Table of Contents

1. Who Is Professional Case Management?
2. Scope of This Privacy Statement
3. Purpose
4. Types of Personal Information We Collect and Why We Collect it
   • Website Visitors
5. Processing of Your Personal Information
6. Marketing and Advertising
7. Your Rights and How to Exercise Them
8. Cookies and Automated Tracking Technologies
   • Universal Opt-Out Preference Signals

11. Sharing Your Personal Information with Third Parties
12. Security of Your Personal Information
13. Linked Websites
14. Data Retention
16. Children’s Online Privacy Information
17. Changes to This Privacy Statement
19. Contact Us

Who is Professional Case Management?

Act for Health, Inc., doing business as Professional Case Management (PCM), and Cold War Patriots (collectively, “PCM”, “we”, “us”, “our”) value your privacy and we are committed to protecting your personal information. This Privacy Notice applies to Professional Case Management and its activities.

Professional Case Management (“PCM”) is headquartered in Denver, Colorado, and is dedicated to providing home care services, impairment evaluations, catastrophic home health care. When you provide your personal information directly to Professional Case Management, PCM will be the controller. PCM will act as a processor or service provider when we act or provide services on behalf of an authorized third party.

If you have questions about how we use your personal information or any requests relating to your information, please email PCM’s Data Protection Officer at [email protected]. If you prefer to write or call, additional contact information can be found in the “Contact Us” section of this Notice.

Scope of This Privacy Statement

Professional Case Management has established a comprehensive privacy program designed to help us respect and protect your privacy rights. When we use information that identifies, relates to, describes, or can reasonably be linked, directly or indirectly, to an individual, (“personal information”), we use it in a reasonable and responsible way, minimizing the type of information we collect and hold about you, the period of time we store it, and the ways we use it.

In this Privacy Notice, we refer to you as “you” or “your.” We use the terms “process”, “processing”, “use” or “using” when we refer to the access, collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, disclosure, dissemination, transfer, deletion or other use of your personal information.

This Privacy Notice concerns PCM operations including outreach, client onboarding and care, project management, administration, and the use of our websites. This Privacy Notice does not apply to personal information that we process on behalf of our prospective, current, and former employees and independent contractors, which are covered in separate notices.

When using your personal information, we will do so in compliance with applicable data privacy and protection laws and regulations, including by respecting any privacy rights that may apply depending on the state in which you reside (“applicable data protection laws”).

Purpose

The purpose of this Notice is to provide our current, former and potential clients with an understanding of:

• The types of personal information we collect;
• How and why we collect your personal information;
• Who we share your personal information with;
• How we use, process, share, store, and protect your personal information; and
•  Our contact details so you can request information about the processing of your personal information and your rights to do so.

Types of Personal Information We Collect and Why We Collect it

PCM collects the following personal information:

Type of Personal Information	Categories	Why We Collect It
Identifiers and contact information	Name Title Physical address Email address Phone number Company name	To respond to inquiries; provide requested information, services, or access to events; communicate with you; maintain records; administer surveys; and where permitted, for marketing and advertising.
Client care and eligibility information	Impairment Data White Card status Date of Birth Nuclear-weapons or uranium employment information EEOICPA (Energy Employees Occupational Illness Compensation Program) or RECA (Radiation Employee Compensation Act) benefits status Health condition or diagnosis Records, e.g., a request for services Emergency Contact, Caregiver, or Alternate Contacts and other information you provide in connection with us providing our services to you (including health information)	To respond to service inquiries; determine eligibility for requested services; onboard clients; coordinate and provide care; maintain client and benefits-related records; and comply with legal, regulatory, and contractual obligations.
Commercial Information	Records of request for information or services; communication with PCM; event registrations; and survey responses	To respond to and manage requests; administer the website, including record keeping, data analysis, testing, surveys, and troubleshooting; provide information and services; administer events and surveys; maintain business records; conduct marketing and advertising; monitor aggregate trends; and ensure website security.
Internet; Device and Network Activity Information	Cookies and similar technology identifiers; IP address; browser type; internet service provider; referring/exit pages; files viewed (HTML pages, graphics, etc.); operating system; date/time stamp; clickstream data	Internet or network activity for aggregate trend monitoring; administer the website, including data analysis, testing and troubleshooting; marketing and advertising; ensure website security.

Some of the information identified above may be considered sensitive data under certain laws. If required under applicable law, we will collect and process sensitive personal information only with your consent. If you choose not to provide or allow us to collect some information, we may not be able to provide you with requested services or information.

PCM collects identifiers, contact information, client and care information, and commercial or inquiry information directly from you or from someone acting on your behalf. We collect internet, devices or network activity automatically from your use of our website. We may share these categories of personal information as described in the “Sharing your Personal Information” section.

We may ask you to voluntarily participate in a survey or poll, such as feedback on website content or services. If you choose to participate, we will explain the purpose of the survey and how we will use the information you provide. Your responses are anonymized unless you opt-in or ask to be contacted.

Website Visitors

We also collect certain data automatically on our website, including your internet and network activity information. This may include your IP address, browser type, your internet service provider, referring/exit pages, files viewed (HTML pages, graphics, etc.), operating system, date/time stamp, cookies, and clickstream data. We use this information for website administration, record keeping, data analysis, testing, troubleshooting, aggregate trend monitoring, and website security.

Please read the section below regarding “Cookies and Automated Tracking Technologies” for more information.

Processing of Your Personal Information

We use the personal information that we collect about you, or that you provide to us, for the following purposes:

• To provide our services and deliver home care;
• To enable access to our services online;
• To provide information about our services;
• To administer surveys and questionnaires available through our website;
• To respond to your requests and inquiries;
• To comply with legal obligations, resolve disputes, and enforce our agreements;
• To protect against, detect, investigate, and prevent fraudulent, harmful, unauthorized, or unlawful activity;
• To process and respond to recruitment and employment inquiries;
• To improve our services, website, and user experience;
• To fulfill any other purpose disclosed at the time the information is collected; and
• To carry out any purpose for which you have provided your consent.

Marketing and Advertising

If you have previously consented, requested information, or had a relationship with Professional Case Management, you may receive marketing materials, including emails, from PCM or our affiliates. We may use service providers to deliver these communications on our behalf.

You may opt-out of receiving promotional communications at any time by using the “unsubscribe link” or “opt-out link” in the email or by using the following opt-out form:

• Consumer (e.g. client, member, etc.): Consumer Unsubscribe
• Business (e.g. professional contacts such as doctor’s office, etc.): Business Unsubscribe

Please note that if you opt out of receiving our marketing-related emails, PCM may still need to send transactional emails regarding important service communications because of our relationship or contract with you.

Promotional and informational offers: Sometimes we send offers to certain users. To do so we may use third parties working on our behalf. We provide you with a number of ways to let us know you do not want to receive these offers. For example, where required by law, we may provide an opt-in box for customers to receive information that is sent by a third party and we make clear that, by opting in, you are submitting your data to a third party. You can elect not to receive promotional or informational material from us by following the instructions to opt-out as mentioned or included in each of our programs or communications sent to you.

Your Rights and How to Exercise Them

Depending on the state you reside in, you may have certain rights related to your personal information as set forth below. The exact scope of these rights may vary by state. There are also several exceptions where we may not have an obligation to fulfill your request.

In some circumstances we may ask for additional personal information in connection with your request if, for example, we need to verify your identity or the nature of your request. PCM will make every effort to respond in a reasonable timeframe with a determination of our responsibilities or seeking verification of the request, as per applicable Data Protection Laws.

Your Rights:

• Access and Data Portability: You may confirm whether we process your personal information and access a copy of the personal information we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information, which will be included in the response to your access request.
  • FOR COLORADO & CALIFORNIA RESIDENTS: You have the right to ask us to disclose to you any personal information we have collected about you in the last 12 months including the categories of personal information we have collected about you; the types and sources used to collect personal information about you; the types of third parties with which we have shared any of your personal information (if applicable); and the purpose(s) of collecting your personal information.

• Correction: If you believe the personal information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
• Opt-Out: You can contact us to let us know that you object to the collection or use of your personal information for certain purposes. You can choose not to disclose your information. However, if you elect to skip such disclosures, our ability to respond to inquiries or provide services will be limited to the information you chose to share.
• Deletion: You can request the deletion of some or all of your personal information from our systems, subject to certain exceptions under applicable law.
• Right to File a Complaint: You have the right to lodge a complaint about PCM’s practices with respect to your personal information with the applicable state’s Attorney General’s Office.
• DO NOT SELL: PCM does not sell any personal information.
• ADDITIONAL INFORMATION FOR COLORADO & CALIFORNIA RESIDENTS:
  • Authorized Agents: You have the right to designate an authorized agent to act on your behalf to exercise your rights. In order to do so, PCM must verify your identity, and your authorized agent must have written permission from you. We reserve the right to deny a request from an agent that does not submit proof that they are authorized to act on your behalf.
  • Non-Discrimination: You have the right to be free from unlawful discrimination for exercising your privacy rights under the law.
  • Consumers with Disabilities: PCM strives to accommodate all individuals regardless of disabilities.  If you need this information contained in this document in a different format, please contact us using the contact information below.

To make any of the following requests pursuant to your rights under the applicable privacy law, please contact Professional Case Management at [email protected] or by using the contact details below in the “Contact Us” section of this Privacy Notice. We will do our best to comply with your request(s) as soon as reasonably practicable.

Cookies and Tracking Technologies

As you navigate through and interact with our website, we or our service providers may use automated data collection technologies to collect certain information about your equipment, browsing activity and patterns, including:

• Details of your visits to our website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically helps us to improve our website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Analyze website usage trends.
• Store information about your preferences, allowing us to customize our website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). Cookies are small data files placed on your device when you visit a website. They enable the website to remember your actions, preferences, and other information related to your visit (IP address, time of visit, number of visits, login data, preferred language, time spent on the website, etc.), for a certain period of time. EmVenio and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and gather demographic information about our user base. For information regarding the cookies or similar technologies that PCM uses and how to change your preferences, please review our Cookie Statement.
• Web Beacons. Pages of our website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit PCM, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We also use customer relationship management, marketing automation, and campaign-measurement that may use cookies or similar technologies to collect information about your interaction with our website, forms, emails, and other communications, including pages visited, links selected, referring source, and form submissions. We use this information to understand campaign performance, measure marketing effectiveness, and attribute leads and conversions.

We comply with applicable data protection Laws in the collection and use of cookies and automated tracking technologies on our website, including through our cookie banner and management tool.

Universal Opt-Out Preference Signals

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data “sales” as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

Sharing Your Personal Information with Third Parties

Professional Case Management does not sell your personal information to third parties for marketing purposes.

We may disclose personal information to third parties in connection with services they perform for or with PCM as described below.

Affiliates and subsidiaries.  We may share Personal Data with our corporate affiliates including parent entities, subsidiaries, business units, or other companies that share common ownership. Access to your personal information is limited to those Company employees who need to know for work or administrative purposes.

Service Providers and Authorized Agents: We may share your personal information with companies and individuals that perform services on our behalf, such as website hosting, information technology, data storage, communications, event registration, analytics, marketing assistance, and customer support. These parties may use your personal information only as necessary to provide services to us or as otherwise permitted by law.

Professional Case Management’s practice is to (i) perform reasonable and appropriate due diligence on our service providers; and (ii) obtain written contracts regarding the processing of personal information, including that the service provider will only act in accordance with our instructions, adopt adequate technical and organizational measures, and not retain data when it is no longer required. Details concerning our service providers are available from Professional Case Management by contacting its Data Protection Officer at [email protected].

Partners and Professional Advisors: We may share personal information with business partners (including medical providers as part of your care), outreach representatives, pharmacies and durable medical equipment companies, professional advisors and advocates such as lawyers, bankers and insurers, and other individuals or organizations assisting us in providing requested services, resources, benefits information, or advocacy support. We limit what we share and provide only the minimum amount of information necessary to complete/utilize the requested products, services, or to complete a transaction. These third parties are not permitted to use your personal information except for the limited purpose of providing the requested service or information.

Government Agencies and Program Administrators. We may share your personal information with the U.S. Department of Labor (DOL), the U.S. Department of Energy (DOE), or other government agencies involved in administering programs or benefits relevant to you, including EEOICPA. We may share this information to help respond to your request for information, resources, or assistance concerning eligibility, benefits, or a claim.

Entities in connection with a corporate transaction: If we sell or transfer a business unit or an asset (such as a website) to another company, we may transfer the Personal Data collected to the relevant third party.

Law enforcement, government agencies, and other recipients for legal, security, or safety purposes. As required by law, we may respond to subpoenas, court orders, or similar legal process by disclosing your personal information and other related information, if necessary. We also may use personal information and other related information to establish or exercise our legal rights or defend against legal claims.

We may collect and possibly share personal information and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of PCM’s terms of service, or as otherwise required by law.

Further, our websites and services may provide links to other third-party websites and services which are outside our control and not covered by this Privacy Notice. We encourage you to review the privacy notices posted on these (and all) sites you visit or services you use.

Security of Your Personal Information

Professional Case Management is committed to protecting the personal information you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your personal information from unauthorized access, use or disclosure.

Data in Transit: When we transfer personal information over the Internet, we protect it using multiple encryption methods as required by system protocols.

Data at Rest: Where appropriate, we use encryption, pseudonymization (such as key coding), de-identification and other technologies that can assist us in securing the information about you, including measures to restore access to your information.

Service Providers: We require our service providers to comply with reasonable and recognized data privacy and security requirements.

We recommend you take every precaution in protecting your personal information when you are on the Internet: change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser. If you have any questions about the security of your personal information, you can contact us at [email protected] or by using the contact details below in the “Contact Us” section of this Privacy Notice.

Linked Websites

Our websites and services may provide links to other third-party websites and services which are outside our control and not covered by this Privacy Notice. We encourage you to review the privacy policies/statements/notices posted on these (and all) sites you visit or services you use.

Data Retention

We keep the categories of personal information described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal information. At the end of the retention period, personal information will be deleted, destroyed, or de-identified.

Children’s Online Privacy Information

Our Services are not intended for, and we do not knowingly collect any personal information from, children under the age of 18. We do not knowingly collect personal information from individuals under 18. If we learn that we have collected personal information from an individual under 18 without appropriate consent, we will delete the information.

If you believe that we have mistakenly or unintentionally collected the personal information of a minor under the age of 18, please notify us at [email protected].

Changes to This Privacy Notice

We may make changes to this Notice from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business. Any changes made in the future will be posted on this page.