GT IndependenceCalifornia Privacy Policy

Privacy Policy – California

Effective Date: January 1, 2020

This Privacy Policy for California Residents supplements the information contained in GT Independence’s Privacy Policy and by law applies solely to GT Independence beneficiaries, caregivers, customers, and others who are residents of the State of California (“consumers” or “you”). We are providing you with this notice as part of our efforts to comply with the California Consumer Privacy Act of 2018 (“CCPA”).  Any bolded terms used in this Privacy Policy are defined by the CCPA and have the same meaning when used in this notice.  Information concerning the CCPA may be found here: https://oag.ca.gov/privacy/ccpa.

The Categories of Personal Information We Collect

GT Independence collects information in order to deliver the products and services you request.  We also collect it to improve your experience as our customer and to support how we do business.

GT Independence may collect the following categories of personal information from you. Please note that we may not collect all categories about every individual:

  • Name
  • Social Security Number
  • Date of Birth
  • Personal Health Information
  • Medicaid Number
  • Postal Address
  • Contact Information
  • Billing/Insurance Information
  • Email Address
  • Phone Number
  • Agency ID Number
  • Driver’s License Number
  • Characteristics of protected classifications under California or federal law, including age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, and veteran or military status
  • Professional or Employment-Related Information
  • Non-Publicly Available Education Information
  • Case Manager Information
  • Signature
  • Height
  • Weight
  • Eye Color
  • Hair Color
  • History of Criminal Convictions
  • Places Lived for the Previous 5 Years
  • Bank Account Information for Payment
  • Internet protocol (IP) address

Sources of the Personal Information We Collect

Information we collect about you is either provided to GT Independence by you or third parties. For example, beneficiaries and caregivers provide us with information falling under many of the categories listed above when you become a beneficiary or caregiver.  We also receive certain categories of information from you or third parties such as regional centers and companies that conduct background checks in order to help us deliver services, detect fraud, and maintain the security of our beneficiaries and caregivers.

GT Independence may collect personal information using the following methods. Please note that we may not collect information about every individual from each source:

  • Beneficiary Enrollment Packet
  • Caregiver Enrollment Packet
  • Employment Application
  • Regional Centers
  • Website Usage
  • Third Parties

We may obtain information about you from third parties and may combine this information with other personal information we maintain about you. If we do so, this Privacy Policy governs any combined information that we maintain in personally-identifiable format.

Purposes for Which We Collect Personal Information

GT Independence uses personal information to provide the services we offer.  For example, we use it to enable a beneficiary to become a sole proprietor, consider an individual for employment, or to enable a caregiver to work as an employee of a beneficiary.  We may also use personal information to support our business functions, market our products and services, prevent fraud, and maintain the security of our beneficiaries and caregivers.

Some additional examples include:

  • Website User Experience
  • Website Security
  • Employment
  • Quality Assurance
  • Other Business Purposes

We may combine personal and non-personal information collected.

The Categories of Third Parties with Whom, and Purposes for Which, We Share Personal Information

Categories of personal information that we collect may be shared in limited circumstances with third parties, including our corporate family, subsidiaries, and affiliates for business purposes.

Please note that we do not sell your personal information.

We may share personal information with the following categories of third parties:

  • Background Check Services
  • Regional Centers
  • Marketing Service Providers
  • Employment Benefits Service Providers
  • Other Service Providers
  • Governmental Entities

We may share personal information with third parties for the following purposes:

  • Background Checks
  • Processing Sole Proprietorship Applications
  • Employment Benefits Administration
  • Other Business Purposes

Your Rights Under the CCPA

You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you.

Please note that the CCPA limits our ability to provide you with the requested information only upon receipt of a verifiable consumer request from you, or a person registered with the Secretary of State that is authorized by you to act on your behalf.

When we receive a verifiable consumer request from you to access personal information, we will promptly take steps to disclose and deliver, free of charge to you, the personal information required by the CCPA.

We may choose to deliver the information by mail or electronically. If we are delivering the information electronically, the information will be in a portable and, to the extent technically feasible, readily useable format that allows you to transmit this information to another entity without hindrance.

Pursuant to the CCPA, we may provide you with personal information at any time, but we are not required to provide that information to you more than twice in a 12-month period.

Please note that the CCPA does not require us to retain any personal information collected for a single, one-time transaction, if that information is not sold or retained by us.  It also does not require us to reidentify or otherwise link information that is not maintained in a manner that would be considered personal information.

Exercising Access, Data Portability, and Deletion Rights

You may take advantage of the following designated methods for submitting requests concerning your personal information:

  1. our toll-free telephone number: 1-877-659-4500
  2. by sending an e-mail request to: customerservice@gtindependence.com

Verification of Identity

A verifiable consumer request means a request that is made by:

  • a consumer,
  • by a consumer on behalf of the consumer’s minor child, or
  • by a natural person or a person registered with the Secretary of State, authorized by the consumer to act on the consumer’s behalf,

and that the business can reasonably verify under the law to be the consumer about whom the business has collected personal information.

Please be aware that after we receive a verifiable consumer request from you, we will take steps to determine whether the request being made is a verifiable consumer request. In light of the nature of the personal information requested, we will require authentication of your identity. However, you are not required to create an account with us in order to make a verifiable consumer request. In order to verify your request, we may request information from you to that we have previously collected. We make our best efforts not to collect any additional information from you that we have not previously collected.

Pursuant to the CCPA, and for your security, we will not provide information in response to a consumer request if we cannot verify that the consumer making the request is the consumer about whom the business has collected information or is a person authorized by the consumer to act on such consumer’s behalf.

Timeframe for Our Response to a Verifiable Consumer Request

Once we receive a verifiable consumer request from you, we will disclose and deliver the required information to you free of charge within 45 days.  It may be necessary for us to extend the time period to provide you with the required information by an additional 45 days.  If that is the case, we will provide you with notice of the extension.

The CCPA provides that our disclosure shall cover the 12-month period preceding our receipt of your verifiable consumer request.  We will make the required disclosure in writing and it will be delivered through your account with us, if you maintain an account with us.  We may also make the required disclosure in writing and delivered by mail or electronically if you do not maintain an account with us.

Deletion Request Rights

You have the right to request that we delete any personal information about you that we have collected from you.

After we receive a verifiable consumer request from you to delete your personal information, we will delete your personal information from our records in accordance with the CCPA.  We will also direct any applicable service providers to delete your personal information from their records.

Please note that the CCPA limits our obligation to comply with your request to delete your personal information if your personal information is necessary in order to:

  1. Complete the transaction for which your personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  3. Debug to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
  7. To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Personal Information Sales Opt-Out and Opt-In Rights

The CCPA provides consumers with the right, at any time, to direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information. The CCPA refers to this right as the right to opt-out.  Please note that we do not sell your personal information, so the right to opt-out does not apply to our business relationship.

The CCPA also provides that a business shall not sell the personal information of consumers if:

  • the business has actual knowledge that the consumer is less than 16 years of age, unless the consumer, in the case of consumers at least 13 years of age and less than 16 years of age, or
  • the consumer’s parent or guardian, in the case of consumers who are less than 13 years of age, has affirmatively authorized the sale of the consumer’s personal information.

The CCPA refers to this right as the “right to opt-in.”  Please note that this website and the services we provide are intended for audiences and consumers at least 18 years old. We do not knowingly collect or disclose any personal information from anyone under the age of 18. GT Independence  reserves the right to delete from its records any such information provided to us.  Accordingly, because we do not knowingly collect or sell personal information of consumers that are the subject of the right to opt-in, the right to opt-in is not applicable.

Limitations on the Applicability of the CCPA

The CCPA does not restrict a business’ ability to:

  1. Comply with federal, state, or local laws.
  2. Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities.
  3. Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law.
  4. Exercise or defend legal claims.
  5. Collect, use, retain, sell, or disclose consumer information that is deidentified or in the aggregate consumer information.
  6. Collect or sell a consumer’s personal information if every aspect of that commercial conduct takes place wholly outside of California. Commercial conduct takes place wholly outside of California if the business collected that information while the consumer was outside of California, no part of the sale of the consumer’s personal information occurred in California, and no personal information collected while the consumer was in California is sold. The CCPA does not permit a business from storing personal information about a consumer when the consumer is in California and then collected that personal information when the consumer and stored personal information is outside of California.

Please further note that the CCPA does not currently apply in all respects to personal information that we collect from a person in the course of the person acting as a job applicant, employee, owner, director, officer, or contractor of GT Independence  to the extent that the person’s personal information is collected and used by us solely within the context of the person’s role, or former role, as a job applicant, employee, owner, director, officer, or a contractor of GT Independence. The CCPA also does not apply to personal information that we collect that constitutes emergency contact information of a person acting in any of the aforementioned roles to the extent that the personal information is collected and used solely within the context of having an emergency contact on file. Lastly, the CCPA does not apply to personal information that is necessary for us to retain in order to administer benefits relating to a person’s capacity in any of the aforementioned roles to the extent that the personal information is collected and used by GT Independence solely within the context of administering those benefits.

California’s Shine the Light Law

GT Independence does not share your personal information with non-affiliated third parties for their own marketing use.

Changes to Our Privacy Policy

GT Independence reserves the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Site and update the notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions about our Privacy Policy, please contact us:

GT Independence
215 Broadus Street
Sturgis, MI 49091

Main Phone: 269-651-4500
Toll Free Customer Service: 1-877-659-4500

Contact Us

Last Updated: October 28, 2020