Skip to main content

California Privacy

California Privacy Policy

Last Updated: August 2023

This California Privacy Policy (“Policy”) provides additional provisions that apply to residents of California. In the event of a conflict between this Policy and the SKYGEN Privacy Policy, this Policy shall take precedence for California residents. In this Policy only, any capitalized terms not defined in this Policy have the meanings set forth in the California Consumer Privacy Act of 2018 (the “CCPA”).

Categories of Personal Information.  We collect the following categories of personal information:

  • Identifiers: Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address (“IP Address”), email address, account name, or other similar identifiers.
  • Internet Activity: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement. 

Categories of Sources From Which Personal Information is Collected.

The categories of sources from which your personal information is collected are:

  • Directly From You: We collect personal information that you provide directly to us. Personal Information is required to use certain website features.
  • Automatically: We automatically collect certain information from you when you access our website.
  • From Third Parties:  We collect personal information from third parties, such as integrated social media platforms, when you access our website.

Purposes for Collecting Personal Information.

Our purposes for collecting your personal information are described in Section (B) - (D) of the SKYGEN Privacy Policy.

Categories of Third Parties / Services Providers With Whom Personal Information is Shared.

The categories of third parties and / or service providers with whom we share your personal information are described in Section (B) - (D) of the SKYGEN Privacy Policy.

Categories of Personal Information Sold and Shared

SKYGEN may Sell certain de-identified information, which is information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer.  In such circumstances, SKYGEN will use the HIPAA safe harbor method to create the de-identified data sets that it Sells.  SKYGEN has not sold such de-identified information in the last 12 months.  

In addition, SKYGEN has Sold and Shared (for the purposes of cross-context behavioral advertising) the following categories of Personal Information (that has not been de-identified) in the last 12 months:

  • Identifiers
  • Internet Activity

SKYGEN has no actual knowledge that it Sells or Shares (for purposes of cross-context behavioral advertising) the personal information of California residents under 16 years of age. 

Categories Of Personal Information Disclosed For A Business Purpose

In the last 12 months we disclosed the following categories of personal information for our Business Purposes, where “Business Purposes” has the definition set forth in the CCPA. Please see the section above titled “Categories of Personal Information” for more detail on the type of personal information in each category.

  • Identifiers
  • Internet Activity

Data Retention.  We will keep Personal Information for the period necessary to fulfill the purposes described in this Policy, unless a longer retention period is permitted or required by law.

Your Rights.  California residents have certain rights under the CCPA.  Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, California residents may exercise the following rights with regard to their personal information:

Right to Access.  You have the right to access any of the following: (a) the categories of personal information we collected from you, (b) the categories of sources from which the personal information was collected, (c) the business or commercial purpose for collecting, Selling or Sharing your personal information, (d) the categories of third parties with whom we shared your personal information, (e) the specific pieces of personal information we collected from you, and (f) a list of categories of personal information we disclosed for a Business Purpose. 

Right to Deletion.  You have a right to request that we delete personal information we collected from you. We will comply with such request, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.

Right to Correction.  You have a right to request that we correct inaccurate personal information that we maintain on you.  We will comply with such request, subject to certain exceptions permitted by applicable law.

How to Exercise Your Rights to Access, Delete, or Correct.  To exercise your California rights described in this Section, you may submit your request to us by contacting us at any of the following:


Verifiable Consumer Request for Your Rights to Access, Delete, or Correct.  In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.

When we receive your request to exercise your rights under the CCPA: (a) we will acknowledge receipt of your request; (b) we will try to match the information you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including personal information; (d) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.

We will only use personal information we collect during the verification process for the purpose of verifying your identity.  If you maintain an account with us, we may use that account to respond to your request and/or verify your identity.  If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.  

When We Will Respond.  We will try to respond to your request for access or deletion within 45 days. If we require additional time, we will inform you of the reason and extension period.  We may charge a fee to process or respond to your request if it is excessive or repetitive. 

Your Rights to Opt-Out of the Sale or Sharing of Personal Information.  California residents may direct us not to Sell or Share (for purposes of cross context behavioral advertising) their personal information at any time. 

To opt-out online, please click on the "Do Not Sell or Share My Personal Information" link in the footer of our webpages.

Please also see Section D of our main privacy notice, " 'Cookies' and Data Automatically Placed On Your Computer or Mobile Device" for additional information on your choices regarding targeted advertising.

Other ways you may opt-out include contacting us at the e-mail address set forth above.

Right to Limit Use of Sensitive Personal Information.  We do not collect your Sensitive Personal Information.  However, if we collected, used, or disclosed your Sensitive Personal Information, you would have the right to limit certain uses of such Sensitive Personal Information.

Rights regarding Automated Decision-Making.  You may have the right to request information about the logic involved in automated decision-making and a description of the likely outcome of processes, and the right to opt out. We do not currently engage in any automated decision-making practices. 

Right to Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under the CCPA. 

Who May Exercise Your Rights?  You may only make a request to exercise your rights on behalf of yourself. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. An authorized agent must be registered with the Secretary of State in California to conduct business in California. If you choose to use an authorized agent, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request.  We may also require you to verify your own identity directly with us or directly confirm with us that you provided the authorized agent permission to submit the request.  

Do Not Track.  The Platform does not recognize “do not track” signals from your web browser.

Shine the Light.  California law permits users that are residents of California to request the following information regarding our disclosure of their personal information to third parties for those third parties’ direct marketing purposes (i) a list of certain categories of personal information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year; (ii) the identity of certain third parties that received personal information from us for their direct marketing purposes during that calendar year; and (iii) examples of the products or services marketed (if we have that information). If you are a California resident and would like to make such a request, please contact us through your Platform account.

Contact Us.  If you have any questions about our practices or this Policy, please contact us at  You may also contact us at:  855-609-5156.

Learn how you can transform the delivery of health benefits with SKYGEN.