Infinx Privacy Policy

Last updated April 17, 2024

Thank you for choosing to be part of our community at TIS International (USA), Inc., doing business as Infinx Healthcare on behalf of itself and its affiliates, Enhanced Revenue Solutions, Inc. and Ni2 Health, Inc. (collectively, “Infinx Healthcare”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at [email protected]. When you visit our websites, including without limitation www.infinx.com and www.ni2health.com (collectively, the “Site”), and use our services, you trust us with your personal information.

We take your privacy very seriously. In this privacy policy, we describe our data handling practices. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Site and our services. This privacy policy applies to all information collected through our Site, and/or any related services, sales, marketing or events (we refer to our Site and our services collectively in this privacy policy as the “Services”). Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, and payment information. We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect can include the following: Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data. Credentials. We collect passwords, password hints, and similar security information used for authentication and account access. Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. We do not store payment card information; rather we utilize a third party payment processor and store only an electronic receipt that sets forth confirming payment details, such as purchase date, the expiration date of the payment card and the payment ID, but not complete payment card information. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

If you inquire about a career with us through the Site’s careers page, you will also be asked to provide additional information, including your resume. We utilize a third party provider to host our job applications and assist with the application process.

Information automatically collected In Short: Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Services. We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal information like your name or contact information but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies. See Section 4 below for more information.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.

We use the information we collect or receive:

• To send you marketing and promotional communications. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the ”WHAT ARE YOUR PRIVACY RIGHTS” section below).
• Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
• To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, to evaluate and improve our Services, products, marketing and your experience, and to fill employment positions. We may use and store this information on an identifiable basis as well as in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

• Affiliated companies. We may share your data with our affiliated companies for administrative purposes as well as in connection with the provision of Services and our marketing efforts.
• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition of all or a portion of our business to another company, assignment, liquidation or other disposition of all or any portion of our business, assets or stock with such third party.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information. We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

We use Google Analytics which uses cookies to identify the frequency of use of certain areas of our Services and to identify preferences. For more information regarding how Google collects, uses, and shares your information please visit http://www.google.com/policies/privacy/partners/. Google will use this information to analyze your use of the Services, compile reports on activity for us, and perform further services associated with website use and Internet use. Google may also transmit this information to third parties where required by law or to the extent that third parties process these data on behalf of Google. You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=en.

We operate social media pages on third party networks and have social media icons on our Site. When you visit or link to our social media pages, data is processed both by us and the applicable social media provider. Social media providers are unaffiliated with us, and we are not responsible for the content or privacy practices of social media providers. Social media providers have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). Notwithstanding the generality of the foregoing, we store email addresses until you request to be unsubscribed or you remove yourself through any self-service account profile tools.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age. We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at [email protected].

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale or sharing of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at [email protected].

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit http://wwvv.aboutads.info/choices/.

You may opt out of receiving electronic marketing communications from us by clicking on the “unsubscribe” link on the communication or contacting us at [email protected]. Some non-marketing communications may not be subject to a general opt-out, such as communications about transactions, disclosures to comply with legal requirements, software updates and other support-related information. If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.

Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority and the right to appeal our decision regarding a data access request.

Your European Privacy Rights and Choices: While we do not specifically market our products and services to those outside the United States, we will provide accommodations for the exercise of the rights of individuals located in the European Union, the United Kingdom or another jurisdiction that has adopted laws substantially similar to the European Union’s General Data Protection Regulation (GDPR), which privacy rights include the following:

• Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time.
• Right of access, correction, restriction of processing, erasure. You may contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information, which requests we will do our best to honor subject to any legal and contractual obligations. To make a request or to ask us a question about our data practices, please contact us via email at [email protected].
• Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time.
• Right to object at any time. You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial e-mails or by contacting us, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal and contractual obligations. Some non-marketing communications are not subject to a general opt-out, such as communications about transactions and disclosures to comply with legal requirements.
• Right to data portability. You have the right to data portability of your own personal data by contacting us.
• Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you.
• Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according to the European Privacy regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement. You can find their contact details here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

California Disclosures:

California “Shine the Light” Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to [email protected] with “California Shine The Light Rights” in the subject line.

California Consumer Privacy Act Disclosures. Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act effective January 1, 2023 (“CCPA/CPRA”), California residents have the right to request:

• The categories of personal information (including sensitive personal information if applicable) we have collected about you;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose of collecting, selling or sharing personal information;
• The categories of third parties with whom we share or sell personal information;
• The categories of personal information about you that we have disclosed; and
• The specific pieces of personal information we have collected about you.

Additionally, you have the right:

• to know the length of time we retain your personal information;
• to request deletion of your personal information;
• to request the correction of any inaccurate data;
• to opt out of the sale or sharing of your information (if applicable);
• to limit the use of sensitive personal information (if applicable); and
• to not be discriminated against for exercising any of your CCPA/CPRA rights.

Please see the chart below regarding the categories of data we may have collected or received in the 12 months preceding the effective date of this Privacy Policy from Consumers in connection with providing our Services and to whom we may have disclosed the information for business purposes.

Personal Information Category	Source of Personal Information	Purpose for Collecting the Personal Information	To whom we disclose the Personal Information
Identifiers such as a name, address, unique personal identifier, email, phone number	Information you provide to us; Information we collect automatically; Information collected from third party providers.	See Sections 2 and 4 above.	See Section 3 above.
Information described in 1798.80(e) (and not otherwise addressed in this table), including bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information	Information you provide to us.	See Sections 2 and 4 above.	See Section 3 above.
Protected Classifications under California and federal law, including gender, age and citizenship.	Information you provide to us; Information collected from third party providers (such as our job application hosting providers).	We use this information to evaluate any application for employment.	See Section 3 above.
Commercial information such as records of products or services purchased, obtained, or considered, purchase histories and tendencies	Information you provide to us when you make purchases via our Site.	See Sections 2 above.	See Section 3 above.
Biometric information	We collect this information from our personnel for access to our premises	We use this information to secure our premises.	See Section 3 above. Personnel may learn more in their handbook.
Internet or other electronic network activity information, including browsing history and search history and interactions with an advertisement.	Information you provide to us; Information we collect automatically	See Sections 2 and 4 above.	See Section 3 above.
Geolocation data that is sufficient to identify a precise physical location.	We do not collect this information.
Sensory data, such as audio, electronic, visual, or other similar information.	We may record our voice calls with you for customer service purposes. We utilize video surveillance of our premises.	See Sections 2 above.	See Section 3 above.
Professional or employment-related information	Information you provide to us; Information collected from third party providers (such as our job application hosting providers).	We use this information to evaluate applications for employment.	See Section 3 above. Personnel may learn more in their handbook.
Education Information	Information you provide to us; Information collected from third party providers (such as our job application hosting providers)	We use this information to evaluate applications for employment.	See Section 3 above.
Inferences about preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Information you provide to us; Information we collect automatically; Information collected from third party providers.	See Sections 2 and 4 above.	See Section 3 above.

Any sensitive data we collect is used only for a business purpose and not for the purposes of inferring characteristics of a consumer.

In the last 12 months preceding the effective date of this Privacy Policy, we have shared (as defined under CCPA/CPRA) consumers’ personal information in the context of cross-context behavioral advertising.

We do not sell or share personal information for monetary consideration under CCPA/CPRA. Personal data may be provided to our service providers, contractors and, pursuant to Sections 1798.140(ad)(2)(A) and 1798.140(ah)(2)(A) of the CCPA/CPRA, to third parties.

You may opt out of the use of Cookies using your browser settings and opt out of the use of Google Analytics Cookies by downloading the browser add-on here: https://tools.google.com/dlpage/gaoptout?hl=en.

Our contact information is listed at the bottom of this policy. You may also submit a request on our Site by clicking on the Privacy Request link located on our homepage. If you submit a data subject request, we will ask for your name, email address and username (as applicable). We may also require that you submit your request via the Services’ standard authentication procedures (i.e., log on with username and password to submit a request) and/or provide information about any historical transactions with the Services to ensure you are the person you say you are. If this information or these processes are insufficient to verify your identity and assess your privacy request, we may need to ask for additional information. You may also designate an authorized agent to make a CCPA privacy request.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Our Site utilizes a tool designed to detect and honor Global Privacy Control signals from visitors to our website in a frictionless manner. The website will automatically opt the user out of certain cookies depending on how the user has set the signal.

9. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws. We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

10. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact us via email at [email protected] or by post to TIS International (USA), Inc. 20380 Town Center Lane, Suite 165, Cupertino, CA 95014 United States, Attention: General Counsel.