California Privacy Policy & Notice

Introduction

This California Privacy Policy & Notice (“Policy”) is based upon the California Consumer Privacy Act of 2018 as amended by the California Privacy Right Act (“CCPA”) and supplements the information provided in the TriWest Privacy Policy (“TWPP”). This Policy applies to consumers in the State of California and describes privacy rights and options available to California consumers. Additionally, this Policy provides instructions and methods for California consumers to exercise their rights in connection with collected Personal Information. If you are a resident of California, this Policy applies to you.

Categories of Personal Information, Sources, Third Parties and Business Purposes

The categories of Personal Information collected by TriWest, the categories of sources of Personal Information, the categories of Personal Information disclosed to third parties, the categories of third parties with whom TriWest discloses Personal Information, and the business purposes for the collection and disclosure of such Personal Information are defined on pages 2 - 6 of the TWPP.

TriWest has not “sold” or “shared” Personal Information in the 12 months preceding the Last Updated Date of this Policy. TriWest does not knowingly sell or share the Personal Information of consumers under 16 years of age. TriWest does not use sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.

Description of Your CCPA Privacy Rights

As a California consumer, your rights under the CCPA include all of the following:

1. The Right to Know and Access Your Personal Information

   You have the right to know what Personal Information we have collected about you (including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), and the categories of third parties to whom we disclose Personal Information (if applicable)) and to access the specific pieces of Personal Information we collected about you.

2. The Right to Request Deletion of Your Personal Information

   You have the right to request that TriWest delete the Personal Information that we collected about you, subject to applicable CCPA legal exceptions and exemptions. TriWest may reject your request under certain circumstances, including, where TriWest needs to collect, use and retain your Personal Information to comply with the business purposes as set forth in the TWPP.

3. Right to Opt Out of the Sale or Sharing of Personal Information

   If we sell or share your Personal Information to third parties, you have the right to opt out of the sale or sharing. As stated above, we do not sell or share Personal Information under the CCPA.

4. The Right to Correct Inaccurate Personal Information

   You have the right to correct inaccurate Personal Information that TriWest maintains about you. In order to exercise your right to correct your Personal Information, you must send to TriWest a Request, as detailed in the section “Submitting Requests” below. Your Request must specify and describe the inaccurate information and how you would like it corrected.

5. The Right to Non-Discrimination

   You have the right to not receive discriminatory treatment in connection with the exercise of your privacy rights under the CCPA. TriWest will not take any discriminatory action against you resulting from exercising your privacy rights under the CCPA.

6. The Right to Limit the Use and Disclosure of Sensitive Personal Information

   If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, you have the right to limit our use and disclosure of such sensitive Personal Information. As stated above, we do not use sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.

Exercising Your CCPA Privacy Rights

If you would wish to know about, access, correct, and/or delete your Personal Information, you must submit to TriWest a verifiable Request using the “Request Form” and its processes and procedures.

1. Submitting Requests

   TriWest provides to you two (2) different intake channels for submitting a verifiable Request to TriWest. You (or your Agent, as described in Section B) may exercise your rights in connection with your Personal Information by submitting a Request Form to the TriWest Privacy Officer either electronically (online) or by telephone as set forth below. You may only submit a Request Form to TriWest twice within a 12-month period.

   You may exercise these rights by:

   1. Submitting a Request Online. You have the option of submitting an online Request to TriWest through our Consumer Privacy Request Form which can be accessed at any time directly through the following URL:

      https://consumerprivacy.triwest.com

      or

   2. Submitting a Request by Calling. You have the option to submit a Request to TriWest by calling TriWest’s toll-free telephone number at:

      866-434-8156 and answering the questions on the Consumer Privacy Request Form as asked by a TriWest representative.

2. Only You or Your Authorized Agent May Submit a Request

   Only you or a person authorized by you to act on your behalf (an “Agent”) can submit a Request to TriWest in connection with your Personal Information. You may designate an authorized Agent to submit a Request about your Personal Information on your behalf.

3. Written Proof Required for Agents

   All Agents must have your signed permission to submit a Request Form on your behalf or provide proof that they have power of attorney in accordance with applicable state law.

   TriWest may contact you directly to confirm that you have given your permission and/or to verify your identity. We have the right to deny a Request from any Agent that does not submit written proof that she or he was authorized by you to act on your behalf.

4. Verification of Your Request to Know, Access, Delete, and/or Correct

   We will comply with your Request upon verification of your identity and, to the extent applicable, the identity of the California consumer on whose behalf you are making such Request.

   We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.

The California Civil Code Section 1798.80(e)

The CCPA requires that TriWest notify you whether we collect any Personal Information that is described in the California Civil Code § 1798.80(e). Section 1798.80(e) includes a variety of categories of Personal Information, including, but not limited to, the name, contact information, physical characteristics, credit card or billing information, health or medical information. TriWest collects Personal Information as described in § 1798.80(e).

CCPA Exemptions and Exceptions

The CCPA includes certain legal exceptions and exemptions which are applicable to TriWest and allow us to collect and process Personal Information and SPI for the business purposes set forth on pages 4 - 6 of the TWPP.

Retention of Personal Information

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.

Opt-Out Preference Signals

We do not engage in “sales,” or “shares,” as those terms are defined under applicable laws and therefore the TriWest Websites do not recognize the Global Privacy Control (“GPC”) signal. For more information and to download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the TriWest Websites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.

Shine the Light Law

We do not disclose Personal Information to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.

Effective Date: October 1, 2024.