PawsitiveHealth Pet Insurance Services, LLC’s Privacy Policy for

California Residents
Effective Date: 12/12/24
Last Modified: 12/12/24
This Privacy Policy for California Residents supplements the information contained in PawsitiveHealth Pet Insurance Services, LLC’s General Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

Information We Collect
For the purposes of this Policy, the term “Website” shall be defined as the web address [“Root
URL”] and shall include all pages, subpages, subdomains, directories, and any other content
accessible through the URL.
Our Website collects information that identifies, relates to, describes, references, is reasonably
capable of being associated with, or could reasonably be linked, directly or indirectly, with a
particular consumer, household, or device (“Personal Information”). Personal Information does
not include:
● Publicly available information from government records.
● Deidentified or aggregated consumer information.
● Information excluded from the CCPA’s scope, like:
○ health or medical information covered by the Health Insurance Portability and
Accountability Act of 1996 (HIPAA) and the California Confidentiality of
Medical Information Act (CMIA), clinical trial data, or other qualifying research
data;
○ personal information covered by certain sector-specific privacy laws, including
the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or
California Financial Information Privacy Act (FIPA), and the Driver’s Privacy
Protection Act of 1994.

In particular, our Website has collected the following categories of Personal Information from
consumers within the last twelve (12) months:

 

 

 

Category Examples Collected
A. Identifiers 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. YES
B. 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. Some Personal Information included in this category may overlap with other categories. NO
C. Protected classification characteristics under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO
D. Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
E. Biometric information Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data Physical location or movements. YES
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other Personal Information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES

Our Website obtains the categories of Personal Information listed above from the following
categories of sources:
● Directly from you. For example, from forms you complete or products and services you
purchase.
● Indirectly from you. For example, from observing your actions on our Website.
● Through Google Analytics. To learn more about Google Analytics tracking technologies,
please visit https://policies.google.com/technologies/partner-sites.

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following
purposes:
● To fulfill or meet the reason you provided the information. For example, if you share
your name and contact information to request a price quote or ask a question about our
products or services, we will use that Personal Information to respond to your inquiry. If
you provide your Personal Information to purchase a product or service, we will use that
information to process your payment and facilitate delivery. We may also save your
information to facilitate new produce orders or process returns.
● To provide, support, personalize, and develop our Website, products, and services.
● To process your requests, purchases, transactions, and payments and prevent transactional
fraud.
● To provide you with support and to respond to your inquiries, including to investigate and
address your concerns and monitor and improve our responses.
● To personalize your Website experience and to deliver content and product and service
offerings relevant to your interests, including targeted offers and ads through our Website,
third-party sites, and via email or text message (with your consent, where required by
law).
● To help maintain the safety, security, and integrity of our Website, products and services,
databases and other technology assets, and business.
● For testing, research, analysis, and product development, including to develop and
improve our Website, products, and services.

● To respond to law enforcement requests and as required by applicable law, court order, or
governmental regulations.
● As described to you when collecting your Personal Information or as otherwise set forth
in the CCPA.
● To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or
other sale or transfer of some or all of our assets, whether as a going concern or as part of
bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us
about our Website users is among the assets transferred.
We will not collect additional categories of Personal Information or use the Personal Information
we collected for materially different, unrelated, or incompatible purposes without providing you
notice.

Sharing Personal Information

We may share your Personal Information by disclosing it to a third party for a business purpose.
We only make these business purpose disclosures under written contracts that describe the
purposes, require the recipient to keep the Personal Information confidential, and prohibit using
the disclosed information for any purpose except performing the contract. In the preceding
twelve (12) months, Company has disclosed Personal Information for a business purpose to the
categories of third parties indicated in the chart below.
We do not sell Personal Information. In the preceding twelve (12) months, Company has not sold
Personal Information to the categories of third parties indicated in the chart below. For more on
your Personal Information sale rights, see Personal Information Sales Opt-Out and Opt-In
Rights.

 

 

 

Personal Information Category Category of Third-Party Recipients Business Purpose Disclosures Sales
A: Identifiers Data analytics providers and partners None
B: California Customer Records personal information categories Data analytics providers and partners None
C: Protected classification characteristics under California or federal law None None
D: Commercial information Data analytics providers and partners None
E: Biometric information None None
F: Internet or other similar network activity Data analytics providers None
G: Geolocation data Data analytics providers None
H: Sensory data None None
I: Professional or employment-related information None None
J: Non-public education information None None
K: Inferences drawn from other Personal Information Data analytics providers and partners None

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their
personal information. This section describes your CCPA rights and explains how to exercise
those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and
use of your Personal Information over the past 12 months (the “right to know”). Once we receive
your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will
disclose to you:
● The categories of Personal Information we collected about you.
● The categories of sources for the Personal Information we collected about you.
● Our business or commercial purpose for collecting or selling that Personal Information.
● The categories of third parties with whom we share that Personal Information.
● If we sold or disclosed your Personal Information for a business purpose, two separate
lists disclosing:

○ sales, identifying the Personal Information categories that each category of
recipient purchased; and
○ disclosures for a business purpose, identifying the Personal Information categories
that each category of recipient obtained.

● The specific pieces of Personal Information we collected about you (also called a data
portability request).
Right to Delete
You have the right to request that we delete any of your Personal Information that we collected
from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your
request and confirm your identity (see Exercising Your Rights to Know or Delete), we will
review your request to see if an exception allowing us to retain the information applies. We may
deny your deletion request if retaining the information is necessary for us or our service
provider(s) to:

  1. Complete the transaction for which we collected the Personal Information, provide a
    good or service that you requested, take actions reasonably anticipated within the context
    of our ongoing business relationship with you, fulfill the terms of a written warranty or
    product recall conducted in accordance with federal law, or otherwise perform our
    contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal
    activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech
    rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §
    1546 et. seq.).
  6. 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 the
    information’s deletion may likely render impossible or seriously impair the research’s
    achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based
    on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the
    context in which you provided it.
    We will delete or deidentify Personal Information not subject to one of these exceptions from our
    records and will direct our service providers to take similar action.
    We do not provide these deletion rights for B2B Personal Information.
    Exercising Your Rights to Know or Delete
    To exercise your rights to know or delete described above, please submit a request by:
    ● Emailing us at info@getpawsitivepethealth.com.

● Complete the Personal Data Inquiry and Request Form available here:
Be aware that we do not accept or process requests through other means (e.g., via fax, chats,
social media, etc.).
Only you, or someone legally authorized to act on your behalf, may make a request to know or
delete related to your Personal Information.
You may also make a request to know or delete on behalf of your child.
You may only submit a request to know twice within a 12-month period. Your request to know or
delete must:
● Provide sufficient information that allows us to reasonably verify you are the person
about whom we collected Personal Information or an authorized representative, which
may include:
○ Age, telephone number, mailing address, email address
● Describe your request with sufficient detail that allows us to properly understand,
evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify
your identity or authority to make the request and confirm the Personal Information relates to
you.
We will only use Personal Information provided in the request to verify the requestor’s identity or
authority to make it.
For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales
Opt-Out and Opt-In Rights.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive
confirmation within the 10-day timeframe, please contact info@getpawsitivepethealth.com.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45)
days of its receipt. If we require more time (up to another 45 days), we will inform you of the
reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your
request. The response we provide will also explain the reasons we cannot comply with a request,
if applicable. For data portability requests, we will select a format to provide your Personal
Information that is readily usable and should allow you to transmit the information from one
entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is
excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee,
we will tell you why we made that decision and provide you with a cost estimate before
completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are age 16 or older, you have the right to direct us to not sell your Personal Information at

any time (the “right to opt-out”). We do not sell the Personal Information of consumers we
actually know are less than 16 years old, unless we receive affirmative authorization (the “right
to opt-in”) from either the consumer who is between 13 and 15 years old, or the parent or
guardian of a consumer less than 13 years old. Consumers who opt-in to Personal Information
sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to
us by visiting the following Internet Web page link:
Do Not Sell or Share My Personal Information

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to
reauthorize Personal Information sales. However, you may change your mind and opt back in to
Personal Information sales at any time by:

● Emailing us at info@getpawsitivepethealth.com

You do not need to create an account with us to exercise your opt-out rights. We will only use
Personal Information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted
by the CCPA, we will not:
● Deny you goods or services.
● Charge you different prices
● Charge you different prices or rates for goods or services, including through granting
discounts or other benefits or imposing penalties.
● Provide you a different level or quality of goods or services.
● Suggest that you may receive a different price or rate for goods or services or a different
level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website
that are California residents to request certain information regarding our disclosure of Personal
Information to third parties for their direct marketing purposes. To make such a request, please
send an email to info@getpawsitivepethealth.com.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we
make changes to this privacy policy, we will post the updated notice on the Website and update
the notice’s effective date. Your continued use of our Website following the posting of

changes constitutes your acceptance of such changes.
Contact Information

If you have any questions or comments about this notice, the ways in which PawsitiveHealth Pet
Insurance Services, LLC collects and uses your information described here and in the Privacy
Policy, your choices and rights regarding such use, or wish to exercise your rights under
California law, please do not hesitate to contact us at:
Phone: (925) 453-9852
Website: https://getpawsitivepethealth.com/home/
Email: info@getpawsitivepethealth.com
Postal Address:
4700 Tassajara Rd., Dublin, CA 94568, Unit 3318
Attn: PawsitiveHealth Pet Insurance Services, LLC
4700 Tassajara Rd., Dublin, CA 94568, Unit 3318

If you need to access this Policy in an alternative format due to having a disability, please contact info@getpawsitivepethealth.com.

Do Not Sell My Information