Policy describes what Personal Information eCW collects and how it is used
eCW describes the policy as telling readers what Personal Information eClinicalWorks, LLC may collect, how it collects it, how it uses it in connection with Services provided to the reader or to Provider customers, and what choices the reader has. The policy defines Personal Information as information that identifies an individual or relates to an identifiable individual or household, with the types collected depending on the purpose and the reader’s role. The same section states that Personal Information as used in the policy excludes Protected Health Information.
Supporting quotations
This Privacy Policy (this "Privacy Policy") informs you what Personal Information eClinicalWorks, LLC ("eCW," "we," "us," or "our") may collect, how eCW collects such Personal Information, how eCW uses such Personal Information in connection with the Services we provide to you or our customers (i.e., Providers as defined below), and your choices related to your Personal Information.
"Personal Information" is information that identifies an individual or relates to an identifiable individual or household.
Qualifications & exceptions
Collection is expressed permissively ("may collect") and the categories collected depend on role and purpose.
Personal Information excludes Protected Health Information.
Data Access & Collection · Context
Personal Information is data identifying or relating to a person or household
The policy defines Personal Information as information that identifies an individual or relates to an identifiable individual or household. It adds that the types collected and the uses made of them depend on the purpose of collection, giving the examples of a Site visitor, a Portals user or a Services customer, and that Personal Information as used in the policy excludes Protected Health Information.
Supporting quotations
2.1.1. "Personal Information" is information that identifies an individual or relates to an identifiable individual or household. The types of Personal Information collected, and the uses thereof depend on the purposes for which we collect the Personal Information (e.g., whether you are a visitor to our Sites, a user of our Portals, or a customer of our Services). As used in this Privacy Policy, Personal Information does not include Protected Health Information.
Qualifications & exceptions
The definition is functional rather than an enumerated list of data elements.
Personal Information excludes Protected Health Information.
Not stated here
Whether household-level data is collected outside the online context is not stated in this section.
Data Access & Collection · Company practice
Collection is framed permissively and tied to accessing and using the Services
The collection section opens by saying that when a reader accesses and uses the Services, eCW may collect the types of information that follow. It then repeats that eCW may collect Personal Information in the ways described below. Collection is therefore framed as possible rather than as something that happens for every visitor in every case.
Supporting quotations
2.1. When you access and use the Services, we may collect the following types of information:
When you use the Services, eCW may collect Personal Information in the following ways described below.
Qualifications & exceptions
Uses permissive language ("may collect") and ties collection to accessing and using the Services.
Not stated here
The section does not say which of the listed information types every user necessarily provides.
Data Access & Collection · Company practice
Users provide Personal Information by message, form, office visit and social media
The policy describes collecting Personal Information that users provide when they interact with the Services, listing communication with eCW about the Services by letter, e-mail, online chat window or telephone; completing and submitting forms on the Sites or Provider Portals; visiting eCW offices; and visiting the Sites or interacting with eCW on social media and providing Personal Information. The list is introduced as examples ("such as when you").
Supporting quotations
3.2. Information You Provide to eCW: eCW collects Personal Information when you use and interact with the Services, such as when you:
3.2.1. Communicate with eCW about our Services whether by letter, e-mail, online chat window, or telephone;
3.2.2. Complete and submit forms to us on our Sites or Provider Portals (e.g., to register for an account on a Provider Portal, authenticate yourself to verify your authorized use of the Services, to register for our events, or to subscribe to our newsletters);
3.2.3. Visit our offices; or
3.2.4. Visit our Sites or interact with us on social media and provide us Personal Information.
Qualifications & exceptions
The channels are introduced by "such as", so the list is illustrative rather than exhaustive.
Not stated here
The policy does not describe retention periods or sensitivity limits for data arriving through each channel in this section.
Data Access & Collection · Context
Usage Data covers logs, cookies, device and connection details about Site use
Usage Data is defined as information eCW automatically collects about use of the Sites through Web server logs, Web beacons, cookies and similar tracking technologies, including how a visitor interacts with the Sites. The definition lists IP address and connection details, browser type and version, operating system and platform, confirmation that an e-mail was opened, purchase history, and the URLs that lead to and around the Site with date and time of access. It notes that Usage Data may overlap Location Information and generally does not directly identify an individual but may be Personal Information in some instances, and that eCW does not deploy non-essential third-party cookies or similar tracking technologies on the Portals.
Supporting quotations
2.1.3. "Usage Data" is information that we automatically collect about your use of the Sites and includes the sort that Web browsers and servers typically make available, through Web server logs, Web beacons, cookies and other similar tracking technologies, about the devices you use to access our Sites, as well as information on how you interact with our Sites. We do not deploy non-essential third-party cookies or similar tracking technologies on the Portals; however, we may collect log information including Usage Data for internal uses or uses by our service providers on our behalf, such as ensuring the security and integrity of our Services. Usage Data may include the IP address of a device or internet service used to connect your device to the Internet and may provide information about your Location; computer and connection information such as your browser type and version; operating system and platform; confirmation when you open e-mail that we send you; purchase history; and the URLs which lead you to and around the Site including the date and time of access. Usage Data may overlap with Location Information. Usage Data generally does not directly identify an individual, but may constitute Personal Information in some instances.
Qualifications & exceptions
Usage Data is described as usually not directly identifying, but as Personal Information in some instances.
The Portals cookie limit covers non-essential third-party cookies and similar tracking technologies, not all collection.
Not stated here
The precise set of tracking technologies deployed on the Sites is described only in general terms here.
Data Access & Collection · Company practice
Automatic Usage Data collection runs subject to device settings and consent
When a reader uses the Services, eCW may automatically collect Usage Data subject to the settings of the device used to access the Services, and with consent may collect device information to facilitate use of certain features. eCW says it may use the data to analyze trends and statistics to improve the online experience or customer service, and that although it does not deploy non-essential third-party cookies on the Portals it may still collect Usage Data for purposes such as ensuring the security and integrity of the Services.
Supporting quotations
3.3. Information that eCW Collects Automatically: When you use the Services, eCW may automatically collect Usage Data subject to the settings of your device that you use to access the Services. With your consent, we may also collect information from your device to facilitate your use of certain features of the Services. eCW may use this data to analyze trends and statistics to improve your online experience or our customer service. We do not deploy non-essential third-party cookies or similar tracking technologies on our Portals but may collect Usage Data for purposes such as ensuring the security and integrity of our Services.
Qualifications & exceptions
Automatic collection is qualified by device settings; additional device collection is qualified by consent.
The Portals limitation is specific to non-essential third-party cookies and does not exclude first-party or security-related collection.
Not stated here
Which features require the consented device collection is not identified.
Data Access & Collection · Company practice
eCW also collects Personal Information from public, commercial and authorized sources
eCW says it may collect Personal Information from the Internet and other publicly available sources and databases, data aggregators, marketing companies and other third parties, including sources the reader authorizes eCW to obtain information from on the reader’s behalf. If a reader later withdraws an authorization, the policy says the reader may need to contact the third-party source directly to stop the transmission, and it gives the example of authorizing eCW to obtain claims information directly from CMS. Readers are referred to the third party’s own privacy policy for how that party collected and used the information.
Supporting quotations
3.4. Information from Other Sources: eCW may collect Personal Information from other sources such as the Internet and other publicly-available sources and databases, data aggregators, marketing companies, and other third parties, including sources from which you authorize us to obtain Personal Information about you on your behalf. If you authorize us to collect information from a third party, or if you authorize a third party to send us information, and you later decide that you no longer want us to obtain that information, you may need to contact the third-party source directly and request that they stop transmitting information to us. For example, if you submit claims to the Centers for Medicare and Medicaid Services ("CMS"), you may decide to authorize us to obtain information directly from CMS. For more information about how those third parties collected and used your Personal Information, please review the privacy policy of the respective third party.
Qualifications & exceptions
Includes sources the reader authorizes, not only unrelated third parties.
Withdrawal of an authorization is handled with the third-party source, not solely through eCW.
Not stated here
The policy does not list which data aggregators or marketing companies supply information.
Data Access & Collection · Restriction or exception
Sites are generally not intended to collect PHI, so Site collection rules do not apply to it
eCW says its Sites are generally not intended to collect or retain PHI, so the policy sections describing Personal Information collection on the Sites do not apply to PHI, and eCW says it does not request, obtain, use or disclose PHI through its Sites.
Supporting quotations
4.1.3. Our Sites are generally not intended to collect or retain any PHI. Thus, sections of this Privacy Policy that discuss Personal Information collection on the Sites do not apply to PHI, and we do not request, obtain, use or disclose any PHI through our Sites
Qualifications & exceptions
Qualified by “generally”, so the exclusion is not framed as absolute.
Not stated here
What happens if PHI reaches the Sites incidentally, for example through a contact form, is not addressed here.
Data Access & Collection · Company practice
Sites use cookies, beacons and log files, but Portals avoid non-essential third-party cookies
eCW says it and its service providers may use cookies, Web beacons, log files and other technologies, collectively called Data Collection Technologies, to help provide, customize and improve the Sites, and it lists the technologies it uses on the Sites. In the same paragraph it states that it does not deploy non-essential third-party cookies or similar tracking technologies on its Portals.
Supporting quotations
6.1. We and our service providers may use cookies, Web beacons, log files, and other technologies (collectively, "Data Collection Technologies") to help us provide, customize, and improve the Sites. We do not deploy non-essential third-party cookies or similar tracking technologies on our Portals. The Data Collection Technologies we use on our Sites include:
Qualifications & exceptions
Collection by service providers as well as by eCW is contemplated.
The Portals limitation covers non-essential third-party cookies and similar tracking technologies, not all collection.
Not stated here
The policy does not identify which service providers deploy these technologies.
Data Access & Collection · Company practice
Web beacons in Sites and e-mails can record clickstream data
A Web Beacon is described as a Web page element, such as a clear gif, pixel tag or single-pixel gif, that may be embedded in the Sites or in e-mail communications and may employ cookie technology to enable eCW to record clickstream data. The description confirms that tracking extends to e-mail communications and not only to pages on the Sites.
Supporting quotations
6.1.1. Web Beacons: A Web Beacon is a Web page element (such as a clear gif, pixel tag or single-pixel gif) that may be embedded into our Sites or e-mail communications, and which may employ cookie technology to enable eCW to record clickstream data
Qualifications & exceptions
Described in permissive terms (“may be embedded”, “may employ”).
Not stated here
The policy does not say which e-mails carry beacons or what is recorded about recipients.
Data Access & Collection · Context
Cookies collect clickstream and traffic data, and browsers can reject them
Cookies are described as small text files placed on a device to store data that a Web server in the domain that placed the cookie can recall, enabling eCW to collect clickstream data including traffic on the Sites. Readers can set their browser to reject certain cookies or to notify them when a cookie is sent, though rejecting cookies may limit Site functionality, and third-party software exists that allows visiting the Sites without providing certain types of this information.
Supporting quotations
6.1.2. Cookies: Cookies are small text files placed on your device to store data that can be recalled by a Web server in the domain that placed the cookie. Cookies enable eCW to collect clickstream data, including traffic on the Sites. You may set your browser to reject certain cookies or to notify you when you are sent a cookie. Rejecting cookies may limit functionality of the Sites. Third parties also provide software that allows you to visit the Sites without providing certain types of this information. Our Sites may use the following types of cookies:
Qualifications & exceptions
Browser rejection is offered as a control, subject to reduced functionality.
The paragraph notes third-party software that suppresses some information collection without naming it.
Not stated here
The policy does not state how cookie choices interact with the cookie banner described for advertising cookies.
Data Access & Collection · Company practice
Essential cookies cannot be switched off and support logins and forms
Essential or strictly necessary cookies are described as necessary for the Sites to function and as not switchable off in eCW systems. They are usually set in response to actions that amount to a request for services, such as setting privacy preferences, logging in or filling in forms, and blocking them in the browser can prevent parts of the Sites from working.
Supporting quotations
6.1.2.1. Essential/Strictly Necessary Cookies: These cookies are necessary for the Sites to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Sites will not then work.
Qualifications & exceptions
The category is presented as exempt from the switch-off mechanism, with browser blocking as the only lever.
Data Access & Collection · Company practice
Analytics cookies measure visits, traffic sources and page popularity
Analytics or performance cookies are described as allowing eCW to count visits and traffic sources so that it can measure and improve Site performance, showing which pages are most and least popular and how visitors move around the Sites.
Supporting quotations
6.1.2.2. Analytics/Performance Cookies: These cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our Sites. They help us know which pages are the most and least popular and see how visitors move around the Sites.
Not stated here
The paragraph does not say whether these cookies are first-party or third-party, or how long they persist.
Data Access & Collection · Company practice
Advertising partners may set targeting cookies where a cookie banner is shown
Targeting or advertising cookies may be set by eCW’s advertising partners at Sites where a cookie banner is displayed, and those partners may use them to build a profile of the reader’s interests and show relevant adverts on other websites. Readers may disallow them using the cookie banner, and California residents and residents of states with consumer privacy protection laws may also opt out of certain sharing of information through these cookies by using the “Your Privacy Choices” section, as described in Section 18.5.1. Disallowing them results in less targeted advertising.
Supporting quotations
6.1.2.3. Targeting/Advertising Cookies: These types of cookies may be set by our advertising partners at Sites at which a cookie banner is displayed. These cookies may be used by those advertising partners to build a profile of your interests and to show you relevant adverts on other websites. You may disallow these targeting/advertising cookies using the cookie banner. California residents and residents of states with consumer privacy protection laws may also opt-out of certain sharing of information through these cookies including by visiting the "Your Privacy Choices" section of our website and following the instructions there, as described further in Section 18.5.1. If you do not allow these cookies, you will experience less targeted advertising.
Qualifications & exceptions
Third-party setting is conditioned on a cookie banner being displayed at the Site.
Refusing these cookies reduces targeting rather than removing advertising.
Not stated here
Which advertising partners set these cookies is not identified in this section.
Data Access & Collection · Company practice
Third-party analytics services such as Google Analytics analyze Site usage
eCW may use third-party Web analytics services, giving Google Analytics as an example, and other technologies on the Sites to collect and analyze usage information through cookies and similar tools, to conduct auditing, research or reporting, and to provide certain features. It points readers to the Google Analytics Opt-out Browser Add-on as a way to prevent that use of their information for analytics.
Supporting quotations
We may use third-party Web analytics services (such as those of Google Analytics) and other technologies on our Sites to: collect and analyze usage information through cookies and similar tools; engage in activities such as auditing, research, or reporting; and provide certain features to you.
Qualifications & exceptions
The named provider is an example; other analytics services may be used under the same description.
Not stated here
The policy does not describe what is done with analytics output beyond auditing, research and reporting.
Data Access & Collection · Company practice
eCW honours Global Privacy Control but does not recognize Do Not Track signals
The policy describes Do Not Track as a browser privacy preference, says eCW provides a variety of opt-out mechanisms and recognizes Global Privacy Control through its vendor OneTrust, and states that it does not currently use technology that specifically recognizes DNT signals from a Web browser.
Supporting quotations
Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above and recognize "Global Privacy Control" through our vendor, OneTrust. However, we do not currently use technology that specifically recognizes DNT signals from your Web browser.
Qualifications & exceptions
The DNT statement is present-tense and limited to current technology.
Global Privacy Control recognition runs through the named vendor OneTrust.
Not stated here
Which opt-out mechanisms make up the “variety” referred to is not enumerated in this paragraph.
Data Access & Collection · Context
Sensitive Personal Information covers government ID, financial, demographic and status data
The policy defines Sensitive Personal Information as Personal Information regarding more sensitive areas, giving government ID and certain other financial information, gender, marriage status, race or ethnicity, and veteran or disability status as examples.
Supporting quotations
refers to Personal Information regarding more sensitive areas, such as government ID and certain other financial information, gender, marriage status, race/ethnicity, or veteran or disability status.
Qualifications & exceptions
The list is introduced by “such as”, so the categories are examples.
Not stated here
The definition does not say whether it matches any particular statute’s sensitive-data category.
Data Access & Collection · Company practice
Biometric data such as fingerprints or facial scans may be collected to verify identity
In connection with the Services, eCW may collect or store biometric data such as fingerprints or facial geometry scans that may identify the reader, used for authentication and verification of identity, and it notes that this information may be biometric data under laws governing its collection, use, storage and disclosure. eCW says that by providing the information the reader acknowledges having been advised of and understanding that eCW and its agents and contractors may collect, use, store and disclose biometric data for the purposes described in the policy or otherwise described in the Services.
Supporting quotations
In connection with the Services, eCW may collect or store biometric data, such as fingerprints or facial geometry scans that may identify you, which are used for authentication and verification of your identity. This information may be biometric data under certain laws governing the collection, use, storage, and disclosure of biometric data. By providing such information, you acknowledge that you have been advised of, and understand that, eCW, and its agents and contractors, may collect, use, store, and disclose biometric data for the purposes described in this Privacy Policy, or as otherwise described in the Services.
Qualifications & exceptions
Consent is expressed through providing the information and the accompanying acknowledgement rather than a separate signature in this text.
Agents and contractors are included in the permitted handling.
Not stated here
Which specific Services use biometric data is not identified.
Data Access & Collection · Restriction or exception
Sites are not directed at under-18s and eCW does not knowingly collect their data
eCW says the Sites are not directed toward individuals under the age of 18, that it does not promote the Sites to them, and that it does not knowingly collect Personal Information through the Sites from individuals under 18. Access to the Portals is said to be governed separately by the Portals’ posted Terms of Use.
Supporting quotations
Our Sites are not directed toward individuals under the age of 18. We do not promote our Sites to individuals under 18, and we do not knowingly collect any Personal Information through our Sites from individuals under 18. Access to our Portals is separately governed by the Portals' posted Terms of Use.
Qualifications & exceptions
The threshold is 18 rather than the 13 used in some children’s privacy regimes.
The limitation is stated for Personal Information collected through the Sites.
Not stated here
What eCW does if it learns it has collected data from a person under 18 is not stated here.
Data Access & Collection · Context
CCPA/CPRA Personal Information covers data linked to a consumer or household
CCPA/CPRA Personal Information is defined as information eCW collects through a user’s interactions with the Services 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.
Supporting quotations
Through a user's interactions with our Services, eCW collects 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 ("CCPA/CPRA Personal Information"). CCPA/CPRA Personal Information does not include:
Qualifications & exceptions
The definition extends to household-level linkage, not only individuals.
Collection is described as occurring through interactions with the Services.
Data Access & Collection · Company practice
Identifiers collected include names, government IDs, contact details and provider identifiers
The categories table lists identifiers with examples including a real name, alias, postal address, unique personal identifiers, Internet Protocol address, e-mail address, account name, Social Security number, driver’s license or state identification number, passport number, telephone and fax numbers, username, National Provider Identifier and APU ID, or other similar identifiers.
Supporting quotations
Identifiers A real name, alias, postal address, unique personal identifiers, Internet Protocol address, e-mail address, account name, Social Security number, driver's license or state identification number, passport number, telephone number, fax number, username, National Provider Identifier (NPI), APU ID, or other similar identifiers
Qualifications & exceptions
The listed items are examples of the category.
Data Access & Collection · Company practice
The California customer-records category covers financial, medical and insurance data
The table lists the personal information categories in the California Customer Records statute, with examples including name, signature, Social Security number, physical characteristics or description, address, telephone and passport numbers, driver’s license or state identification card number, insurance policy number, education, employment and employment history, bank, credit card and debit card numbers, other financial information, medical information and health insurance information. The notice adds that items in this category may overlap with other categories.
Supporting quotations
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Note that some CCPA/CPRA Personal Information included in this category may overlap with other categories.
Qualifications & exceptions
Includes medical information and health insurance information as examples within this category.
Overlap with other table categories is acknowledged.
Data Access & Collection · Company practice
Biometric collection is tied to biometric authentication integration in the Services
For biometric information the table says that if the reader has a biometric authentication integration as part of eCW’s Services, eCW may collect information concerning fingerprints, faceprints, voiceprints and iris or retina scans. The collection is conditioned on that integration being part of the Services.
Supporting quotations
Biometric information If you have biometric authentication integration as part of eCW's Services, then we may collect information concerning your fingerprints, faceprints, voiceprints, and iris or retina scans.
Qualifications & exceptions
Conditioned on the reader having a biometric authentication integration as part of the Services.
Biological identifiers listed are fingerprints, faceprints, voiceprints and iris or retina scans.
Data Access & Collection · Company practice
Internet activity covers browsing, search, page views and conversions
The Internet or other similar network activity category lists browsing history, search history, information on a consumer’s interaction with a website, application or advertisement, page views, first and recent conversion, domain name and hosting space.
Supporting quotations
Internet or other similar network activity Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement, page views, first and recent conversion, domain name, and hosting space
Not stated here
The entry does not say which of these fields are collected on the Sites as opposed to customer applications.
Data Access & Collection · Company practice
Geolocation data comes from conference events, applications and IP-based location
Geolocation data is described as gathered from attendees at eCW conference events and from users of its applications, including the conference event application, and as derived from IP address where associated with a geographic location.
Supporting quotations
Geolocation data Geolocation data from attendees at our conference events, users of our applications, including conference event application, and based on IP address, where associated with a geographic location
Qualifications & exceptions
IP-derived location is included where it is associated with a geographic location.
Data Access & Collection · Company practice
Audio, visual and similar data include call recordings, photos and videos
The audio, electronic, visual, thermal, olfactory or similar information category is illustrated with call recordings, photographs such as those from practices or depicting providers or staff, videos from practices, and photos and videos relating to marketing.
Supporting quotations
Audio, electronic, visual, thermal, olfactory, or similar information Call recordings, photographs such as from practices or depicting providers or staff, videos from practices, photos and videos relating to marketing
Qualifications & exceptions
Illustrated by examples rather than a closed list.
Data Access & Collection · Company practice
Professional and employment data include role, job history and practice details
Professional or employment-related information is described as current or past job-related information including role, job history and performance evaluation data, information related to a particular company or practice, and NPI.
Supporting quotations
Professional or employment-related information Current or past job-related information, including role, job history, and performance evaluation data; information related to a particular company or practice; NPI
Qualifications & exceptions
Performance evaluation data appears in this category.
Data Access & Collection · Company practice
Education information covers credentials, institution and graduation year
Education information is described as education credentials, the school or university attended, and year of graduation.
Supporting quotations
Education information Education credentials; school or university attended; year of graduation
Data Access & Collection · Company practice
Inferences include profiles of preferences, behaviour and abilities
The table lists inferences drawn from the other categories to create a profile about a consumer reflecting preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities and aptitudes, with the examples repeating that profile description.
Supporting quotations
Inferences drawn from any of the information identified in this table to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Qualifications & exceptions
The category is expressly built on the other listed categories.
Data Access & Collection · Context
Sensitive personal information in the table is limited to licence numbers and passwords
The sensitive personal information row lists a driver’s license or state identification number and account passwords. The examples given are narrower than the main policy’s description of Sensitive Personal Information, which also refers to gender, marriage status, race or ethnicity and veteran or disability status.
Supporting quotations
Sensitive personal information Driver's license or state identification number; account passwords
Qualifications & exceptions
The row gives two examples rather than a full statutory enumeration.
Not stated here
Why the table’s examples differ from the policy definition is not explained.
Data Access & Collection · Company practice
Other collected information includes event, customer, testimonial and policy-described data
The table closes with an other category covering information the reader provides about attending an eCW event, customer information regarding products and services, testimonials, and other information as described in the privacy policy.
Supporting quotations
Other Information you provide us regarding your attending an eCW event; customer information regarding products and services; testimonials; other information as described in this Privacy Policy.
Qualifications & exceptions
The final element is a catch-all referring back to the privacy policy.
Data Access & Collection · Company practice
California sources include information given directly and collected automatically
The notice lists the categories of sources from which CCPA/CPRA Personal Information is collected, beginning with information provided directly by the reader and information collected indirectly, which it describes as including information collected in the course of delivering services and information collected automatically through use of its website or other services.
Supporting quotations
Directly from you
Indirectly from you, which includes information collected in course of delivering services and information collected automatically through use of our website or other services
Qualifications & exceptions
Indirect collection expressly includes data gathered while delivering services, not only website tracking.
Data Access & Collection · Company practice
Sources also include integrations, providers, payors, authorities and purchased data
Further listed sources are third-party applications integrated with eCW’s CRM software, other third parties that interact with eCW in connection with the services it performs, medical providers, third-party payors and government authorities, data brokers or resellers from which eCW purchases data to supplement the information it collects, employees and prospective employees, and other vendors or suppliers.
Supporting quotations
Third-party applications integrated with our CRM software
Other third parties that interact with us in connection with the services we perform
Medical providers, third-party payors, and government authorities
Data brokers or resellers from which we purchase data to supplement the information we collect
Employees and prospective employees
Other vendors/suppliers
Qualifications & exceptions
Includes data purchased from brokers or resellers to supplement collected information.
Employees and prospective employees appear as a source category.
Not stated here
The notice does not identify which brokers or providers supply data.
Data Access & Collection · Company practice
The notice at collection covers online interactions including email, chat and portals
The notice says the CCPA/CPRA requires disclosures at or before collection of CCPA/CPRA Personal Information from California residents, and that the following notice at collection for online sources explains how eCW collects and uses, sells or shares and retains that information in the online context. The online context is described as interacting with the Services online, including communicating by e-mail or online chat window, completing or submitting forms on the Sites or Provider Portals, visiting the Sites, or interacting on social media.
Supporting quotations
The CCPA/CPRA requires us to provide certain disclosures at or before our collection of CCPA/CPRA Personal Information from California residents. The below CCPA/CPRA Notice at Collection for Online Sources provides you with information about how we collect and use, sell or share and retain your CCPA/CPRA Personal Information in the online context. When you use or interact with our Services online, including when you communicate with eCW by e-mail or online chat window, complete or submit forms to us on our Sites or Provider Portals, or when you visit our Sites or interact with us on social media, we may collect and use the following categories of information.
Qualifications & exceptions
The notice-at-collection scope is limited to the online context.
Channels named include e-mail, chat windows, Site and Provider Portal forms, and social media.
Not stated here
The notice does not state how offline collection is disclosed.
Data Access & Collection · Company practice
Identifiers are collected for marketing, accounts, diligence, research and service
The identifiers row of the notice-at-collection table lists as purposes for collection and use marketing and communicating about eCW’s products, services, events and other offerings, administering user accounts, conducting diligence regarding vendors and partners and administering those relationships, conducting research and analysis, providing, supporting, personalizing and developing offerings, and providing service to eCW’s customers including Providers.
Supporting quotations
Administer user accounts
Conduct diligence regarding our vendors and partners and administer vendor/partner relationships
Conduct research and analysis
Provide, support, personalize, and develop our products, services, events, and other offerings
Provide service to our customers, which include Providers
Qualifications & exceptions
Vendor and partner diligence appears as a purpose for ordinary identifiers.
Data Access & Collection · Company practice
Customer-record data is collected for marketing, accounts, diligence, service and billing
The California customer-records row lists marketing and communications, administering user accounts, vendor and partner diligence, providing, supporting, personalizing and developing offerings, providing service to customers including Providers, and processing payments, administering fees, invoicing and resolving billing issues.
Supporting quotations
Administer user accounts
Conduct diligence regarding our vendors and partners and administer vendor/partner relationships
Provide, support, personalize, and develop our products, services, events, and other offerings
Provide service to our customers, which include Providers
Process payments, administer fees, provide users with invoices, or resolve billing issues
Qualifications & exceptions
Adds payment and billing purposes that the identifiers row does not list.
Data Access & Collection · Company practice
Internet activity is collected for marketing and for research and analysis
The internet or other similar network activity row lists two purposes, marketing and communicating about eCW’s products, services, events and other offerings and conducting research and analysis.
Supporting quotations
Conduct research and analysis
Internet or other similar network activity Market and communicate about our products, services, events, and other offerings Yes, to Market and communicate about our products, services, events, and other offerings. As necessary to fulfill the specified purposes for collection and use (or a reasonable time thereafter) or other compatible purposes including satisfying legal requirements.
Qualifications & exceptions
This row lists fewer purposes than the identifiers and customer-records rows.
Data Access & Collection · Company practice
Professional and employment data is collected for accounts, diligence, service and billing
The professional or employment-related information row lists administering user accounts, vendor and partner diligence, providing, supporting, personalizing and developing offerings, providing service to customers including Providers, processing payments and billing, and marketing and communications.
Supporting quotations
Conduct diligence regarding our vendors and partners and administer vendor/partner relationships
Provide, support, personalize, and develop our products, services, events, and other offerings
Provide service to our customers, which include Providers
Process payments, administer fees, provide users with invoices, or resolve billing issues
Market and communicate about our products, services, events, and other offering
Professional or employment-related information Administer user accounts Yes, to Market and communicate about our products, services, events, and other offerings. As necessary to fulfill the specified purposes for collection and use (or a reasonable time thereafter) or other compatible purposes including satisfying legal requirements.
Qualifications & exceptions
The row’s purpose list includes account administration and billing alongside marketing.
Data Access & Collection · Company practice
Sensitive information collected online is limited to passwords and identification numbers
The notice says eCW may collect sensitive personal information from certain online sources, including password information gathered in the course of users accessing its registration system and driver’s licence and state identification numbers in some instances. The sentence is framed as “may collect” and names only these two examples.
Supporting quotations
eCW may collect sensitive personal information from certain online sources, including password information in the course of users accessing our registration system, and driver's license and state identification numbers in some instances.
Qualifications & exceptions
Collection is framed as possible rather than certain.
Identification numbers are qualified by “in some instances”.
Not stated here
The notice does not enumerate all sensitive personal information collected online.
Data Access & Collection · Permission or license
Visitors outside the United States must comply locally and consent to transfer
The notice says visitors who use the Site and reside outside the United States do so on their own initiative and are responsible for compliance with local law where it applies, and that by using the Site a non-US resident consents to the transfer and use of their information outside their country.
Supporting quotations
Visitors who use this Site and reside outside the United States do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. If you reside outside of the United States, by using our Site, you consent to the transfer and use of your information outside your country.
Qualifications & exceptions
The consent is framed as arising from use of the Site.
Local-law compliance is placed on the visitor.
Not stated here
The notice does not describe transfer safeguards or destinations.