Privacy Policy

This Privacy Notice for Primary ENT, LLC (doing business as Primary ENT) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

Visit our website at primaryent.com, or any website of ours that links to this Privacy Notice
Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@primaryent.com.

Summary of Key Points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using the table of contents to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.

Do we collect any information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. It may include:

Names
Phone numbers
Email addresses
Contact preferences
Debit/credit card numbers
Billing addresses

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

Financial data

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the associated security code. All payment data is handled and stored by ModMed. You may find their privacy notice here.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. This includes:

Log and Usage Data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, recorded in log files — IP address, device information, browser type and settings, activity in the Services (date/time stamps, pages and files viewed, searches, and other actions), and device event information (system activity, error reports, hardware settings).
Device Data. Information about the computer, phone, tablet, or other device you use to access the Services — IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data. Information about your device's location, precise or imprecise. We may use GPS and other technologies to estimate your current location based on your IP address. You can opt out by refusing access to the information or disabling your device's Location setting — though some features may not work without it.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and other third parties. This includes mailing addresses, job titles, email addresses, phone numbers, intent/user behavior data, IP addresses, social media profiles and URLs, and custom profiles, for purposes of targeted advertising and event promotion.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts, so you can create and log in to your account and keep it in working order.
To request feedback and contact you about your use of our Services.

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, designed to help safeguard your personal information — they cannot do anything with it beyond our instructions, won't share it with anyone outside us, and commit to protect and retain it only for the period we instruct.

The categories of third parties we may share personal information with are:

Ad networks
Data analytics services
Payment processors
User account registration & authentication services

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g. Google Maps API, Places API). Google Maps uses GPS, Wi-Fi, and cell towers to estimate your location — GPS is accurate to about 20 meters, while Wi-Fi and cell towers help improve accuracy when GPS signals are weak, like indoors. This data helps Google Maps provide directions, but it is not always perfectly precise.

4. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, tailor advertisements to your interests, or send abandoned shopping cart reminders (depending on your communication preferences). These third parties use their technology to provide advertising about products and services tailored to your interests, which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (including targeted advertising, as defined under applicable laws) under applicable US state laws, you can opt out by submitting a request as described in "Do United States Residents Have Specific Privacy Rights?" below.

Google Analytics. We may share your information with Google Analytics to track and analyze use of the Services, including Remarketing and Demographics and Interests Reporting features. To opt out of being tracked by Google Analytics across the Services, visit tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings, and other opt-out means include networkadvertising.org/optout and the NAI's mobile choices page. For more on Google's privacy practices, see the Google Privacy & Terms page.

5. How Long Do We Keep Your Information?

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

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice requires us to keep your personal information for longer than the period of time in which you have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if that isn't possible (for example, because it's stored in backup archives), we will securely store it and isolate it from further processing until deletion is possible.

6. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Transmission of personal information to and from our Services is at your own risk — please only access the Services within a secure environment.

7. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18, or that you are the parent or guardian of such a minor and consent to that minor dependent's use of the Services. If we learn that personal information from users under 18 has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under 18, please contact us at info@primaryent.com.

8. What Are Your Privacy Rights?

In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

Withdrawing your consent. If we are relying on your consent to process your personal information, you have the right to withdraw it at any time by contacting us using the details in "How Can You Contact Us About This Notice?" below. This won't affect the lawfulness of processing before withdrawal, nor, where applicable law allows, processing conducted in reliance on lawful grounds other than consent.

Account Information. If you would like to review or change the information in your account, or terminate it, you can log in to your account settings and update it directly. Upon a request to terminate your account, we will deactivate or delete your account and information from our active databases — though we may retain some information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and similar technologies. Most web browsers accept cookies by default. You can usually set your browser to remove or reject cookies, though this could affect certain features or services.

If you have questions or comments about your privacy rights, you may email us at info@primaryent.com.

9. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized, so we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard is adopted that we must follow, we will inform you in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there is not currently an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

10. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months, with illustrative examples of each. For a full inventory, see "What Information Do We Collect?" above.

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, IP address, email address, and account name	YES
B. Personal information as defined in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	NO
C. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	NO
D. Commercial information	Transaction information, purchase history, financial details, and payment information	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	YES
G. Geolocation data	Device location	YES
H. Audio, electronic, sensory, or similar information	Images and audio, video, or call recordings created in connection with our business activities	YES
I. Professional or employment-related information	Business contact details to provide Services at a business level, or job title, work history, and professional qualifications if you apply for a job with us	YES
J. Education Information	Student records and directory information	NO
K. Inferences drawn from collected personal information	Inferences drawn from any collected personal information to create a profile or summary about an individual's preferences and characteristics	NO
L. Sensitive personal information	Debit or credit card numbers	YES

We only collect sensitive personal information as defined by applicable privacy laws or for purposes allowed by law or with your consent. It may be used or disclosed to a service provider or contractor for additional, specified purposes, and you may have the right to limit its use or disclosure. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories when you interact with us in person, online, or by phone or mail in the context of: receiving help through our customer support channels; participation in customer surveys or contests; and facilitation in the delivery of our Services and to respond to your inquiries.

We use and retain collected personal information as needed to provide the Services, generally for as long as you have an account with us (Categories A, F, G, H, I, and L).

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider — see "When and With Whom Do We Share Your Personal Information?" above. We may also use your personal information for our own business purposes, such as undertaking internal research for technological development and demonstration — this is not considered "selling" your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in that period: Category A (Identifiers), Category F (Internet or other electronic network activity information), and Category G (Geolocation data).

Your Rights

You have rights under certain US state data protection laws, though these are not absolute and in certain cases we may decline your request as permitted by law. These rights include the right to:

Know whether or not we are processing your personal data
Access your personal data
Correct inaccuracies in your personal data
Request the deletion of your personal data
Obtain a copy of the personal data you previously shared with us
Non-discrimination for exercising your rights
Opt out of the processing of your personal data if used for targeted advertising (or "sharing" as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects

Depending on your state, you may also have the right to access categories of personal data being processed (MN and others), obtain a list of categories of third parties your data has been disclosed to (CA, DE, MD), obtain a list of specific third parties (MN, OR), obtain a list of third parties your data has been sold to (CT), review and correct how your personal data has been profiled (CT, MN), limit use and disclosure of sensitive personal data (CA), and opt out of collection of sensitive data and data collected through voice or facial recognition features (FL).

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing info@primaryent.com, or by referring to the contact details at the bottom of this page.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof they have been validly authorized to act on your behalf.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. If we cannot verify your identity from information already maintained by us, we may request additional information for identity verification and security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity, and the agent will need to provide written and signed permission from you to submit the request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing info@primaryent.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, the "Shine The Light" law, permits California resident users to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of those third parties in the preceding calendar year. To make such a request, please submit it in writing using the contact details in "How Can You Contact Us About This Notice?" below.

11. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to stay informed of how we are protecting your information.

12. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at info@primaryent.com or contact us by post at:

Primary ENT, LLC
14020 State Highway 13 #350
Savage, MN 55378
United States

13. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please submit a data subject access request.