FirstLight Home Care
CA Privacy Policy

Additional California Privacy Rights

This Privacy Notice For California Residents supplements the information contained in the Privacy Policy of FirstLight Home Care Franchising, LLC, and its subsidiaries (collectively hereinafter “FirstLight,” “we,” “us,” or “our”) and applies solely to visitors, users and others who reside in the State of California (“consumers” or “you”). FirstLight adopts this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

FirstLight collects information that identifies, relates, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, FirstLight has collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, such as:
  • 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) or clinical trial data;
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

FirstLight obtains the categories of personal information listed in the above table from the following categories of sources:

• Directly from consumers. For example, from documents and applications which consumers provide to FirstLight when applying for employment or through for submissions, or entering information when searching for locations.
• Indirectly from consumer. For example, through information FirstLight collects from consumers in the course of providing services or employment to them, or from considering applications for employment.
• Directly and indirectly from activity on our website (www.firstlighthomecare.com). For example, from submissions through FirstLight’s website or website usage details collected automatically by Google Analytics, Google Ads, Google Maps, by way of heatmapping, or through IP look up.
• From third-parties that interact with us in connection with the services FirstLight provides. For example, from third party agencies when assessing applications for employment.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason that the information is provided. For example, if you provide us with personal information in support of an application for employment, we will use that information to assess the employment request.
• To provide you with information, products or services that you request from us, or that will supplement the services you have requested from us such as locations near you.
• To provide you with email alerts or notices concerning our products, services, or news that may be of interest to you.
• To improve our website, the user experience and present its contents to you.
• For analysis, research and product development.
• To better understand visitor behavior when interacting with our website.
• To better improve accessibility.
• As necessary or appropriate to protect the rights, property or safety of FirstLight, its clients and others.
• 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, round of funding, investment, restructuring, reorganization, dissolution, or other sale or transfer of come or all of our assets, in which personal information held by us 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 disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to keep the personal information confidential or not use it for any purpose other than performing the contract.

In the preceding twelve (12) months, FirstLight has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers

Category B: California Customer Records personal information categories.

Category C: Protected categories

Category D: Commercial Information

Category F: Internet or network activity

Category G: Geolocation data

Category I: Professional or employment-related information

Category K: Inferences drawn from other personal information.

FirstLight may disclose your personal information for a business purpose to the following third parties or categories of parties:

• Our affiliates and franchisees
• Service providers
• Google
• Third party credit reporting agencies
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products, services or employment which we may ultimately provide to you.
• Hireology, Wellsky, Teletrack, Carezmart, Peoplematter, Nowhiring.com, Google Forms, Mailchimp, WP Engine Server, Mailchimp and Franconnect.

In the preceding twelve (12) months, FirstLight has not sold any personal information.

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.

Access to Specific Information and Data Portability Rights

You have the right to request that FirstLight disclose certain information to you about its collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, 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
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  1. Sales: Which would identify the personal information and categories of personal information which a third party purchased from us; and
  2. Disclosures for a business purpose: Whereby we would identify the personal information and categories of personal information which we disclosed to a third party.

Deletion Request Rights

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. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; this would include information related to providing care or ongoing employment with FirstLight.
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 by law.
5. Comply with the California Electronics 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 adhere 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 upon 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 said information.

Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Emailing us at: Info@firstlighthomecare.com
• Calling us at: (866)985-4031; or
• Mailing us at: FirstLight Home Care Franchising, LLC
  Attention: Privacy Compliance
  7870 East Kemper Road, Suite 400
  Cincinnati, OH 45249

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable request must:

• Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or are an authorized representative.
• 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. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

FirstLight will endeavor to respond to a verifiable consumer request within 60 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension needed in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response electronically or by mail, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain if applicable, any reasons for which we cannot comply with a request. 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 without hinderance.

FirstLight does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If FirstLight determines 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.

Non-Discrimination

FirstLight will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, FirstLight will not:

• Deny you services;
• Charge you different prices or raise the rates for services, including through the granting of discounts or other benefits, or imposing penalties;
• Provide you with a different level or quality of services; or
• Suggest that you may receive a different price or rate for services or a different level or quality of services;

Solely on the basis of you exercising your rights under the CCPA.

Changes To Our Privacy Notice

FirstLight reserves the right to amend this privacy notice at its discretion and at any time. When FirstLight makes changes to this privacy notice, it will notify the consumer exclusively through a notice on the FirstLight website homepage.

Contact Information

If you have any questions or comments about this Notice, FirstLight ‘s Privacy Policy, the ways in which FirstLight collects and uses your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Tel: (866)985-4031

or

FirstLight Home Care Franchising, LLC
Attention: Privacy Compliance
7870 East Kemper Road, Suite 400
Cincinnati, OH 45249

This CCPA policy is effective as of September 1, 2022, and was last modified on September 1, 2022.