Privacy Policy

Last Updated: June 24, 2025

PDS Health, including its affiliates (collectively, “PDS Health”, “we”, “us”, “our”), is committed to protecting your privacy. This Privacy Policy (‘Policy’) describes how PDS Health (‘PDS Health,’ ‘we,’ ‘us’ or ‘our’) collects, uses, and discloses personal information when you use our corporate website (the ‘Site’) or otherwise interact with us online or offline (the “Services”).

This Privacy Policy does NOT apply to:

• Dental Office and Medical Office Websites: Websites we host for affiliated dental and medical practices post their own privacy notices; this Policy does not apply to them.
• Patient Health Information: This Policy does not govern patient health information (including information subject to HIPAA) available through patient portals such as PDS Health MyChart. For those practices, please see the Dental Office and Medical Offices’ Notice of Privacy Practices.
• Workforce Application Information: This Policy does not cover personal information provided to us or collected by us about a person in the course of the person acting as a job applicant or employee, which is covered by our Employee and Applicant Privacy Notice.
• Third Party Links: The Site may contain links that will let you leave the Site and access another website. Linked websites are not under our control. We accept no responsibility or liability for these other websites.

1 Changes to this Policy

From time to time, we may change this Policy. If we do, we will post an amended version on this webpage. Please review this Policy periodically. 

2 Personal Data We Collect

We collect personal data from you through your use of the Site and Services. We collect the following types of personal information.

2.1 Personal Data You Provide

We collect personal information when you provide it directly to us, such as when you provide information online or in person, type information into and submit forms, or otherwise provide us with information via phone, email, or other communications. This occurs primarily in the following ways:

• Contact Information. This may include your name, email address, mailing address, phone number, username, or similar information.
• Submitted Content. If you submit content, such as messages or files, to use through the Service, we will collect any personal information contained in the submitted content. 

2.2 Personal Data Automatically Captured When You Use Our Site

We use cookies, pixels, and similar technologies (‘Data Collection Tools’) to collect the following information (‘Site Data’):

• Device & Browser Information. We collect device and browser identifiers (e.g., IP address, cookie ID, browser type, screen resolution).
• Site Interaction Data. We collect data about how you navigate to/from our Site (such as the URLs that referred you to our website), your browsing activity (such as the web pages you viewed), and your navigation activity (such as the buttons you clicked, your mouse movements, and whether you interacted with various features on the Site).
• User Preferences. We record your online preferences, such as communication preferences, language, time/zone, and general location information, and privacy choices and configurations.
• Location Information.  We may collect and store information about your general location by converting your IP address into a rough geo-location, so we can, for example, provide you with information about opportunities or resources in your geographic market. We may also access your mobile device’s GPS coordinates or course location, but only if you have previously agreed that we can collect this information by allowing the sharing of your location information. If you do not want us to have your location information, you may disable the location sharing feature on your device or browser.

2.3 Personal Data We Collect From Other Sources

We obtain information from businesses which provide us with our business and Services, such as our data analytics providers, marketing or advertising service providers, fraud prevention service providers, vendors that provide services on our behalf, and publicly available sources. We also create information based on our analysis of the information we have collected from you, which are sometimes referred to as “inferences.”

3 How We Use Your Personal Data

We use personal information for several purposes, including to provide our Site and continually improve it. This section provides an overview of the purposes for which your personal data is used. Please note that the actual information collected, and its use, may vary depending on your interactions with us and the features of the Site you choose to use.

• Operating our Site. Some personal data is required to provide our Site, and its various features and functionalities, to you.  For example, we need to collect Device and Browser Information to ensure that the Site is presented to you in a safe and secure manner on the device through which you access it. 
• Communications and Support. We use your personal information to communicate with you in response to your requests or inquiries, to provide updates, notices, newsletters, surveys, to request feedback, or as necessary to fulfill our obligations to you.
• Our Business Operations. Personal information is used to: (i) make strategic decisions concerning our business operations; (ii) enforce and review compliance with the legal terms that govern our offerings; (iii) comply with our legal obligations; (iv) protect the rights, safety, and property of our Services and of other individuals; (v) anonymize, aggregate, and/or de-identify your personal information (so it can no longer identify you) in furtherance of conducting research and analysis; and (vi) facilitate our other business operations such as record keeping, training and development, generating business intelligence reports, strategic decision making.
• Advertising.  We share personal information with vendors to prepare, serve, and analyze advertising content, including cross-contextual advertisements.
• Analytics/Personalization. We use personal information to research and analyze how you interact with our Services, including our advertisements. Personal information is used to enhance your experience with our Services, we may use your data to personalize features, content, and recommendations, in line with applicable laws and your preferences.
• With Your Consent. We use information about you where you have given us consent to do so for a specific purpose not listed. 
• Additional Uses Described. If we use personal information in ways other than as described here, we will provide a description of the purposes for collection and use at the time of such collection
  
  

  While less frequent, there are other scenarios where we may use or disclose your personal information:

  
  
• Audits Involving External Entities. We may share personal data with external organizations, including those we collaborate with or those that evaluate our business operations, to ensure compliance with industry standards, certifications, or legal obligations.
• Legal Obligations. My may need to share personal data to fulfill legal obligations such as responding to subpoenas, court orders, or other binding government requests. In the rare event of litigation, we may use your data to establish, exercise, or defend legal claims.
• Reorganization. If a business transaction such as a sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization occurs, your personal information may be shared or transferred.

4 Disclosure of Your Personal Data

Depending on how you interact with our Services, we may share your personal data with various third parties who assist of with our processing activities. These parties include: 

• Other PDS Health-Affiliated Entities. We may share personal information with other PDS Health affiliate entities that are related by common ownership or control. We share personal information for our routine business purposes and to develop new and improve existing services.
• Website Services Providers. These are entities who assist us in maintaining our Site. In many instances, these parties use their own servers to serve the content and features to your browser and require Site Data in order to do so. They include the following:
  
  - Web Hosting Providers. Our website hosting and infrastructure providers.
  - Font and Content Providers. Various third parties assist us in providing content, including videos, and other features for our Services.
  - Functionality Providers. Third parties assist us in providing various online functionality, such as our accessibility tools, and consent management tools. 
  - Analytics and Advertising Providers. We allow third-party partners and service providers (such as advertising networks, analytics providers, and social media platforms and networks) to gather data when you interact with our Services for our analytics and marketing purposes, including to help manage and display advertisements, to tailor advertisements to your interests, and target you on other websites (depending on your communication preferences). These parties use their technology to provide advertising about products and services tailored to your interests which may appear either on our Site or on other websites.
• Business Services Providers. These are persons or entities with whom we have a relationship to provide business operations services and support to PDS Health. These companies, known as “service providers,” are contractually obligated to use your data only for the service they're providing and cannot use it for anything else. These providers may include the following:
  
  - IT Operations Providers. These include cloud computing service providers, internet service providers, data backup and security providers, functionality and infrastructure providers, and similar service providers.
  - Business Operations Providers. These include service providers with whom we partner to provide day-to-day business operations, including payment processors, security vendors, business software service providers, banks, facilities management providers and similar entities.
  - Professional Service Providers. These include lawyers, accountants, consultants, security professionals, and other similar parties when disclosure is reasonably necessary to comply with our legal and contractual obligations, prevent or respond to fraud or abuse, defend ourselves against attacks, or protect the rights, property, and safety of us, our customers, and the public.
• Marketing and Advertising Providers. These include advertising, direct marketing, and lead generation providers, affiliate marketing program providers, retargeting platforms, data brokers, ad networks, marketing consultants, and similar services providers.
• Law Enforcement/Government Agencies. These include entities to whom we are required by law to provide information, such as a court pursuant to a subpoena or a court order.
• Corporate Transaction Disclosures. These include persons involved in the consideration, negotiation, completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.
• Authorized Disclosures. We may disclose personal data to any party when authorized by the individual to whom it pertains to share it.

5 Universal Opt-Out Mechanisms

The Site recognizes the Global Privacy Control (“GPC”) signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Some internet browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Because browsers do not send the Do Not Track signal consistently, the Site does not respond to it.

6 Data Retention

We retain personal information only as long as needed to fulfill the purposes we collected it for, including satisfying legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider (i) the amount, nature, and sensitivity of the personal information; (ii) the potential risk of harm from unauthorized use or disclosure of your personal information; (iii) the purposes for which we process your personal information and whether we can achieve those purposes through other means; and (iv) the applicable legal requirements related to our processing activities. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.  If you have any questions about the specific retention periods for different types of your personal information, please feel free to contact us.

7 Children’s Privacy

The Site and Services are not intended for children under 16 years of age. We do not knowingly collect, use, or disclose personal data from children under 16.

8 Adjusting Communication Preferences

Below are the avenues through which you can manage the types of communications you receive from us:

• Email: To opt out of promotional emails, you may follow the ‘unsubscribe’ instructions located at the bottom of each email. Alternatively, you may contact us directly using the information provided in the Contact Information section. Please be advised that opting out of promotional communications will not preclude you from receiving transactional emails, such as those related to purchases or account activity.
• Text Messages: To discontinue receiving automated text notifications, simply reply ‘STOP’ to any of our messages, or use any alternative opt-out keyword we may have provided.
• Mail Promotions: Should you wish to be removed from our mailing list for physical promotions and solicitations, please send a written request to our customer service department using the address provided in the Contact Information section of this Policy. Ensure your full name and mailing address are included in your correspondence.

9 Security

We implement recognized physical, technical, and organizational safeguards tailored to protect the confidentiality, integrity, and availability of the specific categories of personal information we collect and process. These safeguards are designed to prevent unauthorized or unlawful access, destruction, loss, alteration, or disclosure of your personal information. However, despite our best efforts, no controls can provide absolute protection against all security threats, and we cannot guarantee that unauthorized access or loss will never occur. We have procedures in place to deal with any suspected data security breach. We will notify you and/or any applicable regulator of a suspected data security breach where we are legally required to do so in accordance with any legally prescribed timeframes.

10 Your Privacy Rights

10.1 Description of Your Privacy Rights

Based on the legal requirements applicable to your jurisdiction, and subject to any legal restrictions or exceptions, you may request to exercise your privacy rights as described below, which may be limited by applicable laws and regulations. We will acknowledge and coordinate these requests as timely as possible. We will not discriminate against you for exercising any of your privacy rights.

Your Privacy Rights

• Access/Know. Request confirmation from us as to whether or not your personal data is being processed by PDS Health and, if so, access to such data and/or the more detailed circumstances of the data processing.
• Correction/Rectification. Request that we correct any inaccurate personal data relating to you without undue delay. In this context, taking into account the purposes of the processing, you may also have the right to request the completion of incomplete personal data - also by means of a supplementary declaration.
• Deletion/Erasure. Request that your personal data be deleted without undue delay. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if the processing is necessary for the performance of a contract.
• Opt-Out of Targeted Advertising. Request that PDS Health not use your personal data from third parties, or disclose, disseminate, or transfer your personal data to a third party, for PDS Health’s targeted advertising or marketing purposes (also known as “cross-context behavioral advertising”). You may opt out of this activity by:
  
  - Clicking on the “Your Privacy Rights” link at the bottom of the website and opting out of Targeting/Advertising Cookies. 
  - California residents have the right to opt-out of the “sale” or “sharing” of your personal information with third parties who are not our service providers (as those terms are defined under the CCPA and CPRA). To exercise this right, click the “Your Privacy Rights” link on the bottom of the webpage where your information is being collected and select “Do Not Sell/Share My Information.”
  - Additional information on how to opt out of targeted advertising in your browser on a specific device is available at http://optout.aboutads.info and http://optout.networkadvertising.org.
• Portability. Request that we provide a copy of the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, and transfer this data to another controller without hindrance from us, where feasible.
• Restriction of Processing. Request that we restrict processing of your personal data. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if we can demonstrate compelling legitimate grounds otherwise.
• Consent Withdrawal. Withdraw your consent that you have previously provided for PDS Health’s collection, use or disclosure of your personal data, subject to reasonable notice and any contractual or legal exceptions. Note that this will not affect the lawfulness of our processing of your personal data based on consent before its withdrawal.
• Automated Individual Decision-Making. Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Note that this right shall not apply if such a decision is necessary as part of a contract we have with or want to conclude with you, we have your consent, or we are permitted by law to engage in such automated decision making. In these cases, we will implement measures to safeguard your rights and freedoms and legitimate interests and you may contest the decision by contacting us as set forth in Section 12 (“Contact Us”) below.
• Complaints. Lodge a complaint with a supervisory authority at any time if you are of the opinion that the processing of personal data relating to you violates applicable law.
• Limit Use and Disclosure of Certain Sensitive Personal Information. Direct us to limit our use of certain sensitive personal data to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer. In certain cases PDS Health may collect your precise geolocation for purposes of providing content relevant to you and based on your consent. PDS Health does not otherwise use sensitive personal information beyond what is necessary to perform the services or provide the goods that have been requested of us.
• Appeal. Appeal our refusal to take action on your request within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us as described in Section 12 (“Contact Us”).

10.2 Exercising Your Privacy Rights

To exercise the above privacy rights, please visit our Privacy Rights Request Form or email privacy@pacden.com.

If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in this section. We will process the agent’s request consistent with applicable law. As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity and/or confirm that you provided the agent permission to submit the request. If you use an authorized agent to submit a request to exercise your rights, please have the authorized agent take the following steps in addition to the steps described above:

• Mail a copy of your signed written declaration authorizing the authorized agent to act on your behalf to privacy@pacden.com; and
• Provide any information we request in our response to your email to verify your identity. The information requested will depend on your prior interactions with us and the sensitivity of the personal information at issue.
• If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

Please note that not all requests will be granted. Certain legal exceptions may apply, such as if we are unable to verify your identity, or if there are legal or contractual reasons that prevent us from fulfilling a deletion request. Regardless of the outcome, you will receive a written response that either details the actions we took or explains why no action was possible. If you are dissatisfied with our initial response, you may seek further review. To initiate an appeal, please contact us within 30 days of receiving our initial response using the method provided in the response. You should include a copy of your original request, our response, and a detailed explanation of why you are seeking reconsideration. You may also attach any additional supporting information and documents that you believe are relevant. We will review your appeal and provide a final determination within 60 days.

11 California Privacy Rights

This section is tailored to meet the specific requirements imposed by California law. While this section outlines state-specific rights for California residents, the preceding sections of this Policy also apply to them.

11.1 Additional Notice to California Residents

California law requires us to disclose the following additional information with respect to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of the Policy.

Sources and Uses of Personal Information. We collect and use the categories of personal information listed above as described in Section 2 (“Personal Data We Collect").

11.2 California-specific Privacy Rights

California law grants specific rights to California consumers regarding their personal information. Note that these may be duplicative of the rights described above in “Your Privacy Rights.” They are as follows:

• Access to Personal Information. You can request (a) the categories of personal information we collected about you and the categories of sources from which we collected such personal information; (b) the business or commercial purpose for collecting or “sharing” personal information about you; (c) the categories of personal information about you that we “shared” and the categories of third parties to whom we “shared” such personal information; and (d) the categories of personal information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such personal information. We have made this information available to you without having to request it by including it in this Notice. Up to two times each year, you can request that we disclose the categories and/or specific pieces of personal information that we collect, use, disclose, and may sell.
• Correction of Personal Information. You have the right to have inaccurate personal information corrected.
• Deletion of Personal Information. You can ask us to delete the personal information that we have collected from you, subject to certain exceptions such as to complete a transaction for you, to exercise our rights, or to comply with a legal obligation.
• Sales of Personal Information. In the preceding twelve (12) months, PDS Health has not “sold” personal information as this term is defined in the CCPA.
• "Sharing" of Personal Information. The CCPA defines “sharing” as disclosing, disseminating, or transferring a consumer’s personal information to a third party for cross-context behavioral advertising. In the preceding twelve (12) months, PDS Health has shared certain categories of personal information (identified in the above table) with third-party advertisers to tailor ads to consumers’ interests. You have the right to opt out of your personal information being shared for targeted advertising. To exercise this right, click the “Your Privacy Rights” link on the bottom of the webpage where your information is being collected and select “Do Not Sell or Share My Personal Information.”
• Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to direct us to limit our use of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer. PDS Health does not otherwise use sensitive personal information beyond what is necessary to perform the services or provide the goods that have been requested of us.
• No Retaliation. You are entitled to exercise the rights described above free from retaliation as prohibited by the CCPA.

To exercise your California privacy rights, please see the information in Section 10.2 (“Exercising Your Privacy Rights”).

11.3 Additional California Notices

• Financial Incentives. We may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

12 Contact Information

If you have any questions or concerns about this Policy or our data practices, you can contact us through the following means:

Email:  privacy@pacden.com 

Mail: Compliance Department, PDS Health, 17000 Red Hill Avenue, Irvine, California 92614

Phone: 888-508-2033