Passport Analytics California privacy policy

Passport Analytics-Privacy notice for California Residents (the “Notice”)

This Privacy Notice (the ”Notice”) for California residents supplements the information in the Passport Analytics Privacy Policy (the ”Privacy Policy”). References to “we” and “us” means Definitive Healthcare’s wholly owned subsidiary Analytical Wizards Inc. This notice applies where we act as a business (as defined in the California Consumer Privacy Act of 2018 (collectively with any regulations promulgated thereunder, the “CCPA”)) under the CCPA, (ii) and it shall apply to you only if you are a California resident.

This Notice shall not apply to any situations where we act as a Service Provider (as defined in the CCPA) on behalf of a customer in respect of certain business information. See Section Applicability of this Privacy Policy in the Privacy Policy for more information. In such case(s) the customer for whom we process consumer information is responsible for acting in all matters in accordance with all applicable laws and providing you with all requisite information as required by applicable law. To the extent we process your consumer information for any other lawful business purpose of ours, under the CCPA, to the extent applicable, we will act as a business with respect to such consumer information and this Notice will apply to the processing of such consumer information.

“Sell” and “Selling” As used in this Notice “sell” (including any grammatically inflected forms thereof) means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, consumer information (as defined below) to another business or a third party for monetary or other valuable consideration. “Selling” does not include (i) disclosing consumer information to a third party at your direction, provided the third party does not sell the consumer information except in accordance with the CCPA, (ii) where you intentionally interact with a third party through the Site, provided the third party does not also sell the consumer information, (iii) using or sharing your consumer information with a service provider as necessary to perform business purposes, provided that such service provider provides its services on our

behalf and provided that the service provider does not further collect, sell or use the consumer information except as necessary to perform the business purpose, or (iv) transfers of your consumer information to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction, provided that information is used or shared consistently with the CCPA. In the preceding twelve (12) months, Analytical Wizards has not sold, nor does it or will it sell, consumer information that is subject to this Privacy Policy.

1.1 Consumer information collected. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with particular California residents, devices or households (“Consumer Information”). Consumer information does not include deidentified or aggregated information or any other information that is excepted from the definition of “personal information” under the CCPA, or any information that is otherwise not regulated by the CCPA. In particular, with respect to the activities covered by this Privacy Policy, we have collected the following categories of consumer information from California residents, households or devices within the last twelve (12) months:

Category	Examples	Business or commercial purposes for which we collect, use consumer information
A. Identifiers.	Name, e-mail address, job title, postal address, age, birthday, company, support chat transcripts, city, country, continent, IP address, online identifier, telephone number, prospective use-case interests, and any other information you may choose to share with us or which we state we collect as per the Privacy Policy	To provide the Services to you; To provide a Webinar that you sign up for or participate in; To help us understand how you use the Services; For internal operations such as operating and improving the Services; To contact you for customer service and for support call purposes; and For sales and related purposes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Name, telephone number, postal address, and job title.	To provide the Services to you; To provide a webinar that you sign up for or participate in; To help us understand how you use the Services For internal operations such as operating and improving the Services To contact you for customer service and for support call purposes; and For sales and related purposes
C. Internet or other similar network activity.	IP address, search history, user log-in information, language, internet service provider, demographic information, browser types, browser system, unique device identifiers, email client, device types, requested URL, referring URL, traffic source, browser language, the date and time of your visit, location (city, country, continent), the duration of your visit, operating system, domain names, general usage data, and statistical data involving the use of the Services.	To provide the Services to you; To provide a webinar that you sign up for or participate in; To help us understand who uses the Services For internal operations such as operating and improving the Services To contact you for customer service and for support call purposes; and For sales and related purposes.

1.2 Use of consumer information; Categories of sources. We use consumer information for the business or commercial purposes described in the table above and in the manner described in the Privacy Policy with respect to personal information. We also receive information that is otherwise collected when you engage with us as described in the Privacy Policy. Regarding the categories of sources from which consumer information is collected, we collect consumer information that you submit to us, including when you engage in direct communication with one of our representatives. We may receive consumer information from or about you when you sign up for or participate in a Webinar, or when you contact us for a support call. If we receive a question for support, we collect and store the question as well as the answer to the question. We also collect aggregated statistics connected to support issues. Finally, we receive information about you when you are a user when you register an account as well as from the enterprise customer you represent.

1.3 Disclosures of consumer information for a business or commercial purpose. We may disclose your consumer information described in the table above to a third party for a business or commercial purpose, as described in the table above and in the section of the Privacy Policy entitled How your information is shared with respect to personal information. In the preceding twelve (12) months, we have disclosed each of the categories of consumer information described in the table above for a business or commercial purpose to the categories of third parties as further described in the Privacy Policy.

1.4 California residents’ rights and choices.

The CCPA provides California residents with specific rights regarding their consumer information. This Section 1.4 describes your CCPA rights (to the extent applicable to you) and explains how to exercise those rights.

1.4.1 Access to specific information and data portability rights. You may have the right to request that we disclose certain information to you about our collection and use of your consumer information over the past 12 months. Once we receive and confirm your verifiable consumer request (in the manner described in Section 1.6 below), to the extent required by the CCPA, we will disclose to you:

The categories of consumer information we collected about you.
The categories of sources for the consumer information we collected about you.
Our business or commercial purpose for collecting that consumer information.
The categories of third parties with whom we share that consumer information.
The specific pieces of consumer information we collected about you (also called a data portability request).
If we disclosed your consumer information for a business purpose, a list disclosing disclosures for a business purpose, identifying the consumer information categories that each category of recipient obtained.

1.4.2 Deletion request rights. You have the right to request that we delete any of your consumer information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm a verifiable request from you (if you are a California resident) in the manner described in Section 1.6 below (“verifiable consumer request”), we will delete (and direct our service providers to delete) your consumer 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:

Complete the transaction for which we collected the consumer information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfil the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products or services to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
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.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

1.6 Exercising access, data portability, and deletion rights.

1.6.1 To exercise the access, data portability, and deletion rights described in Section 1.4 above, please submit a verifiable consumer request to us by either:

By Phone: Call us at 1-866-679-6461
E-mail: Contact us by email at: aw-privacy@definitvehc.com
By postal mail or courier:

492 Old Connecticut Path
Suite 401,
Framingham, MA 01701
Attn: Passport Analytics-Privacy Team

Only you, or someone legally authorized to act on your behalf (such as an authorized agent), may make a verifiable consumer request related to your consumer information. You may also make a verifiable consumer request on behalf of your minor child. You may make a verifiable consumer request for access or data portability no more than twice within a 12-month period.

The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected consumer information or an authorized representative; and (ii) 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 consumer information if we cannot verify your identity or authority to make the request and confirm the consumer information relates to you. Making a verifiable consumer request does not require you to have or create an account with us. We will only use consumer information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. In the event you make a request we may take various approaches to verify your identity depending on the nature of your request. These approaches may include telephone calls with you or reaching out to by email or otherwise to ask you questions pertaining to the information we have about you

1.6.2 We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days in total), we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, 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 consumer information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify you of the reason for refusing the request.

1.7 Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights, including, unless permitted by the CCPA, by:

1.7.1 Denying you goods or services.

1.7.2 Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

1.7.3 Providing you a different level or quality of goods or services.

1.7.4 Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.