Innovative Perioperative Technologies, LLC 
Privacy Policy

Effective Date: April 1, 2022

This Privacy Policy (“Privacy Policy” or “Policy”) describes the types of information gathered by Innovative Perioperative Technologies, LLC (“IPT”, “us” or “we”) in the process of providing this website (https://www.ipthealthcare.com) (the “Website”), computing application, services, information, tools, functionality, updates and similar materials relating thereto (collectively, the “Services”), how we use it, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us through the Services. By using the Services, you hereby consent to allow us to process information in accordance with this Policy.

Please also refer to our Terms of Service available here, https://limelight360.com/auth/tnc , which are incorporated as if fully recited herein. Terms defined in the Terms of Service that are not defined herein shall have the same definition as in the Terms of Service.

This Privacy Policy is subject to the provisions of the European Union (“EU”) General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act  of 2018, as amended (“CCPA”), and other applicable privacy laws. IPT agrees that under the GDPR, IPT is a data “Controller” and you are a “Data Subject” with certain protected privacy rights concerning your “Personal Data”, and IPT will take commercially reasonable steps to maintain compliance with GDPR requirements.  Similarly, to the extent that the CCPA applies to you, under the CCPA, IPT is a “Business”, and you are a “Consumer” with certain protected privacy rights concerning your “Personal Information”, and IPT shall take commercially reasonable steps to maintain compliance with the CCPA.  Your Personal Data and Personal Information may identify you as a person, and thus may be referred to as Personally Identifiable Information (“PII”).

Policy Updates

This Policy is subject to change. If our information retention or usage practices change, we will let you know by posting the Privacy Policy changes on the Services and/or otherwise making you aware of the changes. Please refer to the “Effective Date” above to see when this Policy was last updated.

Information Collected

We collect two types of information about and from persons who use the Services: PII and Anonymous Information. Under the CCPA we are a “Business”. We collect information from you on the Service, and we are responsible for protection of your information.

“Personal Information” is information that is personally identifiable to you, such as your name, address, email address or phone number, as well as other non-public information that is associated with the foregoing. Anything you publicly post or that is available publicly will not be considered Personal Information, and will be outside the restrictions of this policy.

“Anonymous Information” means information that is not associated with or linked to your Personal Information. We may create Anonymous Information from (i) automatically gathered information or (ii) Personal Information by excluding information (such as name) that may make the information personally identifiable to you.

Personal Information Collected

We collect certain Personal Information about you or about those you identify, which may be supplied when you interact with the Services, complete a survey, make a purchase, when you request services or otherwise when you submit such information. The information collected may include one or more of the following:

  • Name
  • Email
  • Address
  • Phone number
  • Geolocation
  • Information from your activities on the Services

The Service may permit you to log in through a third-party gateway, such as Facebook or Twitter. If you do so, we may collect additional information about you from those sources.

The Service may use a third-party gateway to collect and process credit card information, but that information is not be shared with us other than our right to hold that information in connection with a change in vendors for this service.

Anonymous Information

Anonymous Information is collected about you by us when you use the Services, including but not limited to enrollment history, the type of device you used and its operating system, the pages accessed most frequently, how pages are used, search terms entered, and similar data.

Automatically Tracking Internet Protocol (IP) addresses is one method of automatically collecting information about your activities online and information volunteered by you. An IP address is a number that is automatically assigned to your device whenever you surf the internet. Further, the Services may utilize web beacons, pixel tags, cookies, third-party cookies, embedded links, and other commonly used information-gathering tools. Some of these tools may provide information directly to third part service associates.

Although it may be possible to turn off the collection of cookies through your device, that may interfere with your use of the Services.

We need to collect your personal information so that we can respond to your requests for information and demonstrations or to be added to our emailing lists, and to process your requests for access to and payment for our Services. We also collect aggregate information to help us better design the Website. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Website, calculate usage levels, and otherwise provide services to you.    

Use of Information

Internal Use of Information by Us

We accept and gather Personal Information and Anonymous Information in an effort to provide the Services to you. We may also use this information to help us develop and improve our Services, create and/or maintain your account, fulfill your requests, send materials to you, inform you about our offers and those of others, tailor our Services to meet your interests, and for other purposes permitted by law.

We may use Anonymous Information or non-personal information for any business purpose.

Sharing Collected Information

In general, we will not share your personal information except for the purposes for which you provided it, as you direct, or with your consent. For example, our host and internet service provider may have access to this information.

On a confidential basis, we may also share Personal Information, non-Personal Information, and Anonymous Information with third-parties with whom we contract to carry out internal site operations, or as otherwise needed to provide the Services, e.g. for marketing and analytics, when marketing our Products and Services, for the purposes of those third-parties and for other purposes permitted by law. The use of information by third-parties will be governed by their own policies, and may be broader than the uses outlined in this Policy.

Further, we may disclose collected information, including PII, non-Personal Information and Anonymous Information, to the extent we believe it necessary to comply with the law, such as in response to a subpoena or court order, to defend a legal claim or establish or protect our legal rights or otherwise as permitted by applicable law. We may disclose any information in our possession in the event that we believe it necessary or appropriate to prevent criminal activity, personal injury, property damage or bodily harm.

We may also share your PII, non-Personal Information, and Anonymous Information with third parties whom are involved in the hosting, sponsoring, planning, and/or administration of events in which you may participate through our Services (“Third Party Partners”).  Such third-party events can be contests and/or sweepstakes (“Third Party Sponsored Events”), or generic and/or non-competitive in nature (“Third Party Hosted Events”, and together with the Third Party Sponsored Events, the “Third Party Events”).  If you participate in any Third Party Event, we may disclose your information to the relevant Third Party Partner(s).  The use of information by Third Party Partners will be governed by their own policies, and may be broader than the uses outlined in this Policy.  Please note that we are not responsible for the privacy practices of any Third Party Partner.

Additionally, we may transfer your information to a successor in interest, which may include but may not be limited to a third-party in the event of an acquisition, sale, asset sale, merger or bankruptcy. The policies applicable to your information thereafter may be determined by the transferee.

Use of Cookies and Other Network Technologies

To enhance your online experience with us, our web pages may presently or in the future use “cookies.”  Cookies are text files that our web server may place on your hard disk to store your preferences.  We may use session, persistent, first-party and third-party cookies. Cookies, by themselves, do not tell us your e-mail address or other PII unless you choose to provide this information to us.  Once you choose to provide PII, however, this information may be linked to the data stored in the cookie.

Our Service uses Google Analytics, provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 (“Google”).  Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  This service may collect information regarding the use of other websites, apps and online resources.  For more information on how Google uses data when you use our Website or Service, please follow this link: https://policies.google.com/technologies/partner-sites.  You may be able to opt-out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on, available at, https://tools.google.com/dlpage/gaoptout.  For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit http://optout.aboutads.info.

We may also use monitoring services of DataDog and UXCam, which may include recording 

Screens visited, Interaction patterns (such as screen actions, gestures: taps, scrolls), and Device details (Type, Version, Model, Operating System), to improve our app. DataDog and UXCam do not track your browsing habits across apps.  For more information on how DataDog and UXCam use and store this information, please see DataDog’s privacy policy, which is available by clicking on this link: https://www.datadoghq.com/legal/privacy/ and UXCam’s privacy policy, which is available by clicking on this link: https://help.uxcam.com/hc/en-us/articles/360004158171. 

We or our service providers may also use “pixel tags,” “web beacons,” “clear GIFs” embedded links, and other commonly used information-gathering tools in connection with some Website pages and HTML-formatted email messages for such purposes as compiling aggregate statistics about Website usage and response rates. A pixel tag is an electronic image (often a single pixel), that is ordinarily not visible to website visitors, and may be associated with cookies on visitors’ hard drives. Pixel tags allow us and our service providers to count users who have visited certain pages of the Website, to deliver customized services, and to help determine the effectiveness of our Website and Services. When used in HTML-formatted email messages, pixel tags can inform the sender of the email whether and when the email has been opened.

As you use the Internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as “clickstream data”, can be collected and stored by a website’s server.  Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to the Website.  We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Website, how visitors navigate through the Website, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our Website.

Access and Control of Your Information

After registering for an account on the Website, you may log-in to the account and edit your personal information in your profile. For instructions on how you can further access your personal information that we have collected, or how to correct errors in such information, please send an e-mail to contact@ipt.com. We will also promptly stop using your information and remove it from our servers and database at any time upon your e-mail request. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections or removing your information.

Links

The Services may contain links to other websites. We are not responsible for the privacy practices of such other sites. When you leave our Service to visit another website or application, please read the privacy statements of websites that may collect personally identifiable information. This Privacy Policy applies solely to information collected by us through the Services.

Storage and Protection of Your Information

After receiving your PII, we will store it on our Website systems for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect.  Unfortunately, no data transmission over the Internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers’ systems.

Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. By visiting the Website and using the Services, you unequivocally and unambiguously consent to the collection and processing in the united states of any information collected or obtained by us through voluntary submissions, and that U.S. Law governs any such collection and processing.

E-Mail and Electronic Newsletters

We may offer electronic newsletters and e-mails concerning available properties, as well as new products and services, or may provide other marketing materials as a service to our users. Users may receive newsletters and e-mails concerning promotions and marketing of ours or of our business partners, after registering with the Services or after engaging with us in person or through our agents.

If you have received a message from us, and you no longer wish to receive such materials, you may opt-out by following the unsubscribe instructions included in each electronic newsletter and e-mail.

Please note that you may be required to separately opt out of any e-mails sent by our business associates.

Children and Privacy

We do not knowingly collect any information from anyone under the age of 13 years old, and we comply with all applicable privacy laws including the CCPA, USA Children’s Online Privacy Protection Act (“COPPA”) and associated Federal Trade Commission (“FTC”) rules for collecting personal information from minors. Please see the FTC’s website (www.ftc.gov) for more information. If you have concerns about this Website or its Services, wish to find out if your child has accessed our Services, or wish to remove your child’s personal information from our servers, please contact us at contact@ipt.com. Our Website will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian.  In the event that we discover that a child under the age of 13 has provided PII to us, we will make efforts to delete the child’s information in accordance with the COPPA. If you believe that your child under 13 has gained access to our Website without your permission, please contact us at contact@ipt.com.

Do Not Track

At present, the Services do not specifically respond to browser do-not-track signals.

‘EEA’ Privacy Rights.

If you currently reside in the EEA, the GDPR applies to your PII and you are a Data Subject.  The GDPR requires that we, as a Controller, have a legal basis to process your PII.  

  1. We process your PII under one or more of the following legal bases: 
  • Processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; 
  • To perform the contract that we are about to enter with you (e.g., our Terms of Service); 
  • To comply with a legal obligation; and/or
  • If we have your consent to do so, such consent can be revoked at any time.
  1. Under the GDPR, as a Data Subject you have certain rights. They are:
  • The right to be informed. This is your right to be informed about what they are processing, why, and who else the data may be passed to.
  • The right of access. This is your right to see what data about you is held by us.
  • The right to rectification. This is the right to have your data corrected or amended if what is held is incorrect in some way.
  • The right to be forgotten. This is the right to have your personal data to be deleted in the event that such data is no longer required for the purposes it was collected for, your consent for the processing of the data is withdrawn, or the data is being unlawfully processed.
  • The right to restrict processing. This is the right to ask for a temporary halt to processing of your personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
  • The right to data portability. This is the right to ask for your personal data to be provided to you in a structured, commonly used, and machine-readable format.
  • The right to object. This is the right to object to further processing your personal data if such processing is inconsistent with the primary purposes for which it was collected.
  • Rights in relation to automated decision making and profiling. This is the right to not be subject to a decision based solely on automated processing. The Service does not engage in automated decision making and profiling. 

You can find instructions for enforcing some of these rights elsewhere in this Privacy Policy. Otherwise, if you wish to find out more about these rights, please contact us at [INSERT EMAIL].

California Privacy Rights

The CCPA applies to our practices with respect to Personal Information of California residents.

Under the CCPA, Consumers have certain rights regarding their Personal Information.

  1. California Consumers have the right to request that we disclose personal information we have collected about them in the previous 12 months including, but not limited to, the categories of information collected by us, the source(s) of such information by category, and the purpose for collecting such information.  This right may not be exercised more than twice in a 12 month period.  

In the previous 12 months, we have collected the following categories of personal information about Consumers: 

  • Identifiers, such as your name, mailing address, social security number, unique personal identifiers, account names, and similar information;
  • Personal Information Under the California Consumer Records Law (Cal. Civ. Code §1798.80) (“CCRLPI”); 
  • Internet/Network Activity, which can includes browsing history, cookies, search history and a Consumer’s interaction with a website; 
  • Geolocation Data, such as GPS data; 
  • Professional and employment information; and
  • Inferences drawn from any other category of personal information.

We collect the Personal Information from our Users, third parties, and/or automatic means.  Such Personal Information is collected in order to provide the Service, to comply with applicable law, and as otherwise described above in this Privacy Policy.

  1. As a California Consumer, you also have the right to request that we tell you which of your Personal Information we have disclosed for a business purpose, or sold, in the previous 12 months, if any.  In the past 12 months, we have disclosed Personal Information falling under the following categories of personal information: Identifiers; CCRLPI; Internet/Network Activity; and Professional and employment information.

We disclose Personal Information in the preceding categories to our users, the Consumers themselves, to third parties as the Consumer may direct, our service providers, third parties, and/or government/law enforcement agencies pursuant to the following business purposes, the provision of Services (the purpose that you provided it for), in response to a user’s or Consumer’s specific request, to comply with applicable law, our legitimate internal business operations, and as otherwise described above in this Privacy Policy.

IN THE PAST 12 MONTHS WE HAVE NOT SOLD, AND DURING THE PERIOD OF TIME WHICH THIS PRIVACY POLICY IS POSTED WE SHALL NOT SELL, THE PERSONAL INFORMATION OF ANY CONSUMER, OF ANY AGE.

  1. You also have the right to request the deletion of Personal Information that we have collected from you at any time.  However, we may not be required to comply such request under several circumstances including, but not limited to, when the data is necessary for the underlying transaction, to comply with applicable law, to detect security incidents, to debug glitches, and for our internal purposes.
  1. In the event that you exercise one of your rights under the CCPA, you will not be discriminated by IPT in any way, whether it is through the denial of goods/services, providing you a different level of goods/services, or charging (or suggesting that we will charge) you different prices for the goods/services unless such change in price is reasonably related to the value you receive from your personal information.
  1. How do you exercise your rights under the CCPA?

            Because we offer the Services exclusively online, you may submit requests to exercise your rights under the CCPA by emailing us at contact@wealthbase.com, please include “Request for Privacy Information” in the subject line.  You can also submit requests by calling us toll-free at 1-800-316-8967.

            We will acknowledge receipt of your request within 10 days of receiving it, and use best efforts to respond within 45 days of receipt of your request, but in no event will our response come more than 90 days after your request.  If we are unable to provide our response within the first 45 days following your request, we shall notify you as soon as we become aware of the possible delay and provide an explanation of why additional time is needed to respond.

            Before we respond to any CCPA based requests relating to your personal information, we may take steps to reasonably verify the identity of the person making the request to make sure it’s you, or your authorized agent (in either case, the “Requestor”).  We do this to this avoid disclosing your information to third parties and bad actors, not to inconvenience you in any way.  For purposes of verifying identity, we will ask the Requestor to confirm at least two pieces of information that we have in our files.  If an agent is acting on behalf of the Consumer, we will also need to verify the agent’s identity and their authority to act on the Consumer’s behalf.  As the sensitivity of the information being requested increases, we will ask the Requestor to provide more information to verify their identity and/or authority to make the request.  If the identity of the Requestor cannot be reasonably verified, either as the Consumer or their agent, then in order to protect that Consumer, we may not disclose or delete the personal information that is the subject of the request.

Contact Information

If you have any questions or suggestions regarding our Privacy Policy, please contact us via e-mail at contact@ipt.com.

Copyright © Innovative Perioperative Technologies, LLC. All rights reserved. The Website is the property of Innovative Perioperative Technologies, LLC, and is protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Website, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.