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Epic Privacy Notice for California Residents

Effective Date: January 1, 2020

This Privacy Notice for California Residents (“Notice”) supplements the information contained in Epic Systems Corporation’s (“Epic” or “we”) privacy policies and applies to visitors and users who reside in the State of California (“consumers” or “you”). We provide this notice in compliance with the California Consumer Privacy Act of 2018 (CCPA). Certain terms in this Notice are defined by the CCPA and their meanings may differ from the meanings that apply elsewhere on our websites.

The CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information“) from some of its requirements. This exemption is referenced, where applicable, in the Notice.

Notice Scope

This Notice applies to your use of publicly-available Epic resources available via the internet, which include but are not limited to: Epic.com, Epic’s Careers website, UserWeb and UserWeb-connected websites, Epic Earth, Open.epic, App Orchard, Epic USCDI on FHIR, websites for UGM and other Epic-hosted events, Lucy, MyChartCentral, and Epic’s mobile applications, such as MyChart (each item is an “Epic Website or Mobile Application”).

Personal Information We May Collect

By using an Epic Website or Mobile Application, you may provide Epic with information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you, your household, or your device (“personal information“). Please review the privacy policy associated with the Epic Website or Mobile Application you use to review the personal information you may provide to Epic during your use.

In particular, Epic has received the following categories of personal information from users of Epic Websites or Mobile Applications within the last 12 months (indicated with a “Yes”):

 

Category Examples Collected
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. Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). 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.

Yes
C. Protected classification characteristics under California 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).

 

Careers.epic.com: Yes

 

Other Epic Websites or Mobile Applications: No

D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No
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
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes
G. Geolocation data. Physical location or movements. No
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No
I. Professional or employment-related information. Current or past job history or performance evaluations. Careers.epic.com, UserWeb and UserWeb-Connected Sites, Epic Earth, App Orchard, Open.epic: Yes

 

Other Epic Websites or Mobile Applications: No

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. Careers.epic.com: Yes

 

Other Epic Websites or Mobile Applications: No

K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Careers.epic.com: Yes

 

Other Epic Websites or Mobile Applications: No

Potential Sources of Personal Information

Epic Websites and Mobile Applications obtain personal information from the following categories of sources:

  • Directly from you. For example, from forms you complete, communications you send, job applications you fill out, etc.
  • Indirectly from you. For example, from observing your actions on the Epic Websites and Mobile Applications.
  • From your representative. For example, someone at your organization may provide Epic with information to create a UserWeb account on your behalf, register you for an Epic-hosted event, list you as a developer for an application on App Orchard, etc.

How We May Use Personal Information

We may use personal information for the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to apply for a job or ask a question about our products or services, we will use that personal information to respond to you.
  • To provide, support, personalize, and develop Epic Websites or Mobile Applications.
  • To create, maintain, customize, and secure your account on any of our websites that require a personal login.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your experience on Epic Websites or Mobile Applications and to deliver content relevant to your interests.
  • To help maintain the safety, security, and integrity of Epic Websites and Mobile Applications, products and services, databases and other technology assets, and business.
  • For testing, analysis, and product development, including to develop and improve our Epic Websites or Mobile Applications.
  • 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.

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. Please review the privacy policy associated with the Epic Website or Mobile Application you use in order to review the specific ways in which your information may be used.

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 a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Please review the privacy policy associated with the Epic Website or Mobile Application you use in order to review the individuals or third parties that may have access to your personal information.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Epic 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 classification characteristics under California or federal law.

Category F: Internet or other similar network activity.

Category I: Professional or employment-related information.

Category J: Non-public education information.

Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to our third party service providers. We do not sell your 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 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 (see Exercising Access, Data Portability, and Deletion Rights), 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 you.
  • Our business or commercial purpose for collecting 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 disclosed your personal information for a business purpose, a list of the disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for B2B personal information.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 provider(s) to:

  1. Complete a transaction for which we collected the personal information, provide something that you requested, take actions reasonably anticipated within the context of our ongoing relationship with you, or fulfill any legal obligations we may have.
  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 for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B personal 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:

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. To designate an authorized agent, email us at PrivacyInquiries@epic.com and include a designation of your authorized agent in your email, including the agent’s name, email address, and other relevant information that will help us identify your authorized agent.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 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, which may include:
    • First, Middle (if available), and Last Name
    • California address
    • Valid email address
  • 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.

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 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 usable and should allow you to transmit the information from one entity to another entity.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services or provide you a different level or quality of goods or services for exercising any of your CCPA rights.

Changes to Our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on this website and update the Notice’s effective date. Your continued use of an Epic Website or Mobile Application following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Notice, the ways in which Epic collects and uses your information described here and in the privacy policy associated with the Epic Website or Mobile Application you use, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 608-271-9000

Email: PrivacyInquiries@epic.com

Postal Address:

Epic Systems Corporation

Attn: General Counsel

1979 Milky Way

Verona, WI 53593