Passport Analytics U.S. supplemental privacy policy
Effective date: July 1, 2024 (last updated October 1, 2024)
This Privacy Notice (the ”Notice”) for California residents supplements the information in the Passport Analytics Privacy Policy (the ”Privacy Policy”). References to “we” and “us” means Definitive Healthcare’s wholly owned subsidiary Analytical Wizards Inc.It is applicable only for Personal Information collected or processed by us from or about residents of U.S. states with comprehensive privacy laws (collectively, hereafter, “Comprehensive State Privacy Laws”), including, for example: the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CPRA”), together referred to as (“CCPA”); the Colorado Privacy Act (“CPA”); the Connecticut Personal Data Privacy and Online Monitoring Act (“CTDPA”); the Virginia Consumer Data Protection Act (“VCDPA”); the Oregon Consumer Data Privacy Act (“OCDPA”); the Texas Data Privacy and Security Act (“TDPSA”), the Montana Consumer Data Privacy Act (“MTCDPA”) and similar state privacy and data protection laws. This Supplement describes the categories of Personal Information that we may collect or process from U.S. residents in those states, how we may use and disclose that Personal Information, and how you may exercise any rights you may have regarding our processing of your Personal Information.
Personal Information subject to this Supplement does not include the information covered by certain federal and state laws, such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA), clinical trials, or other exemptions as described in Comprehensive State Privacy Laws. In addition, even Personal Information covered in this Supplement may be collected and processed—including by disclosure to governmental entities or third parties—outside the requirements of this Supplement where applicable Comprehensive State Privacy Laws allow, including where such action is necessary to comply with federal, state, and local laws; to prepare for any law suit; to protect the vital interests of a consumer or other individual; to act in the public interest in areas of public health; to cooperate with government authorities; or to protect against security threats and illegal, fraudulent, or malicious activity and any subsequent investigation of that activity.
This Supplement uses the terms “consumer,” “personal data” or “personal information,” and “sale” as defined in their respective laws. References to “Personal Information” include personal data or personal information as defined under Comprehensive State Privacy Laws.
This Notice shall not apply to any situations where we act as a Service Provider (as defined in the CCPA) on behalf of a customer in respect of certain business information. See Section Applicability of this Privacy Policy in the Privacy Policy for more information. In such case(s) the customer for whom we process consumer information is responsible for acting in all matters in accordance with all applicable laws and providing you with all requisite information as required by applicable law. To the extent we process your consumer information for any other lawful business purpose of ours, under the CCPA, to the extent applicable, we will act as a business with respect to such consumer information and this Notice will apply to the processing of such consumer information.
In the preceding twelve (12) months, Analytical Wizards has not sold, nor does it or will it sell, consumer information that is subject to this Privacy Policy.
1.1 Personal information collected. In the past 12 months, we may have collected, processed the following categories of Personal Information in developing and providing the Passport Analytics products and Services and we license such Services to categories of third parties as described in the table below:
| Category | Examples | Business or commercial purposes for which we collect, use consumer information |
| A. Identifiers. | Name, e-mail address, job title, postal address, age, birthday, company, support chat transcripts, city, country, continent, IP address, online identifier, telephone number, prospective use-case interests, and any other information you may choose to share with us or which we state we collect as per the Privacy Policy |
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| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Name, telephone number, postal address, and job title. |
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| C. Internet or other similar network activity. | IP address, search history, user log-in information, language, internet service provider, demographic information, browser types, browser system, unique device identifiers, email client, device types, requested URL, referring URL, traffic source, browser language, the date and time of your visit, location (city, country, continent), the duration of your visit, operating system, domain names, general usage data, and statistical data involving the use of the Services. |
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1.2 Use of consumer information; Categories of sources. We use consumer information for the business or commercial purposes described in the table above and in the manner described in the Privacy Policy with respect to personal information. We also receive information that is otherwise collected when you engage with us as described in the Privacy Policy. Regarding the categories of sources from which consumer information is collected, we collect consumer information that you submit to us, including when you engage in direct communication with one of our representatives. We may receive consumer information from or about you when you sign up for or participate in a Webinar, or when you contact us for a support call. If we receive a question for support, we collect and store the question as well as the answer to the question. We also collect aggregated statistics connected to support issues. Finally, we receive information about you when you are a user when you register an account as well as from the enterprise customer you represent.
1.3 Disclosures of consumer information for a business or commercial purpose. We may disclose your consumer information described in the table above to a third party for a business or commercial purpose, as described in the table above and in the section of the Privacy Policy entitled How your information is shared with respect to personal information. In the preceding twelve (12) months, we have disclosed each of the categories of consumer information described in the table above for a business or commercial purpose to the categories of third parties as further described in the Privacy Policy.
During the last year, we have disclosed Personal Information to service providers (e.g., cloud computing and storage vendors; security contractors, and consultants), for our own operational business purposes.
1.4 Your privacy rights
As a resident of a state with a Comprehensive State Privacy Law, you may have some of the following privacy rights, subject to some limitations or exemptions as required or allowed by law:
- To opt-out of sharing your Personal Information for cross-context behavioral advertising or, in other states, to opt-out of targeted advertising;
- To opt-out of the sale of your Personal Information;
- To request to know and access your Personal Information which we have collected or processed;
- To obtain a copy of your Personal Information, i.e., a right to data portability;
- To request that we correct your Personal Information;
- To request that we delete your Personal Information;
- To request that we limit the use of your Sensitive Personal Information (if applicable);
- To opt-out of processing of Sensitive Personal Information;
- To not be discriminated against for exercising any of the rights above; and
- To appeal the denial of a request, including in some states to lodge a complaint with the Attorney General.
If you wish to exercise your privacy rights, please submit a Privacy Rights Request by:
E-mail: aw-privacy@definitivehc.com
Phone: 1-866-679-6461
Verifiable requests
We will make reasonable efforts to promptly respond to your requests in accordance with applicable laws, but your rights under Comprehensive State Privacy Laws are not absolute. For example, any such request must provide sufficient information that allows us to verify that you are the consumer whose Personal Information we have collected. We may, after receiving your request, require additional information from you to honor your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.
Requests by Authorized Agents
Where required by applicable Comprehensive State Privacy Laws, we permit residents of certain states to designate an authorized agent to submit certain requests on your behalf, as outlined below.
California residents may designate an authorized agent to submit a request to opt-out of sale or share of Personal Information, to limit the use of Sensitive Personal Information, or to access, correct, or delete your Personal Information. In each case, the agent must provide us with documentation demonstrating that you have provided signed permission to the agent to exercise these rights with us on your behalf. We may deny the request if we do not receive such proof. In addition, for requests to access, correct, or delete your Personal Information, we may also require you to do either of the following: (1) verify your own identity directly with us; or (2) directly confirm with us that you have provided the authorized agent permission to submit the request on your behalf. These requirements of proof do not apply if the agent has a power of attorney pursuant to California Probate Code.
Colorado, Connecticut, Oregon, Montana, and Texas residents may designate an authorized agent to submit a request to opt-out out of our processing of personal data for the purposes of targeted advertising or sale. If you use an authorized agent to submit a request, we will not act on that request unless we are able to authenticate, with commercially reasonable effort, both your identity and the authorized agent’s authority to act on your behalf.For all requests via authorized agents, we require that your agent provide us with your Personal Information as required on the request form and provide signed documentation demonstrating that you authorized the agent to submit a request on your behalf. The request must also include sufficient detail that allows us to properly understand, evaluate, and respond to the request. If we need more information to process your request, we will contact you via e-mail or in writing.
Authorized agents may submit requests using one of the following designated methods.
By E-mail: aw-privacy@definitvehc.com
By Phone: 1-866-679-6461
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with your state’s law pertaining to powers of attorney.
Children’s information
Our products and services are directed at business professionals and are not targeted to children under the age of 18. We do not knowingly collect or maintain any Personal Information for children under the age of 18. If we discover we have collected any information for persons under the age of 18, we will delete their Personal Information.
Questions?
We committed to protecting the privacy of Consumers’ Personal Information and being transparent about our privacy practices. To exercise any rights, you might be entitled to under applicable Comprehensive State Privacy Laws, please utilize the designated mechanisms provided in the “Your Privacy Rights” section, above. For other questions, comments, or feedback on this Supplement or our Privacy Policy, please contact us through the Definitive Healthcare-privacy team:
E-mail: aw-privacy@definitvehc.com
Phone: 1-866-679-6461
Mail:
Definitive Healthcare
Attn: Privacy Team
492 Old Connecticut Path
Suite 401
Framingham, MA 01701