Legal

FinnitivHealth Privacy Policy

Last Updated: May 19, 2026

1. Introduction

FinnitivHealth ("FinnitivHealth," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you visit our website at finnitivhealth.com (the "Site"), interact with our Site content, or otherwise communicate with us, including through offline channels, about our products or services (collectively with the Site, "Services"). Subject to applicable law, this Privacy Policy also applies to personal information we collect from or about you when you submit a job application and/or seek employment opportunities with us.

FinnitivHealth provides outsourced surgical services and equipment to hospitals, ambulatory surgery centers, and physician practices through our family of brands, Sightpath Medical and United Medical Systems (UMS). Our Services are intended for healthcare professionals and business decision-makers — not patients. We do not knowingly collect any protected health information (PHI) subject to the Health Insurance Portability and Accountability Act of 1996 through our Services.

2. Information We Collect

2.1 Information You Provide to Us

We collect personal information from you in connection with our Services or you voluntarily provide us such information. Such information includes:

Name and contact information: such as your name, your company name, and your contact information (e.g., postal addresses, email addresses or telephone numbers), when you submit an inquiry through our contact form through the Site or otherwise request information about our Services.
Demographic data: such as your race, national origin, gender, citizenship or immigration status you may provide in connection with your job application.
Professional or employment related information: such as your job title, job history, education information, certifications, and other information you may provide in connection with your job application.
Video and audio information: such as video recordings or photographs of our events or programs (e.g., our trainings, conferences, etc.), or voicemails you may leave us.
Government-issued identifiers: such as your driver's license number, Social Security number or national ID number, or other government-issued identification numbers when you provide this information when applying for a position through our careers page.
Other information: any other personal information you may choose to provide, such as personal information you provide when you communicate with us by email, phone, or other means (e.g., contents of your emails, contents of your "Contact Us" form or other form made available by us, responses to our surveys or questionnaires (if applicable), voicemails, or other communications).

2.2 Information Collected Automatically

When you visit our Site, we automatically collect certain information about you and your device, such as your browsing activity, by automated means, using cookies, pixel tags, web server logs and other technologies. For more information regarding such technologies, please refer to the Cookies and Tracking Technologies section below. Such information includes:

Internet or other network activity information: such as your IP address, browsing history or search history on our Site.
Geolocation Data: such as your general/approximate location (city or region level) based on your IP address.
Device information: such as device identifiers (e.g., device ID), browser type and version, operating system, or domain server.
Clickstream and usage data: such as information regarding your usage of or interactions with our Site, including the referring and exiting URL pages, pages viewed and time spent on the Site, date and time of visits to the Site, the links clicked, items viewed and/or downloaded or other data regarding your usage activity of our Site, and your interactions with our email communications.

2.3 Information from Third Parties

We may receive personal information about you from certain third parties, such as:

Social media platforms: such as comments, content or details that you post on publicly available websites or social media platforms, including any information that accompanies those posts, such as your name, username, email address, your likes or preferences, or profile picture, subject to your privacy settings on these platforms and/or websites. Some of these platforms (e.g., LinkedIn) may also provide aggregated insights about visitors to our Site.
Service providers: such as our customer relationship management (CRM) provider (e.g., Salesforce) that may match your inquiry to existing records.
Publicly available sources: such as publicly available information from professional directories or publicly available company websites.
Background check information and references: such as information collected in connection with background checks or employment references in connection with your job application.

3. How We Use Your Information

We may use the personal information we collect for the following purposes:

Communications: To communicate with you about our Services, including responding to your inquiries or provide you the requested information about our Services.
Provide and improve our Services: To provide, manage and improve our Site and our Services.
Maintenance of security of our systems: To verify your identity and to maintain the integrity and security of our systems and Services.
Operate our business: To support our internal business functions, including performing accounting, auditing, and analyzing the usage of our Site and trends.
Marketing and advertising purposes: To conduct B2B marketing activities, including advertising tailored to your interests or retargeted advertising.
Talent management and recruiting purposes: To recruit and evaluate candidates who apply for available positions on our careers page.
Compliance with law and protection of our interest: To comply with our legal obligations (including to comply with a subpoena or similar legal process) and protect our rights (including to take precautions against liabilities, investigate and defend ourselves against any claims or allegations, protect our rights and property, and enforce our policies and terms).
Other purposes: For any other purpose disclosed at the time of collection. We also may use your personal information with your consent or at your direction.

Deidentified and aggregated information: We may aggregate and/or de-identify your personal information such that it is no longer able to be linked to you or your device(s). This Privacy Policy does not limit our ability to use or disclose such aggregated or de-identified information, which we may disclose, in our sole discretion, to third parties for their own use. To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

4. Cookies and Tracking Technologies

When you visit our Site or interact with our email communications, we collect certain personal information about you by automated means, using cookies, pixel tags, web server logs, or other similar tracking technologies to collect information about you or your device, such as your interactions with our Site, including your browsing activity. Cookies are small data files that websites send to your computer or device to uniquely identify your browser or to store information or settings in your browser. Cookies enable us to recognize you as the same user who was at our Site in the past and relate your use of our Site to other information about you. We may use cookies to enhance and customize your experience on our Site, collect general usage and aggregated statistical information about our Site, detect and prevent fraud, and tailor the advertising you receive from us to your interests. A pixel tag (also known as a "clear gif" or "web beacon") is a tiny image that links webpages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. We may use pixel tags to help us measure the effectiveness of our content by, for example, counting the number of individuals who visited our Site.

Third-Party Analytic Services: We use third party analytics services on our Site, such as Google Analytics and LinkedIn Analytics, who may use cookies or other similar tracking technologies to help us analyze your use of our Site. For more information about how Google uses data when you visit our Site and how to opt out of such technologies, see https://policies.google.com/technologies/partner-sites. For information about LinkedIn's practices, see https://www.linkedin.com/legal/privacy-policy.

Cross Context Behavioral Advertising: On our Site, we and our advertising partners may collect personal information about you and your online activities (through cookies and other tracking technologies) over time and across sites to provide you with advertising about products and services tailored to your interests. Such information may include device information, geolocation data, and clickstream data, as described in the Information Collected Automatically subsection above. We also may disclose the information we collect about you to third parties for cross context behavioral advertising (to serve you targeted advertising over time and across sites) and for purposes of tracking the effectiveness of our marketing efforts. For more information about our use of cookies and how to communicate your choices about how they are used to collect personal information about you, please refer to our Cookie Notice and the Your Privacy Rights and Choices section below.

5. How and To Whom We Disclose Your Information

We may share the personal information we collect in the following circumstances:

With service providers who provide services to us or perform services on our behalf (such as hosting providers, CRM platforms, analytics providers, and marketing platforms), bound by contractual obligations to protect the information.
Within the FinnitivHealth family of brands, including Sightpath Medical and UMS, for the purposes set forth in this Privacy Policy.
With our affiliates and parent or subsidiary entities, for the purposes set forth in this Privacy Policy.
In connection with a business transaction that we contemplate and/or conduct, such as a merger, acquisition, or sale of our all or portion of our business or assets, in which personal information held by us is among the assets transferred.
To comply with legal obligations, respond to lawful requests from public authorities, or protect our legal rights.
With our business partners, including our advertising or other strategic partners, or our event co-sponsors.
With your consent or at your direction.

6. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect the information we collect against accidental, unlawful or unauthorized access, destruction, loss, alteration, disclosure or use. However, no method of transmission over the internet or electronic storage is fully secure, and we cannot guarantee absolute security.

7. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, comply with our legal obligations, resolve disputes, and enforce our agreements. We consider the following criteria when determining how long to retain the personal information we collect: why we collected the information; our legal obligations related to the information (taking into account applicable statutes of limitation and records retention requirements under applicable law, as well as our records retention requirements and policies); and the risks associated with retaining the information.

8. Legal Bases and Data Transfers

FinnitivHealth will be the data controller of your personal information processed by or for us in connection with our Services. In addition, certain business partners also act as data controllers for the information that we share with them and any personal information that partners may collect independent of our relationship with them. If you have any questions about the processing of your personal information by a business partner, you should contact the business partner directly.

Under some data protection laws, we can only use your personal information if we have a relevant lawful basis. The most common lawful bases we rely upon are as follows: (i) where you have given consent ("Consent"); (ii) to comply with our legal obligations ("Legal Obligations"); (iii) for the performance of a contract with you or to take steps at your request before entering into a contract ("Contract"); or (iv) for our legitimate interests or those of a third party ("Legitimate Interests"). A Legitimate Interest is when we or a third party have a business or commercial reason to use your personal information, so long as this is not overridden by your own rights and interests.

We do not process information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or genetic or biometric data (also known as "Special Category Personal Data") unless permitted by applicable law.

Failure to provide us with the relevant personal information, in cases where you are legally or contractually required to provide it, may result in us being unable to establish or continue our relationship with you or to provide Services to you. We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

We make our Services available in a number of jurisdictions. As a result, any information that we collect, disclose or share, including your personal information, can be stored and processed in various other jurisdictions around the world ("Other Jurisdictions"), including (but not limited to) the United States, for the purposes detailed in this Privacy Policy. Where applicable, we only transfer personal information to Other Jurisdictions in compliance with applicable laws, which might include ensuring there are applicable contractual arrangements with our subsidiaries, affiliates and other third parties in respect of such transfers in place.

You can obtain more information about our policies and practices with respect to the use of service providers located in other jurisdictions by contacting us as described in the "Contact Us" section below.

9. Your Privacy Rights and Choices

Subject to applicable law, you may have the following privacy rights and choices:

Unsubscribe from our marketing communications by following the instructions in any communication you receive or by contacting us directly, as set forth in the "Contact Us" section below. Please understand that it may take us a few days to process an opt out request.
Update or correct your information by contacting us using the information in the Contact Us section below.
Manage cookie preferences by setting your browser settings to detect cookies and give you an opportunity to reject them. You can also manage your cookie preferences by using our cookie preference tool or cookie banner on the Site. Note that refusing or disabling certain cookies may inhibit or preclude your use of our Site or certain features.
Opt-out of cross context behavioral advertising by managing your cookie preferences on our cookie preference tool or cookie banner on the Site. Our practice is to use or disclose your personal information to our advertising partners for cross context behavioral advertising at your direction using our cookie preference tool. You may communicate your choices about the use and disclosure of your personal information for such purposes by clicking "Cookies Settings" on the bottom of our Site to access our cookie preference tool and making your selection. You may also change your direction as to future use and disclosure for such purposes by accessing our cookie preference tool and changing your selection. Your choice about the use and disclosure of your personal information for cross context behavioral advertising will be specific to the browser and device you are using to access the Site at the time you communicate such choice. If you clear your browser, or access our Site from another browser or device, you will need to communicate your choice again.

In addition to our cookie preference tool, there are certain third party tools you may use to communicate your choices. You may communicate your choice as to whether advertising networks that participate in self regulatory programs like the Digital Advertising Alliance ("DAA") and Network Advertising Initiative ("NAI") may use your personal information for cross-context behavioral advertising by visiting the DAA's WebChoices or NAI's Consumer Opt Out. You may also communicate such choices by clicking on the "ad choices" icon on an advertisement and selecting the types of advertisements to which you wish to opt out.

Please note that if you do not direct us to use or disclose your personal information for cross context behavioral advertising, or if you later change your direction to reject this, you may continue to see our ads on our Services or third party sites, but they will not be targeted based on personal information we collected about you.

Individual Privacy Rights: In addition to the choices detailed above, depending on the jurisdiction in which you reside, you may have the rights described below. If you are a resident of California, the rights afforded to you can be found in the California Supplement.

Receive confirmation as to whether or not your personal information is being processed by us and access to your personal information.
Receive a copy of the personal information you directly volunteer to us in a structured, commonly used and machine readable format.
Request rectification of your personal information that is in our control.
Object to the processing of your personal information by us.
Request to restrict the processing of your personal information by us.
Withdraw your consent to our processing of your personal information, where consent was required and previously provided (subject to applicable law, we may not be able to provide you with a particular service when you withdraw your consent).
Request erasure of your personal information.
Lodge a complaint about our processing of your personal information with a supervisory authority.

These rights are not absolute and may be subject to our own legitimate interests, and regulatory and legal requirements. If you would like to exercise any of the rights mentioned in this section, please contact us as detailed in the "Contact Us" section below.

10. Children's Privacy

Our Services, including our Site, are not directed to children under 16, and we do not knowingly collect personal information from children under 16. If we learn we have collected personal information from a child under 16, we will promptly delete it from our records. If you believe a child under 16 may have provided us with personal information through our Site, please contact us as specified in the "Contact Us" section below.

11. Links to Third-Party Websites and Services

Our Site may contain links or widgets that lead to other websites or online services (such as social media platforms) not owned or operated by us. We are not responsible for these other sites or online services, and their posted privacy policies (not this Privacy Policy) will govern the collection and use of your personal information on them. We encourage you to read the privacy policies of each website or online service visited after leaving our Site to learn about how your information is treated by others.

We maintain a presence on certain social media platforms, such as LinkedIn, to communicate with our customers. This Privacy Policy applies to our use of personal information you submit to us on such platforms or receive about you from such platforms, but it does not apply to what those third party platforms do with your personal information. These platforms have their own privacy policies. In accordance with those policies (and your privacy settings within your social media accounts), information about your activities on our Site or the relevant social media platform (such as "John follows FinnitivHealth") may be published to your social media account.

12. Changes to this Privacy Policy

We may update this Privacy Policy (including any supplement) from time to time. When we do, we will revise the "Last Updated" date at the top of the policy or any supplement. We encourage you to revisit this Privacy Policy (and any supplement) often to remain fully informed of our privacy practices. Your continued use of the Site after any changes indicates your acceptance of the updated Privacy Policy (and any supplement). Material changes will be communicated through the Site or, subject to applicable law, through other appropriate means.

13. Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or wish to file a complaint, please contact us at:

FinnitivHealth
Attn: Privacy Officer
5775 W Old Shakopee Road, Suite 90
Bloomington, MN 55437
Email: privacy@finnitivhealth.com
Phone: (800) 516-9425

California Supplement

Last Updated: May 19, 2026

This California Supplement ("Supplement") supplements the FinnitivHealth Privacy Policy and provides information required by California law, which provides their residents particular rights, subject to certain legally permitted exceptions. This Supplement applies solely to individuals residing in California ("you"). You should read this Supplement in combination with our Privacy Policy to fully understand our collection, use and disclosure of your personal information, and how you may exercise your rights under these laws.

For purposes of this Supplement, the terms "personal information", "sell", "share", "sensitive personal information" and "business purposes" have the meanings given to them in the California Consumer Privacy Act of 2018, as amended, and its implementing regulations (the "CCPA"). Any capitalized terms we do not define in this Supplement are defined in our Privacy Policy.

Personal Information We Collect

We may collect (and may have collected during the last 12 months) the following categories of personal information about you:

Identifiers: identifiers such as a real name, postal address, telephone number, online identifier (such as device identifier, cookie ID, etc.), IP address, email address, Social Security number, driver's license number and other similar identifiers.
Protected Classifications: characteristics of protected classifications under California or federal law, such as race, national origin, gender, citizenship or immigration status.
Internet or other Electronic Network Activity Information: Internet and other electronic network activity information, including browsing history, search history, and information regarding your interaction with our Site.
Biometric Data
Geolocation Data
Sensory Information: electronic and similar information.
Professional or Employment-Related Information: professional or employment-related information.
FERPA Information: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sensitive Personal Information

Certain categories of personal information listed above may be considered "sensitive personal information" under the CCPA. We do not use or disclose (and have not used or disclosed during the last 12 months) sensitive personal information for any purpose other than those expressly permitted under the CCPA.

Sources of Personal Information

During the last 12 months, we may have obtained personal information about you from various sources, as follows:

Directly from you or your devices, such as through your use of our Site or your communications with us.
Our family of brands, affiliates, parent company and their subsidiaries.
Service providers who provide services to us or on our behalf.
Our business partners, such as our advertising partners or other strategic partners.
Recruiting and talent agencies.
References you provide to us, such as when applying for an employment opportunity.
Background and credit check providers.

Use of Personal Information

We may use (and may have used during the last 12 months) the categories of personal information listed above for the purposes described in the "How We Use Your Information" section of our Privacy Policy and for certain business purposes specified in the CCPA, such as:

Performing services, including providing access to and maintenance of this Site, providing customer service, responding to inquiries, or conducting analytics services.
Providing advertising and marketing services to you.
Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
Short-term, transient use, including non-personalized advertising shown as part of your current interaction with us.
Helping to ensure security and integrity, to the extent the use of your personal information is reasonably necessary and proportionate for these purposes.
Debugging to identify and repair errors that impair existing intended functionality.
Undertaking internal research.

In addition, we may use certain personal information for purposes of managing career opportunities with us or managing our relationships with current or prospective partners, corporate customers, vendors, suppliers and other business partner personnel.

Sale or Share of Personal Information

We do not "sell" or "share" (and have not "sold" or "shared" in the last 12 months) your personal information. We do not have actual knowledge that we "sell" or "share" personal information of individuals under 16 years of age.

Our practice is to use or disclose your personal information to our advertising partners for cross-context behavioral advertising at your direction using our cookie preference tool. You may communicate your choices about the use and disclosure of your personal information for cross context behavioral advertising by clicking "Cookie Settings" on the bottom of our Site to access our cookie preference tool and making your selection. You may also change your direction as to future use and disclosure for such purposes by accessing our cookie preference tool and changing your selection. Although our Site does not respond to do not track signals, our Site does recognize the global privacy control ("GPC") signal, and you may communicate your preference that we not use or disclose your personal information for cross context behavioral advertising by activating the GPC signal in your browser. For more information about what types of browsers support the GPC signal, please visit https://globalprivacycontrol.org/. Your choice about the use and disclosure of your personal information for cross context behavioral advertising will be specific to the browser and device you are using to access the Site at the time you communicate such choice. If you clear your browser, or access our Site from another browser or device, you will need to communicate your choice again.

Disclosure of Personal Information

We may disclose (and may have disclosed in the last 12 months) the following categories of personal information about you for the purposes described above: Identifiers; Protected Classifications; Internet or Other Electronic Network Activity Information; Geolocation Data; Sensory Information; Professional or Employment-Related Information; FERPA Information and Inferences, to the categories of third-party recipients below:

Our family of brands, affiliates, parent company and their subsidiaries.
Service providers who provide services to us or on our behalf.
Our business partners, such as our advertising partners or other strategic partners.
Background and credit check providers.
Our professional advisors (such as our lawyers, auditors, accountants, consultants agents and insurers).

We may also disclose your personal information if we are required to do so by law, regulation or legal process, such as in response to a subpoena or law enforcement authorities; when we believe disclosure is necessary or appropriate to prevent physical, financial, or other harm, injury or loss; or in connection with an investigation of suspected or actual unlawful activity. Additionally, we may disclose your personal information to third parties in connection with a business transaction as described in the Privacy Policy (e.g., in the event we sell or transfer (or contemplate the sale or transfer of) all or a portion of our business or assets).

CCPA Privacy Rights

Your privacy rights under the CCPA may include the below (subject to certain legally permissible exceptions):

Access Right/Right to Know: Right to access your personal information or receive certain information regarding our processing of your personal information, including:
- the categories of personal information we collected about you;
- the categories of sources for the personal information we collected about you;
- our business or commercial purpose for collecting, disclosing, selling or sharing that personal information (as applicable);
- the categories of third parties with whom we disclose, sell or share personal information (as applicable);
- if we sold, shared, or disclosed your personal information for a business purpose, (a) the categories of personal information sold, shared or disclosed and (b) the categories of recipients to whom we sold, shared or disclosed personal information; and
- the specific pieces of personal information we collected about you.
Correction Right: Right to request that we correct any inaccuracies in the personal information we have collected about you.
Deletion Right: Right to request that we delete the personal information provided by you.
Right to Opt-out of "Sale" or "Share": If applicable, right to request that we refrain from "selling" or "sharing" (each as defined under applicable law) your personal information.
Right to Limit the Use or Disclosure of Sensitive Personal Information: If applicable, right to limit certain uses or disclosures of sensitive personal information.
Appeal Right: Right to appeal our decision if we deny your request or state we cannot fulfill it.
Non-Discrimination: Right not to receive discriminatory treatment if you exercise any of the rights explained in this Supplement.

We do not use automated decision-making technologies (as defined under applicable law) or use or disclose your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects on you without either your explicit consent or where otherwise permitted by applicable law.

How to Exercise Your Rights

Access, Correction and Deletion Requests: To submit an access, correction or deletion request, call us at (800) 516-9425 or by emailing privacy@finnitivhealth.com. An authorized agent, subject to applicable law, may submit a request on your behalf by emailing privacy@finnitivhealth.com.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide any of the following information: name, email address, phone number and mailing zip code. Subject to applicable law and depending on the nature of the request, we may also require you to sign a declaration under penalty of perjury that you are the individual whose personal information is the subject of the request. If you designate an authorized agent to make a request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) we may require you to verify your own identity directly with us (as described above). A valid power of attorney will constitute signed written permission, but you are not required to obtain a power of attorney to use an authorized agent. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

Appeal Requests: If we deny your request or cannot fulfill it, you may, subject to applicable law, appeal our decision by emailing privacy@finnitivhealth.com. Your request should include "Appeal" in the subject line.

Changes to this Supplement: We may change this Supplement from time to time. When we do, we will let you know by posting the changed Supplement on this page with a new "Last Updated" date. We encourage you to revisit this Supplement often to remain fully informed of our privacy practices. Material changes will be communicated through the Site or, subject to applicable law, through other appropriate means.

Contact Us: If you have any questions about this Supplement or our privacy practices, you may contact us at privacy@finnitivhealth.com.