This privacy policy (the “Privacy Policy”) describes Rawlings & Associates, PLLC’s (“Rawlings”, “our”, “us”, or “we”) practices regarding the handling of information provided by visitors to our websites (the “Site(s)”) as well as information that we may collect about you via other means, as described below.

Please carefully read this Privacy Policy. Our Privacy Policy explains what types of information we gather, how we gather that information, what disclosures of that information we might make, and how we safeguard that information. By using this Site(s), you indicate your understanding and acceptance of these terms. If we materially alter our Privacy Policy, we will notify you of such changes by posting a notice on our Site(s). Your continued use of the Site(s) will be deemed your agreement that your information may be used in accordance with the new policy.

Our Privacy Policy does not cover the privacy practices of any other websites to which the Site(s) may link. We do not accept any responsibility or liability for linked sites’ policies whatsoever as we have no control over them. We encourage you to read and understand those websites’ policies prior to using those websites.

How does Rawlings gather my information?

We gather information from you in various ways. For example, when you visit the Site(s), you may send us your information directly, such as by completing an online questionnaire, making an online payment, or completing the “Contact Us” form. We also automatically collect certain information regarding your use of the Site(s).For instance, we may collect information about your computer’s IP address, what type of web browser you use, and what pages of the Site(s) you visit to understand how the Site(s) is being used. See the “What are ‘cookies‘ and how does Rawlings use them?” section below for more information.

Our health plan clients also provide us with protected health information (“PHI”) about their health plan members so we can determine whether claims they covered were paid correctly and by the correct party. We also obtain information from commercially available sources of claims, demographic and similar information. We do this to make sure the correct insurance carrier covers medical claims and to make sure we have the correct addresses and identifying information for people we need to contact to do our work. In the course of performing our services for health plans we may receive additional information from third parties including but not limited to attorneys, medical providers, courts, state and federal agencies, and insurance companies and insurance services offices.

What information does Rawlings collect?

As used in this Privacy Policy, personal information is 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. We may collect and process the following categories and examples of personal information about you:

• Identifiers, such as your name, address, email address, unique personal identifier, online identifier, Internet Protocol address, account name, Social Security number, driver’s license number, passport number or other similar identifiers;
• Personal information categories under California law, including name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number or other financial information (some personal information included in this category may overlap with other categories);
• Characteristics that are considered protected classifications under certain laws, such as national origin and marital status;
• Professional or employment-related information; • Geolocation data, such as geographic location information about a particular individual or device;

We may collect information that is considered “sensitive” under some data protection laws, such as your Social Security number. When we do so, we use such information only for lawful purposes in compliance with applicable data protection laws, such as to perform the services and to resist malicious, deceptive, fraudulent or illegal actions, and we do not use such information to infer characteristics about you.

To the extent you choose to make an online payment through the Site(s), we ask you to provide certain personal information about yourself by filling out and submitting an online form. It is completely optional for you to make a payment through the Site(s). If you elect to make a payment through this Site(s), however, we will ask that you provide us personal information, such as your last name, zip code, reference number, and balance due. Once you submit this information and click the “Next” button, you are directed to the Authorize.Net payment gateway to complete the online payment process. (If you choose to give us this information orally, as a convenience to you, we will input it into the Authorize.net site and we will not keep any of the information you provide us in order to do so). Additional personal information is requested on the Authorize.Net payment portal that is necessary to complete your payment transaction. Our Privacy Policy does not cover the privacy practices of Authorize.Net. We do not accept any responsibility or liability for Authorize.Net’s policies whatsoever as we have no control over them. We encourage you to read and understand those policies prior to using their websites. Authorize.Net’s privacy policy may be found at https://www.authorize.net/company/privacy/.

What are “cookies” and how does Rawlings use them?

Cookies are small text files that a website sends to a web browser, which are stored on the web browser’s computer. Cookies are commonly used to track web activity and provide an enhanced web experience. Most web browsers automatically accept cookies. You can change your browser settings to notify you of the cookies being set or updated, and to block cookies. We do not use any tracking cookies. To learn more about how to manage cookies on different types of browsers, you can visit the website www.allaboutcookies.org.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not currently recognize or respond to browser-initiated DNT signals.

How does Rawlings use my information?

We process your personal information for our business purposes, including the following:

• To determine whether the claims of our health plan clients were paid correctly by the correct party.
• To provide and improve the content and functionality of our Site(s) and deliver our services;
• To transact business with you, such as to allow you to pay your balance;
• To detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of Rawlings and others;
• To respond to your inquiries or provide you with information;
• For our own internal purposes and, where appropriate, to contact you directly. By submitting a telephone number to Rawlings, you agree that a representative of Rawlings may contact you at any number you provide, including a mobile phone number.
• As Rawlings believes necessary or appropriate: (a) to comply with any legal, regulatory, or contractual obligation and to respond to requests from public and governmental authorities; and (b) to protect Rawlings’s rights, privacy, safety and property and the rights, privacy, safety and property of others;
• To fulfill any other purpose for which you provide it; and
• In any other way Rawlings may describe when you provide the information.

How does Rawlings disclose my information?

We may disclose your personal information to the following categories of third parties for our business purposes:

• Your health plan, other insurers, and to other parties when we are legally permitted to or contractually required to disclose your information;
• Attorneys, auditors, accountants, consultants, and other professional service providers;
• As required by law or in connection with a legal claim, dispute, or proceeding or in response to requests by governmental regulatory authorities, or as we may reasonably determine to be necessary or appropriate to protect our rights or the rights of others or to avert loss or harm to persons or property;
• Third parties as needed to protect our legitimate interests, including to establish or defend our legal rights;
• Third parties in the event that we sell all or part of our business or makes a sale or transfer of assets or are otherwise involved in a merger, restructuring or business transfer;

In the preceding 12 months, we have not sold or shared for purposes of cross-context behavioral advertising any personal information to third parties.

How does Rawlings safeguard my information?

As a HIPAA Business Associate of our client health plans, Rawlings has developed systems, procedures and training designed to protect the personal information that is provided to us. Despite the measures we have put in place, please be aware that no such measures can guarantee security or protect against unauthorized activity.

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy, or as long as we are legally required or permitted to do so. When deciding how long to retain your personal information, we take into account our legal and regulatory obligations, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information described above and whether we can achieve those purposes through other means. We may also retain your personal information to investigate or defend against potential legal claims in accordance with the limitation periods in jurisdictions where legal action may be brought.

NOTICE TO CHILDREN UNDER THE AGE OF 18 AND THEIR PARENTS OR LEGAL GUARDIANS

OUR SITE IS INTENDED FOR ADULTS. WE DO NOT KNOWINGLY OR INTENTIONALLY COLLECT PERSONAL INFORMATION FROM ANYONE UNDER THE AGE OF 18. IF YOU ARE UNDER THE AGE OF 18, PLEASE DO NOT SEND RAWLINGS ANY PERSONAL INFORMATION THROUGH THIS WEB SITE(s). IF YOU KNOW OF ANYONE UNDER THE AGE OF 18 WHO HAS PROVIDED US WITH INFORMATION THROUGH THIS WEB SITE(s), PLEASE CONTACT US IMMEDIATELY at PrivacyPolicy@rawlingscompany.com.

NOTICE TO CONNECTICUT RESIDENTS

Pursuant to Connecticut Public Act No. 08-167, this section outlines the additional security measures we use in regards to our collection, storage, and disposal of Social Security numbers. We regularly review our physical, electronic, and procedural safeguards to confirm they are effectively designed to protect the confidentiality of Social Security numbers. We limit access to Social Security numbers to only those persons with a legitimate business purpose and prohibit the unlawful disclosure of Social Security numbers. We also provide appropriate training to our employees. Finally, we protect the confidentiality of Social Security numbers by using data encryption and data storage procedures and by destroying, erasing, or making unreadable Social Security numbers prior to disposal.

NOTICE TO CALIFORNIA RESIDENTS

If you are a California resident, then this section of our Privacy Policy may apply to you and is intended to describe our practices and your rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) and applies to personal information of California residents. Personal information under the CCPA does not include PHI subject to the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations, as amended (collectively, “HIPAA”). As such, if you are a California resident seeking information about your PHI, you should contact your health plan directly.

Subject to certain limitations and exemptions, California residents may have the right to:

• Know what personal information we process about you and to obtain specific information about such personal information;
• Correct or delete personal information;
• Opt out of the sale of personal information or sharing of personal information for cross-context behavioral advertising—we do not sell personal information or share personal information for purposes of cross-context behavioral advertising, and so you are already opted out of such practices; and
• The right to opt-out of certain uses of sensitive personal information.

We will not discriminate against you for exercising any of these rights. If you wish to exercise any of these rights, please email privacypolicy@rawlingscompany.com. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. If you make a request related to personal information about you, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive information, we may require additional proof of identification. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. We will process your request within the time provided by applicable law.

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not distribute your personal information to outside parties without your consent for their direct marketing.

Contact

If you have any questions or concerns about this Policy, please contact us at: privacypolicy@rawlingscompany.com.

1 – Introduction.

This notice (“Notice”) describes the categories of personal information that Rawlings collects about California residents who apply or are recruited for a job with us (“candidates”), and how we use and share that information. For purposes of this Notice “Rawlings”, “the Company”, “we”, “us”, and “our” means Rawlings and Associates, PLLC

This notice applies to personal information you provide when you apply for or inquire about a position with the Company or that others provide to us in connection with your candidacy for a position. See our Privacy Policy for information about our practices when you interact with us in the same manner that a customer, user or other non-candidate may interact with us, including our practices regarding cookies and similar technologies.

For purposes of this Notice, “personal information” and “sensitive personal information” have the meaning given in the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) but excludes information exempted from the CCPA’s scope.

This Notice does not create or form part of any contract for employment or otherwise.

If you have questions about this Notice, please contact PrivacyPolicy@rawlingscompany.com.

1 – Introduction.

This notice (“Notice”) describes the categories of personal information that Rawlings collects about California residents who apply or are recruited for a job with us (“candidates”), and how we use and share that information. For purposes of this Notice “Rawlings”, “the Company”, “we”, “us”, and “our” means Rawlings and Associates, PLLC

This notice applies to personal information you provide when you apply for or inquire about a position with the Company or that others provide to us in connection with your candidacy for a position. See our Privacy Policy for information about our practices when you interact with us in the same manner that a customer, user or other non-candidate may interact with us, including our practices regarding cookies and similar technologies.

For purposes of this Notice, “personal information” and “sensitive personal information” have the meaning given in the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) but excludes information exempted from the CCPA’s scope.

This Notice does not create or form part of any contract for employment or otherwise.

If you have questions about this Notice, please contact PrivacyPolicy@rawlingscompany.com.

2 – Information we collect about candidates.

2.1 Categories of personal information.

Below are the categories of personal information we may collect and process during the application and recruitment process.

• Contact information such as home address, telephone number, and email address;
• Information from job application materials or recruiters such as your job application, resume or CV, cover letter, writing samples, references, work history, education transcripts, whether you are subject to prior employer obligations, and information that referrers provide about you;
• Professional qualifications such as licenses, permits, memberships, and certifications;
• Information from the application process such as any phone-screens, interviews, evaluations and outcomes of recruiting exercises;
• Immigration status and other information that would allow us to verify your employment eligibility;
• Biographical information such as name, gender, date of birth, professional history, references, language proficiencies, education details, and information you make publicly available through job search or career networking sites;
• Job preferences such as desired position and compensation, location preferences and willingness to relocate;
• Employment history;
• Background check information such as information necessary to complete background, credit, drug/alcohol and/or other checks when permitted by law, and information received during these checks;
• Information needed to understand and assess accommodation requests regarding potential disabilities or other health conditions;
• Medical information if you meet with us in-person, such as your body temperature, health symptoms, vaccination status and other screening information in connection with the Company’s health and safety plans and protocols, including screening required to access Company offices/facilities and other measures designed to prevent the transmission of COVID-19 or other infectious diseases; and
• Other information you provide to us.

Providing personal information to us is voluntary. However, if you do not provide sufficient information, we may be unable to consider your application or, if you are hired, your subsequent promotion, transfer or relocation.

In certain cases we may ask you for additional information for purposes of complying with applicable laws. We may also inquire about criminal records. We will do so only where permitted by applicable law.

2.2 Sensitive personal information.

With the possible exceptions of contact information, professional qualifications, application process information, job preferences, and employment history, all of the categories above include, or contain information from which it may be possible to infer, sensitive personal information. However, we do not use or disclose sensitive personal information in ways subject to the right of California residents to limit use of sensitive personal information under the CCPA.

2.3 Sources of personal information.

We collect personal information from you when you apply for a job and throughout the job application or recruitment process. We may also collect your personal information from other sources and combine it with the personal information you provide us. For example, we may collect your personal information from:

• Job board websites you may use to apply for a job with us;
• Prior employers that provide us with employment references;
• Professional references that you authorize us to contact;
• Pre-employment screening services such as background check providers (where permitted by law);
• Employment agencies and recruiters;
• Your educational institutions;
• Your LinkedIn profile or other publicly-available sources;
• Other Company personnel.

This section generally describes our practices currently and during the preceding 12 months. You should assume that each category of personal information we collect may have been collected from each category of sources listed above in this section.

3 – How we use personal information about candidates.

3.1 Purposes for which we use personal information.

We may use the categories of personal information above for the following purposes:

• Recruitment management
  • operating the careers website we maintain at any site to which this Notice is posted (“Careers Site”);
  • recruiting, interviewing and evaluating job candidates;
  • conducting background checks and other pre-employment screening (where permitted by law);
  • analyzing and improving our application and recruitment processes;
  • accommodating disabilities or health conditions;
  • communicating with you regarding your candidacy, opportunities with the Company or about the Careers Site and any changes to applicable terms or policies; and
  • other business operations.
• Compliance, safety and fraud prevention
  • complying with or monitoring compliance with legal and other requirements, such as reporting and equal opportunities monitoring requirements, where applicable;
  • complying with internal policies and procedures;
  • complying with lawful requests and legal process, such as to respond to subpoenas or requests from government authorities;
  • protecting our, your or others’ rights, safety and property, including by complying with applicable public health guidelines and requirements, including, without limitation, guidance from the Centers for Disease Control or other public health authorities relating to the prevention and control of COVID-19 or other infectious diseases;
  • investigating and deterring against fraudulent, harmful, unauthorized, unethical, or illegal activity, or conduct in violation of our policies or procedures;
  • controlling access to and monitoring our physical premises (e.g., by requiring health screenings to access offices/facilities; and
  • pursuing legal rights and remedies, including investigating, making and defending complaints or legal claims; administering and enforcing internal policies and procedures; and
  • sharing information with government authorities, law enforcement, courts, or private parties where we have a good-faith belief it is necessary for the foregoing purposes.
• Analytics. Creating anonymous, aggregated or de-identified data that we use and share to analyze our application and recruitment activities, business, and for other lawful business purposes.

3.2 Sharing personal information.

We may share your personal information with the following parties for the purposes described above.

• Affiliates. Our corporate parent, subsidiaries, and other affiliates under the control of our corporate parent, for purposes consistent with this Notice or to operate shared infrastructure, systems and technology.
• Company service providers. Companies that provide us with services that help us manage the recruiting process and operate our business, such as job boards, recruiters, interviewing and testing, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), and recruitment analytics.
• Government authorities, law enforcement and others. Government authorities, law enforcement, courts, and others as described in the compliance, safety and fraud prevention section above.
• Business transfers. Parties to transactions and potential transactions whereby we sell, transfer or otherwise share some or all of our business or assets, including your personal information, such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
• Professional advisors. Lawyers, immigration advisors, and other outside professional advisors who require your information in the course of providing their services.
• Customers and business partners. Customers, other companies and individuals with whom the Company does business or is exploring a business relationship.

Other parties not listed above but that are identified at or before the point at which we collect your personal information along with the purposes for which the information will be shared.

This section generally describes our practices currently and during the preceding 12 months. You should assume that each category of personal information we collect may be disclosed, and may have been disclosed during the preceding 12 months, to each category of other parties listed above in this section.

3.3 Retention.

The criteria for deciding how long to retain personal information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this Notice, including complying with our legal obligations.

4 – California privacy rights

Your privacy rights.

California residents have the rights listed below under the CCPA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. We may use the categories of personal information above for the following purposes:

• Information. You can request the following information about how we have collected and used your personal information during the past 12 months:
  • the categories of personal information that we have collected.
  • the categories of sources from which we collected personal information.
  • the business or commercial purpose for collecting or selling personal information.
  • the categories of third parties with which we share personal information.
  • the categories of personal information that we sold or disclosed for a business purpose.
  • the categories of third parties to whom the personal information was sold or disclosed for a business purpose.
  • other business operations.
• Access. You can request a copy of the personal information that we have collected about you.
• Deletion. You can ask us to delete the personal information that we have collected from you.
• Correction. You can ask us to correct inaccurate personal data that we have collected about you.
• Opt-out of sales or sharing of personal information. California residents can opt-out of any “sale” or “sharing” of personal information as such terms are defined under the CCPA. We do not sell or share personal information of candidates and have not done so in the preceding 12 months. However, we encourage you to review our Privacy Policy for information about the sale or sharing of personal information that may occur when you interact with us online in the same manner that a consumer or other non-employee may interact with us.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA, including exercising such rights without retaliation.

4.2 How to exercise your California privacy rights.

You may submit requests to exercise your rights to privacypolicy@rawlingscompany.com. Submitting your request through such channels allows us to verify your identity as required by the CCPA. As such, we cannot accept requests through other channels. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. We reserve the right to confirm your current California residency.

Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with confirmation that you have given the authorized agent permission to submit the request.

5 – Other information about this Notice

5.1 Third parties

This Notice does not address, and we are not responsible for the practices of any third parties, which have their own rules for how they collect and use your personal information. Our links to third-party websites or services are not endorsements.

5.2 Changes to this Notice

We reserve the right to change this Notice at any time. The “Effective Date” heading at the top of this Notice indicates when it was last revised. Any changes will become effective when we post the revised notice on our Careers Site.

5.3 Children

The Careers Site is not intended for minors under the age of 18.

6 – Your obligations

Among other obligations, including without limitation the obligation to provide complete and accurate information in recruiting documents and processes, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

You should keep your personal information on file with the Company up to date and inform us of any significant changes to it.