Privacy Policy

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

• providing the information, products and services you request;
• security, credit or fraud prevention purposes;
• providing you with effective customer service;
• providing you with a personalized experience when you use this Website;
• contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
• contacting you with information and notices related to your use of this Website;
• inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
• better understanding your needs and interests;
• improving the content, functionality and usability of this Website;
• improving our products and services;
• improving our marketing and promotional efforts; and

• any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.

How We Share Your Information

We do not sell or lease your Personal Information to any third party.  We may share your Personal Information by disclosing it to a third party for a business purpose. When we disclose your Personal Information, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract. In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:

• Identifiers; and
• Internet or other network activity information.

We disclose your Personal Information for a business purpose to the following categories of third parties:

• Our affiliates; and
• Third party vendors who provide services that enhance our Website, products and services to you (such as vendors for advertising, marketing and customer support).

Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:

• Legal Reasons.

• We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;
• To respond to duly authorized information requests from law enforcement or other governmental authorities;
• To enforce our agreements, policies, or the Terms of Use;
• To investigate and prevent security threats, fraud, or other malicious activity; or
• To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.”

• Sale of Business or Merger. There are circumstances where the Company may decide to buy, sell, or reorganize its business in selected countries. Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, the Company will ensure your information is used in accordance with this Policy.

Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information. If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed.  Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing. You may opt out of email newsletters at any time by selecting the “unsubscribe” link at the bottom of each email.  Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.

We strive to maintain and process your information accurately.  We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements.  We employ technologies designed to help us maintain information accuracy on input and processing. To view and change the Personal Information that you have provided to us, you can contact us directly for assistance.

Information of Minors

We do not intentionally seek to gather information from individuals under the age of eighteen (18).  We do not target the Website to minors, and would not expect them to be engaging with our Website or services.  We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet.  If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

Submissions

We welcome inquiries or feedback on the services or products you might use or like to use. Any inquiries, feedback, suggestions, ideas, materials, comments or other information you provide to us (collectively, “Submissions”) will be treated as non-proprietary and non-confidential. Your Submissions on or through this Website are available to others who visit this Website. In addition, we may use your Submissions in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the Submissions for such purposes. Therefore, you should have no expectation of privacy with respect to your Submissions on or through this Website. You should not submit any content you do not wish to make available to the general public, and you must take special care to make sure your Submissions comply with our Terms of Use or other applicable agreements. All terms and conditions of our Terms of Use apply to Submissions on or through this Website. In particular, your Submissions must not violate the privacy or other rights of others. You may not use false identifying information or contact information, impersonate any person or entity, or otherwise mislead us as to the origin of any Submission.

Third-party Websites

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates.  Our Website may link to third-party websites and services. For example, if you click on an advertisement on this Website, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them.  Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.

Your California Rights

Do Not Track Signals.  Other than as disclosed in this Policy, the Website does not track users over time and across third-party websites to provide targeted advertising.  Therefore, the Website does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser. WE DO NOT SELL YOUR PERSONAL INFORMATION. If we ever decide to sell Personal Information, we will update you via this Policy and include a link entitled “Do Not Sell My Personal Information,” to provide you with an opportunity to opt out of sales of your Personal Information. California Consumer Rights.  If you are a California consumer, as defined by the California Consumer Privacy Act of 2018 (“Act”), please be advised that Surgical Theater, Inc. does not currently meet the regulatory thresholds of a “business” as that term is defined under the Act and therefore is not required to comply with the Act.  Regardless, all Personal Information will be processed in accordance with this Policy.

For Website Users or Visitors Outside of the United States

Our Website is designed for use by individuals in the United States only.  We do not warrant or represent this Policy or the Website’s use of your Personal Information complies with the laws of any other jurisdiction.  Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours.  Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

For Website Users or Visitors in the European Union (“EU”)

Under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), individuals in the EU are afforded specific rights with respect to their Personal Information, or “personal data” as defined under the GDPR.  For the purposes of this Policy, the Company operates as a data controller.  Any personal data we collect from you is processed in the United States and under the terms of this Policy. Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing.  You may always withdraw your consent to our use of your personal data as described below.  We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below. The Data Controllers are: NAME: Surgical Theater, Inc. ADDRESS: 11500 W. Olympic Blvd Suite 545, Los Angeles CA 90064 EMAIL ADDRESS: [email protected] You can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:

• Access. You may email us at [email protected] to request a copy of the personal data our Website databases currently contain.

• Automated Processing and Decision-Making. You may email us at [email protected] to request that we stop using your personal data for automated processing, such as profiling.  In your email, please explain how you wish us to restrict automated processing of your personal data.  When such restrictions are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.
• Correction or Rectification. You can correct what personal data our Website database currently contains by accessing your account directly, or by emailing us at [email protected] to request that we correct or rectify any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.
• Restrict Processing. When applicable, you may restrict the processing of your personal data by submitting a request via email to [email protected]. In your email, please explain how you wish us to restrict processing of your personal data.  When such restrictions are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
• Object to Processing. When applicable, you have the right to object to the processing of your personal data by submitting a request via email to [email protected]. When such objections are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
• Portability. Upon request and when possible, we can provide you with copies of your personal data. You may submit a request via email to [email protected].  When such a request cannot be honored, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent.  Where applicable, we will ensure such changes are shared with any trusted third parties.
• Withdraw Consent. At any time, you may withdraw your consent to our processing of your personal data through this Website by notifying us via email at [email protected]. Using the same email address associated with your Website account, simply type the words “WITHDRAW CONSENT” in the subject line of your email.  Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data.  Where applicable, we will ensure such changes are shared with trusted third parties.
• Erasure. If you should wish to cease use of our Website and have your personal data deleted from our Website, then you may submit a request by emailing us at [email protected]. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted.  Where applicable, we will ensure such changes are shared with trusted third parties.
• Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below.  If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.

Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure.  However, we can never promise 100% security.  Please notify us of any actual or suspected unauthorized use.

Changes to this Policy

This Policy describes our current policies and practices with regard to the information we collect through this Website. We are continually improving and adding to the features and functionality of this Website along with the products and services we offer through this Website. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

How to Contact Us

We value your opinions and welcome your feedback.  To contact us about this Policy or your Personal Information, please contact us by email at: [email protected]