CentraCare Wayfinding Privacy Notice

Effective Date: February 9, 2023

CentraCare (“we” or “us”) is committed to protecting the privacy of all individuals (“you” or “your”) who utilize our App (as defined in the End User License Agreement ). Please read the following statement to understand how we collect, use, and safeguard the information you may provide to us via the App.

1. What Information Does CentraCare Collect from You?

CentraCare may collect certain information related to your use of the App. We collect personal information and non-personal information. When we use the term “personal information” in this Privacy Notice, we mean information about you that is personally identifiable to you. We collect the following personal information from you:

Your precise geolocation within CentraCare’s facilities.

As stated above, we also collect information that does not identify you (“non-personal information”). Personal information and non-personal information may be collectively referred to as “information” throughout this Privacy Notice. The information we collect is limited to technical information. When you access the App from a mobile device, we may collect non-personal information from your use of the mobile device, including:

The date and time you started and stopped using the App;
The route taken while using the App;
Your mobile device manufacturer, model, and operating system and version;
Any errors detected while using the App;
Any wi-fi signal observed (if using an Android device); and
The version of the App and map you are using;

In order to collect some of the above information, we, or our service providers (such as Purple Wifi), utilize certain indicators in order to provide functionality in the App. These indicators include your BLE (Bluetooth Low Energy) beacon strength, surrounding WiFi networks (Android Only), and motion/orientation sensors. The processing of information from these indicators takes place on your device, and this information does not leave your device.

2. How is Your Information Used?

We collect, retain, and use your personal information for the following purposes:

To provide you the Services and products you requested;
To operate and improve the App;
To respond to an inquiry from you;
To create aggregated, non-personal information, or to create de-identified information;
To comply with applicable laws, regulations or legal process;
To comply with requests of relevant regulatory and law enforcement and/or other governmental agencies or authorities; and
To enforce our End User License Agreement; and/or to protect the rights, property, or safety of CentraCare and other users of the App.

We may use any non-personal information for any purposes as appropriate and subject to applicable law, since non-personal information cannot identify you as an individual. For example, we may use non-personal information collected to monitor visitor traffic patterns and App usage and to improve our App. We may also use non-personal information in the aggregate to create summary statistics that help us analyze App usage trends, determine technical design specifications, arrange our App in a user-friendly way, and identify system performance or problem areas. We also use non-personal information to protect the security and integrity of the App.

3. When Do We Share Your Information?

We share your information in the following circumstances:

Service Providers. We may share your information with affiliated and unaffiliated companies (such as Purple Wifi) that perform tasks on our behalf related to our business. Such tasks include analyzing usage data, fixing errors in the App, and protecting the security and integrity of the App. Third-party service providers receive your information as necessary to perform their role, and we instruct them not to use your information for any other purposes.
As Required by Law. We will disclose your information as necessary or appropriate, including as required by law, regulation, subpoena, court order, legal process or government request; to enforce our End User License Agreement , including investigations of potential violations thereof; to detect, prevent or otherwise address fraud, security or technical issues; when we believe in good faith that disclosure is necessary to protect your safety or the safety of others; to protect our rights, to investigate fraud, or to respond to a government request.
Business Transfers. CentraCare may, in the future, sell or otherwise transfer some or all of its assets to a third party. The information we obtain from you via the App may be disclosed to any potential or actual third-party purchasers of such assets and/or may be among those assets transferred in accordance with applicable law.

4. Your Privacy Choices

Depending on where you live, you may have the following rights with respect to your personal information, to the extent applicable to the App:

Access
Data portability
Erasure
Correction
Opt out of sales of personal information

For a description of these rights, please see the applicable chart in Section 10 of this Privacy Notice. In addition, you may have the right to opt out of targeted advertising and profiling, to the extent that profiling makes decisions that produce legal or similarly significant effects concerning you. To exercise any of these rights available to you, see Section 12 below.

5. Children

The App does not permit children under 13 to become users, and we do not collect information from children. By using the App, you represent that you are not under the age of 13. Any information we receive from users we believe to be under the age of 13 will be purged from our database.

6. Third Party Websites

CentraCare may reference or provide links to third party websites or CentraCare’s other websites. You should review the privacy notices posted on such sites, as those privacy notices will control once you are directed to those websites. Please be aware that CentraCare does not control, nor are we responsible for, the privacy notices or information practices of third parties or their websites.

7. Retention

We have policies and procedures relating to the retention of personal information based upon a classification scheme consisting of business functions and process areas, and the classification and types of data and records. We retain personal information for as long as we reasonably require it for business and legal purposes. In determining data retention periods, we consider contractual and legal obligations, and the expectations and requirements of customers, vendors, suppliers and others who disclose their personal information with us. When we no longer need personal information, we securely delete or destroy it.

8. Security

CentraCare and its service providers employ security systems to protect the information we receive from you from unauthorized disclosure. We make commercially reasonable efforts to keep your information secure using appropriate technical, physical and organizational measures to prevent against unlawful use, alteration, unauthorized access accidental destruction and loss. No transmission of data over the internet is guaranteed to be completely secure. Due to the nature of the internet, we cannot guarantee that information, during transmission through the internet or while stored on its system or otherwise in its care, will be absolutely safe from intrusion by others, such as hackers. Because security is important to both CentraCare and you, we will always make reasonable efforts to ensure the security of our systems.

9. Updates

We may update this Privacy Notice from time to time to reflect changes to our information practices. We will provide you with advance notice of a major change prior to your access of any portion of the App. For example, we may (i) require that you re-accept the updated version of this Privacy Notice, (ii) send you an electronic notification advising of the update to this Privacy Notice, or (iii) include a notice on our App. We do not ordinarily provide advance notice of a minor change.

We encourage you to periodically review this page for the latest information on our privacy practices. You can tell when changes have been made to the Privacy Notice by referring to the “Effective Date” legend on top of this page.

10. California Residents

This section supplements the information above and applies solely to California residents whose personal information is subject to California Consumer Privacy Act, as amended by the California Privacy Rights Act and its regulations (“CCPA”).

During the last twelve (12) months, CentraCare collected the following categories of personal information from California consumers:

Geolocation data; and
Sensitive personal information, including precise geolocation.
CentraCare collects the categories of personal information listed above from the following categories of sources:
Directly from you; and
Our service providers.

CentraCare collects the categories of personal information listed above for the following business and/or commercial purposes:

Providing the requested services, such as operating our App or responding to inquiries;
Enhancing your user experience;
Monitoring and maintaining the security and functionality of the App; and
For compliance and legal obligations, and to exercise our legal rights.

During the last 12 months, CentraCare has disclosed personal information in accordance with the below chart:

Categories of Personal Information We Collect	Categories of Third Parties to Which We Disclose Personal Information for a Business or Commercial Purpose	Categories of Third Parties to Which We May Sell or Share Personal Information
Geolocation data	Service providers	We do not sell or share personal information.
Sensitive personal information, including precise geolocation	Service providers	We do not sell or share personal information.

Please see Section 7 with regard to our data retention practices.

We will not collect additional categories of personal information or use the personal information collected for materially different, unrelated, or incompatible purposes without providing notice to the California consumer, unless required or permitted by applicable laws.

We also do not knowingly sell or share personal information of consumers under the age of 16.

Subject to certain exceptions, if you are a resident of California, you may have the following rights:

Privacy Right	Description
Notice	The right to be notified of what categories of personal information will be collected at or before the point of collection and the purposes for which they will be used and shared.
Access	The right to request the categories of personal information that we collected in the previous twelve (12) months, the categories of sources from which the personal information was collected, the specific pieces of personal information we have collected about you, and the business purposes for which such personal information is collected and shared. You may also have the right to request the categories of personal information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your personal information.
Data Portability	The right to receive the personal information you have previously provided to us.
Erasure	The right to have your personal information deleted. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required or permitted to retain your personal information for one or more of the following categories of purposes: (1) to complete a transaction for which the personal information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); or (4) to otherwise use your personal information internally, in a lawful manner that is compatible with the context in which you provided it.
Correction	You have the right to request that we correct any incorrect personal information that we collect or retain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see below), we will correct (and direct any of our service providers that hold your data on our behalf to correct) your personal information from our records, unless an exception applies. We may deny your correction request if (a) we believe the personal information we maintain about you is accurate; (b) correcting the information would be impossible or involve disproportionate; or (c) if the request conflicts with our legal obligations.
Automated Decision Making	You have the right to request information about the logic involved in automated decision-making and a description of the likely outcome of processes, and the right to opt out. CentraCare does not currently engage in any automated decision-making practices.
To Opt Out of Sales or Sharing of Personal Information	CentraCare does not sell or share your personal information. If we did, you would have the right to opt-out of the sale and sharing of your personal information. When you opt-out of sales, we will not share your personal information with our advertising vendors or marketing partners. However, for personal information already shared, you will need to submit your access, deletion, and opt-out requests to each partner individually. When you opt out of sharing, we will not share your personal information with third parties for purposes of cross-context behavioral advertising.
Limit Use of Sensitive Personal Information	CentraCare does not use or disclose sensitive personal information other than to provide our services to you. However, if we used or disclosed sensitive personal information for other purposes, you would have the right to opt out.

Only you or a person who is authorized to act on your behalf (“Authorized Agent”) may make a request related to your personal information. Requests may also be made on behalf of a minor child. Requests must:

Provide sufficient information that allows CentraCare to reasonably verify the requestor is the person about whom the Personal Information is collected or an Authorized Agent and
Describe the request with sufficient detail that allows CentraCare to properly understand, evaluate, and respond to it.

You, or your Authorized Agent, may submit requests to CentraCare by sending an email to CentraCare at CCISServiceDesk@CentraCare.com.

CentraCare cannot respond to requests or provide personal information if it is unable to verify a requestor’s identity or authority to make the request and confirm the personal information relates to the requestor. Making a request does not require you to create an account with CentraCare. Personal information provided for identity verification for such requests will only be used to verify your identity or authority to make the request.

Identity Verification Requirements. In order to verify your identity, you may need to submit certain information. CentraCare will match this information against information CentraCare has previously collected about you to verify your identity. If an Authorized Agent is being utilized for a request, CentraCare will require proof of the Authorized Agent’s authority. If we are unable to verify your identity, your request may be denied.

Depending on the nature of the personal information which is the subject of your request, our verification process may include using existing authentication practices or matching two or three additional data points, and may also include submitting a declaration.

Non-Discrimination. CentraCare will not discriminate against you for exercising any rights under applicable privacy law.

Appeals. If you are not satisfied with the resolution of your request and would like to submit an appeal, please submit your appeal using the information provided above.

11. Users from Outside the United States

Our App is hosted in the United States and are governed by United States law. If you are using the App from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our (or our service provider’s) servers are located. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the App, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Notice.

12. Questions Regarding This Privacy Notice

Questions regarding this Privacy Notice should be directed to CentraCare at privacyline@CentraCare.com.

CentraCare may also be contacted directly at the following address and phone number:

CentraCare
Attn: Privacy Officer
1406 Sixth Avenue North
St. Cloud, MN 56303

Email: privacyline@CentraCare.com
Phone: 800-835-6652 or 320-251-2700, ext. 53046