Effective Date: January 2, 2023

Last Updated: June 28, 2023

This Privacy Notice for Virginia Residents (“Notice”)supplements the information contained in the Optimum Outcomes, Inc.’s (“OOI”) general Privacy Policy (available on our website) and applies solely to consumers who reside in the State of Virginia (“consumers” or “you”). This Notice is intended to describe our online and offline information practices as they relate to your Personal Information and also to describe your rights related to your Personal Information. We adopt this Notice to comply with the Virginia Consumer Data Protection Act (VCDPA) and any terms defined in the CCP have the same meaning when used in this notice.

This Notice Does Not Apply to Everyone or to All Types of Information

The VCDPA applies to certain information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”).

Under the VCDPA, Personal Information does not include publicly available information from government records or certain de-identified or aggregated consumer information. In addition, the VCDPA does not apply at all to some specific types of information, like (1) data subject to Title V of the Gramm-Leach-Bliley Act (“GLBA”), (2) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the Health Information Technology for Economic and Clinical Health Act, (3) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), (4) and the Driver’s Privacy Protection Act of 1994. Accordingly, this Notice does not apply to these types of information.

We only knowingly collect Protected Health Information or “PHI” that is subject to HIPAA, or which otherwise is not included in the VCDPA’s definition of Personal Information. Therefore, we do not knowingly collect any Personal Information that is subject to the VCDPA. This Notice is therefore only applicable in the unlikely event we have collected information subject to the VCDPA.

This Notice also does not apply to any of our California Job Candidates or California Resident Colleagues. Information about our collection and use of Personal Information for these categories can be found within our Privacy Policy.

Information we collect

In the unlikely event we collected any Personal Information about you in the preceding 12 months that is not exempt from the VCDPA, such information would be included in the following categories. PLEASE NOTE: Although we may have inadvertently collected Personal Information from these categories to the extent described below, we would not necessarily have collected all of the specific pieces of Personal Information described within a particular category of Personal Information, or any of them, for any individual consumer:

In particular, the Company has collected or disclosed the following categories of personal information about its consumers within the last twelve (12) months:

Category	Examples	Collected	Sold or Shared	Disclosed for Business Purpose	To whom we disclosed personal information
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.	NO	N/A	N/A	–
B. Personal information categories	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	N/A	N/A	N/A
C. Protected classification characteristics under Virginia 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	N/A	N/A	N/A
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO	N/A	N/A	N/A
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	N/A	N/A	N/A
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	NO	N/A	N/A	N/A
G. Geolocation data.	Physical location or movements.	NO	N/A	N/A	N/A
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO	N/A	N/A	N/A
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO	N/A	N/A	N/A
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	N/A	N/A	N/A
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES	NO	NO	N/A
L. Sensitive Personal Information	A social security, driver’s license, state identification card, or passport number	NO	N/A	N/A	N/A
	Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account	NO	N/A	N/A	N/A
	Precise geolocation or any data that is derived from a device and that is used or intended to be used to locate a consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet, except as prescribed by regulations	NO	N/A	N/A	N/A
	Racial or ethnic origin, religious or philosophical beliefs, or union membership	NO	N/A	N/A	N/A
	The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication	NO	N/A	N/A	N/A
	Genetic data	NO	N/A	N/A	N/A
	The processing of biometric information for the purpose of uniquely identifying a consumer.	NO	N/A	N/A	N/A
	Personal information collected and analyzed concerning a consumer’s health.	NO	N/A	N/A	N/A
	Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.	NO	N/A	N/A	N/A

OOI does not collect credit card numbers through its website. Online credit card payments are processed through a secure link provided by a third-party payment processor, and OOI cannot access your credit card information from that third party.

OOI’s website (www.oorcm.com) do not use cookies.

Sources of Personal Information

We only knowingly collect Protected Health Information or “PHI” that is subject to HIPAA and, therefore, exempt from the VCDPA, or information that is otherwise not included in the VCDPA’s definition of Personal Information. In the unlikely event we collected any Personal Information about you in the last 12 months that is not exempt from the VCDPA, each of the above-listed categories would have been collected from the following categories of sources:

· Directly from a medical facility we provide services to, including for collections purposes.

Use of personal information

We only knowingly collect Protected Health Information or “PHI” that is subject to HIPAA and, therefore, exempt from the VCDPA, or information that is otherwise not included in the VCDPA’s definition of Personal Information. In the unlikely event we collected any Personal Information about you in the last 12 months that is not exempt from the VCDPA, we potentially would have disclosed or used Personal Information from each of the above-listed categories for one or more of the following business purposes, if permitted by applicable law:

To fulfill or meet the reason for which the information is provided. For example, if you have provided Personal Information to a medical facility we receive accounts from, for a service to be provided, we will use that information for the purpose for which it was provided.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and a medical facility, or between us and a medical facility we provide services to, including for collections purposes.
As necessary or appropriate to protect the rights, property, or safety of us, our affiliates, or 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 VCDPA.
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 is among the assets transferred.

We will not collect Personal Information or use any Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you Notice.

Sharing of Personal Information

In the preceding twelve (12) months, OOI has not sold or shared Personal Information.

OOI does not sell Personal Information or share Personal Information for cross-context behavioral advertising.

Your rights and choices

The VCDPA, provides Virginia consumers with specific rights regarding their Personal Information. This section describes your rights and explains how to exercise those rights.

Your Right to Know and Access Specific Pieces of Personal Information (Data Portability Rights)

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. Once we receive and confirm your verifiable consumer request and confirm that we have Personal Information about you that is applicable under the VCDPA, we will disclose the following to you unless the information is exempt from the VCDPA:

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, selling, or sharing that personal information.
Please note that we do not sell any Personal Information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (if requested, also called a data portability request).
We do not sell any Personal Information, but if we disclosed your Personal Information for a business purpose, a separate list of disclosures for a business purpose, identifying the categories of Personal Information that each category of recipient obtained.

Your Right to Delete Personal Information

You have the right to request that the Company 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 and confirm that we have Personal Information about you that is subject to the VCDPA, we will delete your Personal Information from our records, unless an exception applies, or the information is exempt from the VCDPA.

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

Complete the transaction for which we collected the personal information.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
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.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Your Right to Correct Inaccurate Personal Information

You have the right to request that the Company correct inaccurate personal information that we maintain about you. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Deletion, and Correction Rights), and confirm that we have Personal Information about you that is subject to the VCDPA, we will use commercially reasonable efforts to correct your inaccurate personal information in our records.

Exercising access, data portability, deletion and correction rights

To exercise the access, data portability, deletion and correction rights described above, please submit a verifiable consumer request via our webform or 1-833-770-3100.

Only you, or someone legally authorized 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. Your request for access or data portability will apply to personal information collected on or after January 1, 2022 that is still maintained by the Company at the time of the request. You may specify a shorter time period for your request at your option.

The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Authorized representatives may be asked to provide documentation to support their role.
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

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period 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 by mail or electronically, at your option.

The response we provide will 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 useable 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.

Your Right to Opt-Out of Personal Information Sale or Sharing

We do not sell any or share personal information, including without limitation any Personal Information of minors under the age of 16 either with or without affirmative authorization. Accordingly, we have not sold any Personal Information in the last 12 months.

Your Right to Limit the Use and Disclosure of Sensitive Personal Information

We only knowingly collect Protected Health Information or “PHI” that is subject to HIPAA, and, therefore, exempt from the VCDPA, or information that is otherwise not included inthe VCDPA’s definition of Personal Information. In the unlikely event we collected any Sensitive Personal Information about in the last 12 months that is not exempt from the VCDPA, you have the right to request that the Company limit its use of your sensitive Personal Information when used for purposes other than those permitted by the VCDPA and its implementing regulations.

Your Right to No Retaliation

You have the right to exercise your rights without retaliation. We will not discriminate against you for exercising any of your VCDPA rights. Unless permitted by the law, we will not:

Deny you goods or services.
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.

If you feel you have experienced retaliation, you are encouraged to call the Company’s Helpline at 1-844-606-1748, Organization Name: Optimum Outcomes. Callers can report concerns anonymously and confidentially.

Changes to our privacy notice

OOI reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the website and update the notice’s effective date.

Contact information

If you would like information about how colleagues with disabilities may access this privacy notice in an alternative format, or if you have any questions or comments about this notice, please do not hesitate to contact us at privacy.officer@oorcm.com.