Effective as of January 1, 2020
Last updated August 16, 2021
1. Collecting and Using Information
Personally Identifiable Information We Collect Online
We collect Personally Identifiable Information from you through your use of the Sites and Services. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. We collect the following types of Personally Identifiable Information:
Information You Provide
We may collect the following Personally Identifiable Information that you voluntarily provide to us:
- Account. If you create an account for any of our Services, we will collect your first and last name, a home or other physical address, phone number, email address, Medicaid ID, disability information for ADA assessments, driver’s license/insurance/vehicle information for transportation reimbursement, and password.
- Member Chat. If you use our online chat feature, we will collect your first and last name and certain Personally Identifiable Information pertaining to the Member, including the Member’s first and last name and phone number. We also will ask you to provide the Member’s date of birth and postal zip code.
- Contact Us. When you complete our online contact form, we will collect your first and last name, a home or other physical address, phone number, email address, and any Personally Identifiable Information that you choose to provide in your comments.
- Subscribe to Newsletter. When you sign up to receive our newsletter, we will collect your first and last name, email address, and company.
Information as You Navigate Our Sites
We automatically collect certain Personally Identifiable Information through your use of the Sites and Services, such as the following:
- Usage Information. For example, the pages on the Sites you access, the frequency of access, and what you click on while on the Sites.
- Device Information. For example, hardware model, operating system, application version number, and browser.
- Mobile Device Information. Aggregated information about whether the Sites are accessed via a mobile device or tablet, the device type, and the carrier.
- Location Information. Location information from site visitors on a city-regional basis.
Third Party Information
How We Use Your Personally Identifiable Information
We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Services and Sites, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:
- Operate our Sites and deliver the Services you have requested, including without limitation, any interactive services you use;
- Improve existing services or develop new services;
- Validate your access;
- Process your account registration;
- Schedule appointments or transportation;
- Approve use of personal vehicles for transportation;
- Reimburse for transportation expenses;
- Assess for ADA transportation services;
- Deliver reminders and details of upcoming appointments or denial of services;
- Perform analytics to improve services;
- Communicate with you about our Sites or Services or to inform you of any changes to our Sites or Services;
- Contact you regarding our products and services that we feel may be of interest to you;
- Provide support;
- Maintain and improve our Sites and Services;
- Defend our legal rights and the rights of others;
- Efficiently maintain our business; and
- Comply with applicable law.
How We Share Your Personally Identifiable Information
We may share the information that we collect about you in the following ways:
- With our affiliates and subsidiaries;
- With outsourced or contracted service providers or vendors to provide our Services. Any such service providers will be under an obligation to us to maintain the confidentiality of your Personally Identifiable Information;
- With your health plan;
- With public authorities in instances where we must disclose personal information as required by applicable law;
- With service providers who perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.);
- To service providers to prepare, deploy and analyze advertising content;
- To the extent that we are required to do so by law;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
- To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personally Identifiable Information;
- To any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition or in preparation for any of these events; and
- To any other person or entity where you consent to the disclosure.
2. Cookies and Other Tracking Technologies
- Estimate audience size and usage patterns;
- Understand and save your preferences for future visits, allowing us to customize the Sites and Services to your individual needs;
- Advertise new content and services that relate to your interests;
- Keep track of advertisements and search engine results;
- Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and
- Recognize when you return to the Sites.
How You Can Opt-Out of Cookies
Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Sites.
You can opt out of Cookies set by specific entities by following the instructions found at these links:
Advertising Industry Resources
You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.
Please note that these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.
3. Third Party Processors
To ensure that your Personally Identifiable Information receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share it with to ensure that it is treated consistent with applicable data security and privacy laws. For example, we use a third-party marketing service provider.
4. “Do Not Track” Signals
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Sites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.
5. Choices About Your Personally Identifiable Information
Review and Request Changes to Your Personally Identifiable Information
You may use your account to access, correct, or view certain Personally Identifiable Information we have collected and which is associated with your account. To review or request changes to any of your Personally Identifiable Information, please contact us at 888-444-1189 or #QCContractCompliance@mtm-inc.net.
To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us at #QCContractCompliance@mtm-inc.net.
We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.
7. Third Party Links
8. Children’s Privacy
For MTM’s non-HIPAA regulated businesses, Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to #QCContractCompliance@mtm-inc.net.
9. Notice to Nevada Residents
10. Notice to California Residents
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, de-identified or aggregated information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”
The CCPA, including the consumer rights described in this section, however, does not apply to any protected health information that we collect through our Medical Transportation Management business in our capacity as a business associate governed by the privacy, security, and breach notification rules issued by the United States Department of Health and Human Services established pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health Act (HITECH). We will use that information only for the purposes for which we were engaged by the HIPAA covered entity.
The CCPA contains an additional exception that is relevant to us. Some of the CCPA’s privacy rights explained below do not apply to personal information collected in a business-to-business context. That is information reflecting a written or verbal communication or a transaction between us and a consumer, where the consumer is acting as an employee, owner, director, officer, or contractor of another entity and when the communication or transaction occur solely within the context of us conducting due diligence regarding, or providing or receiving a product or service to or from such entity.
Right to Know About Personal Information Collected, Disclosed, or Sold
If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:
- Specific pieces of Personal Information that we have collected about you;
- Categories of Personal Information that we have collected about you;
- Categories of sources from which the Personal Information was collected;
- Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
- Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
- The business or commercial purpose for collecting or, if applicable, selling Personal Information.
The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.
Collection of Personal Information
- Identifiers (name, alias, postal address, online identifier, internet protocol address, email address)
- Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology)
- Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)
- Geolocation data
- Professional or employment-related information (company name)
- Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences
The Personal Information is collected from California residents directly.
In addition to the purposes stated above in the section “Collecting and Using Information” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:
- Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- Debugging to identify and repair errors that impair existing intended functionality
- Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction
- Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business
- Advancing a person’s commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
Disclosure of Personal Information
|Category of Personal Information
|Category of Third Parties to Whom Information was Disclosed
|Name; postal address
|Online identifier; IP address
|Marketing provider; Data analytics provider
|Device identifier; geolocation data
|Data analytics provider
|Cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; browsing and search history; information regarding consumer’s interaction with website, application, or advertisement
|Data analytics provider; Marketing provider; Advertising networks
|Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences
|Data analytics provider; Marketing provider; Advertising networks
We do not knowingly sell the Personal Information of minors under 16 years of age.
Right to Request Deletion of Personal Information
If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected. However, per the CCPA, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
How to Submit a Request to Know or Delete
You may submit a request to know or delete by 888-444-1189 or #QCContractCompliance@mtm-inc.net.
Our Process for Verifying a Request to Know or Delete
If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable.
For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
Right to Opt-Out of Sale of Personal Information
If you are a California resident, you have the right to direct businesses to stop selling your Personal Information. We do not sell Personal Information as it is defined in the CCPA.
Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights
We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.”
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.
Shine the Light Law
We do not disclose personal information obtained through our Sites or Services to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.
12. How To Contact Us
To contact us for questions or concerns about our privacy policies or practices please contact us at 888-444-1189 or #QCContractCompliance@mtm-inc.net or write us at:
Medical Transportation Management, Inc.
16 Hawk Ridge Circle
Lake St. Louis, MO 63367