Last Updated: April 20, 2023

SAI MedPartners, LLC, including its affiliates and its and their business divisions (“sai group”, “we, “us” or “our”), acknowledge the importance of data privacy. This privacy policy (“privacy policy”) sets forth the terms and conditions with respect to how we process personal information about you and other third parties. This privacy policy describes, among other issues, the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information. This privacy policy applies to the personal information we collect when you visit any website that we own, license, or otherwise operate and that links to this privacy policy (each a site, collectively, the “Sites”), enroll in, purchase or receive products, goods, or services provided by or through sai group via a site, apply for a job with us, or otherwise contact or engage with us. For purposes of this privacy policy, the site and all products, goods and services furnished by us shall be referred to collectively as the “Services.”.

For the avoidance of doubt, this privacy policy applies to the following sites, brands, and SAI group operating entities and divisions thereof: sai Medpartners LLC; Thratraq; www.sai-med.com; and www.theratraq.com.

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING OUR SITES AND RELATED SERVICES, OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY, OUR TERMS OF USE AND OUR COOKIE POLICY, EACH BEING INCORPORATED INTO, AND FORMING AN INTEGRAL PART OF, THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AND OUR TERMS OF USE AND COOKIE POLICY, YOU SHOULD NOT USE SITES OR SERVICES, OR PROVIDE US WITH ANY PERSONAL INFORMATION, AND SHOULD LEAVE THE SITE IMMEDIATELY.

Scope

This Privacy Policy applies to personal information where we act as a “data controller” – which means we determine the purpose and means of processing such personal information. For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual, household, or device and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual, household, or device and that is not otherwise subject to a data protection law, statute, or regulation. To the extent excluded pursuant to applicable law, personal information does not include publicly available information . We may anonymize or de-identify personal information, and such data is not subject to this Privacy Policy, and we may use such data for any purpose.

The Types and Categories of Personal Information We Collect

We collect personal information in order to provide our Services, comply with our legal obligations, promote our legitimate business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal information to us, or opt-out or refuse consent to our use of such personal information, we may not be able to provide you the Services or complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations. For your information, we have also listed other categories of personal information that we do not collect (such list is illustrative and not exhaustive):

Personal Information Category	Example
Personal identifiers	Name, alias, signature, postal or shipping address, phone number, date of birth, unique personal identifier, online identifier, email address, internet protocol (IP) address, state identification card number, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Registration Data	Information provided when you register for an account to use our Services or features on our Site, including usernames and passwords.
Business Contact Data	Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.G., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities (e.G., visitor logs or registries).
Marketing and Communications Data	Information with respect to your marketing preferences and your subscriptions to our publications or other offerings, including feedback and survey responses.
Service or Product Related Information	Information provided when you use or participate in any of our Services or offerings other than Registration Data. Information an individual provides when visiting a physical location or premise, or interacting with a representative, of SAI Group (e.g. workshops, conferences, trade show booths or similar interactions).
Professional or Employment Data	If you apply for a job with us, we collect information set forth in a resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education-level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references. (For more information, see “Employment Applications and Workforce Management” below).
Biometric information	WE DO NOT COLLECT – Fingerprint, voice print, retinal print, scan of hand or facial geometry.
Information from multimedia	Audio, electronic, visual or similar information.
Internet or other electronic network activity information	Browsing history, search history, information regarding your interaction with our site, applications or advertisements, linking behavior, web pages you visit while visiting our site or applications, browser type, internet service provider (isp), cookies, and mobile device information including device identifier or other information. (for more information, see “technical data and cookies” below).
Geolocation data	WE DO NOT COLLECT – Physical location, movements, or trip tracking information.
Inferences	Profile data reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

We do not collect or process sensitive personal information (for example, your social security number, financial account information, your precise geolocation data, or your genetic data), and you agree not to provide us with sensitive personal information.

Technical Data and Cookies

When you access the Site, we collect certain data automatically using technical means and tools. This data relates to your device, and your experience on the Site and other websites, including the following:

Usage and Device Data. When you access and use the Site, we automatically collect details of your access to and use of the Site, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Site (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Site may collect “diagnostic” data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.

Cookies and Tracking Data. We use “cookies” and other tracking technologies within the Site. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of the Site may become inaccessible or not function properly. In addition, the Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of the Site (e.g., recording the popularity of certain content and verifying system and server integrity). The Site may collect data about the advertisements you have seen or engaged. For more information, see our Cookie Policy, the terms of which are incorporated herein by reference.

Sources of Information

We collect the personal information identified herein directly from you when you use our Services, through automated means when you are using the Site, and from third parties including publicly available sources. More specifically, we collect personal information from the following sources:

First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., account registration, completing purchases, signing-up for subscriptions) or whenever you directly engage with us, such as when you interact with us, such as through conferences, workshops, trade shows or other events or contacts, when you visit our offices or premises or otherwise contact us.

Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Site (see “Technical Data and Cookies” above).

Third-Party Sources. We collect personal information from third parties, such as publicly available databases, directories, social networking providers, advertising companies, our service providers, and third-party references.

How We Use your Personal Information / Purpose of Collection

We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our legitimate business interests, including to (i) provide, operate, maintain, improve, and promote our Services, (ii) enable you to access and use our Services, (iii) process and complete transactions, and send you related information, including purchase confirmations and invoices, (iv) send transactional messages (e.g., responses to your comments, questions, and requests) and provide customer service and support for our Services, (v) furnish technical notices, updates, alerts, and support and administrative messages to you, (vi) provide you promotional and marketing communications (e.g., information about our Services, features, surveys, newsletters, offers, promotions, and events), (vii) monitor and analyze trends, usage, and activities in connection with our Services to promote our business interests (e.g., marketing), (viii) investigate and prevent fraudulent transactions, unauthorized access to or use of our Services, and other illegal activities, and (ix) personalize our Services, including providing features or advertisements that match your interests and preferences. Notwithstanding the foregoing, we may collect and use your personal information for any other purpose for which we obtain your consent. For the avoidance of doubt, you hereby agree that we may contact you via any means, including SMS/text message and email, to furnish you information regarding a contract or agreement with us or similar data and information pertaining to a commercial transaction.

Sharing Information / Third-Party Disclosures

We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below. However, we do not share personal information with third parties that we have reason to believe use such information for purposes unrelated to our Services.

• Intra-Group. We may share your personal information within the affiliates and business divisions of SAI Group to support our business practices and in the event SAI Group entities act as “service providers” to other SAI Group affiliates or subsidiaries.
• Service Providers. We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing the Site, conducting surveys and marketing on our behalf, processing transactions, tracking and responding to customer questions or complaints, and performing analyses to improve the quality of our Services.
• Business Partners. We may share your personal information with third parties that help promote or provide our Services and marketing materials.
• Customers and Prospects in Connection with our Services. We may share your personal information with other of our customers and prospects in connection with our Services. For example if we have lawfully included your personal information in a database of subject matter experts, we may provide appropriate information to a customer who has engaged us to identify referrals having your subject matter expertise for their legitimate business interests in connection with their use of our Services.
• Business Sales or Restructurings. Circumstances may arise where for strategic or other business reasons we decide to sell, buy, divest, merge or otherwise reorganize our business in whole or in part. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of such business.
• Security; Business Interests; Legal. We may disclose personal information (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, we may disclose your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests.
• Consent. We may also disclose your information upon your express consent for the purpose such consent was provided. In the event that you facilitate a transaction with us, or request information from or otherwise engage with us, and such activities require us to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct us to intentionally disclose your personal information to the service provider or third party.

Opt-Out Rights / Do Not Sell My Personal Information

You have the right to opt-out of the sale of your personal information. The terms “Sale” “Sell” or “Selling” with respect to your personal information means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your personal information by us to another business or a third party for monetary or other valuable consideration. If you opt out of permitting us to sell your personal information some Services or features of the Services may not be available to you, or may not function as designed, and will not affect other uses of personal information that may be undertaken pursuant to this Privacy Policy. For example, if you opt-out of sales of your information, you may be excluded from databases made available to customers who may seek to engage you as a subject matter expert, and such opt out will not affect your receipt of email marketing communications (See, Email Marketing and Your Rights (below)). You may exercise your right to opt-out of such sales even if you have previously provided your express consent to such sales. To exercise your opt-out rights, please click on the link and complete the information at Do Not Sell My Information.

Links to Other Websites; Your Direct Third-Party Disclosures

As a resource to you, the Site and certain online Services may include links to third-party websites or provide you the opportunity to disclose information directly to third parties. Our Privacy Policy does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Services. For
a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.

Data Retention, Localization and Transfer

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information needed to provide you with our Services, to facilitate transactions you have requested, or to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy and in accordance with our data retention processes.

SAI Group is based in the United States and maintains business locations in other countries as set forth on our Site (See “Locations”). The personal information that we collect and process is retained and stored in the United States and in such other countries. SAI Group also uses service providers that store personal information on our behalf in the United States and in such other countries. Please be aware that the United States, and these other countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us, or permit our use in accordance with the terms of this Privacy Policy, of such information, you hereby consent to your personal information being transferred to, and stored in, the United States and in such other countries in compliance with applicable laws. We transfer personal information to countries using mechanisms to ensure that we can fulfil our obligations under applicable laws and this Privacy Policy.

Where required by applicable law, international transfers take place only when there is an adequate level of protection to the fundamental data protection rights of individuals. In some circumstances, we may choose to rely upon an adequacy decision to lawfully transfer personal information. Standard contractual clauses (“SCCs”) are one of several mechanisms that allow for personal information to be transferred across jurisdictional borders and we may rely on these for transfers to and from our affiliates, vendors and business partners where applicable. In general, we have no reason to believe that the laws and practices in the country of destination applicable to the processing of the personal information by the data importer, including any requirements to disclose personal data or measures authorizing access by public authorities, prevent the data importer from fulfilling its obligations under the SCC or other applicable mechanisms. Where required by applicable law, an assessment of that belief is made on a case-by-case basis. Please contact us to request a copy of our appropriate safeguards.

Security

We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. No information system can be fully secure and we cannot guarantee the absolute Security of your personal information. Moreover, we are not responsible for the security of personal information you transmit to the site and/or the services over networks that we do not control, including the internet and wireless networks, and you provide us with any personal information and data at your own risk. To the extent permitted by law, we shall not be liable or otherwise responsible for any data incident or event that may compromise the confidentiality, integrity, or security of your personal information. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately if you have reason to believe that your username or password to our services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.

No Data Collected from Children

The Site is not directed at, nor intended for use by, children. As a result, if you are under the age of eighteen (18), you are prohibited from accessing or using the Services (including the Site) or with providing us with your personal information, unless you provide us written and verifiable authorization from your parent or legal guardian permitting you to do so and consenting to this Privacy Policy and our Terms of Service.

Your Responsibilities

You are permitted, and hereby agree, to only provide personal information to us if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO US, YOU EXPRESSLY REPRESENT AND WARRANT TO US THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE US WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT THE USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY US FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO US.

Updating Your Information

It is important that your personal information is accurate and reliable. In certain circumstances, the Site or our Services may provide you the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email). Please update such information when such changes are warranted. If the Site or Service does not contain such features, please directly notify us of any changes or updates to your personal information in accordance with the “Contact Us” section listed below.

Email Marketing and Your Rights

You have the right to opt-out of receiving email marketing communications from us. Generally, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email marketing communications from us. You may also unsubscribe from such email marketing via our interactive webform or by contacting us in accordance with the “Contact Us” section listed below. You hereby agree to immediately notify us, in writing, of any change to the email address to which you subscribed or consented to receive email marketing from us. Note that exercising your right to unsubscribe or opt-out of receiving email marketing communications will not affect other processing activities that may be lawfully undertaken with respect to your personal information.

California Privacy Rights

Data Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), California residents have additional data privacy rights, including the following:

• Right to Know: The right to know about what personal information SAI Group collects about you, and our intended use of, and purposes for collecting, your personal information. The personal information that we collect from you, the purposes for which it is used, the source of such personal information, and the parties to whom we share your personal information, among other issues, are set forth in this Privacy Policy (see above).
• Access: The right to access general categories and/or the specific pieces of personal information we have collected, used, disclosed, or sold about you over the past twelve (12) months, including the sources from which the personal information was collected; the business or commercial purpose for which your personal information was collected, used, disclosed, or sold; and the third parties with whom we have shared your personal information.
• Deletion/Correction/Erasure: The right to request that we delete/erase your personal information under certain circumstances, and/or correct personal information that is inaccurate.
• Data Portability: The right to request that we transfer, to the extent technically feasible, personal information in certain forms and formats.
• Nondiscrimination: The right not to be subject to discrimination for asserting your rights under the CCPA.

To exercise any of the CCPA’s data privacy rights set forth herein, please contact us in accordance with the “Contact Us” section listed below. If you would prefer, you may designate an authorized agent to submit a CCPA privacy request on your behalf. An authorized agent must be registered with the California Secretary of State to conduct business in California.

Privacy Request Verification Process. If you (or your authorized agent) make any request related to your personal information under the CCPA, we will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. we will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email or other means and match at least two pieces of personal information we have previously collected from you before granting you access to, or erasing, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights are absolute and are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA, please see: https://oag.ca.gov/privacy/ccpa.

Third-Party Marketing. We do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes unrelated to our Services. If you have any questions or concerns about our marketing, please contact us in accordance with the “Contact Us” section listed below.

Do-Not-Track Signals

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.

Persons with Disabilities

SAI Group strives to ensure that every person has access to information related to our Services, including this Privacy Policy. Please contact us if you would like this Privacy Policy provided in an alternate format, and we will take reasonable measures to meet your needs.

Employment Applications and Workforce Management

As part of our recruitment and workforce management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as the following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email address); information in a curriculum vitae, resumé, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and, information related to previous applications to us or previous employment history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our diversity and inclusion programs. We use this information for the following purposes: to identify and evaluate job applicants; to verify your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required, or permitted, by law. We share this personal information with third parties (see “Sharing Information / Third-Party Disclosures”), and we may also use this employment and application data for any other purpose set forth in this Privacy Policy.

Events; Video Teleconferencing; Support Services; Recordings

SAI Group hosts and uses video teleconferencing platforms, text messaging, and telephone capabilities to facilitate conferences, workshops, meetings, training events, customer support, and other programs. We often use online platforms and solutions that are owned and administered by a third-party service provider (e.g., MS Teams, Google, Zoom, WebEx, Skype for Business). Please be aware that our Site, Services, and video teleconferencing and telephone customer support capabilities may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By using our Site, or participating in our video teleconferencing or telephone customer support capabilities, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.

Changes to the Policy

We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto. Your use of the Site and Services including continued use after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto.

Contact Us

If you have questions regarding this Agreement or your access or use of the Sites governed by this Agreement, would like to make a data subject request or exercise any of your rights described above, or request more information from us, please contact us by: (email) [privacy@sai-med.com]; (telephone) [+1 (610) 685-4200]; or (mail) Privacy Officer at 4970 DeMoss Road, Suite 300, Reading, PA 19606, USA. EU data subject may also submit a data subject request by: (email) [privacy@sai-med.com]; (telephone) at [List local Data Protection Officer Contact]; or (akshayk@sai-med.com) Data Protection Officer at [List local Data Protection Officer Contact].