Privacy Policy

Date of Last Modification: February 2, 2022

This Privacy Policy (“Policy”) addresses HealthTrust, LLC’s (“HealthTrust,” “we,” “our,” or “us”) information collection, use, and disclosure practices when you visit https://www.healthtrust.com (the “Website”). References in this Policy to “you” or “your” means you, the individual user or visitor to our Website. If you have any questions or concerns regarding any information contained in this Policy, you are encouraged to contact us by email or telephone using the details listed at the bottom of this Policy under the heading “Contact Us.”

HealthTrust is geographically located within the United States. We provide services to businesses located exclusively within the United States and do not target or otherwise have a physical presence in foreign jurisdictions. Your use of our Website from outside of the United States is entirely at your own risk.

What Information Does HealthTrust Collect on the Website?

The information that HealthTrust collects on and through our Website depends upon your interactions with us as follows:

• In connection with the use of our Comps feature on our Website, we will collect the applicable zip code (“Zip Code Information”) for the location where you want to check comparable data for purposes of displaying the data for the zip code that you provided. We do not store this zip code information.

• If you choose to contact us through our general contact form, we will collect your first name, last name, company name, email address, a contact phone number, and the content of any message that you choose to provide us (collectively, “General Contact Information”). Please do not include any sensitive personal information in your message to us, including without limitation any social security or financial account numbers.

• Our Website includes the capability for you to request a demonstration of our asset management services and on this web form, we will collect your first name, last name, company name, email address, contact telephone number, number of properties currently under management, and information about how you heard about us (collectively, “Asset Contact Information”).

• The Website enables you to contact us to order an assignment. In conjunction with your choice to order an assignment, we will collect your first name, last name, company name, email address, contact telephone number, the assignment type, and a description of the engagement (collectively, “Assignment Contact Information”).

• Our Website utilizes internet cookies, which are described in more detail in the section titled “Internet Cookies.”

• If you choose to retain us to perform services for you, we will collect your billing address and information about a billing contact person on your account (collectively, “Account Information”)

How Does HealthTrust use the Information that it Collects on the Website?

HealthTrust uses the information that we collect on or through our Website for the following purposes:

• We use Zip Code Information solely to provide you with comparable financial data for the zip code that you have provided us on the Website. We do not store or use Zip Code Information for any other purpose.

• General Contact Information is used by us for purposes of responding to your particular inquiry or comment to us.

• Asset Contact Information is used by us for purposes of responding to you based on the information that you have provided to us in our web form, which will be used, to the extent that you choose to engage HealthTrust, in connection with our performance of any services.

• Assignment Contact Information is also used by HealthTrust for purposes of responding to you regarding the specific type of assignment that you are interested in.

• We use Account Information for purposes of rendering services to your business and in connection with administering any customer support services.

Internet Cookies

The HealthTrust Website utilizes internet cookies, which are small files that are transmitted to your computing device when you visit our Website. Internet cookies are used to collect certain information about you and your computing device. Specifically, our Website uses Google Analytics, which collects statistical information about the use of our Website, including the number of unique web visitors, the geographic regions where our web visitors originate, the date and time of the visit, duration of the visit browsing our Website, computing device type, the name and version of the user’s web browser, and other related statistical information (collectively, “Usage Information”). We are unable to link any of this Usage Information back to a person or household.

We use Usage Information for the following purposes:

• to identify, troubleshoot and resolve issues with our Website;
• to combat against fraudulent, malicious, and criminal activities that may be perpetrated by third parties on our Website; and
• to understand, in an aggregated and de-identified manner, where visitors to our Website originate, and the most commonly utilized internet browsers and computing devices, which is ultimately used by us to improve and optimize the visitor’s experience on our Website by helping to inform future updates to our Website.

Your Options For Internet Cookies

Depending upon your internet browser type, you may have the option to reject or block internet cookies from being deployed to your computing device. To learn more about the options that your internet browser may include, please consult the program or application’s help file. Please note that if you choose to block or reject internet cookies, the Website and some of the functions of the Website, such as your ability to submit web forms with information, will not properly function.

Does HealthTrust Disclose the Information it Collects on the Website to Third Parties?

HealthTrust utilizes multiple third party service providers in connection with making its Website available to you. These third party service providers render an array of services to us, including data and website hosting, website development, design, and software services. To the extent that one of our third party service providers needs access to or must handle the information that you provide to us, we prohibit those third party service providers from using your information except as strictly necessary for such service provider to render its services to HealthTrust.

There are other instances in which we will disclose the information that we have collected from or about you, subject to applicable law, including as follows:

Legal Requirements

On rare occasions, HealthTrust may be required by applicable law to disclose information that we have collected about you, including in response to a court order, subpoena, or other lawful request from an administrative, judicial, or governmental authority. We reserve the right, in our sole discretion, to lawfully challenge any legal requirement to prevent against such disclosure. We will also disclose the information that we have collected about you, if we determine that such disclosure is required in order for HealthTrust to protect or defend its rights, property, or the safety of HealthTrust, its customers, or a third party.

Business Reorganization, Sale, or Insolvency

If HealthTrust reorganizes its business, merges with another company, or all or substantially all of our assets are sold to a third party, the information that we have collected from you, including personal information, will be among the assets transferred in connection with any such transaction with the acquiring business or merging entity. In the unlikely event that HealthTrust seeks the protection of or is otherwise involuntarily placed into bankruptcy, HealthTrust assets could be subject to a sale to a third party. Under such a circumstance, the information that we have collected from you, including your personal information, could be sold to a third party, unless: (1) the sale of such personal information is prohibited by applicable law, or (2) you have exercised any data rights afforded to you under applicable law that would prohibit us from selling such information about you.

Revisions to this Policy

HealthTrust reserves the right to update this Policy from time-to-time and in our sole discretion. In the event that we make a revision to this Policy, we will revise the “Date of Last Modification” that is listed at the top of this Policy. Any updates to this Policy will become effective as of the date of posting, unless otherwise required by applicable law. Please note that it is your responsibility to regularly check this Website for revisions to this Policy. If you do not agree with any term or condition of the Policy, including any revisions, then you must immediately cease your use of the Website. Your use of the Website after the Date of Last Modification listed above shall be deemed as your acceptance thereof.

In the event that we make a material change to our information collection, use, or disclosure practices, we will post a notice on the main page of our Website to help direct your attention to this Policy so you can review such changes.

Options Regarding the Information Collected by HealthTrust on the Website

HealthTrust values your privacy. If you would like to review or make changes to any information that we have collected from you, such as your first and last name, email address, or contact telephone number, you may contact us by telephone or email by using the details included at the bottom of this Policy under the heading “Contact Us.”

Do Not Track Signals or Requests

Our Website does not currently honor “Do Not Track” signals or requests that are transmitted by or from internet web browsers.

Third Party Hyperlinks

Our Website contains hyperlinks to websites that are owned, operated, and controlled exclusively by third parties (“Third Party Websites”). Hyperlinks to these Third Party Websites are provided for your convenience and for informational purposes only. HealthTrust does not have any control over any content, information, business, or privacy practices of any Third Party Websites. Your use of any Third Party Websites is entirely at your own risk. Under no circumstances will HealthTrust be liable or responsible to you or any other party in connection with your use of such Third Party Websites.

Children’s Online Privacy

HealthTrust markets and sells it services to businesses. HealthTrust does not knowingly market to or otherwise solicit personal information from children under the age of thirteen. You must be at least eighteen years of age to use our Website. If you are under the age of eighteen, please do not provide us with any personal information. If you are the parent or legal guardian of a child that is under the age of eighteen and you believe that your child may have provided us with personal information, please contact us using one of the methods provided under the “Contact Us” heading so that we may immediately delete your child’s information.

For purposes of this Section, the term “personal information” has the same meaning set forth in the United States Children’s Online Privacy Protection Act (15 U.S.C. § 6501, et. al.) and its regulations. The term “personal information” includes first and last name, home or other physical address, email address, telephone number, social security number, and other identifiers as determined by the Federal Trade Commission.

California Consumer Privacy Act Notices

The State of California affords California consumers certain privacy rights and disclosures as detailed in this Section, which are requirements under the California Consumer Privacy Act of 2018, as amended (“CCPA”).

NOTICE OF COLLECTION PRACTICES

The table below includes details about the categories of personal information, as that term is defined under the CCPA, which we have collected about consumers during the preceding twelve (12) months, the reasons for the collection of such personal information, and the category of sources that the personal information has been collected from.

Category of Personal Information	Types of Information Collected	Reason for Collection	Category of Sources for the Information Collected
Identifiers	If you choose to complete one of the forms to contact us with a general inquiry, a demonstration of our asset management program, or to order an assignment, we will collect your first and last name, email address, telephone number, and company name.	We collect identifier information for a business purpose in connection with contacting you regarding the services that you have expressed an interest in or otherwise responding to your general inquiry of us.	We collect all identifier information directly from you.
Categories of personal information described under Cal. Civ. Code § 1798.80(e)	We collect telephone number in connection with completing any one of our contact forms. We will also collect a billing address and billing contact if your business chooses to engage us for services.	We collect telephone number, billing address, and a billing contact person for a business purpose in connection with establishing your business’ account.	We collect telephone number, billing address, and a billing contact person for the account directly from you.
Characteristics of protected classifications under California Law	Not Applicable	Not Applicable	Not Applicable
Commercial Information	To the extent that you choose to engage us for services, we will collect any pertinent commercial information relevant to the engagement.	We collect commercial information for a business purpose in connection with providing you the desired services.	We collect commercial information directly from you.
Biometric Information	Not Applicable	Not Applicable	Not Applicable
Geolocation Data	We collect originating country information based upon IP address through Internet Cookies.	We collect geolocation information for a business purpose in connection with understanding where visitors to our Website originate.	We collect geolocation information through internet cookies deployed to your computing device, unless you block or reject cookies.
Audio, electronic, visual, thermal, olfactory or similar information	Not Applicable	Not Applicable	Not Applicable
Professional or employment related information	Not Applicable	Not Applicable	Not Applicable
Education Information, defined as information not publicly available personally identifiable information as defined under the Family Educational Rights and Privacy Act	Not Applicable	Not Applicable	Not Applicable
Education Information, defined as information not publicly available personally identifiable information as defined under the Family Educational Rights and Privacy Act	Not Applicable	Not Applicable	Not Applicable

Categories of Personal Information Disclosed for a Business Purpose

We do not sell any personal information that we collect from you on or through the Website and have no plans to do so.

HealthTrust has disclosed identifier, information for a business purpose to our data and web hosting provider who collects this information on our behalf and transmits it to us for the purposes detailed in this Privacy Policy.

A California Consumer’s Data Rights Under the CCPA

The CCPA affords California consumers the right to request certain information from a business that collects personal information about the consumer, including:

• The categories of personal information that the business has collected from that consumer;

• The categories of sources from which the personal information is collected;

• The business or commercial purpose for collecting or selling personal information;

• The categories of third parties with whom the business shares personal information; and

• The specific pieces of personal information the business has collected about that consumer.

In addition to the foregoing, a California consumer is afforded data rights as detailed in the following sections of this Policy.
Right to Request to Know The Personal Information Maintained by HealthTrust

A California consumer has the right to know the specific pieces of personal information that HealthTrust has collected about that consumer. If you would like to exercise your right to know, you may submit a request to us by email at [email protected], or you may submit a request by telephone to us toll-free at 941-363-7500. Within ten (10) business days of receipt of your request, we will provide you with an email confirmation that we have received your request.

With each request, we will collect your first name, last name, and email address. If the information that you provide us matches the information that we have on file, we will notify you when your information is available to access. In accordance with applicable law, we will respond to your request with the applicable information within forty-five calendar days of your request; provided, however, that if we cannot verify your identity, we may contact you to extend the period of our response for an additional forty-five calendar days. Please note that we reserve the right to deny Requests to Know under circumstances where we are unable to verify the requestor’s identity, are unable to match the data points provided by the requestor against those in our system, or if we reasonably believe the request is fraudulent. In each such instance, we will provide the requestor with the appropriate rationale for why a specific request is not being fulfilled.

Right to Request Deletion of Personal Information

The CCPA affords California consumers the right to request deletion of their personal information from a business that maintains personal information about that consumer. In the event that you would like to exercise your right to deletion, you may submit a request to us via email at [email protected] or you may make a request over the telephone toll-free at 941-363-7500. Within ten (10) business days of received your request for deletion, we will provide you with an email to confirm receipt of your request.

We will respond to your request with the applicable information within forty-five calendar days of your request; provided, however, that if we cannot verify your identity, we may contact you to extend the period of our response for an additional forty-five calendar days. If your request for deletion conflicts with an applicable state or federal legal obligation imposed on us to retain certain information, then we will specify this rationale in denying your request.

No Discrimination

The CCPA expressly prohibits us from discriminating against any consumer who may choose to exercise their rights as outlined under the CCPA.

Authorized Agent Disclosure

If you are an authorized agent of a consumer who desires to make a data request from us, we will require the authorized agent to provide a Power of Attorney form pursuant to California Probate Code Sections 4121 to 4130. We will also seek a copy of the authorized agent’s government-issued identification card so that we can maintain information on the request in accordance with the law.
Contact Us

Please feel free to contact us if you have any questions or concerns about this Policy, or would like to exercise any options regarding your data:

• via Telephone at 941-363-7500
• via Email at [email protected]