Privacy Policy
1. Introduction & About Us
Implansense Inc. (“we”, “us”, or “our”) operates implansense.com and related services (the “Service”). Our principal place of business is located at 1650 Market Street, Suite 3200, Philadelphia, PA 19103.
We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your personal information, with specific disclosures required by the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), effective January 1, 2023.
For privacy inquiries, contact us at:
Email: [email protected]
Phone: +1 (215) 475-5187
Postal: Privacy Team, Implansense Inc., 1650 Market Street, Suite 3200, Philadelphia, PA 19103
2. Categories of Personal Information We Collect
In the past 12 months, we have collected the following categories of personal information as defined by the CCPA:
| CCPA Category | Examples | Collected? | Sources |
|---|---|---|---|
| A. Identifiers | Real name, alias, email address, IP address, account name, unique personal identifiers | Yes | You directly; automatically |
| B. Personal Records | Name, address, telephone number, employer name | Yes | You directly |
| C. Protected Classifications | Age, gender (if voluntarily provided) | Limited / only if voluntarily provided | You directly (optional) |
| D. Commercial Information | Services requested, subscription history, preferences | Yes | You directly; transactions |
| E. Biometric Information | Fingerprints, facial recognition | No | — |
| F. Internet / Electronic Activity | Browsing history on our site, interaction with our content | Yes | Automatically via cookies/analytics |
| G. Geolocation Data | Physical location derived from IP address (city/country level) | Yes (approximate) | Automatically |
| H. Sensory Data | Audio data if you contact us by phone | Only if you contact us by phone | You directly (if applicable) |
| I. Professional / Employment Info | Job title, employer, clinic type, EHR system | Yes (via access request form) | You directly |
| J. Education Information | Education history | No | — |
| K. Inferences | Profile reflecting preferences, characteristics | Yes (for service improvement) | Derived from categories above |
| L. Sensitive Personal Information | Account log-in credentials (security credentials only) | Yes (credentials only) | You directly (account creation) |
2.1 Sources of Personal Information
- Directly from you — access request forms, account registration, contact inquiries, support requests;
- Automatically — cookies, web beacons, server logs when you use our Service;
- Third parties — analytics providers where you choose to interact with us via those platforms.
3. Business & Commercial Purposes for Collection & Use
We collect and use personal information for the following business and commercial purposes:
- Providing, maintaining, and improving our products and services;
- Processing access requests and managing clinic relationships;
- Sending transactional communications (account alerts, service notices);
- Providing customer support and responding to inquiries;
- Conducting analytics to understand how our Service is used;
- Sending marketing communications (where you have opted in or where permitted);
- Fraud prevention, security monitoring, and protecting legal rights;
- Complying with applicable laws, regulations, and legal process.
4. Disclosure, Sale & Sharing of Personal Information
4.1 Categories Disclosed for Business Purposes
In the past 12 months, we have disclosed the following categories of personal information to service providers and contractors for business purposes:
- Identifiers (A) — to cloud hosting providers, email service providers, analytics providers;
- Professional information (I) — to CRM platforms for account management;
- Internet / electronic activity (F) — to analytics platforms.
4.2 Sale & Sharing of Personal Information
Under the CCPA, “sale” includes exchanging personal information for money or other valuable consideration. “Sharing” includes disclosing personal information to third parties for cross-context behavioural advertising, even without monetary exchange.
| PI Category | Sold? | Shared for Cross-Context Advertising? | Third-Party Recipients |
|---|---|---|---|
| Identifiers (A) | No | Limited (cookie IDs, IP for analytics) | Analytics providers |
| Internet / Electronic Activity (F) | No | Limited (browsing behaviour for analytics) | Analytics providers |
| All other categories | No | No | — |
4.3 Do Not Sell or Share — Opt-Out
California residents have the right to opt out of the sale or sharing of their personal information at any time. To exercise this right:
- Email: [email protected] with subject “CCPA Opt-Out Request”;
- Global Privacy Control (GPC): We honour GPC signals in supported browsers;
- Phone: +1 (215) 475-5187.
4.4 Sensitive Personal Information
We collect only account log-in credentials as sensitive personal information, used solely to authenticate your account. We do not use or disclose sensitive personal information beyond what is necessary to provide the Service.
5. Your California Privacy Rights
If you are a California resident, you have the following rights under the CCPA/CPRA:
Right to Know
Request disclosure of the categories and specific pieces of personal information we have collected about you, sources, and purposes. You may request this up to twice per 12-month period.
Right to Delete
Request deletion of personal information we have collected, subject to certain exceptions (completing a transaction, security, legal obligations).
Right to Opt-Out of Sale/Sharing
Direct us not to sell or share your personal information with third parties for cross-context behavioural advertising.
Right to Non-Discrimination
We will not discriminate against you for exercising your CCPA rights — no denial of goods/services, no different prices or quality.
Right to Correct
Request correction of inaccurate personal information we maintain about you, taking into account the nature of the information and our purposes for processing.
Right to Limit SPI Use
Direct us to limit our use and disclosure of sensitive personal information to what is necessary to perform the services you request.
5.1 How to Submit a Consumer Request
California residents may submit requests by:
- Email: [email protected] with subject “CCPA Privacy Request”;
- Phone: +1 (215) 475-5187;
- Postal mail: Implansense Inc., Attn: Privacy Team, 1650 Market Street, Suite 3200, Philadelphia, PA 19103.
5.2 Verification of Requests
To protect your information, we must verify your identity before fulfilling a request. We will ask you to provide information that matches what we have on file. We will not use information provided for verification beyond that purpose.
Authorised agents: You may designate an authorised agent to make a CCPA request on your behalf. We may require written proof of authorisation and may verify your identity directly.
5.3 Response Timeline
We will acknowledge your request within 10 business days and respond within 45 calendar days. If we need more time, we will notify you and may extend the response period by an additional 45 days.
6. Retention of Personal Information
We retain personal information for as long as necessary to fulfil the purposes described in this policy, comply with our legal obligations, resolve disputes, and enforce our agreements.
| Category | Retention Period |
|---|---|
| Account / identity data | Duration of account + 2 years after closure |
| Access request records | 3 years from last interaction |
| Marketing consent / opt-out records | Indefinitely (to honour your preference) |
| Analytics / usage data | 26 months |
| Security / fraud logs | 12 months |
7. Security of Personal Information
We implement technical, administrative, and physical security measures designed to support protection of your personal information from unauthorized access, disclosure, alteration, or destruction, including encryption in transit (TLS) and at rest, access controls, and regular security assessments. No system is 100% secure; please contact us promptly if you suspect unauthorized access to your account.
8. Children’s Privacy
We do not knowingly collect personal information from consumers under 16 years of age. If you believe we have collected personal information from a minor under 16, please contact us at [email protected] and we will delete it promptly.
9. Privacy Rights for Other Jurisdictions
Residents of other U.S. states with comprehensive privacy laws (including Virginia — VCDPA, Colorado — CPA, Connecticut — CTDPA, Utah — UCPA, Texas — TDPSA, and others) may have similar rights. For more information about your state-specific rights, please contact us at [email protected].
10. Cookies & Online Tracking
We and our partners use cookies and similar tracking technologies to collect internet and electronic activity data. Some of this data may be used for analytics. You may opt out by:
- Clicking “Essential Only” on our cookie consent banner;
- Emailing [email protected] with subject “CCPA Opt-Out Request”;
- Enabling the Global Privacy Control (GPC) in your browser.
See our Cookie Policy for full details.
11. Changes to This Privacy Policy
We may update this Privacy Policy as required by changes in law or our practices. When we make material changes, we will update the “Last updated” date and provide appropriate notice. We encourage you to review this policy periodically.
12. Contact Us
For questions, concerns, or to exercise your privacy rights:
- Company: Implansense Inc.
- Email: [email protected]
- Phone: +1 (215) 475-5187
- Address: 1650 Market Street, Suite 3200, Philadelphia, PA 19103