, to protect the safety of employees and third parties, and to protect our property from theft, vandalism and damage.
• Assess and take action in relation to disciplinary, capability, grievance and conduct issues.
• To comply with applicable legal and regulatory requests and obligations (including investigations and reports to government agencies).
• To establish or defend legal claims and allegations.
• To seek advice from lawyers, auditors, and other professional advisors.
• Detecting or preventing security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture, or control, and to improve, upgrade, or enhance the service or device.

We will only use your sensitive personal information for business purposes.

Personal Information We Disclose

We may disclose (and may have disclosed during the last twelve (12) months) the following categories of personal information, including sensitive personal information to the following categories of third parties for business purposes:

We do not sell your personal information to non-service provider third parties, we do not share or disclose your personal information, including sensitive personal information with non-service provider third parties, and we only use your sensitive personal information for business purposes.  We do not have actual knowledge that we sell or share personal information of minors under 16 years of age.

Consumer Privacy Rights

As a California resident you have certain privacy rights, subject to exceptions, regarding your personal information, as described below.

• Right to Know: You have the right to request what personal information we have collected, used, disclosed and sold/shared about you during the past 12 months.
• Right to Delete: You have the right to request that we delete certain personal information we have collected about you.
• Right to Correct: You have the right to request that we correct inaccurate personal information we have about you

To Submit a Right to Know or a Right to Delete Request visit  https://versanthealth.com/contact/ or call 1 (800) 571-3366 Monday to Friday, 9:00 AM to 9:00 PM eastern standard time, excluding holidays.

To Submit a Right to Correct Request call 1-800-Versant Health Monday to Friday, 9:00 AM to 9:00 PM eastern standard time, excluding holidays or email us at Email: Privacy@versanthealth.com and provide your first and last name, your relationship to Versant Health and the best method for us to contact you regarding your request.

In order to process your request and to help protect your privacy and mahttps://versanthealth.com/contact/intain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide some personal information to us. If you are making a request on behalf of someone else, we will need to verify that you have the authority to do so.

You may also opt out of Google ad personalization via the Google Ads Settings page. For more information about our ad service provider and its cookies, including information about how to opt out of these technologies, go to https://www.google.com/intl/en/policies/privacy/ and https://www.aboutads.info/consumers.

Non-Discrimination

You have a right not to receive discriminatory treatment for the exercise of your privacy rights. Versant Health does not discriminate against any individual who exercise their legal rights.

Designation of an Authorized Agent

If an authorized agent submits a request to know, a request to correct or a request to delete on your behalf, we may require that you provide the authorized agent written permission to do so. To designate an authorized agent, please visit  Privacy@versanthealth.com or call  1 (800) 571-3366.

Retention of Personal Information

Versant Health’s Record Retention Schedule establishes the retention periods for our Records consistent with Versant Health business needs and  legal and regulatory requirements. Our company periodically conducts a review of the Record Retention Schedule to ensure the Schedule continues to align with business needs and legal and regulatory requirements. Versant Health.  Consequently, will retain personal information only for as long as is necessary for the purpose set out in our policies, for as long as an account or relationship with Versant Health is active, as needed to provide services to our customers or to comply with our  Record Retention Schedule.

Changes to this Notice

We may change this Privacy Notice from time to time and will post the revised Privacy Notice on this site.  When we do, we will let you know by posting the revised Privacy Notice with a new “Last Updated” date. Any changes to this disclosure will become effective when posted unless indicated otherwise.

Contact Us for More Information

If you have questions about our privacy policies and practices or would like to receive this Privacy Policy in an alternative format call us at 1 (800) 571-3366 or visit https://versanthealth.com/privacy-policy/

This California Employee Privacy Notice supplements any other notice received and applies solely to California residents. The purpose of this Privacy Notice (“Notice”) is to inform employees and job applicants of Versant Health, Inc. and its affiliates (the “Company” or “we” or “us”) of the categories of personal information we collect and the purposes for which we use such personal information. This Notice is intended to comply with all applicable laws, such as the California Consumer Privacy Act.  If any provision below conflicts with a legal requirement, then the Company will comply with the applicable law.

Personal Information We Collect

The Company may collect, use, and disclose employee and job applicant personal information for business purposes and consistent with applicable laws.  Where the Company discloses personal information to third parties, it does so for the same business purposes described below.

We may collect and use the following categories of Personal Information about you in an employment relations and/or job applicant context:

• Identifiers, such as name, alias, postal address, unique personal identifier, Internet Protocol (IP) address, email address, telephone number, passport number, date of birth Social Security number, driver’s license number, or other similar identifiers.
• Additional data subject to (Cal. Civ. Code § 1798.80(e)), such as signature, physical characteristics or description, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
• Characteristics of protected classes under California or federal law, such as age, race, national origin, citizenship, religion, marital status, veteran or military status, medical condition, disability, sex, gender, gender identity, gender expression, and medical conditions.
• Commercial information, such as records of personal property, products or services purchased, including travel-related records and purchases.
• Biometric information, such as fingerprints and fingerprint and facial recognition scan templates.
• Online activity, Internet or other electronic network activity information, such as browsing history, search history, interaction with web sites, applications, or advertisements.
• Geolocation data, such as IP Address.
• Sensory information, audio, electronic, visual, thermal, olfactory or similar information, such as photographs and videos.
• Education information, such as degrees, grades, certificates, licenses and education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
• Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

How We Use Personal Information

We may use your personal information for the purposes described in the “How We Use

Your Personal Information” section of other applicable Company Privacy Notices that you may have received in an employment relationship and/or as a job applicant and for one of more of the following business purposes, including as specified in the CCPA.

• Enable you to express interest in and/or allow you to apply for employment.
• Verify your identify and consider your candidacy and suitability for employment.
• Conduct a background investigation, which may include, but not limited to, criminal record check, criminal history and/or FBI background search, Social Security number and name verification, and other searches applicable to the position for which you applied, in accordance with applicable laws.
• Open and maintain your employee records, communicate with you for internal business purposes or emergencies, maintain an internal employee directory and grant you access to internal systems.
• Manage our human resources operations, including performing analytics.
• Career planning, assessing your personal and professional development, benefits and other awards, job moves, conflict of interest reporting, and to fulfill our obligations to regulators.
• Conduct equal opportunity and diversity monitoring where permitted or required by law.
• Arrange or reimburse travel, contact you during travel, as necessary with travel service providers, or in an emergency situation.
• Maintain safety and security controls and features, including workplace safety, electronic systems and digital properties, and to comply will applicable laws.
• Monitor your compliance with our internal policies and procedures, to investigate security breaches and misuse of computer equipment and systems, to protect the safety of employees and third parties, and to protect our property from theft, vandalism and damage.
• Assess and take action in relation to disciplinary, capability, grievance and conduct issues.
• To comply with applicable legal and regulatory requests and obligations (including investigations and reports to government agencies).
• To establish or defend legal claims and allegations.
• For security or the prevention, detection, or investigation of fraud, suspected or actual illegal activity, violations of company policy or rules, or other misconduct.
• To seek advice from lawyers, auditors, and other professional advisors.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture, or control, and to improve, upgrade, or enhance the service or device.

Privacy Policy

Versant Health’s Privacy Policy can be found at https://versanthealth.com/privacy-policy/.