Privacy Policy

We take your privacy seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use, and are responsible for certain limited personal information about you. When we do so we are subject to various laws in the United States, and we are responsible as a controller of that personal information for the purposes of those laws.

1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:

We, us, our: Community Health Design Corps, LLC

Our representative and data protection officer Margaret Allard: maggie@chdesigncorps. com

Personal information: Any information relating to an identified or identifiable individual

Special category personal information: Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership

Genetic and biometric data

Data concerning health, sex life, or sexual orientation

2. Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person, consumer, or household:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)	Name, employer or affiliated organization, position/title and email address.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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.	Name Credit card information will be processed by a third party. Please see the Terms and Conditions page on their website.
Characteristics of protected classifications under California or federal law.	No information collected.
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)	No information collected.
Biometric information	No information collected.
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)	No information collected.
Geolocation data	Geolocation data may be collected
Audio, electronic, visual, thermal, olfactory, or similar information	No information collected.
Professional or employment-related information	Employer or affiliated organization, email address.
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)	No information collected.
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	No information collected.

This personal information is required to provide services and information to our customers and website visitors. If you do not provide personal information we ask for, it may delay or prevent us from providing services and information to you.

3. How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text, or email and via our website. However, we may also collect information:

▪ From publicly accessible sources (e.g., property records);

▪ Directly from a third party (e.g., screening providers or customer due diligence providers);

▪ From a third party with your consent (e.g., your bank);

▪ From cookies on our website; and

▪ Via our IT systems, including:

▪ Automated monitoring of our websites and other technical systems, such as our computer networks and connections and access control systems, communications systems, email, and instant messaging systems.

4. How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:

▪ To comply with our legal and regulatory obligations;

▪ For the performance of our contract with you or to take steps at your request before entering into a contract;

▪ For our legitimate interests or those of a third party; or

▪ Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide services and information to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or Community Health Design Corps, LLC	For our legitimate interests or those of a third party, i. e. , to minimize fraud that could be damaging for us and for you
Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our regulators	For our legitimate interests or those of a third party
Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies	For our legitimate interests or those of a third party
Ensuring business policies are adhered to, e.g., policies covering security and internet use	For our legitimate interests or those of a third party, i. e. , to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i. e. , to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i. e. , to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range, or other efficiency measures	For our legitimate interests or those of a third party, i. e. , to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i. e. , to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to: – existing and former customers; – third parties who have previously expressed an interest in our services; – third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i. e. , to promote our business to existing and former customers
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i. e. , to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

The above table does not apply to special category personal information, which we will only process with your explicit consent.

5. Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone, or mail) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell it to other organizations outside the Community Health Design Corps, LLC group for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

▪ Contacting us at info@chdesigncorps. com for marketing opt-out; or

▪ Using the “unsubscribe” link in emails or “STOP” number in texts. ▪ Our affiliates, including companies within the Community Health Design Corps, LLC group;

▪ Service providers we use to help deliver our services to you, such as payment service providers, warehouses and delivery companies;

▪ Other third parties we use to help us run our business, such as marketing agencies or website hosts;

▪ Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;

▪ Credit reporting agencies;

▪ Our insurers and brokers; and

▪ Our banks.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. Who We Share Your Personal Information With. We routinely share personal information with:

We seek service providers who take appropriate measures to securely handle your personal information. We also seek service providers who ensure they use your personal information to provide services to us and to you. Nonetheless, we cannot impose restrictions if you agree to permit third parties to use your personal information per their own terms and agreements including the security and scope of use of your data. We may also share personal

information with external auditors, e.g., in relation to accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

8. Where Your Personal Information is Held. Information may be held at our offices and those of third-party agencies, service providers, representatives, and agents as described above (see above: “Who We Share Your Personal Information with”).

10. Your Rights Under the CCPA. You may have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: • The categories of personal information we have collected about you; • The categories of sources from which the personal information is collected; • Our business or commercial purpose for collecting personal information; • The categories of third parties with whom we share personal information, if any; and • The specific pieces of personal information we have collected about you. Please note that we are not required to: • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or • Provide the personal information to you more than twice in a 12-month period.
Personal Information Used for a Business Purpose	In connection with any personal information we may disclose to a third party for a business purpose, you have the right to know: • The categories of personal information that we disclosed about you for a business purpose.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: • Delete your personal information from our records; and Please note that we may not delete your personal information if it is necessary to: • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; • Debug to identify and repair errors that impair existing intended functionality; • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; • Comply with the California Electronic Communications Privacy Act; • 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; • Comply with an existing legal obligation; or • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: • Deny goods or services to you; • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; • Provide a different level or quality of goods or services to you; or • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information. ▪ Enough information to identify you (e.g., your full name, address, and a customer or matter reference number if applicable); ▪ Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and ▪ A description of what right you want to exercise and the information to which your request relates.

11. Keeping Your Personal Information Secure. We or our service providers have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. When we become aware, we will investigate any suspected security breach and take measures to mitigate a data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

12. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please call, email, or write us at the contact information below.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period. If you choose to contact directly, you will need to provide us with:

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf. Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

13. Changes to This Privacy Notice. This privacy notice was published on March 5, 2022, and last updated on March 1,

2022. We may change this privacy notice from time to time–when we do, we will inform you via our website and via email if we maintain your email address in our newsletter database.

14. How to Contact Us. Please contact us by mail, email, or phone if you have any questions about this privacy policy or the information we hold about you.

Our contact details

Community Health Design Corps, LLC

info@chdesigncorps. com

15. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, or braille) please contact us using the contact information above.