Trajector Detailed US Privacy Notice
Information for US Residents
We collect Personal Data from US residents and comply with the consumer privacy laws of California, Colorado, Connecticut, Utah, and Virginia (“US Privacy Laws”). This Detailed US Privacy Notice applies to US residents (“users,” “you,” or “your”).
For the purposes of this Detailed US Privacy Notice, “Personal Data” means information that is linked or reasonably linkable to a particular individual or household. However, the following categories of information are not Personal Data:
- Publicly available information;
- Deidentified or aggregated data; or
- Information otherwise excluded from the scope of US Privacy Laws.
This Privacy Notice provides the following information to US residents:
- Categories of Personal Data we collect;
- Purposes for which we use Personal Data;
- Categories of Personal Data we disclose to third parties;
- Categories of third parties to which we disclose Personal Data; and
- How US residents can exercise their rights under US Privacy Laws:
- The rights to access, correct, or delete Personal Data;
- The right to obtain a portable copy of Personal Data;
- The right to limit the use of sensitive Personal Data in certain circumstances;
- The rights to opt out of targeted advertising, sales of Personal Data, or profiling; and
- The right to appeal our decisions about your requests.
Categories of Non-Sensitive Personal Data
The table below outlines the non-sensitive categories of Personal Data Trajector collects about US residents and whether and how they are disclosed to third parties.
We collect Non-Sensitive Personal Data from the following sources:
- Directly from our users
| Category of Personal Data:
Identifiers |
| Examples |
| Identifiers may contain the following: name, address, social security number, driver’s license number, email address, telephone number, date of birth |
| Purpose(s) for Collection |
| Providing medical consulting services, providing representation before the Social Security Administration, and conducting internal research and development to improve these services. |
| Targeted Advertising |
| We do not engage in targeted advertising or disclose this information for targeted advertising purposes |
| Sale |
| This information is not sold to third parties |
| Other Disclosures |
| This information is not otherwise disclosed to third parties |
| Retention Period |
| We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. |
| Category of Personal Data:
Personal Characteristics |
| Examples |
| Personal Characteristics may contain the following: age, gender, height, weight |
| Purpose(s) for Collection |
| Providing medical consulting services, providing representation before the Social Security Administration, and conducting internal research and development to improve these services. |
| Targeted Advertising |
| We do not engage in targeted advertising or disclose this information for targeted advertising purposes |
| Sale |
| This information is not sold to third parties |
| Other Disclosures |
| This information is not otherwise disclosed to third parties |
| Retention Period |
| We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. |
| Category of Personal Data:
Commercial Data |
| Examples |
| Commercial Data may contain the following: statements from clients regarding ownership of assets and income |
| Purpose(s) for Collection |
| Providing medical consulting services and providing representation before the Social Security Administration |
| Targeted Advertising |
| We do not engage in targeted advertising or disclose this information for targeted advertising purposes |
| Sale |
| This information is not sold to third parties |
| Other Disclosures |
| This information is not otherwise disclosed to third parties |
| Retention Period |
| We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. |
| Category of Personal Data:
Internet/Electronic Activity |
| Examples |
| Internet/Electronic Activity may contain the following: cookie ID, device ID |
| Purpose(s) for Collection |
| To optimize marketing |
| Targeted Advertising |
| We do not engage in targeted advertising or disclose this information for targeted advertising purposes |
| Sale |
| This information is not sold to third parties |
| Other Disclosures |
| This information is not otherwise disclosed to third parties |
| Retention Period |
| We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. |
| Category of Personal Data:
Imprecise Geolocational Data |
| Examples |
| Imprecise Geolocational Data may contain the following: IP address |
| Purpose(s) for Collection |
| To optimize marketing and comply with relevant state laws |
| Targeted Advertising |
| We do not engage in targeted advertising or disclose this information for targeted advertising purposes |
| Sale |
| This information is not sold to third parties |
| Other Disclosures |
| This information is not otherwise disclosed to third parties |
| Retention Period |
| We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. |
| Category of Personal Data:
Professional Data |
| Examples |
| Professional Data may contain the following: statements from clients as to employment history, statements as to income |
| Purpose(s) for Collection |
| Providing medical consulting services, providing representation before the Social Security Administration, and conducting internal research and development to improve these services. |
| Targeted Advertising |
| We do not engage in targeted advertising or disclose this information for targeted advertising purposes |
| Sale |
| This information is not sold to third parties |
| Other Disclosures |
| This information is not otherwise disclosed to third parties |
| Retention Period |
| We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. |
| Category of Personal Data:
Educational Data |
| Examples |
| Educational Data may contain the following: client statements as to educational history |
| Purpose(s) for Collection |
| Providing medical consulting services and providing representation before the Social Security Administration |
| Targeted Advertising |
| We do not engage in targeted advertising or disclose this information for targeted advertising purposes |
| Sale |
| This information is not sold to third parties |
| Other Disclosures |
| This information is not otherwise disclosed to third parties |
| Retention Period |
| We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. |
Categories of Sensitive Personal Data
The table below outlines the categories of Sensitive Personal Data Trajector collects about US residents and whether they are disclosed to third parties. Trajector obtains affirmative consent from US residents to process Sensitive Personal Data to the extent required by US Privacy Laws.
We collect Sensitive Personal Data from the following sources:
- Directly from our users
| Category of Sensitive Personal Data:
Government ID Data |
| Examples |
| Government ID Data may contain the following: Social Security number, driver’s license |
| Purpose(s) for Collection |
| Providing medical consulting services, providing representation before the Social Security Administration, and conducting internal research and development to improve these services. |
| Targeted Advertising |
| We do not engage in targeted advertising or disclose this information for targeted advertising purposes |
| Sale |
| This information is not sold to third parties |
| Other Disclosures |
| This information is not otherwise disclosed to third parties |
| Retention Period |
| We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. |
| Category of Sensitive Personal Data:
Sensitive Category Data |
| Examples |
| Sensitive Category Data may contain the following: race and health data |
| Purpose(s) for Collection |
| Providing medical consulting services, providing representation before the Social Security Administration, and conducting internal research and development to improve these services. |
| Targeted Advertising |
| We do not engage in targeted advertising or disclose this information for targeted advertising purposes |
| Sale |
| This information is not sold to third parties |
| Other Disclosures |
| This information is not otherwise disclosed to third parties |
| Retention Period |
| We typically retain client data for a period of six years to protect our clients’ interests and to comply with federal regulations such as HIPAA or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services. |
Use of Personal Data
We use Personal Data for the purposes described above. Personal Data may also be used or disclosed as otherwise permitted or required by applicable law.
Disclosing Personal Data
We share Personal Data with the following categories of third parties:
- Processors: We use processors to securely handle Personal Data on our behalf and only on our instructions. These companies may not use your Personal Data for their own purposes.
See the tables above for more details about how different categories of Personal Data are disclosed.
We do not sell Personal Data to anyone.
Exercising Your Personal Data Rights
US residents have the following rights under US Privacy Laws:
- The rights to access, correct, or delete Personal Data;
- The right to obtain a portable copy of Personal Data;
- The right to limit the use of Sensitive Personal Data in certain circumstances;
- The rights to opt out of targeted advertising, sales of personal data, or profiling;
- The right not to receive discriminatory treatment for exercising your privacy rights; and
- The right to appeal our decisions about your requests if you disagree with them.
If you are a US resident, you can submit a request to exercise your personal data rights under US Privacy Laws by visiting our online portal at ttps://www.requesteasy.com/6400-4075 or sending an email to [email protected] with the subject line “Privacy Rights Request”.
To protect your privacy, we may need to authenticate your identity before we respond to your rights request. We will verify your identity by .We may ask you for additional information as part of this process, including the last four digits of your social security number. If you do not complete the verification process, we may be unable to process your request. Any information you provide to authenticate your identity will only be used to process your rights request and not for any other purpose. Please be aware that we do not accept or process rights requests submitted through other means.
We will respond to your rights request within 45 days, though in certain cases we may inform you that we will need up to another 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic. Also note that each of the rights are subject to certain exceptions.
We reserve the right to decline to process, or charge a reasonable fee for, requests from a US resident that are manifestly unfounded, excessive, or repetitive.
Notice of Right to Limit the Use of Sensitive Personal Information
You have the right to limit some uses of Sensitive Personal Data. In particular, you may direct companies not to use Sensitive Personal Data except as necessary to provide goods or services you have requested or other exempt purposes.
However, we only use Sensitive Personal Data for purposes that are exempt from this right, such as to provide you with goods or services you have requested, to detect and prevent security incidents, or verifying the quality of our goods and services. The full list of these exempt purposes are specified in California Code of Regulations, Title 11, Section 7027(m).
Children’s Data
We do not knowingly collect or use the Personal Information of children under 16. If you believe that we have collected the Personal Information of a child under 16, please contact us at [email protected].
Authorized Agent Requests
You may designate an authorized agent to make a rights request on your behalf. Your authorized agent may submit such a request by following the same method described above in the section titled Exercising Your Personal Data Rights. We may require verification of your authorized agent’s authority in addition to the information we require for verification of your identity.
Contact Us
If you have any questions or concerns regarding this Detailed US Privacy Notice, contact us at [email protected].
The Trajector California HR Privacy Notice can be found here
Last updated: July 13, 2023