Website privacy policy.

01Scope — Three Kinds of Data, Three Rulebooks

1.1 Website visitors, prospects and business contacts — this Policy

This Policy applies to personal information collected through platinumsystem.com, public contact and demo forms, website accounts, marketing communications, sales interactions and Platinum’s sales CRM.

1.2 Clinic platform data, including PHI — MSA and BAA

Data entered by or for a subscribed practice into the Platinum platform is governed by the practice’s MSA and BAA, not this Website Privacy Policy. The clinic controls its patient records and PSCRC processes PHI as a HIPAA Business Associate. Patients seeking access, correction or other rights regarding their clinical record should generally contact their treating clinic, subject to the applicable BAA and law.

1.3 Patient App users — patient-facing documents

The Patient App and patient portal have separate Patient Terms of Use and a Patient Privacy Policy presented in-app at enrollment.

02Personal Information We Collect

2.1 Information you provide

Depending on how you interact with us, we may collect:

• identifiers and contact details, such as name, business email address and telephone number;
• professional and practice information, such as practice name, role, NPI and practice address;
• billing and transaction information needed for account administration and payments;
• communications with Platinum, including demo requests, contact forms and support or business correspondence; and
• other information you choose to submit through a public website form, subject to the health-information restrictions in Section 10.

2.2 Information collected automatically

When you use the website, we may collect device and browser information, IP address, log and usage data, approximate location derived from IP address, and cookie or similar technology data described in Section 6.

2.3 Sources

We collect the information described in this Policy from you and from your interactions with our website and business teams. Platinum does not purchase contact lists and does not use data-enrichment services.

03How We Use Personal Information

We use personal information to:

• provide, operate, maintain and improve the website and related business services;
• respond to inquiries, schedule or conduct demonstrations, and manage prospective and existing business relationships;
• process billing and transactions where applicable;
• send service, administrative and transactional communications;
• send marketing communications where permitted by law and honor applicable preferences or consent requirements;
• analyze website use and performance;
• secure systems, prevent misuse, investigate incidents and enforce applicable terms;
• comply with legal, regulatory, tax and recordkeeping obligations; and
• support corporate transactions and professional advice where appropriate.

AI training. Platinum does not use identifiable personal information from the public website or sales CRM to train AI models.

04How We Disclose Personal Information

4.1 Affiliates

PSCRC and Platinum System USA Inc. may disclose personal information to each other as necessary to operate the website, provide Services, administer accounts, and perform U.S. billing and collection functions consistent with their respective roles.

4.2 Service providers

We disclose information to contracted service providers that perform functions for us, such as hosting, analytics, payment processing, support and e-signature services, subject to contractual and legal requirements appropriate to the information involved.

4.3 Other permitted disclosures

We may disclose information to professional advisors; to parties involved in a merger, acquisition, financing, reorganization, sale of assets or similar corporate transaction; and to governmental authorities, courts or other parties when required by law or reasonably necessary to protect rights, security or safety.

4.4 No sale or targeted-advertising sharing

We do not sell personal information for money. We do not sell or “share” personal information as those terms are defined by California law for cross-context behavioral advertising, and we do not use advertising pixels on the website. Google Analytics 4 is used for analytics purposes.

05Security

5.1 Safeguards

We maintain administrative, physical and technical safeguards designed to protect information, including encryption in transit and at rest, multi-factor authentication, role-based access controls, logging and monitoring. The Platinum platform infrastructure is covered by a SOC 2 Type II report. No security measure or method of transmission is completely secure.

06Cookies and Analytics

6.1 Cookies

We use essential, analytics and functional cookies. We do not use advertising or marketing cookies. Our website analytics tool is Google Analytics 4.

6.2 Choices and preference signals

You can manage applicable cookie preferences through the website cookie banner and your browser settings. We recognize valid Global Privacy Control (GPC) or other legally required universal opt-out preference signals where applicable. Because we do not currently sell personal information or use it for targeted advertising, an opt-out signal does not change those practices but will be honored as required if our practices or legal obligations change.

07Retention

We retain personal information only for the periods described below or longer where reasonably necessary to comply with law, resolve disputes, enforce agreements, complete a transaction, maintain security records or satisfy another lawful retention requirement. The periods below reflect Platinum’s current business rules for the website and related business data.

08U.S. State Privacy Rights

8.1 Rights that may apply

Depending on your state of residence and the applicability of state privacy law to Platinum and the particular information involved, you may have rights to request access or confirmation, correction, deletion, a portable copy, and information about certain disclosures. You may also have rights to opt out of a sale, sharing for cross-context behavioral advertising, targeted advertising or certain profiling, and to limit certain uses of sensitive personal information where applicable. We will not unlawfully discriminate against you for exercising an applicable privacy right.

8.2 How to submit a request

Email privacyoffice@platinumsystem.com or call (888) 880-8602. We may take reasonable steps to verify your identity and authority before acting on a request. Where applicable, an authorized agent may submit a request on your behalf.

8.3 Timing and appeals

We respond within the period required by applicable law. Many state privacy laws provide a 45-day response period and permit an extension in specified circumstances. Where applicable law provides an appeal right, you may appeal a denial by replying to our response or emailing privacyoffice@platinumsystem.com with “Appeal” in the subject line. Our appeal response will include any additional complaint mechanism required by applicable law.

09California Notice at Collection

If the California Consumer Privacy Act, as amended, applies to our processing, this Section serves as a notice at collection for the public website and related business interactions. The more detailed descriptions in Sections 2–8 are incorporated into this notice.

Retention. Retention periods for these categories are described in Section 7. We do not sell personal information and do not share it for cross-context behavioral advertising.

10Public Website and Consumer Health Data

10.1 Do not submit health information through public forms

The public website, demo forms and marketing forms are not designed to collect PHI, patient records or consumer health data. Do not submit patient names linked to health information, diagnoses, symptoms, treatment details or other health information through these public channels.

10.2 If health information is voluntarily included in a request

If an individual nevertheless includes information about their own health status or healthcare in a public website message, the categories collected are limited to the health-related information the individual voluntarily provides. The source is the individual. We use that information only as reasonably necessary to respond to or route the request, protect our systems or rights, comply with law, or as otherwise authorized by the individual and applicable law.

10.3 Disclosure of such information

We do not sell consumer health data. To the extent consumer health data is handled through the public website, it may be disclosed only as necessary to Platinum System USA Inc. as the website operator, to contracted hosting, CRM or support providers acting for Platinum, to professional advisors, or as legally required. We do not disclose consumer health data for targeted advertising.

10.4 Consumer health rights

Where Washington My Health My Data, Nevada consumer health privacy law or another applicable consumer health law applies, you may have rights to confirm and access consumer health data, obtain information about recipients, withdraw consent where processing is based on consent, request deletion, and appeal a refusal. Submit requests through the methods in Section 8. Deletion requests will be extended to applicable affiliates, processors, contractors and other recipients as required by law.

10.5 Consent and requested services

Where collection or disclosure of consumer health data is necessary to provide a product or service that you requested, Platinum will limit the processing to what is necessary for that request. Where applicable law requires separate affirmative consent for additional collection or sharing, Platinum will obtain that consent before the additional processing.

11Children

11.1 Public website

The public website is directed to adults and business users and is not directed to children under 13. We do not knowingly collect personal information from children under 13 through the public website.

11.2 Patient minors

Patient records and Patient App access for minors are outside the scope of this Website Privacy Policy and are governed by the treating clinic, the applicable BAA, patient-facing documents and applicable law.

12International Processing

12.1 Locations

Because PSCRC is based in Barbados and Platinum System USA Inc. operates the U.S. website and billing functions, personal information covered by this Policy may be processed in the United States and Barbados. We apply contractual, technical and organizational safeguards appropriate to the information and processing involved.

13Changes to This Policy

13.1 Updates

We may update this Policy to reflect changes in our practices, technologies, legal requirements or Services. Material changes will be posted with a revised effective date and communicated by email, website, account or in-app notice where appropriate or legally required. We will obtain consent where applicable law requires consent for a new use or disclosure.

14Contact