Privacy Policy

SCOPE AND PURPOSE:
This Privacy Policy describes the practices of INTEGRA CONNECT, a limited liability company (“we,” “our,” or “Integra Connect”), with regard to personal information about users of this website (each of which is collectively referred to herein as “you,” “your,” or “Users”) that we obtain, either directly or indirectly through our Users or third parties, or through our website www.IntegraConnect.com (the “site”)

Integra Connect hereby advises that: (i) as you navigate through the site, certain anonymous information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as “cookies,” “Internet tags” or “web beacons,” and “navigational data collection” such as “log files,” “server logs,” and “clickstream” (as those terms are defined below or otherwise are commonly understood to mean); (ii) your Internet browser automatically transmits to the site some of this anonymous information, such as the URL of the website you just came from and the Internet Protocol (“IP”) address and the browser version your computer is currently using; (iii) the site may also collect anonymous information from your computer through cookies and Internet tags or web beacons; (iv) you may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of the site might not work without cookies; (v) the site may use and combine such passively collected anonymous information with other sources to provide better service to Users, customize the site based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve the site for your use; and (vi) such information is not combined with personally identifiable information collected elsewhere on the site unless you have given your consent.

This Privacy Policy does not apply to other Integra Connect platforms or to other websites that we operate or websites of third parties to which we provide links.

We do not control and are not responsible for the privacy practices of, or the data available on, the websites of third parties, and we urge you to evaluate the soundness of these practices for yourself.

You have clicked on the most updated version of our policy, the date of which is noted above. From time to time, we may revise this policy and material changes will result in the issuance of a new version, which will be posted on our website.

CONTACT:
If you have any questions about this Privacy Policy, or any other aspects of your privacy with respect to Integra Connect, please email compliance@integraconnect.com or call 1-855-252-7606. For consumers who wish to submit requests regarding their data, please note that compliance@integraconnect.com is our designated request address and method for submitting data request appeals. To enable us to process such requests in a timely manner, we advise consumers submitting a request to review or revise their personal data to provide detail on the timeframe and context in which they believe their data was collected.

Integra Connect hereby advises that, to keep personally identifiable information that you provide via the site accurate, current, and complete, you are encouraged to contact Integra Connect and we will take appropriate steps to update or correct such information in our possession, or to delete your information from our contact list.

SPECIAL NOTE FOR MINORS:
Integra Connect values the privacy of those under the age of 18 and does not wish to obtain any information from or about them through the site. Parents are urged to monitor and supervise their children’s online activity. If you are under 18 and are not supervised by an adult, please do not use the site.

WHAT INFORMATION DO WE COLLECT?
The following types of information may be passively collected on the site:

• We may access cookie and web beacon technologies on your computer.
• We may collect your IP address and other data about the equipment used to visit the site, the patterns of searching and browsing that preceded access to the site, and the patterns of searching, viewing and browsing on the site.

Integra Connect will not passively collect personal information, nor will we associate or link such information using cookies or web beacons, unless you voluntarily submit this information. We may collect personal information, including first and last name, phone number and email, company or practice name, job title, and location (state) of your practice if request a demo or access to a recording through the Company website.

We will collect the following personal information from job applicants who complete an application through the Integra Connect careers page:

• First and last name
• Phone number
• Email address
• Resume

HOW DO WE USE YOUR INFORMATION?
We use information collected through cookies and web beacons to improve upon the functionality of the site. For example:

• We track the number of Users using certain portions or features of the site to make changes that may be necessary to improve the site’s functionality.
• We track the popularity of features on the site to guide the development of new ones.

If you choose to provide Integra Connect with personally identifiable information, we will use that information for our business purposes. For example, if you provide us with your email address, we may use it for our own marketing, promotional, hiring, and informational purposes, including solicitations, invitations, newsletters, awareness campaigns, scheduling interviews, and announcements.

Integra Connect further advises that: (i) except as otherwise stated, we collect and may use information collected via the site – – (A) to communicate information to you, (B) to improve the content of the site, (C) to customize the site to your preferences, (D) for our marketing and research purposes, and (E) for any other specified purpose; (ii) if you provide personally identifiable information to the site, Integra Connect may combine such information with other information actively collected by ourselves or third parties; (iii) we may disclose personally identifiable information that you provide via the site to other Integra Connect affiliates worldwide that agree to treat it in accordance with this Privacy Policy and use it for the same purposes; (iv) we may disclose personally identifiable information that you provide via the site to third parties that are not Integra Connect affiliates, but only if – – (A) such disclosure is in response to law enforcement requests or where required by applicable laws, court orders, or government regulations, (B) such third parties take reasonable safeguards to protect such information and use it for the same or similar purposes outlined in this Privacy Policy, or (C) such disclosure is in connection with the sale, assignment, or other transfer of the business of the site to which the information relates, in which case Integra Connect will require any such buyer to agree to take reasonable safeguards to protect such information and use it for the same or similar purposes outlined in this Privacy Policy; (v) we may make full use of all information acquired through the site that is not in personally identifiable form, including sharing it with data analytics vendors; and (vi) the collection, use, and disclosure of information contemplated in this Privacy Policy may involve a transfer of the information to jurisdictions located outside of the United States of America and such jurisdictions may not have equivalent laws and rules regarding personally identifiable information.

SHARING YOUR INFORMATION:
We shall engage, from time to time, certain service vendors for purposes of tracking and associating internet search and browsing behavior with our advertisements and to provide functionality on the site. We enable them to use cookies and web beacons on or in conjunction with the site. The use and collection of information by these vendors is governed by their respective privacy statements and thus is not covered by this Privacy Policy.

UPDATES TO THIS PRIVACY POLICY; SECURITY:
Integra Connect reserves the right to make periodic updates and revisions to our Privacy Policy. Any changes will be posted on this page. Please check this page periodically to review whether any changes have been made to our Privacy Policy. Although the site may take certain steps – – (i) to protect personally identifiable information which you may transmit via the site, and (ii) to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction – – no Internet transmission is ever completely secure or error-free.

KEY TERMS:

• COOKIES: Cookies are small amounts of text files that are sent from a website to your computer’s browser when you visit the site. These cookies are then stored in files within your computer’s browser. Websites can access only the cookies that they have stored on your computer. For example, if the Acme Computer Company stores a cookie on your browser, Acme may access its own cookie to improve the user’s online experience, but it could not access any cookies belonging to another company. For every future time you access the website, your browser sends the cookie back to the server, which notifies the website of the user’s previous activities on the website. Thus, cookies serve several useful purposes, like letting you navigate between pages more efficiently, saving your preferences, and enhancing your user experience with the website.
• INTERNET PROTOCOL (IP) ADDRESS: A numerical label separated by periods that identifies every device (e.g., computer, printer) that participates in a network. IP addresses allow these devices to communicate with one another and transmit relevant information.
• PERSONALLY IDENTIFIABLE INFORMATION (personal information): personal information includes: first and last name; physical mailing address including street name and city/town; email; telephone number; Social Security Number, Internet Protocol address if the IP address identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ; and any other similar identifier that permits the physical or online contacting of a specific individual.
• WEB BEACONS: Web beacons (also called transparent GIFs, web bugs, pixels, or action tags) are strings of code that deliver a tiny graphic image on a web page or in an email which is used to monitor the behavior of the user visiting the website or sending the email. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page on which the web beacon is placed. In general, any file served as part of a web page can act as a web beacon. We use web beacons for various tracking purposes, like determining whether or not you are logged into the site and whether or not you are connected to a third-party service.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
In this section, Integra Connect provides additional information to California residents about how we handle their personal information, whether collected online or offline, as required under California privacy laws including the California Consumer Privacy Act, as amended (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.

1. Categories of Personal Information Under the CCPA (Last Updated: February 25, 2024)

While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about consumers in the prior 12 months since the Last Updated data above. As described in the “What Information Do We Collect” section above, we will not collect personal information, nor will we associate or link such information using cookies or web beacons, unless you voluntarily submit this information.

The table below identifies the categories of personal information (as defined by the CCPA) we have collected about consumers who voluntarily provide their personal information, as well as how we have sold or disclosed for a business purpose such information. Integra Connect discloses HIPAA de-identified information that is de-identified via the expert determination method to third parties customers in exchange for monetary or some other value or benefit. For more information about the business and commercial purposes for which we collect, use and disclose personal information, please see the “How Do We Use Your Information” and the “Sharing Your Information” sections above.

Personal information does not include certain categories of information, such as publicly available information from government records, and deidentified or aggregated consumer information.

We retain your personal information in accordance with our data retention schedule, unless we have or deidentified or deleted your personal information in response to a request to delete. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, including resolving disputes, or as permitted or required by applicable law. We may also retain your Personal Information in a deidentified, anonymized, or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; applicable legal requirements.

2. Purposes We Collect and Use Personal Information

We collect and use your personal information for the following business or commercial purposes. We may change or add to the purposes we collect personal information. In that case, we will inform you and obtain your consent when required by law.

• To provide you with information, products, or services you request from us.
• To fulfill or meet the reason for which the information is provided.
• To contact you and/or provide you with email alerts and other notices concerning our properties, products, services, events, or news that may be of interest to you. For example, we may send you announcements, surveys, and newsletters using any communications preferences you have expressed. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means. Of course, if at any time you no longer wish to receive such communications, you have the option of unsubscribing from our mailing list for that communication.
• To process payments.
• To engage in marketing activities.
• To communicate with you in social media concerning our products and services.
• To ensure your information is accurate and to personalize our communications to you. For example, we may aggregate your personal information with data from various sources for purposes of keeping information up to date. If you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal or share and use it as described elsewhere in this Policy. • To carry out our obligations and enforce our rights including those arising from any contracts entered into with you including for billing, payment, and collections.
• To review, improve, and monitor our website, applications, online services, and overall consumer experience, including to provide customization to meet the specific needs.
• To provide customer service and engage in quality control activities concerning our products and services.
• For testing, research, analysis and product and service development. We may use data, including public feedback and surveys, to conduct research and for the development of the site and the services, products, and information we provide.
• To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes.
• As described to you when collecting your personal information.
• To manage our recruiting efforts and employment and workforce relationships. These activities include, for example, sourcing and processing employment applications, onboarding employees and contingent workers, and carrying out a range of employments activities relating to the employment relationship, such as compensation, benefits, promotion, discipline, termination, and certain post termination activities.
• As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

3. Sources of Personal Information We Collect

• You. We may collect personal information that you provide during your interactions with us, such as through our site, by email, or when you communicate with our associates online, by phone, or when you attend an event, or participate in a promotion or program we sponsor. We collect information when you are an applicant for employment with us and employed by us. We also collect information through certain online tracking tools, such as browser cookies, flash cookies, and web beacons.
• Related Entities and Affiliates. We may collect information about you from our related parties and affiliates, including joint ventures.
• Social media and related services.
• Service providers and contractors. When you obtain products and services from us, we may collect your personal information from service provider and contractors who collected information about you that is needed to provide those products and services.
• News outlets, social media, surveys, and certain third parties. In the course of performing our services or marketing activities, we or third parties on our behalf may conduct research and other activities resulting in the collection of personal information about you.
• Information Collected Automatically. As you navigate through and interact with our site, we may compile statistical information concerning your usage of the site through analytics services, such as those provided by Google Analytics. To do so, we may collect certain information about your equipment, browsing actions and patterns, including:
  • Details of your visits to our site, such as traffic data, location data, logs and other communication data and the resources that you access and use on the site
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.
  • Information about the type of device you are using, mobile ad identifiers, the time and length of your visit, and the website that referred you to our site.
  • Information about your preferences to make your use of the site more productive, via the use of Cookies. For more information on Cookies, please see the Cookies and Other Tracking Technologies section. While all of this information can be associated with the IP address your computer had while you visited the site, it will not be associated with you as an individual or with any other information you may submit through the site or that we may store about you for any other purposes. We may use this information to generate aggregate statistics about visitors to our site. Please check your web browser if you want to learn what information your browser sends or how to change your settings.

4. California Residents’ Rights

CCPA Rights. In general, California residents have the following rights with respect to their personal information:

• Do-not-sell/share (opt-out): We do not sell or share your personal information to third parties. We also do not use or disclose your sensitive personal information for purposes that, with limited exceptions, are not necessary in order to provide our products and services as are reasonably expected by an average consumer requesting those goods and services. We also do not have actual knowledge that we have sold personal information of minors under age 16.
• Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.
  
  There may be circumstances where we cannot delete your personal information or direct service providers or contractors to delete your personal information from their records. Some of these instances include, but are not limited to, if we need to:
  • Complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform a contract between Integra Connect and you.
  • Help to ensure security and integrity to the extent the use of the consumer's PI is reasonably necessary and proportionate for those purposes.
  • Debug to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
  • 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.
  • Engage in public or peer-reviewed scientific, historical, or statistical research that confirms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent.
  • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which the consumer provided the information.
  • Comply with a legal obligation.
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
• Right to know: Upon receipt of a verifiable consumer request (see below), as a California resident, you also have the right to request more information regarding the items listed below. In general, any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. However, with respect to personal information collected on and after January 1, 2022, and to the extent expressly required by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not require a disproportionate effort by us.
• categories of personal information collected;
• categories of sources of personal information;
• categories of personal information about them we have disclosed for a business purpose, shared, or sold;
• categories of third parties to whom we have sold, shared or disclosed the personal information;
• the business or commercial purposes for collecting, selling or sharing personal information; and
• a copy of the specific pieces of personal information we have collected about them.
• Right to Request Correction. You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it. Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we (or our customers) will provide a response to such requests.

Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA. This also includes an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.

If you feel your privacy rights have been violated, you can submit a complaint to the California Privacy Protection Agency at https://www.cppa.ca.gov/webapplications/complaint or the California Attorney General at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company.

Submitting CCPA Requests. California residents may submit CCPA requests to know (access) and requests to delete their personal information through one of the following methods:

• Online at compliance@integraconnect.com
• By phone at 1-855-252-7606

We reserve the right to only respond to verifiable consumer requests to know, delete, or correct. In most cases, we collect your personal information in connection with services we perform for other companies. Accordingly, we also reserve the right to forward your request on to the related customer(s) that will respond to your requests to know, delete, or correct.

When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must provide us with this information via the above number or at compliance@integraconnect.com to verify your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.

Should we deny your request, it is your right to appeal the decision by submitting an appeal request to us via the above methods available for submitting original requests. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal. If the appeal is denied in whole or part, you may file a complaint with the California Privacy Protection Agency or the California Attorney General.

You may authorize a natural person or a business (the “Agent”) to act on your behalf with respect to the rights under this section. When you submit a request to know, correct, or delete, the Agent must provide proof that you gave the Agent signed permission to submit the request, and you either must (i) verify your own identity with the business or (ii) directly confirm with us that you provided permission to the Agent. However, these steps are not required when you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.

Your Privacy Rights Under California Shine the Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email compliance@integraconnect.com or call 1-855-252-7606, and include in your request a current California address and your attestation that you are a California resident.