Consumer Health Data Privacy Policy
Effective as of December 7, 2024
Sorenson Communications, LLC, CaptionCall, LLC and its affiliates (collectively, “Sorenson,” “we”, “us” or “our”) is a language services provider and a provider of communication tools for Deaf and hard-of-hearing people.
This Consumer Health Data Privacy Policy (“Consumer Health Data Privacy Policy”) applies to the extent U.S. state consumer health data-specific privacy laws to which we are subject (“Consumer Health Data Privacy Laws”) apply to our processing of certain health status-related data, such as “consumer health data” as defined by such laws (“Consumer Health Data”). Consumer Health Data does not include “publicly available information” or “deidentified data”, as such terms or similar terms are defined by Consumer Health Data Privacy Laws, or other data excluded from the scope of such laws. This Consumer Health Data Privacy Policy describes how Sorenson processes Consumer Health Data that we collect through our websites, software, telephones, mobile applications, social media pages, Sorenson-branded devices, marketing activities and other activities described in this Privacy Policy. We reserve the right to make changes to this policy at any given time.
This Consumer Health Data Privacy Policy supplements our general Privacy Policy. In the event of a conflict between our Privacy Policy and this Consumer Health Data Privacy Policy, this Consumer Health Data Privacy Policy shall control only with respect Consumer Health Data and to the extent required by applicable Consumer Health Data Privacy Laws.
Consumer Health Data We Collect
Consumer Health Data you may provide to us through our products, services, or otherwise includes the following, to the extent such data is linked or reasonably linkable to you and identifies your past, present or future physical or mental health status. We will obtain your consent where required by applicable Consumer Health Data Privacy Laws.
- Registration data, such as information we collect when you register for or are referred to our products or services, which may include details relating to your hearing loss (including self-certification).
- Communications data based on our exchanges with you, including when you contact us through our services, or communicate with us via chat features, social media, or otherwise.
- Responses to surveys and questionnaires, such as any information you provide to us when you voluntarily respond to market research surveys, which may include products for which you have indicated an interest.
- User-generated content data, such as information about products you may have used when you post, upload, comment, or otherwise submit content on our services, websites, or other Sorenson managed mediums.
- Other data not specifically listed here that may be used to infer or derive health status-related data, which we will use as described in this Consumer Health Data Privacy Policy or as otherwise disclosed at the time of collection.
Consumer Health Data we obtain from third-party sources. We may also obtain the types of Consumer Health Data described above from third-party sources. These third-party sources may include, for example:
- Private sources. Private sources of Consumer Health Data such as data providers and social media platforms.
- Marketing partners. Partners with which we engage in joint marketing activities or co-sponsor events.
Sources of Consumer Health Data
As described in more detail above, we collect Consumer Health Data directly from you, from your interactions with our products and services, and from third-party sources.
How We Use your Consumer Health Data
We use Consumer Health Data for the purposes described in this Consumer Health Data Privacy Policy or as otherwise disclosed to you. We will obtain your consent where required by applicable Consumer Health Data Privacy Laws. For example, we use Consumer Health Data for the following purposes:
Purpose of Use / How Data Is Used | Applicable Categories of Consumer Health Data |
Services delivery and operations: providing our products and services, communicating with you about our products and services, providing support for our products and services, and responding to your requests, questions, and feedback. | Registration data, communications data, responses to surveys and questionnaires, user-generated content data |
Services personalization: understanding your needs and interests and personalizing your experience with our products and services and our service-related communications. | Registration data and communications data |
Research and development: for research and development purposes, including to analyze and improve our products and services, our business, and to develop new products and services. | Registration data, communications data, responses to surveys and questionnaires, user-generated content data |
Direct marketing: communicating with you about new services, upcoming events, and other information. | Registration data and responses to surveys and questionnaires |
Events: to contact or market to you after collecting your personal information at an event. | Registration data and responses to surveys and questionnaires |
Compliance and protection: complying with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities; protecting our, your or others’ rights, privacy, safety or property; auditing our internal processes for compliance with legal and contractual requirements or our internal policies; enforcing the terms and conditions that govern our services; preventing, identifying, investigating and deterring fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. | Registration data, communications data, user-generated content data |
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve our products and services, and promote our business. | Registration data, communications data, responses to surveys and questionnaires, user-generated content data |
How we share your Consumer Health Data
We may “share” (as the applicable Consumer Health Data Privacy Law may define that term) Consumer Health Data with your consent or as we determine necessary to complete your transactions, provide our products and services to you, or as otherwise permitted or required by law. We will obtain your consent where required by applicable Consumer Health Data Privacy Laws. For example, we may share your Consumer Health Data with:
Category of Third Party | Applicable Categories of Consumer Health Data |
Third parties designated by you. We may share your Consumer Health Data with third parties where you have instructed us or provided your consent to do so. | Registration data, communications data, responses to surveys and questionnaires, user-generated content data |
Partners. Third parties with whom we partner, including parties with whom we co-sponsor events, with whom we jointly offer products or services, or whose products or services may be of interest to you. | Registration data, responses to surveys and questionnaires, user-generated content data |
Professional advisors. We may disclose Consumer Health Data to our professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us. | Registration data, communications data, responses to surveys and questionnaires, user-generated content data |
Legal and law enforcement. We will share Consumer Health Data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies. We will also share Consumer Health Data if we believe it is necessary to protect our customers and/or the rights or property of ourselves or others. | Registration data, communications data, responses to surveys and questionnaires, user-generated content data |
Business transferees. We may disclose Consumer Health Data to acquirers and/or other relevant participants in corporate events (including negotiations of or due diligence for such events), such as investments in Sorenson, financing of Sorenson, public stock offerings, or the sale, transfer or merger of all or part of our business, assets, or shares. | Registration data, communications data, responses to surveys and questionnaires, user-generated content data |
Your Consumer Health Data choices
You may have certain rights to your Consumer Health Data under applicable Consumer Health Data Privacy Laws. Any of the rights discussed below may be subject to certain limitations (for example, a monetary charge).
Withdraw consent. To the extent we rely upon your consent for either our collection or sharing of your Consumer Health Data, you may have the right to withdraw such consent from any future collection or sharing.
Access and confirm. You may have the right to ask us to confirm whether we have collected, shared or sold your Consumer Health Data. Further, you may have the right to access (in other words, request a copy of) the Consumer Health Data that we have collected, shared or sold. You may also have a right to access a list of all “third parties” (as applicable law may define that term) and affiliates with whom we have shared or sold your Consumer Health Data and receive certain corresponding information.
Correction. You may have the right to ask us to correct inaccuracies in your Consumer Health Data.
Deletion. You may have the right to ask us to delete your Consumer Health Data.
Appeal. You may have the right to appeal our denying a right you have attempted to exercise. We will provide details on how to appeal our denial in connection with such action.
If a Consumer Health Data Privacy Law applies to you and your Consumer Health Data and you wish to exercise your rights above, please email us at [email protected]. We may need to verify your identity to process your request. To confirm your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you (such as government identification), which we will only use to verify your identity, and for security or fraud-prevention purposes.
Declining to provide information. We need to collect or process Consumer Health Data to provide certain services to you. If you do not provide the information we identify as required or mandatory or if you request that any required Consumer Health Data be deleted or withdraw your consent for future collection or sharing of any required Consumer Health Data, we may not be able to provide those services to you.
Changes to this Consumer Health Data Privacy Policy
We reserve the right to modify this Consumer Health Data Privacy Policy at any time. If we make material changes to this Consumer Health Data Privacy Policy, we will notify you by updating the date of this Consumer Health Data Privacy Policy and posting it on the Site or other appropriate means. Any modifications to this Consumer Health Data Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of our products and services after the effective date of any modified Consumer Health Data Privacy Policy indicates your acknowledging that the modified Consumer Health Data Privacy Policy applies to your interactions with our products, services, and business.
How to Contact Us
- Email: [email protected]
Nevada Supplemental Consumer Health Data Privacy Policy
This Supplement applies to our processing of Consumer Health Data about Nevada consumers, for purposes of providing additional disclosures required by Nevada's Consumer Health Data Privacy Law. We collect, use, process, and share Consumer Health Data for the purposes and manners described above in our Consumer Health Data Privacy Policy. In addition:
Review and Revision of Consumer Health Data. If you are a Nevada consumer and you would like to review and/or revise your Consumer Health Data, you may submit a request to us via the method listed in the Your Consumer Health Data choices section of our Consumer Health Data Privacy Policy.
Third-Party Collection of Consumer Health Data Across Sites. We do not allow third parties (i.e., non-service providers) to collect Consumer Health Data over time and across different Internet websites or online services when you use our products or services.