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Effective Date: March 23, 2023 

This Privacy Policy describes Commonwealth Care Alliance’s (CCA) practices in connection with information we collect through the online and mobile websites, platforms, services, and applications that we own or operate and that contain a link to this Privacy Policy (collectively, “Online Services”). 

As used in this Policy, terms such as “we,” “us,” and “our,” refer to current and future affiliated entities, subsidiaries, agents, contractors, or vendors of Commonwealth Care Alliance, Inc. Our Online Services are targeted to a United States audience. 

Collection of Personal Information 

When you visit our website, we collect information in several ways. There is information which relates to you (“Personal Information”) which you provide, such as your CV, email address, phone number, physical address, employment, and educational history, and (where applicable) background screening reports. 

There is also Personal Information we collect from you as a result of the technology used to operate the Site, such as IP address, geographic location, Internet service provider, and pages visited (“Navigational Information”). We use “cookie” technology to collect site statistical information and improve your customer experience. 

Cookies and clear GIFs 

“Cookies” are small files that are stored by your web browser to help a particular system recognize you and the pages you visited in a website. This website may use cookies to make your online experience more convenient. Additionally, this website may use data from cookies for a variety of internal purposes, such as studying how users navigate this website. We don’t collect any Personal Information from cookies. Further, no other information collected from cookies can be linked back to your Personal Information. Most browsers automatically accept cookies, but if you prefer, you can set yours to refuse cookies. Even without a cookie, you can still use most of the features on this website. To sign in and securely use the portal, you’ll need to enable cookies on your browser. 

“Clear gifs” are tiny graphics with a unique identifier, similar in function to cookies, that are used to track the online movements of website users. The main difference between the two is that clear gifs are invisible on the page and are much smaller than cookies. This website doesn’t collect any Personal Information from clear gifs. Further, no information collected from clear gifs can be linked back to your Personal Information. 

Technical Information 

This website may use third-party web analytics services to track and analyze anonymous usage and volume statistical information from visitors to help the administration of this website, improve this website’s performance, and to report website traffic. These web analytics services use cookies, clear gifs, and other web monitoring technologies to help track visitor behavior on behalf of this website. These services don’t use these technologies to collect any personally identifiable information from this website’s visitors. 

Additionally, as part of the Navigational Information we collect, we also collect statistical data as you browse our websites. For example, we automatically collect, average time spent on our site, information searched for, access times, clickstreamdata, and other relevant information about your online experience. 

Some of this Navigational Information may be linked to the Personal Information you provide directly. Where we connect Navigational Information with Personal Information, we will consider such Navigational Information as Personal Information. 

Our Privacy Policy does not apply to the practices of other companies or other websites or software applications that may be linked from or made available through our Online Services. 

This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party. 

Use of Personal Information 

If you choose to provide us with Personal Information, we use this information for a number of purposes. With the information we collect, we can: 

CCA also uses your Personal Information for a number of internal business purposes. As such, we will also use your Personal Information to: 

Disclosure of Personal Information 

To carry out certain business functions, we sometimes hire other companies to perform services on our behalf (“Service Providers”). Service Providers may use your Personal Information, such as the email address you have supplied when registering, to enable them to perform these services, but they’re required to safeguard this data and are generally not authorized to use it for any other purpose besides completing their contractual requirements to CCA. 

Additionally, we may disclose your Personal Information to other third parties as required by law, or for the purposes disclosed above. For example, we may need to disclose your Personal Information to a governmental agency in response to a warrant, subpoena, or other legal process. Similarly, we may need to disclose your Personal Information to a third party to prevent physical harm to you or some other person. 

Except as otherwise specified in this Policy, or as permitted by applicable law, CCA doesn’t disclose Personal Information outside of CCA or its affiliates. 

A copy of HIPAA Notice of Privacy Practices is available for your review. The Notice of Privacy Practices details the privacy policies of CCA with respect to its members personal health information. We recognize that some users of our websites may not be CCA members. Personal health information that we receive about our members is always treated in the manner described in the HIPAA Notice of Privacy Practices document. 

Suspected privacy violation 

To report a suspected privacy violation, please email us at [email protected] with attention to Privacy and Security Officer. If you believe that the suspected privacy violation may cause the physical harm to yourself or another individual, please call us at 1-866-457-4953. 

Security Safeguards 

We deploy reasonable technical, administrative, and procedural safeguards in order to protect your Personal Information from unauthorized access, disclosure, loss, or destruction. As CCA continues to introduce new functionality to this website, additional features and other safeguards will be introduced to further enhance privacy and security. 

Data Retention 

CCA retains personal information as is reasonably necessary to fulfill the purposes described in this Policy. Your personal information will be retained so as to consider you for roles for which you may be qualified within the CCA. 

We may also retain personal information for any additional period as required by applicable law or regulation, court, administrative or arbitration proceedings, or audit requirements. 

Changes to This Privacy Policy 

We may change this Privacy Policy at any time. If we do so, such change will appear on this page. You may always visit this Policy to learn of any updates. Your continued access to or use of the Online Services constitutes your consent to these changes to this Policy.