Privacy Policy

Welcome

Health Services Innovation and Advancement LLC values your privacy and is committed to protecting your Personal Data. In this Notice, the terms “Health Services Innovation and Advancement LLC,” “the Company,” and “our company” are used interchangeably and refer to the entity responsible for this mobile and web application. This Privacy Notice ("Notice") explains how we collect, use, share, transfer, and process information collected from or about you ("Personal Data") through our applications designed to optimize nutrition and physical therapy for patients undergoing surgeries.

The Health Services Innovation and Advancement LLC entity with whom you, your healthcare provider, or your patient is interacting, or which owns and operates the product or service, is, where applicable, the entity responsible for the collection and use of your Personal Data (known in some jurisdictions as the data controller). A list of the data controllers and contact details can be found in the section "Contact Us" and in Appendix 1 to this Notice.

Please carefully review this Notice. We will process any Personal Data we collect in accordance with applicable law and as explained in this Notice (unless a separate policy or notice governs). In some circumstances, if you do not want to provide us with your information, certain products and services may be unavailable to you. To the extent permitted by applicable law, by providing us your Personal Data or otherwise interacting with us, you are agreeing to this Notice. If you do not agree with our policies and practices, it is your choice not to use our products and services or otherwise engage with us.

If you provide Personal Data of anyone other than yourself, please note that you are responsible for complying with all applicable privacy and data protection laws prior to providing that information to Health Services Innovation and Advancement LLC.

Purpose of this Privacy Notice

This Notice outlines the categories of Personal Data our company collects and processes, the purposes for which we use and disclose such data, and the rights available to you regarding its processing. It applies to all Personal Data gathered or processed by our company.

We collect Personal Data in various contexts, including but not limited to:

• Digital Interactions:When you engage with our online platforms—including our websites, mobile applications, online surveys, newsletters, chat services (with live support or artificial intelligence), social media channels, phone support, email, SMS/text messaging, and other digital communications (“Online Services”).
• Account and Service Usage:Through your account creation and use of our products or services, whether accessed directly by you or provided through your healthcare provider, clinic, or facility.
• In-Person and Event-Based Interactions:During visits to our websites, offices, or events such as trade shows, conferences, and community gatherings. For the purposes of this Notice, Online Services, Events, and our other products and services are collectively referred to as “Products and Services.”
• Research and Clinical Engagement:In connection with recruiting participants for clinical trials or research studies focused on optimizing nutrition and physical therapy outcomes.
• Incident Reporting: Related to adverse events, complaints, or other incident reports.
• Professional Interactions:When you interact with us in a professional capacity—such as healthcare providers or employees of clinics and facilities that partner with us.
• Recruitment Processes: During activities related to employment recruitment.
• Other Instances: In any other situation where this Notice is referenced or made available.

Our company may issue additional, situation-specific privacy notices that govern particular interactions or Products and Services. In those cases, the additional notice will take precedence over this Notice.

Personal Data, Collection, Purposes, Source and Recipients

Personal Data

For the purposes of this Notice, “Personal Data” refers to any information—whether recorded electronically or otherwise—that can be used to identify a specific individual or be directly linked to an individual. This includes, for example, your name, address, email address, telephone number, credit card details, or health and treatment information. In some jurisdictions, Personal Data may also encompass information that does not directly identify you but can be linked to you indirectly, such as a unique identifier assigned by a healthcare provider. Please note that, particularly for patients, a significant portion of the Personal Data we process is received directly from your healthcare provider.

Certain types of Personal Data are considered sensitive under applicable law. These may include biometric data, genetic information, detailed health information, financial account information, specific geolocation data, ethnic or racial origin, data concerning your sex life or sexual orientation, social security numbers, driver’s license or state identification numbers, passport details, and other similar types of information.

The categories of Personal Data collected by our company vary depending on your relationship with us. Below is an overview of the types of Personal Data that may be collected from different groups:

1. Users of Online Services, Website Visitors, and Inquirers:
   These individuals may provide identity and contact details (such as name, email, and telephone number), demographic information (such as age and gender), as well as video, audio, and other recorded data. They may also share technical information related to device usage, basic health details, select commercial or financial data, professional or educational background, and anonymized or de-identified data.
   
   
2. Patients and Users of Medical Devices:
   Patients typically provide comprehensive identity and contact information, detailed demographic data, video, audio, and recorded content, as well as technical information. They may also disclose extensive health and treatment data, relevant financial details, and sometimes professional or educational information, along with anonymized or de-identified data.
   
   
3. Healthcare Providers:
   Healthcare professionals may supply their identity and contact details, demographic information, and recorded data (such as video or audio). They also provide technical data, sensitive health information related to their practice, select commercial and financial data, and professional or educational credentials, as well as anonymized data.
   
   
4. Employment and Apprenticeship Candidates:
   Individuals applying for positions or apprenticeships may share their identity and contact information, demographic details, recorded data, technical information, as well as commercial and financial data, and professional or educational backgrounds, alongside anonymized data.
   
   
5. Business Partners and Their Employees, Agents, and Contractors:
   These parties might provide identity and contact details, demographic information, video, audio, or recorded data, technical data, and commercial and financial information, in addition to professional or educational details and anonymized data.
   
   
6. Attendees and Participants at Events:
   People attending our events may provide similar types of data, including identity and contact information, demographic details, recorded data, technical information, health-related information, commercial and financial data, professional or educational backgrounds, and anonymized data.
   
   
7. Clinical Investigators and Members of Investigator Teams:
   These individuals may furnish identity and contact details, demographic information, recorded data, technical information, as well as commercial and financial data, in addition to professional or educational credentials and anonymized data.
   
   
8. Clinical Study Candidates:
   Individuals considered for clinical studies may provide identity and contact details, demographic data, recorded information, technical data, comprehensive health information, commercial and financial data, professional or educational details, and anonymized data.
   
   
9. Minors:
   Although our services are intended exclusively for adults (18 years and older), in jurisdictions where processing Personal Data of minors is permitted, such processing will only occur with the explicit consent of a parent or legal guardian. We do not knowingly collect Personal Data from minors in other circumstances.
   
   

It is important to note that not every category will apply to every individual. The specific types of Personal Data we collect, process, and disclose depend on your particular relationship with our company. Should your relationship with us change, additional categories of Personal Data may become applicable.

Users of Online Services, Website Visitors, and Inquirers

Our company collects and processes Personal Data from individuals who interact with our online platforms and physical locations. This includes, but is not limited to, those who visit our websites, register for and use our online services, subscribe to newsletters or marketing communications, submit inquiries (whether online via email or chatbot, or offline via written correspondence), contact our customer support centers via phone, email, SMS/text messages, or chat, complete surveys or online questionnaires, and participate in our events.

The types of Personal Data we may collect in these contexts include:

• Identity and Contact Information:
  This encompasses your first and last name (or unique pseudonym), honorifics and titles, preferred form of address, employer or company details, email and postal addresses, phone numbers, as well as your username or code, along with associated security details (such as passwords, security answers, and user preferences). Additional identifiers may include customer or company identification numbers.
  
  
• Other Personal Information:
  We may collect demographic details such as age, gender, preferred language, marital status, disability status, and date of birth.
  
  
• Video, Audio, and Recorded Information:
  This category covers still images, video footage (including recordings from CCTV systems), voicemails, and any recordings of your interactions with our online services—be it via phone, email, SMS/text message, or chat.
  
  
• Technical Information:
  We gather data such as Internet Protocol (IP) addresses (which may indicate your general geographic location or company affiliation), browser type and language, device type, advertising identifiers (like Apple’s IDFA or Android’s AAID), and the dates and times you use our services. Additionally, we record URLs visited prior to and following your access to our services, details of your online activities (including form submissions, video views, clicks, and product descriptions accessed), information collected via cookies or similar technologies, and, where available, geolocation data.
  
  
• Anonymized / De‑identified Data:
  This refers to information that has been stripped of personal identifiers so that you cannot be identified. Such data is used for internal research, quality assurance, product improvement, and other administrative purposes.
  
  

We obtain this Personal Data directly from you when you engage with our digital or physical services, as well as indirectly through your authorized representatives (such as caregivers or designated proxies), your devices, our security systems (including CCTV), and from third parties that provide access to information you have made publicly available (for instance, via social media).

Your Personal Data is processed for a variety of purposes, including:

• Providing, managing, and personalizing our products and services;
• Communicating important updates and information to you;
• Authenticating your identity and customizing your user experience;
• Detecting, preventing, and mitigating fraud or security incidents;
• Administering our relationship with you and facilitating customer support;
• Conducting internal research, analytics, and development to enhance our offerings;
• Marketing, advertising, and promotional activities related to our products and services;
• Verifying eligibility and coverage, tracking adverse events and complaints, and complying with legal and regulatory obligations;
• Facilitating healthcare or treatment where applicable, and supporting public health initiatives aimed at ensuring high standards of care and safety.

We process your Personal Data under various legal bases, such as obtaining your consent (where applicable), the necessity to perform a contract with you, our legitimate interests, and compliance with legal and regulatory requirements.

Furthermore, we may share your Personal Data with:

• Our affiliates, subsidiaries, and related companies;
• Healthcare providers and your employer;
• Individuals or entities you have designated or instructed;
• Authorized representatives, family members, and caregivers;
• Third parties assisting with fraud prevention, detection, and mitigation;
• Providers supporting our IT and security programs;
• Our legal, auditing, and consulting advisors;
• Partners that help us deliver, manage, and improve our products and services.

This comprehensive approach ensures that your Personal Data is handled responsibly while enabling us to provide you with optimized nutrition and physical therapy support throughout your pre- and post-surgery care.

Patients and Users of Medical Devices

When you are an existing or prospective patient of a healthcare provider who is a customer of our company—or when you receive or use one of our medical devices, including our mobile applications—we may process your Personal Data. This section outlines the types of data we collect, the sources from which we obtain it, the purposes for processing, the legal bases under which processing occurs, and the entities with whom we may share your data.

Types of Personal Data Processed

1. Identity and Contact Information
   We collect details such as your first and last name (or a unique pseudonym), honorifics, titles, and preferred forms of address. Additional contact information includes your employer or company affiliation, email address, postal address, phone number, and login credentials (e.g., username, code, password, security answers, and user preferences). We also obtain contact details for related persons, such as authorized users of your account or designated representatives.
   
   
2. Other Personal Information
   This includes demographic data such as age, gender, preferred language, marital status, disability status, ethnicity, and date of birth.
   
   
3. Video, Audio, and Recorded Information
   We may capture still images, video recordings (including footage from CCTV systems), and recordings of your calls with our customer service representatives. Additionally, we collect voicemails, records of your interactions with our online services (via email, SMS/text messages, or chat), and pictures or videos related to diagnosis and treatment activities.
   
   
4. Technical Information
   Our systems log technical details such as Internet Protocol (IP) addresses (which can indicate your general geographic location or company affiliation), browser type and language, device type, and advertising IDs (such as Apple’s Identifier for Advertising [IDFA] or Android’s Advertising ID [AAID]). We also record the date and time of your interactions with our services, URLs visited before and after accessing our services, details of your online activity (e.g., forms submitted, videos watched, page clicks, product descriptions viewed), data from cookies or similar technologies, and geolocation data.
   
   
5. Health Information
   Given the nature of our service, we collect extensive health-related data, including:
   
   
• Diagnoses, pathologies, and identification of diseases,
• Unique identifiers associated with our products,
• Areas of interest in medical research,
• Dates of treatments and surgeries,
• Medical history and treatment records,
• Patient-reported outcome measures (e.g., responses to health questionnaires and surveys),
• Diagnostic images such as DICOM files, X-rays, MRI scans, and other medical scans,
• Details regarding therapy completion and usage,
• Communications with your healthcare provider (including recordings from telehealth sessions),
• Information on drug allergies, prescriptions, and dosing,
• Vital measurements (e.g., heart rate, blood pressure, gait patterns),
• Data on adverse events,
• Health insurance and payment details,
• Pregnancy status,
• Designated contacts for receiving your health information,
• Additional location data, and
• Pictures or videos related to diagnosis and treatment activities, including your patient ID.
6. Commercial and Financial Information
   This category includes records related to products and services purchased, obtained, or considered, bank account details, documentation of requests, customer service records, financial transaction histories, financial account numbers, and other payment-related information.
   
   
7. Anonymized / De‑identified Data
   Data that has been stripped of personal identifiers so that you are no longer identifiable is also processed. This anonymized information is used for purposes such as internal research, quality assurance, product development, and marketing analytics.
   
   

Sources of Personal Data

We obtain your Personal Data from several sources:

• Directly from You:When you interact with our products or services (e.g., filling out forms, subscribing to updates, or communicating with us).
• Healthcare Providers and Institutions: Your data may be shared with us by your healthcare provider or the medical institution with which you are associated.
• Your Devices and Security Systems: Information may be automatically collected from your devices (including via integrated security systems such as CCTV).
• Third Parties:This may include social media platforms, market research companies, or other public sources where you have made your information available.

Purposes for Processing Personal Data

We process your Personal Data for a range of purposes that include:

• Service Provision:Delivering and managing our products and services aimed at optimizing nutritional, mental, and physical therapy outcomes in the perioperative setting.
• Communication: Sending you important updates, alerts, and information relevant to your care and our services.
• Personalization: Authenticating your identity and tailoring your user experience based on your needs.
• Security: Detecting, preventing, and mitigating security incidents.
• Relationship Management: Administering our relationship with you and managing your account details.
• Quality Improvement: Conducting internal research, analytics, and development to enhance our products and services.
• Performance Analytics:Generating surgeon-specific performance insights and enabling healthcare providers to compare aggregated, de‑identified data regionally or globally.
• Compliance: Fulfilling legal, regulatory, and contractual obligations.
• Marketing: Engaging in marketing, advertising, and product promotion activities.
• Clinical Research: Supporting clinical studies and research initiatives related to optimizing perioperative care.

Legal Bases for Processing Personal Data

Our processing of your Personal Data is based on:

• Consent: Where you have provided explicit consent.
• Contractual Necessity: To fulfill our contractual obligations with you.
• Legitimate Interests: For our legitimate interests in improving our products and services.
• Legal and Regulatory Compliance: To meet legal, regulatory, or public health obligations.
• Protection of Vital Interests: To safeguard your vital interests or those of others.
• Performance of a Contract: To prepare for or execute a contract with you.

Recipients of Personal Data

Your Personal Data may be shared with:

• Our Affiliates and Subsidiaries: Our company, along with our affiliates, subsidiaries, and related entities.
• Healthcare Providers: The providers involved in your care.
• Designated Third Parties:Entities or individuals you have designated or instructed, including authorized representatives, family members, or caregivers.
• Security and IT Partners: Third parties assisting with fraud prevention, security programs, and IT support.
• Advisors and Consultants: Our legal, auditing, and consulting teams.
• Marketing and Service Partners:Partners that help deliver, manage, or enhance our products and services, including those supporting our marketing or administrative functions.
• Other Recipients: Any other parties required by law or with your explicit consent.

This detailed framework ensures that your Personal Data is processed and shared in a manner that supports our mission to provide comprehensive nutritional and physical therapy optimization for patients before and after surgery—all while ensuring compliance with applicable data protection laws.

Talent and Workforce Prospects

Our company collects and processes Personal Data from individuals who apply for employment or apprenticeship opportunities with us. This information is essential for evaluating your qualifications, managing our recruitment processes, and communicating with you regarding job opportunities, while supporting our commitment to delivering cutting-edge nutritional and physical therapy solutions for surgical patients.

Types of Personal Data We Process

1. Identity and Contact Information:
   
   
• Personal identifiers, such as your first and last name (or a unique pseudonym), honorifics, titles, and your preferred form of address.
• Contact details, including email and postal addresses, phone numbers, and login credentials (e.g., username, code, password, and security answers), along with any related user preferences.
• Additional identifiers may include your National Provider Identifier (if applicable), Social Security Number, and digital signature.
2. Other Personal Information:
   
   
• Demographic data, including age, gender, preferred language, marital status, disability status (if applicable), ethnicity, and date of birth.
3. Technical Information:
   
   
• Details such as Internet Protocol (IP) addresses (which may indicate your general location or company affiliation), browser type and language, device type, and advertising identifiers (e.g., Apple’s IDFA or Android’s AAID).
• Information on the date and time you access our recruitment platforms, URLs visited before and after your interactions, and online activity (e.g., forms submitted, pages clicked, and product descriptions viewed), including data from cookies or similar technologies.
• Geolocation data, where available.
4. Professional and Educational Information:
   
   
• Details about your job title or position, employment history, and work experience relevant to the role you are applying for.
• Information about your education, including institutions attended, degrees, certifications, licenses, and specialized training.
• Responses to surveys or questionnaires as part of the application process, as well as any information from background checks or professional references.
5. Anonymized/De‑identified Data:
   
   
• Data stripped of personal identifiers, used for internal research, quality assurance, process improvement, and benchmarking within our recruitment operations.

Sources of Your Personal Data

We obtain your Personal Data from:

• Direct Interactions: Information you provide directly when you submit your application through our recruitment platforms or during interviews.
• Recruitment Partners: Data provided by recruitment agencies, employment websites, or third-party recruiters assisting in the hiring process.
• Third Parties:Information sourced from publicly available professional profiles or references you designate, as well as background check providers.

Purposes for Processing Your Personal Data

We process your Personal Data for several critical purposes:

• Recruitment and Selection:To assess your qualifications and match your skills with available opportunities, including scheduling interviews, conducting assessments, and verifying your background.
• Communication:To keep you informed about the status of your application, provide updates on job opportunities, and manage correspondence throughout the recruitment process.
• Operational Management:To administer our recruitment process, maintain records, comply with legal obligations, and support internal audits and process improvements.
• Security and Fraud Prevention: To detect, prevent, and respond to security incidents or fraud related to our recruitment systems.
• Legitimate Business Interests:To support our broader business goals, including improving our recruitment practices and ensuring a qualified workforce aligned with our mission to optimize patient care.

Legal Bases for Processing Your Personal Data

Our processing is conducted on several legal bases, including:

• Consent: When you have explicitly agreed to share your information.
• Contractual Necessity: When processing is required to enter into or fulfill an employment or apprenticeship agreement.
• Legitimate Interests:For our legitimate business interests in recruiting and enhancing our workforce, provided these interests do not override your rights.
• Legal Obligations: To comply with applicable laws and regulatory requirements regarding employment and data protection.

Recipients of Your Personal Data

We may share your Personal Data with:

• Internal Teams:Including our recruitment, HR, and administrative teams responsible for managing the application process and supporting employment decisions.
• Affiliated Entities: Our affiliates, subsidiaries, and related companies, when necessary, to fulfill employment or onboarding purposes.
• Service Providers: Third-party vendors who assist with background checks, IT security, recruitment platforms, and other support services.
• Legal and Compliance Advisors:External legal, auditing, or consulting professionals to ensure compliance with applicable laws and to safeguard our interests.

This section is designed to ensure transparency about how we handle your Personal Data throughout our recruitment and employment processes, consistent with our commitment to privacy and compliance with applicable data protection laws.

Business Partners and Their Representatives

We process personal data of our business partners, including their employees, agents, and contractors. This applies to collaboration partners, key opinion leaders, vendors, and suppliers. The data we collect and process is essential for managing business relationships, ensuring compliance, and improving our services and products.

Types of Personal Data We Process

1. Identity and Contact Information:
   
   
• Full name or unique pseudonym
• Titles, honorifics, and preferred forms of address
• Employer or affiliated company
• Email and postal addresses
• Phone numbers
• Usernames, codes, passwords, security answers, and preferences
• Customer or account numbers
• Company identification numbers
• National Provider Identifier (NPI) numbers
• Signatures
2. Other Personal Information:
   
   
• Age
• Gender
• Marital status
• Preferred language
• Disability status
• Date of birth
3. Technical Information:
   
   
• IP addresses (which may indicate geographic location or company association)
• Browser type and language
• Device type and settings
• Advertising IDs associated with devices (e.g., Apple’s IDFA, Android’s AAID)
• Date and time of interaction with our services
• Website addresses (URLs) visited before and after using our services
• Online activity and behavior, including forms submitted, videos watched, and product interactions
• Data collected from cookies or similar technologies
• Geolocation information
4. Commercial and Financial Information:
   
   
• Products and services purchased, obtained, or considered
• Documentation of requests and transactions
• Customer service interactions
• Financial transaction history
• Financial account and bank details
• Other payment-related information
• Tax identification numbers
5. Professional and Educational Information:
   
   
• Job title or position
• Employer or affiliated company
• Work location
• National Provider Identifier (NPI) number
• State medical license number
• Work skills and employment history
• Educational background, certifications, and specialized training
• Professional memberships
• Responses to surveys and questionnaires
• Attendance and participation in training or educational events
• Records of professional engagements, such as consulting
• References and background checks
6. Anonymized or De-Identified Data:
   
   
• Data stripped of identifiable characteristics, ensuring compliance with data protection laws.

Sources of Personal Data

We collect personal data from various sources, including:

• Directly from you
• Your employer or affiliated company
• References and third parties conducting background checks
• Your devices and interactions with our digital services
• Our security systems, including CCTV monitoring
• Publicly available sources, such as social media platforms
• Market research firms and other non-clinical research companies
• Business partners and third parties assisting with our operations
• Healthcare providers
• Clinical investigators and research teams
• Patients

Purposes for Processing Personal Data

We process personal data for various business and operational needs, including:

• Providing our products and services
• Communicating and maintaining relationships with you and your organization
• Sending updates and relevant business information
• Identifying and authenticating users
• Personalizing and enhancing user experiences
• Detecting security threats and preventing fraudulent or illegal activities
• Ensuring the proper use of our services
• Improving our products and services through research and feedback
• Conducting short-term operational activities
• Managing administrative processes
• Supporting internal research and development efforts
• Conducting quality assurance and staff training
• Tracking and reporting adverse events and complaints
• Marketing, advertising, and product promotion
• Procuring third-party products and services
• Complying with legal and regulatory obligations

Legal Bases for Processing Personal Data

We process personal data under the following legal bases:

• Fulfilling contractual obligations
• Complying with legal and regulatory requirements
• Legitimate business interests, such as fraud prevention and operational efficiency
• Public health reasons, including ensuring high standards of healthcare and medical devices
• Scientific or historical research and statistical analysis
• Medical diagnosis and healthcare provision
• Establishing, exercising, or defending legal claims
• Situations where consent has been provided or where required by law

Sharing of Personal Data

We may share personal data with:

• Our affiliates, subsidiaries, and related companies
• Healthcare providers
• Patients and their authorized representatives
• Your employer or affiliated company
• References and third parties involved in background verification
• Legal representatives and compliance authorities
• Third-party fraud prevention and security service providers
• IT, security, and loss prevention service providers
• Recruitment and background check agencies
• Legal, auditing, and consulting professionals
• Business partners supporting our services, marketing, or administration

This structured approach ensures transparency in how we handle business-related personal data while aligning with legal, operational, and compliance needs.

Event Attendees and Participants

We process personal data when you attend or participate in professional, educational, or industry-related events and conferences organized or sponsored by our company. This includes business meetings, training sessions, and collaborative engagements.

Personal Data We Process

• Identity and Contact Information– Includes your name, titles, company affiliation, email, postal address, phone number, customer number, and National Provider Identifier (NPI) number. Also includes usernames, passwords, and contact details for designated representatives.
• Personal Information – Covers age, gender, marital status, preferred language, disability status, and date of birth.
• Multimedia and Recorded Data – Includes still images, video footage (including CCTV recordings), and other recorded content.
• Technical Data– Involves IP addresses, browser type and language, device type, advertising identifiers, geolocation data, online behavior, and interactions with digital platforms, including cookies and other tracking technologies.
• Financial and Transactional Data– Covers purchases, payment details, tax identification numbers, financial account history, and transaction documentation.
• Professional and Educational Background– Includes job title, employer, work location, certifications, licenses, degrees, professional skills, training records, and history of engagement with our company.
• Anonymized or De-Identified Data – Refers to data stripped of personal identifiers, ensuring compliance with data protection laws.

Sources of Personal Data

We collect data from various sources, including:

• Directly from you
• Your employer or affiliated company
• Authorized representatives providing information on your behalf
• Your devices and interactions with our digital services
• Security systems, including CCTV
• Publicly available sources, such as social media platforms
• Market research firms and third-party research companies
• Business partners and service providers supporting our operations
• Healthcare professionals and institutions

Purpose of Processing Personal Data

We process personal data for several operational and business-related needs, including:

• Registering and managing event participation
• Communicating with attendees before, during, and after events
• Identifying and authenticating participants
• Ensuring security and preventing fraud or unauthorized access
• Conducting research and development for improving future events, services, and training programs
• Managing customer relationships and sending relevant updates
• Enhancing user experience and personalizing event interactions
• Marketing, advertising, and promotional outreach related to products, services, and industry insights
• Ensuring compliance with legal, regulatory, and corporate obligations
• Conducting scientific, historical, or statistical research
• Establishing, exercising, or defending legal claims

Legal Basis for Processing Personal Data

Our processing activities are supported by the following legal bases:

• Execution of a contract, including event participation agreements
• Compliance with legal and regulatory obligations
• Legitimate business interests, such as fraud prevention, operational security, and business development
• Public health and safety measures in industry-related events
• Scientific and statistical research purposes
• Situations where explicit consent has been obtained or required by law

Sharing of Personal Data

We may share personal data with:

• Our affiliates, subsidiaries, and related business entities
• Healthcare providers and institutions
• Your employer or affiliated company
• Other event attendees, speakers, and organizers
• Third-party service providers involved in event management, security, and logistics
• Fraud prevention, cybersecurity, and data protection service providers
• Our legal, compliance, auditing, and consulting teams
• Marketing, advertising, and research partners assisting with event-related communications and promotions

This structured approach ensures transparency regarding the collection, use, and sharing of personal data while maintaining compliance with data protection and business policies. Let me know if any refinements are needed.

Clinical Research Investigators and Study Team Members

Our company processes Personal Data for individuals who are current or prospective clinical research investigators or members of a study team participating in clinical studies sponsored by our company. These studies focus on optimizing nutritional, mental, and functional status for patients undergoing surgery, helping to enhance recovery and minimize complications.

We collect and process a range of Personal Data, including:

• Identity and Contact Information:
  We gather data such as your full name (or a unique pseudonym), honorifics and titles, and your preferred form of address. Additional contact details include your employer or organization, email and postal addresses, phone numbers, as well as secure login credentials (usernames, codes, passwords, and security responses), customer or account numbers, company identification numbers, National Provider Identifier (NPI) numbers, and digital signatures.
  
  
• Other Personal Information:
  This includes demographic details such as your age, gender, marital status, preferred language, disability status, and date of birth.
  
  
• Visual, Audio, and Recorded Information:
  We may process still images, video recordings (including from CCTV systems), voicemails, recordings of your interactions with our online services, and images or videos capturing treatment or study-related activities.
  
  
• Technical Information:
  We collect technical data like IP addresses (which may reveal your general geographic location or company affiliation), browser type and language, device type, and advertising identifiers (for example, Apple’s IDFA or Android’s AAID). We also record the date and time of your interactions with our services, website addresses visited before and after using our platforms, your online behavior (such as submitted forms, watched videos, clicks, and viewed product descriptions), data from cookies or similar technologies, and geolocation data when available.
  
  
• Commercial and Financial Information:
  This category includes details related to financial transactions, such as bank account information, customer service records, financial transaction histories, financial account numbers, other payment data, and tax identification numbers.
  
  
• Professional and Educational Information:
  We process information about your job title or position, your employer or affiliated organization, and your work location. Additionally, we collect data such as your NPI number, state medical license, professional skills, employment history, academic background (including degrees and certifications), specialized training, responses to surveys or questionnaires, attendance at training events, records of collaborations (such as consulting engagements), information from references, and background checks.
  
  
• Product Usage Information:
  We may also process technical and clinical usage data—such as pre-, intra-, and post-operative metrics—derived from your use of our products and services, including timestamps and details of the specific products or services accessed.
  
  
• Anonymized/De‑identified Data:
  In some cases, we remove personal identifiers from data so that individuals cannot be readily identified. This anonymized data is used for internal research, quality assurance, service improvement, and to develop new products and services.
  
  

Sources of Personal Data

We obtain your Personal Data from various sources, including:

• Directly from you during interactions and study participation.
• From your employer or affiliated organization.
• Through authorized representatives and references assisting with background checks.
• Via your devices and interactions with our digital platforms.
• From our security systems, such as CCTV.
• From publicly available sources, including social media.
• From market research firms and third-party research organizations.
• Through business partners and other third parties that support our study operations.
• From healthcare providers, clinical investigators, and other study team members.
• From patients involved in our clinical studies.

Purpose of Processing Personal Data

We process your Personal Data to:

• Determine your suitability for clinical studies.
• Support the operational management and administration of the study.
• Facilitate effective communication and coordination among study team members.
• Authenticate your identity and tailor your experience during study participation.
• Monitor and enhance study security, and prevent fraudulent or unauthorized activities.
• Improve our products and services through internal research, quality assurance, and development initiatives.
• Comply with legal, regulatory, and contractual obligations.
• Conduct scientific, historical, or statistical research to support better patient outcomes in perioperative care.

Legal Basis for Processing Personal Data

Our processing of Personal Data is based on:

• Contractual Necessity: To manage and execute study participation agreements.
• Compliance with Legal Obligations: To meet regulatory and legal requirements.
• Legitimate Interests: Including business interests such as study efficiency, security, and product development.
• Public Health Purposes: Ensuring high standards of care and safety in clinical studies.
• Scientific Research: For historical or statistical analysis supporting research goals.
• Consent: In cases where explicit consent is obtained or required.

Sharing of Personal Data

We may share your Personal Data with:

• Our affiliates, subsidiaries, and related companies.
• Healthcare providers and other clinical study partners.
• Other clinical investigators and study team members.
• Your employer or affiliated organization.
• Authorized representatives, references, and third parties involved in background checks.
• IT, security, and fraud prevention service providers.
• Legal, compliance, auditing, and consulting advisors.
• Partners assisting with the study's administration, marketing, or service improvement.
• Patients and their authorized representatives, if relevant to study operations.

This comprehensive approach ensures that data processing for clinical research is managed transparently and in compliance with applicable data protection laws, while supporting our mission to optimize patient outcomes in perioperative care.

Potential Clinical Study Participants

Our Company may process your Personal Data when we determine whether you qualify for, or are interested in, participating in a clinical study designed to optimize nutritional, mental, and functional status for patients undergoing surgery. Please note that if you are selected and become a participant, a separate privacy notice will govern the processing of your data during the study.

Types of Personal Data Processed
We collect a broad range of personal information, including:

• Identity and Contact Details:Your full name or a unique pseudonym, titles or honorifics, your preferred form of address, employer or company information, email and postal addresses, phone numbers, login credentials (such as usernames, codes, and passwords), security answers, user preferences, customer numbers, company identification numbers, National Provider Identifier (NPI) numbers, and your digital signature.
• Personal Characteristics:Demographic information such as age, gender, marital status, preferred language, disability status, ethnicity, and date of birth.
• Multimedia and Communication Records:Visual or audio data including still images, video recordings (for instance, CCTV footage), voicemails, and recordings of interactions with our online services (via email, SMS, or chat). These may also include pictures or videos related to treatment activities.
• Technical Data:Information generated from your digital interactions, including your IP address, browser type and language, device type, advertising identifiers (e.g., Apple’s IDFA or Android’s AAID), timestamps of your access to our services, the URLs you visit before and after using our platforms, details of your online behavior (such as form submissions, videos watched, clicks, and product information viewed), data from cookies or similar tracking technologies, and geolocation data.
• Health Information:Data regarding your medical profile, such as identified pathologies or diseases, areas of interest in medical research, medical history, treatment information, drug allergy details, vital health measurements (e.g., heart rate and blood pressure), pregnancy status, and location information relevant to healthcare.
• Commercial and Financial Information:Records related to products and services you have purchased, obtained, or considered, along with banking details, financial transaction history, financial account numbers, and other payment-related information.
• Anonymized or De‑identified Data:Information that has been stripped of personal identifiers so that you can no longer be identified. This data is processed for research, quality assurance, and service improvement purposes.

Sources of Personal Data
We obtain your Personal Data from several sources, including:

• Directly from you during interactions, inquiries, and the application process.
• From your employer or an affiliated organization.
• From references and third parties assisting with background or eligibility checks.
• Automatically through your devices and digital interactions with our platforms.
• Through our security systems, including CCTV.
• From publicly available sources, such as social media, and from market research or non-clinical research companies.
• Via our business partners and other third parties who support and enhance our products and services.
• From healthcare providers and clinical investigators involved in related studies.
• From patients participating in our clinical research initiatives.

Purpose of Processing Personal Data
We process your Personal Data to:

• Determine your eligibility for, and interest in, participation in clinical studies.
• Manage the recruitment and selection process for potential study participants.
• Communicate with you regarding study details, updates, and follow-up information.
• Authenticate your identity and personalize your experience during pre-study evaluations.
• Detect and prevent security incidents, as well as protect against fraudulent or unauthorized activity.
• Ensure the appropriate and efficient use of our products and services in support of clinical research.
• Conduct internal research and development, quality assurance, and process improvements to enhance our service offerings.
• Comply with legal, regulatory, and contractual obligations and to defend our legal claims.

Legal Basis for Processing Personal Data
Our processing activities are conducted on the following legal bases:

• The necessity to execute or prepare for a contract with you related to study participation.
• Compliance with legal and regulatory obligations.
• Our legitimate business interests in recruiting qualified candidates, maintaining operational security, and improving our clinical research processes.
• Public health interests, ensuring high standards in healthcare outcomes.
• Scientific and historical research purposes.
• Where applicable, based on your explicit consent.

Sharing of Personal Data
We may share your Personal Data with:

• Our affiliates, subsidiaries, and other related companies.
• Healthcare providers, clinical investigators, and other study team members involved in the research.
• Your employer or affiliated organization if relevant to the study.
• Third-party service providers assisting in study operations, such as IT, security, fraud prevention, and data processing vendors.
• Legal, auditing, and consulting professionals for compliance and risk management.
• Other parties designated by you to receive your information, in accordance with applicable law.

This comprehensive approach ensures that the processing of Personal Data for potential clinical study candidates is handled transparently and in full compliance with data protection laws, while supporting our mission to optimize patient care before, during, and after surgery.

Minors and Parental Consent

Our company does not intentionally collect, maintain, or process Personal Data from individuals under the age of 18. In the rare event that personal data of a minor is received—only in circumstances where a minor uses one of our products with the express consent of their parent or legal guardian—we will process such data solely for the limited purpose of enabling use of our product. In all other instances, our products and services are intended exclusively for adults.

If personal data of a minor is processed with parental or legal guardian consent, the categories of data may include:

• Identity and Contact Details:This covers the minor’s full name (or a unique pseudonym), titles or honorifics, email and postal addresses, phone numbers, usernames, passwords, security responses, and preferences, along with any designated contact information for authorized representatives.
• Other Personal Information: Such as age, gender, preferred language, disability status, ethnicity, and date of birth.
• Visual, Audio, and Recorded Data:This includes still images, videos (including CCTV recordings), voicemails, and recordings of interactions with our online services, as well as images or videos related to any treatment or usage activities.
• Technical Data:For example, IP addresses, browser type and language, device type, advertising identifiers (such as Apple’s IDFA or Android’s AAID), timestamps of usage, website addresses visited before and after engaging with our services, details of online behavior (such as submitted forms, watched videos, and clicked pages), data from cookies or similar technologies, and geolocation information.
• Health Information:Where applicable, this may include data about any medical conditions, treatment history, and other health-related metrics collected in the context of using our product.
• Commercial and Financial Information: Including details of any products or services purchased or considered.
• Anonymized or De‑identified Data: Data from which personal identifiers have been removed so that the individual is no longer identifiable.

We obtain such Personal Data directly from the minor (or their parent/legal guardian) during product registration or interaction. Data may also be obtained from other authorized sources, including through devices, security systems (like CCTV), and publicly available information.

The purposes for processing this data include:

• Enabling the minor’s use of our product in a secure, compliant manner.
• Communicating with the parent or legal guardian regarding product updates, usage, or important notifications.
• Authenticating identity and personalizing the user experience.
• Monitoring security, preventing fraud, and ensuring proper usage of our product.
• Supporting internal research and development, quality assurance, and product improvements.
• Meeting legal, regulatory, or contractual obligations applicable to such processing.

Our processing of minor data is based on legal grounds that include obtaining explicit parental or guardian consent, fulfilling contractual obligations, complying with legal requirements, and our legitimate interests. In such cases, personal data may be shared with our affiliates, healthcare providers, and selected third-party service providers strictly on a need-to-know basis and solely for purposes related to product functionality, security, and compliance.

This approach ensures that any processing of personal data from minors is carried out with the highest respect for privacy and in full accordance with applicable data protection laws.

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1. Sharing and Distributing Your Personal Data

Our company permits select third parties to collect information about users of our Products and Services in order to support valuable functions such as fraud detection, analytics, and advertising—including behavior-based advertising across different contexts. This means that details about your interactions with our app—like the videos you view, or data related to disease, treatment, or your Healthcare Provider—may be shared. Such sharing allows us to provide you with tailored information and advertising based on your searches, queries, and other activities on our platform. These processes might be classified as a “sale” or “sharing” of personal data under certain laws. If you wish to opt out of this data sharing, please refer to the section titled “Your Rights Regarding Your Personal Data.”

2. Promotional Communications, Cookie Use, and Data Analytics

To the extent allowed by law, and where necessary with your consent, our company may use your contact details to reach out to you about initiating or maintaining a business relationship. For example, we may send you marketing emails and promotional messages, which you can unsubscribe from at any time.

We also automatically collect personal data through cookies and similar technologies. This collection supports essential functions of our Products and Services, such as recognizing you across multiple devices, evaluating usage patterns, and identifying trends. The information gathered helps us enhance our platform’s functionality, tailor the user experience, enforce security controls, and serve you relevant advertisements based on your online activities. Additionally, we conduct statistical analyses of how users engage with our Products and Services to continuously improve content, design, and navigation.

3. Public Forums and Interactive Features

When you participate in public or group discussions—such as newsfeeds, blogs, or message boards—on our Products and Services (collectively “Interactive Features”), please be aware that any content you post, including personal data, is publicly accessible and may be viewed by others. Because these postings are public, you should have no expectation of privacy or confidentiality regarding the information you submit. Any personal data you share through these Interactive Features is disclosed at your own risk. We may also process anonymized or de‑identified data derived from your public contributions for purposes such as research, analytics, and service improvement, ensuring that the data no longer identifies you under applicable data protection laws.

Each section is designed to transparently explain how your personal data may be shared, used for marketing and analytics, or made publicly available through interactive features—while aligning with our commitment to comply with data protection regulations and support our business mission. Let me know if you need any further adjustments or additional details.

External Service Providers

Confidential Data Processors

Service providers, vendors, or processors acting on our behalf are required to sign agreements that bind them to strict confidentiality. They must only process Personal Data in order to deliver the contracted services, and in a manner consistent with this Notice, our other privacy policies, and all applicable laws, regulations, and standards.

Data Aggregation from External Sources

Our company may integrate the information we directly collect with additional Personal Data obtained from external sources. This includes data from healthcare providers and third-party data repositories, such as those maintained by data brokers. By combining these datasets, we enhance our analytical capabilities and improve the personalization and overall performance of our perioperative nutritional and physical therapy optimization services.

External Website References

Our Products and Services may feature links or references to external websites, applications, products, or services that are not owned or managed by our company. These references are provided solely for your convenience and do not imply any endorsement of the third party or its offerings. We recommend that you review the privacy policies and practices of these external platforms, as we have no control over how they collect or handle your Personal Data.

Securing Your Information

In line with all applicable laws and industry standards, our company has implemented robust physical, technical, and administrative safeguards to protect Personal Data from loss, misuse, alteration, theft, unauthorized access, and disclosure. Although we employ comprehensive security measures and comply with all legal obligations, no system can guarantee complete protection of data collected through our Products and Services. We also remind you that it is your responsibility to safeguard your own passwords, identification numbers, and any similar personal credentials associated with your use of our Products and Services.

Your Rights Concerning Your Personal Data

Depending on your jurisdiction, you may have several rights regarding your Personal Data. These rights include:

• The right to learn whether and how we process your Personal Data.
• The right to access and receive a copy of your Personal Data, including the ability to transfer it to another organization (data portability).
• The right to request corrections or updates to your Personal Data.
• The right to request deletion of your Personal Data.
• The right to restrict, block, or object to the processing of your Personal Data—including sensitive information—or to revoke any consent previously given.
• The right to appeal any denial of your data requests.
• The right to lodge a complaint with your local data protection authority.

To exercise any of these rights, to appeal a denial, or to report concerns regarding our processing of your Personal Data, please contact us exclusively by emailingsupport@healthsiacare.com.

Our company will not discriminate against you for exercising these rights. However, please note that in some circumstances, we may be legally unable to fulfill your request, such as when required by law or if we are unable to verify your identity.

Promotional Communications and Email Opt-Out

You may unsubscribe from any marketing or promotional emails at any time. To do so, please contact us exclusively by email atsupport@healthsiacare.comor use the unsubscribe option provided within our communications. Please note that if you have already requested our Products or Services, there may be a brief delay before your preferences are updated and your request is fully honored.

Retention Period for Your Personal Data

We retain Personal Data only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Notice. In some instances, legal or regulatory obligations may require us to retain your data for a longer period. Whenever possible, we will de-identify or anonymize your Personal Data or remove information that can directly identify you from records that we need to keep beyond the required retention period. The duration for which we hold your Personal Data depends on factors such as the length of our relationship with you, any legal obligations, and requirements related to litigation or regulatory mandates.

Important Notice for U.S. Patients

If you are a patient enrolled through our platform in the United States, please be aware that this Privacy Notice is separate from your Healthcare Provider’s HIPAA Notice of Privacy Practices. Your Healthcare Provider’s notice governs how they handle individually identifiable health information collected during treatment. Our company processes Personal Data on behalf of your Healthcare Provider solely in accordance with your provider’s HIPAA Notice of Privacy Practices.

Modifications to Our Privacy Notice

This Privacy Notice is effective as of the date last updated below. We reserve the right to update this Notice periodically without prior notice. We encourage you to review this Notice regularly. Your continued use of our Products and Services after any modifications indicates your acceptance of the updated Notice.

Reach Out to Our Privacy Team

If you have any questions regarding this Privacy Notice, including requests for an alternative format or additional details about the security measures described in our "Securing Your Information" section, please contact us exclusively by email atsupport@healthsiacare.com.