Effective as of January 25, 2021.

This “Privacy Policy” describes the privacy practices of COVID Check Colorado LLC and our subsidiaries and affiliates (collectively, “CCC”, “we”, “us”, or “our”) in connection with all services CCC provides in facilitating SARS-CoV-2 (“COVID-19”) testing, vaccination, and operating the COVIDCheckColorado.org website any other website that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to individuals with respect to their information.  CCC may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. These supplemental privacy policies will govern how we may process the information in the context of the specific product or service.

About CCC

COVID Check Colorado, LLC is a limited liability company created to coordinate a testing, tracing, and response infrastructure to support employers, schools, and childcare providers as they plan for a safe return to work, schools, and child care facilities during and following the SARS-CoV-2 (“COVID-19”) pandemic. CCC is a social benefit enterprise of the Gary Community Investments Company, a certified B Corp.

CCC’s purpose in collecting data is to help respond to the COVID-19 pandemic by providing for testing, contact tracing, and exposure alerting. Any data collected on the Service will be used to help our partners and clients respond to COVID-19 outbreaks. Some of the data collected may contribute to research regarding COVID-19. None of the data collected will be sold to third-party entities for purposes of advertising.

Your interactions with CCC and use of the Service are voluntary. You can at any time direct us to delete your personal information by contacting us at legal@covidcheckcolorado.org. However, doing so may prevent CCC from facilitating any COVID-19 testing, vaccination, or providing any associated services.

Table of Contents

  • Personal Information We Collect
  • How We Use Your Personal Information
  • How We Share your Personal Information
  • Your Choices
  • Other sites, mobile applications and services
  • Security practices
  • International data transfers
  • Children
  • Changes to this Privacy Policy
  • How to Contact Us

Personal Information We Collect

Information you provide to us.  Personal information you provide to us through the Service or otherwise includes:

  • Contact information, such as your first and last name, email and mailing addresses, and phone number.
  • Profile information, such as your gender, date of birth, and the employer, school, childcare provider, or other organization that referred you to CCC.
  • Insurance information, such as the name of the insurer and any related policy, group, or plan information.
  • Appointment information, such as the date, time, location or other information that may be related to appointments you make.
  • Testing information, including the transaction identification number associated with your COVID-19 tests, test sample information, and test results.
  • Vaccination information, including medical history and other health information necessary to facilitate COVID-19 vaccinations.
  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
  • Usage information, such as information about how you use the Service and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Service.
  • Communications information, such as your preferences for receiving communications from CCC and details about how you engage with our communications.
  • Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from other third parties.  We may receive personal information about you from third-party sources. For example, a partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.

Cookies and Other Information Collected by Automated Means

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access.  Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons.

A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Browser web storage, or LSOs, are used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our websites.

Web browsers may offer users of our websites or mobile apps the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. Please see the “Targeted online advertising” section for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Service.  We use your personal information to:

  • provide, operate and improve the Service
  • to facilitate testing for the COVID-19 infection
  • to facilitate COVID-19 vaccinations
  • provide information about our products and services
  • establish and maintain your user profile on the Service
  • communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages
  • communicate with you about appointments
  • provide support and maintenance for the Service
  • to respond to your requests, questions and feedback

For research and development.  We analyze use of the Service to analyze and improve the Service and to develop new products and services, including by studying user demographics and use of the Service.

To send you communications.  We may send you CCC-related newsletters or other communications as permitted by law. You will have the ability to opt-out of our communications as described in the Opt out of communications section below.

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety.  We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent.  In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data.  We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you.  We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

How We Share your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Testing and vaccination partners. We may share your personal information with testing and vaccination partners in order to facilitate testing and vaccination for the COVID-19 infection as outlined below.

  • Clinic partners. We may share your Contact information, Profile information, Insurance information, Appointment information and Testing information with clinics in order to facilitate the collection of samples necessary to conduct testing for the COVID-19 infection.
  • Lab partners. We may share your Contact information, Profile information, Insurance information, and Testing information with labs in order to facilitate testing for the COVID-19 infection.
  • Exposure Alerting partners. We may share your Contact information, Profile information, Insurance information, and Testing information with labs in order to facilitate contract tracing and alerting associated with COVID-19 infections.
  • Vaccination partners. We may share your Contact information, Profile information, Appointment information, Insurance information, and Vaccination information with medical providers in order to facilitate vaccination for the COVID-19 infection.
  • Insurance companies. We may share your Contact information, Profile information, Appointment information, Insurance information, Vaccination information and Testing information with insurance companies, at your direction, for billing purposes.

Public health organizations. We may share your Contact information, Profile information, Vaccination information and Testing information with public health organizations, such as the Center for Disease Control, Colorado Department of Public Health and Environment and local public health agencies in order to make any disclosure specifically required or permitted by law.   We may share your personal information with CORHIO in order to facilitate the transfer of medical records to the state of Colorado.

COVID-19 research. We may share de-identified and/or anonymized information with research partners in order to facilitate further research on the COVID-19 infection.

Affiliates.  We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers.  We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, email delivery, marketing, and data management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.

Reporting. CCC and its test registration and resulting platform, Primary.Health, utilize the services of ReportStream to report test results to the Colorado Department of Public Health and Environment (CDPHE). Disclosure to CDPHE is required by law, and ReportStream is utilized to ensure secure transmission of this protected information. All data is encrypted in transcript, and all data is encrypted when stored using facilities of a secured Federal Risk and Authorization Management Program (FedRAMP) accredited environment. In addition, ReportStream complies with the Federal Information System Modernization Act (FISMA) of 2014. ReportStream was created by the Centers for Disease Control and Prevention and the U.S. Digital Service. For more information, please visit ReportStream’s website at https://reportstream.cdc.gov.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers.  We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or pomary.Healthtential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Your Choices

In this section, we describe the rights and choices available to all users.

Access or Update Your Information. If you have registered for an account with us or one of our partners through the Service, you may review and update certain personal information in your account profile by logging into that account.

Opt out of communications.  You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at support@covidcheckcolorado.org.  You may continue to receive service-related and other non-marketing emails.

Cookies & Browser Web Storage.  We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third party websites. Most browsers let you remove or reject cookies.  To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings.  Please note that if you set your browser to disable cookies, the Sites may not work properly.  Similarly, your browser settings may allow you to clear your browser web storage.

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services.  We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

Other sites, mobile applications and services

The Service may contain links to other websites, mobile applications, and other online services operated by third parties.  These links are not an endorsement of, or representation that we are affiliated with, any third party.  In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions.  Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information.  We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security practices

The security of your personal information is important to us.  We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect.  However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfers

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

Children

We do not knowingly collect any personal information from children under 13 unless a parent or legal guardian has reviewed and agreed to all applicable terms of the Service on the child’s behalf.

If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.  We encourage parents with concerns to contact us.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to legal@covidcheckcolorado.org. You may also write to us via postal mail at:

COVID Check Colorado LLC
Attn: Privacy
1705 17th Street
Suite 200
Denver, CO 80202