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POLÍTICA DE TRATAMIENTO DE DATOS

Estados Unidos

Vigencia desde: 2026-05-19 Última actualización: 2026-05-19 Responsable: Prevention at Work Group
Normativa aplicable: CCPA · California Consumer Privacy Act + CPRA + leyes federales aplicables (HIPAA, COPPA, GLBA)

1. Who we are

Prevention at Work Group ("PAW", "we", "us") operates CIMA. This privacy notice describes how we collect, use, and share personal information of users residing in the United States, in compliance with the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and applicable federal laws (HIPAA where applicable, COPPA, GLBA).

Contact: privacidad@patworkgroup.com

2. Categories of personal information we collect

  • Identifiers: name, surname, email, date of birth, sex at birth, country.
  • Health and wellbeing information (sensitive): responses to validated questionnaires (PHQ-2, GAD-2, WHO-5), cognitive evaluations, physical measurements.
  • Biometric information (optional, granular consent): facial and voice analysis. Processing occurs on-device — raw biometric data is not transmitted.
  • Internet activity: hashed IP address, user-agent.

3. Purposes of processing

  • Provide screening, measurement, and longitudinal tracking of personal wellbeing.
  • Authenticate users via one-time email codes.
  • Generate anonymous aggregate reports (N≥5) to employer organizations, when applicable.
  • Improve CIMA using anonymized data only.

4. Your rights under CCPA / CPRA

Right to knowWhat personal information we collect and how we use it.
Right to deleteRequest deletion of your personal information.
Right to correctUpdate inaccurate information.
Right to opt-out of saleCIMA does NOT sell personal information.
Right to limit useRestrict use of sensitive personal information.
Right to non-discriminationExercise rights without service degradation.

To exercise your rights, email privacidad@patworkgroup.com. We respond within 45 days (extendable to 90 days per CCPA §1798.130).

5. No sale or sharing for cross-context behavioral advertising

CIMA does not sell personal information and does not share it for cross-context behavioral advertising as defined by CPRA. Data shared with service providers is governed by contractual obligations consistent with CCPA §1798.140(ag).

6. Sensitive personal information

We process sensitive personal information (health, biometric data) only with your explicit, informed consent and limit its use to the purposes you authorize. You can revoke consent at any time via account settings or by emailing us.

7. Data retention and security

We retain personal information only as long as necessary for the stated purposes or as required by law. Security measures include TLS encryption in transit, encryption at rest, access controls, and audit logging.

8. Children's privacy

CIMA is not directed to individuals under 18. We do not knowingly collect data from minors. If you believe a minor has provided us with personal information, please contact us to delete it.

9. Authorized agent and complaints

California residents may designate an authorized agent to submit requests. To file a complaint, contact the California Attorney General's Office: oag.ca.gov/privacy.

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