Notice to Alto's California Personnel

This California Privacy Notice is effective as of January 1, 2023

This notice supplements Alto Pharmacy’s (“Alto”, “we”, or “us”) privacy policy and applies only to employees, contractors, and business partners that are residents of California (“California Personnel”).  This California Personnel Privacy Notice sets forth the disclosures and rights for California Personnel regarding their Personal Information, as required by the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California Privacy Rights Act of 2020 ("CPRA"), and any implementing regulations adopted thereunder. Terms (including defined capitalized terms) used in this California Personnel Privacy Notice have the same meanings given in the CCPA and CPRA and the associated regulations, unless otherwise defined.

EXERCISING YOUR CALIFORNIA RIGHTS

California Personnel have the right to request: (1) that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you ("Right to Know"); (2) that we delete the Personal Information we collect from you ("Right to Delete"); and (3) that we correct inaccurate Personal Information we hold about you (“Right to Correct”). Exercise of these rights are subject to the meanings and exceptions set forth in the CCPA and CPRA. More information on each of these rights is below.

Verifying Your Requests

When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making. We may require you to log into your internal personnel account or provide your unique personnel ID. We may also need to ask you to provide us with additional information to verify your identity and fulfill your request. We will only use any such information to verify your identity. If we cannot verify your identity, we will not be able to process the request. 

Authorized Agents  

You may elect to use an agent to submit a request on your behalf. If you choose to do so, your agent must follow the instructions below to make the request. You may also make a request on behalf of your minor child. When your authorized agent submits a request on your behalf, we will request written permission signed by you and authorizing your agent to make the request on your behalf. The written permission must state your full legal name as the subject of the request, the full legal name of the individual who is acting as your agent and must be clear about the scope of permission granted. Alternatively, your agent may, but is not required to, submit a copy of a power of attorney under Probate Code sections 4000-4465.  In either case, your agent should also indicate in their email the nature of the request. Your identity, in addition to your agent’s identity and authorization, will need to be independently verified for us to be able to fulfill the request. We may also ask you to directly confirm with us that you provided your agent permission to submit a request. Please keep in mind that if we do not receive adequate proof that your agent is authorized to act on your behalf, we will deny the request.

Right to Know

To exercise your Right to Know, please submit your request at CCPA@alto.com  or by calling us at 1 (800) 874-5881[.In order to have us provide specific pieces of information, we may require a signed declaration under penalty of perjury that you are the California Personnel whose Personal Information is the subject of the request. We will not provide you specific pieces of information that include the Personal Information of other persons, nor will we disclose certain pieces of information that the law requires us not to or that we determine is a high security risk, including your social security number, driver’s license number, financial account number, health insurance or medical information number, account passwords, security questions and answers, or unique biometric data, as applicable.

Right to Delete

To exercise your Right to Delete, please submit your request at CCPA@alto.com or by calling us at 1 (800) 874-5881. Please note that as part of the verification process, once you submit a request to delete, we may follow up and require you to confirm that you want your information deleted. 

Right to Correct Inaccurate Information

If you would like to exercise your Right to Correct, please submit your request at CCPA@alto.com or by calling us at 1 (800) 874-5881.

Right to Limit the Use and Disclosure of Sensitive Personal Information 

As disclosed in the chart below, we may collect certain information in connection with your employment with us that is considered Sensitive Personal Information under California law. Under the CPRA, a business must only provide the Right to Limit The Use and Disclosure of Sensitive Personal Information when Sensitive Personal Information is collected or processed for the purpose of inferring characteristics about a consumer, or does not fall under certain statutory exceptions, pursuant to CPRA § 1798.121. Alto’s use and disclosure of its personnel’s Sensitive Personal Information falls within this list of exceptions and we therefore do not offer such opt-out right at this time.

Do Not Sell or Share

Alto does not sell, or share for cross-context behavioral advertising, the Personal Information or Sensitive Personal Information of its employees, contractors, or business partners. 

Data Retention 

Alto will not retain or store Personal Information for longer than is reasonably necessary to fulfill the purposes (as described in this California Personnel Privacy Notice and our Personnel Privacy Policy) for which it was collected or that you authorized after collection, or as otherwise required by law.

Data Reporting Personnel Younger than 18

We do not knowingly collect or sell Personal Information of employees, contractors, and business partners or other personnel younger than 18 years of age.

Right to Non-Discrimination for the Exercise of Your Privacy Rights

California Personnel have the right to not receive discriminatory treatment for exercising CCPA and CPRA rights. We will not discriminate or retaliate against you for exercising your CCPA and CPRA rights.

PERSONAL INFORMATION WE COLLECT

The Personal Information we collect about you will depend upon your employment relationship with us, the nature of your specific role with Alto, or how you otherwise interact with us. Accordingly, we may not collect all the below information about you.In addition to the below, we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA and CPRA

Personal Information Not Related to Employment

We may collect Personal Information from you if you engage in transactions with Alto in your individual capacity and outside the context of your employment with us. Personal Information we collect from you during these transactions is not subject to this California Personnel Privacy Notice. We will collect, use, store, disclose, and/or otherwise handle Personal Information collected outside the context of your employment as we describe in our online privacy policy, found at https://alto.com/legal/privacy.