LifeLinc Privacy Policy
Last Updated: February 16, 2023
Effective Date: December 5, 2016
This Privacy Policy (the “Policy”) applies to the websites, applications, and electronic communications on which it appears (the “Platform”). The Policy describes how LifeLinc Corporation as well as our affiliates and subsidiaries (collectively "LifeLinc” or "we" or "us" or "our") use the Personal Information that we collect, receive, maintain, and store about you. Please read this Policy carefully, by interacting with us through the Platform you consent to this Policy. Note, this Policy does not cover LifeLinc’s collection, use, or disclosure of Protected Health Information (“PHI”) as defined by the Health Insurance Portability and Accountability Act of 1996, the Health Information Technology for Economic and Clinical Health Act and the regulations promulgated therein, including, without limitation, the requirements set forth in 45 C.F.R. § 164.400, et seq.
IMPORTANT NOTE: This website is for use by health care facilities and other potential purchasers of LifeLinc’s services, but not for individuals who receive medical services from LifeLinc (not for use by LifeLinc patients). LifeLinc’s use and disclosure of medical information about its patients is governed by the Notice of Privacy Practices for the facility in which LifeLinc’s anesthesia services are provided. Please do not provide any information on this website that identifies or can be used to identify a patient, or that relates to the past, present or future physical or mental condition of a patient, the provision of health care to a patient, or the past, present or future payment for the provision of health care to a patient. If you are a patient or wish to make a payment on behalf of a patient, please click here. (By clicking on this link, you understand that you will be leaving the LifeLinc Anesthesia Website and will be re-directed to a secure third-party site managed by REPAY. The privacy and security policies that govern third-party websites may differ from the privacy and security policies that govern LifeLinc’s website. LifeLinc is not bound by the privacy and security policies of third-party websites.)
MEDICAL DISCLAIMER. IF THIS IS A MEDICAL EMERGENCY, PLEASE IMMEDIATELY CALL EMERGENCY PERSONNEL (911) TO GET PROMPT MEDICAL ATTENTION. DO NOT RELY ON ELECTRONIC COMMUNICATIONS THROUGH THIS WEBSITE FOR ASSISTANCE IN REGARD TO YOUR IMMEDIATE, URGENT MEDICAL NEEDS. THIS WEBSITE IS NOT DESIGNED TO FACILITATE MEDICAL EMERGENCIES.
1.Types of Personal Information Collected
We collect a range of Personal Information. “Personal Information” is information that identifies, relates to, describes, or is reasonably capable of being associated with or linked to an individual. When we combine Personal Information with other information (i.e. information that does not, on its own, identify you), we treat the combined information as Personal Information.
Contact and Demographic Information – If you submit an inquiry, we may collect your contact including your name, email name, and phone number.
Employment Information – If you apply for employment with LifeLinc, we will collect your employment and work history, as well as Personal Information related to your potential employment. This may include your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.
Location Data – While navigating our Platform your mobile device or browser may share your location data, both through WiFi and GPS. LifeLinc will collect this information based on the settings of your phone and browser.
Usage Information – We may also collect usage and device information when you visit our Platform. This may include information about the browser, operating system, and/or device identifier for the device you are using, your ISP and IP information, your navigation activity on the Platform, as well as the websites that you came from and the site you visit when you leave.
2.Method of Information Collection
We collect Personal Information in a variety of ways. We collect Personal Information directly from you; for example, when you register an account on the Platform or correspond with us through the Platform.
We also collect Personal Information from third parties. For example, we work with business partners, subcontractors in technical and delivery services, advertising networks, analytics providers, and search information providers.
We also collect Personal Information from you passively. Our Platform uses tracking tools like cookies, pixels, and web beacons. We do this both on our Platform and in emails that we send to you. Through these tools we collect Personal Information about users over time when you use our Platform. This collection includes usage and browser information. We may also have third parties collect Personal Information in this way. For more information about the trackers that we use, please see Section 6 of this Policy. Additionally, if you enable location data on your device, this data will be collected passively based on the location settings on your device.
3.Combining Information
We may combine Personal Information we obtain. For example, we may combine Personal Information that we have collected online with Personal Information that we have collected offline, for instance during calls between you and our support team. We may also combine Personal Information that we have collected across other third-party sites or from other third parties with Personal Information we already have. Finally, we combine Personal Information across devices.
4.How We Use Personal Information
We will use your Personal Information to respond to your requests and inquiries. For instance, we will use it to communicate with you about eligibility for employment or to answer questions about our services. We will also use it to process employment applications.
We also use your Personal Information to communication with you for transactional purposes. For example, we might contact you about this Policy or our Terms of Use.
We may also use your Personal Information to improve our Platform. This may include using your Personal Information to customize your experience with us. We may also use your Personal Information for the security of the Platform and our company, our customers, and other third parties. We may also use your Personal Information to protect against fraud and other malicious activity.
Finally, we may use your Personal Information for other purposes, as permitted by law.
5.Sharing Personal Information
We may share your Personal Information in the following circumstances:
6.Cookies and Other Technologies
We may collect Personal Information about users over time on the Platform by using several common types of cookies and other tracking technologies including web beacons, pixels, and flash cookies. We also have third parties that collect Personal Information in this way on our behalf and for their own purposes. Cookies are small files that download when you access certain websites. For more information about cookies visit: http://www.allaboutcookies.org/. Web beacons, pixels, and other tracking technologies operate independent of cookies.
To assist us with analyzing our website traffic through cookies and similar technologies, we use analytics services such as Google Analytics. For more information on Google Analytics’ processing of your Personal Information, please see “How Google uses data when you use our partners' Platforms or apps.” You can opt out of Google Analytics by installing Google’s opt-out browser add-on.
These cookies may be ones placed by us (first-party) or by a third party. These cookies may also be Flash Cookies. To learn how to manage privacy and storage settings for Flash cookies click here. We may use cookies that are session-based or persistent. Session cookies expire when you close your browser or turn off your device. Persistent cookies remain on your device after you close your browser or turn off device.
We may use a variety of cookies:
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Type of Cookies
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Description
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Required
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Required cookies are essential for the Platform to function properly and for you to navigate our Site and use its features, such as accessing secure areas of the Platform and using our services.
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Performance
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These cookies collect information about how you use the Platform, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information these cookies collect is aggregated and anonymous. It is only used to improve how the Platform functions and performs.
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Functionality
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Functionality cookies allow the Platform to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Platform after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.
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Targeting or Advertising
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From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit the Platform. We sometimes use cookies delivered by third parties to track the performance of our advertisements. For example, these cookies remember which browsers have visited the Platform. The information provided to third parties does not include Personal Information, but this information may be re-associated with Personal Information after we receive it.
By way of example, as you visit the Platform, advertising cookies may be placed on your computer so that we can understand what you are interested in. Our advertising partners then enable us to present you with retargeted advertising on other sites based on your previous interaction with the Platform.
We also contract with third-party advertising networks and similar partners that collect IP addresses and other information on our Platform, from emails, and on third-party sites. Ad networks follow your online activities over time by collecting Site Navigational Information through automated means, including through the use of cookies. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other websites. This process also helps us manage and track the effectiveness of our marketing efforts.
Third parties, with whom we partner to provide certain features on the Platform or to display advertising based upon your web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.
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You can control cookies and tracking tools. Some browsers have a “do not track” feature that prevents a website from tracking you, as well as additional cookie settings. Our Platform does not currently respond to these signals. If you choose to block cookies and other trackers, certain features of the Platform may not work. Blocking or rejecting cookies will not stop all of the tracking described in this Policy. These features and options are browser and device specific and are not uniform. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful, or you can use the help option in your browser for more details:
To find out more on how to manage and delete cookies, visit aboutcookies.org. For more details on your choices regarding use of your web browsing activity for interest-based advertising you may visit the following sites:
On a mobile device, you may also be to adjust your settings to limit ad tracking.
7.Your Choices
You have certain choices about how we use your Personal Information. Please note that, even if you unsubscribe from certain correspondences, we may still need to contact you with important transactional or administrative information, as permitted by law.
8.Children Under the Age of 13
The Platform is meant for adults and we will not knowingly collect Personal Information from any person under the age of 13 without permission from a parent or guardian. The Platform are not designed to attract the attention of persons under the age of 13. If you are a parent or legal guardian and think your child has given us Personal Information you can let us know by emailing us at privacy@lifelinc.com. Please mark your inquiries “COPPA Inquiry.”
9.California Privacy Rights
We do not share Personal Information with third parties for their marketing purposes. Pursuant to California’s Shine the Light statute (Cal. Civ. Code Sec. 1798.83), if we do share Personal Information in such way, we will provide appropriate notice by updating this policy.
In addition, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain other rights concerning their Personal Information. This section describes (1) the categories of Personal Information, collected and disclosed by Rails, subject to California privacy law, (2) your privacy rights under California privacy law, and (3) how to exercise your rights.
When we use the term “Personal Information” in this section, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
a.Personal Information we Collect.
LifeLinc makes the following disclosures regarding the categories of Personal Information (enumerated in Section 1798.140(o)(1) of the CCPA) that it has collected within the last 12 months:
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Category of Personal Information
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Collected
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Category of Source from which Personal Information is Collected
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Purpose of Collection
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Third Parties to whom Personal Information is Disclosed for a Business Purpose
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Third Parties to whom Personal Information is Sold or Shared
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Retention Period
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Identifiers
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Yes
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Directly from you; cookies and other tracking technologies
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See section above titled “How We Use Personal Information”
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Service Providers
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Third party advertisers
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See *** Below
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Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
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Yes
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Directly from you
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See section above titled “How We Use Personal Information”
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Service Providers
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We do not sell or share this category of Personal Information
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See *** Below
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Protected classification characteristics under California or federal law
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No
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N/A
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N/A
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N/A
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N/A
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N/A
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Commercial information
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No
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N/A
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N/A
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N/A
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N/A
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N/A
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Biometric information
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No
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N/A
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N/A
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N/A
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N/A
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N/A
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Internet or other similar network activity
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Yes
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Cookies and other tracking technologies
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Service Providers
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Third party advertisers
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Varies depending on the type of cookie collecting this category of Personal Information, but no more than 2 years
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Geolocation data
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No
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N/A
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N/A
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N/A
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N/A
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N/A
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Sensory data
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No
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N/A
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N/A
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N/A
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N/A
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N/A
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Professional or employment-related information
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Yes
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Directly from you
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See section above titled “How We Use Personal Information”
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Service Providers
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We do not sell or share this category of Personal Information
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See *** Below
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Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
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No
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N/A
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N/A
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N/A
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N/A
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N/A
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Inferences drawn from other personal information
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No
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N/A
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N/A
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N/A
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N/A
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N/A
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Sensitive Personal Information
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Yes
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Directly from you
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See section above titled “How We Use Personal Information”
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Service Providers
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We do not sell or share this category of Personal Information
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See *** Below
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*** Unless a longer retention period is required by law, we will retain your personal data for as long as is needed to fulfill the purposes outlined in this Privacy Notice, or for as long as we have a legitimate business interest that is not outweighed by your data protection interests or fundamental rights and freedoms. When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it or, if this is not possible (e.g., because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible. As such, we reserve the right to use such anonymous data for any legitimate business purpose without further notice to you or your consent.
b.Your Privacy Rights.
In accordance with the CCPA, California consumers may exercise under certain conditions the following four (4) categories privacy rights with respect to their Personal Information. Please note: you will not be discriminated against in any way by virtue of your exercise of the rights listed below, which means we will not deny goods or services to you, provide a different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.
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Privacy Right
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Description
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Notice
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You have the right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.
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Access
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You have the right to request the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You also have the right to request the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.
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Erasure
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You can request to have your Personal Information deleted from our servers and we will direct our service providers to do the same. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required to retain your Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); (4) to otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
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Correction
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You have the right to request that we correct any incorrect Personal Information that we collect or retain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see below), we will correct (and direct any of our service providers that hold your Personal Information on our behalf to correct) your Personal Information from our records, unless an exception applies. We may deny your correction request if (a) we believe the Personal Information we maintain about you is accurate; (b) correcting the information would be impossible or involve disproportionate; or (c) if the request conflicts with our legal obligations.
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To Opt Out of Sales or Sharing of Personal Information
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You can request to opt out of us selling or sharing your Personal Information. To exercise this right please click here and follow the instructions to submit your request. As noted above, in the past 12 months we may have enabled advertisers to collect certain information from the Platform, which the advertisers may use to improve their interest-based advertising networks. Regardless of whether this is considered a “sale” or “share” under the CCPA, you may adjust your browser settings to opt out of this type of information collection, as described in Section 6 above. Except as described above, LifeLinc does not sell or share your Personal Information. LifeLinc only uses your Personal Information to conduct our normal business operations as outlined above.
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Limit Use of Sensitive Personal Information
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LifeLinc does not use or disclose sensitive Personal Information other than to process applications for employment and facilitate its recruitment operations. If we used or disclosed sensitive Personal Information for other purposes, you would have the right to opt out.
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c.How to Exercise Your Rights.
If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to privacy@lifelinc.com or call us toll-free at: 901-207-2007, ext. 144. You have a right not to receive discriminatory treatment by any business when you exercise your CCPA rights.
While we take measures to ensure that those responsible for receiving and responding to your request are informed of your rights and how to help you exercise those rights, when contacting us to exercise your rights, we ask you to please adhere to the following guidelines:
- Tell Us Which Right You Are Exercising: Specify which right you want to exercise and the Personal Information to which your request relates (if not to you). If you are acting on behalf of another consumer, please clearly indicate this fact and your authority to act on such consumer’s behalf;
- Help Us Verify Your Identity: Provide us enough information to verify your identity. For example, provide us (at a minimum) your full name, address, and phone number. Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
- Direct Our Response Delivery: Inform us of the delivery mechanism with which you prefer to receive our response. You may specify, for example, email, mail, or through your account (if you have one with us).
Please note that you do not need to create an account with us in order to make a request to exercise your rights hereunder.
d.How We Respond to Your Requests.
In all cases, we will respond to your request within 45 days. However, where reasonably necessary, we may extend our response time by an additional 45 days, provided we send you notice of such extension first. We will provide the information to you via your preferred delivery mechanism. If the information is provided to you electronically, we will provide you the information in a portable format and, to the extent technically feasible, in a machine readable, readily useable format that allows you to freely transmit this information without hindrance.
Please note that we will not charge you for making a request, provided that you make no more than two (2) requests per year. If you make three (3) or more requests in any given twelve (12) month period, we may refuse to respond to such requests, if determined by us to be unfounded or excessive (e.g. repetitive in nature), or we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested. If we refuse to act on the request, we will provide you notice and the reason for our refusal to act.
10.Storage, Security and Retention of Information
LifeLinc has taken reasonable steps to protect the information users share with us, including, but not limited to, setup of processes, equipment and software to avoid unauthorized access or disclosure of this information. No transmission of information via the Internet can be entirely secure, however, so please always use caution when submitting Personal Information. We will retain your Personal Information in compliance with the uses described in this Policy, as well as to comply with our legal, financial reporting, or compliance obligations.
11.Links to Third Parties and their Sites
Our Platform may include third party content and links to third party websites and services that collect Personal Information. We do not control these third parties and this Policy does not apply to their privacy practices. We are not responsible for the practices of these third parties or how they use Personal Information you provide to them. Please read the third parties’ privacy policies carefully.
12.Contacting LifeLinc
If you have any questions about this Policy, or the privacy practices of LifeLinc, please email us at privacy@lifelinc.com or write to us at:
Privacy Officer
LifeLinc Anesthesia
3340 Players Club Parkway, Suite 350
Memphis, TN 38125
13.Updates
Please note that this policy may be amended from time to time. Unless otherwise indicated, any changes to this Policy will apply immediately upon posting to the Platform so please check our site periodically for updates. You can see when this Policy was last updated by reviewing the “Last Updated” legend at the top of this page. We will provide notice of material changes by updating the Policy here, and communicating with you in the manner and format in which we typically communicate with you in our regular course of business, as required by applicable law.