Privacy Policy

I. Our Commitment to Privacy.

A. This notice describes Activ Surgical Inc. (“Activ Surgical”) Privacy Policy. This Privacy Policy is designed to advise you about how Activ Surgical collects, uses, and protects the personal information you provide. By visiting this site, you agree to the practices described in this Privacy Policy.

B. This Privacy Policy includes details on:

i. What Information is Collected;
ii. How and When Information is Used;
iii. How we Protect your Information;
iv. Who has Access to the Information;
v. How Long we Keep your Information;
vi. Rights to your Information;
vii. Processing;
viii. Consent;
ix. Changes to the Privacy Policy;
x. Tracking;
xi. Effective date; and
xii. Questions about the privacy policy.

C. Activ Surgical may routinely update this Privacy Policy from time to time. When/if such updates to this Privacy Policy are made, these changes will be available on the Activ Surgical website: www.Activsurgical.com. Any questions regarding Activ Surgical’s Privacy Policy should be directed to: PRIVACY@Activsurgical.com.

II. What Information is Collected.

A. Information You Provide to Us: We collect any information you enter on our site, or that you give us in any other way. You can choose not to provide certain information, but you may not be able to take advantage of our services, which are designed to help users understand our products and vision for a healthier future.

i. We only collect information or data about you that can be used to identify you, such as your name, address(es), telephone number(s), e-mail address(es), vessel identifiers, national ID numbers or work permits, DUNS numbers, geolocation data, photographs, references, professional licenses,  or other information or data (“personal information”) when you voluntarily choose to disclose such information to us. For example, you may disclose personal information to us when you submit information by mail, telephone, or electronically, such as when you select the “Contact” link on www.ActivSurgical.com or submit a resume to us.

ii. We do not direct any of our websites to children or individuals under eighteen (18) years of age. Activ Surgical does not provide services or sell products to children under the age of 18.  Individuals under eighteen (18) should consult with their parent or guardian about the use of this website.

B. Automatic Information: When you visit a website, you disclose certain information, such as your Internet Protocol (IP) address and the time of your visit. This site, like many other sites, records this basic information about visits to our site.

C. “Cookies”: Cookies are pieces of information that are transferred to your computer from a web server. Activ Surgical does not utilize cookies.

III. How and When the Information is Used.

A. Generally: the information we collect is used for administering our business activities. Occasionally we may use the information to notify you about changes to our website, product launches, or news about our company.

B. Marketing: We may process certain aspects of your personal information for direct marketing based on your consent. You have the option to withdrawing your consent at any time.

C. Contract performance: We may use or process personal information in connection with pre-contract activities and discussions with you, and to perform services for you.

D. Legal obligations: We will use or process personal information as necessary for compliance with a legal obligation to which we are subject. This includes using or processing personal information for defense of claims against us and satisfying any government reporting obligations and requests.

E. Other legitimate interests: We will process your personal information for any of our other legitimate interests not described above. These include analyzing your use of our website, services, and setting preferences for electronic mailings, fulfilling obligations to our customers and employees, and improving our website and Activ Surgical’s services.

IV. How We Protect Your Information.

A. The privacy and protection of your information is important to us. We do not make any personal information available to third parties without your permission. Subject to the provisions found in Section VII herein, access to some services and content may be password protected. We advise that you do not disclose your password to anyone. In addition, we recommend you sign out of password-protected services at the end of your session.

B. Activ Surgical uses security software to protect the confidentiality of your personal information. In addition, our business practices are reviewed periodically for compliance with policies and procedures governing the security and confidentiality of our information. Our business practices limit employee access to confidential information and the use and disclosure of the same to authorized persons.

V. Who Has Access to the Information.

A. Information about our customers, prospective employees, and website users is important to us. We will not disclose any personal information to any third party without first receiving that individual’s permission.

B. We will not sell, trade, or rent your personal information. We share your personal information with the following categories of third parties for the purposes described in this Privacy Policy:

i. We operate our website from the United States of America and store the information we collect through our websites in the United States of America. Accordingly, we will disclose information collected through our website, as well as other personal information, across offices and geographical boundaries, within and outside of Activ Surgical, for the purposes described above.

ii. We may also disclose your personal information to service providers that perform services for Activ Surgical on an as needed basis and who are obligated to secure the information, such as information technology suppliers, analytics providers, and security providers. These service providers may be located anywhere in the world and may, in some cases, be considered “Processors” as defined in Regulation 2016/679 of the European Parliament (“GDPR”).

iii. We may also disclose your personal information as required by a court order or any other legal or regulatory requirement, including in response to requests from public and government authorities outside your country of residence or to protect our rights, privacy, safety or property, or that of you or others anywhere in the world.

iv. As an entity providing international services, the recipients of your personal information may be located outside of the jurisdiction where you reside. The laws of these other countries may not provide the same level of protection as the laws of your home country. By providing us with personal information about yourself, you acknowledge the disclosure of such personal information to these recipients. Any processing of your personal information outside of your jurisdiction will be in accordance with this Privacy Policy.

v. Activ Surgical disclaims any responsibility for ensuring that any international recipients of your information are compliant with certain privacy regulations such as the Australian Privacy Principles or those issued by the European Economic Area. By using this website and providing personal information to Activ Surgical, you consent to and agree to this disclaimer.

VI. How Long We Keep Your Information.

A. Activ Surgical retains your personal information only as long as needed for any legitimate purpose described herein and otherwise in accordance with all applicable laws.

B. At the appropriate time, we will take reasonable steps to destroy your personal information or ensure that your personal information is de-identified.

C. You are welcome to request the destruction of your personal information by emailing PRIVACY@Activsurgical.com and stating “PLEASE DESTROY MY PERSONAL INFORMATION” in the subject line. Upon receipt of this email, an associate from Activ Surgical will contact you to discuss the matter and arrange for the destruction or de-identification of your personal information.

VII. Rights to Your Information.

A. Except as otherwise expressly discussed in this Privacy Policy, this policy only addresses our use and disclosure of personal information we collect from you. To the extent that you disclose your personal information to third parties, including any third-party website linked from any of our websites, you are subject to the privacy customs and policies of those third parties. We encourage you to ask questions before you disclose any personal information to such third parties.

B. Subject to local law, you may have certain rights regarding personal information we have collected about you. Such rights might include the following:

i. Know what personal information we have collected about you;

ii. Know what personal information about you was disclosed to third parties;

iii. Update or correct such information if you believe there is an inaccuracy;

iv. Restrict the processing of your personal information;

v. Request deletion of your personal information;

vi. Object to our use of your personal information; and

vii. Request transmission of your personal information to another party.

C. Activ Surgical does not discriminate against any individual for exercising his/her rights. However please be advised that the deletion or restriction of your personal information may prevent you from enjoying Activ Surgical’s website and services.

D. To exercise any of your rights, please email PRIVACY@Activsurgical.com and state your desired action in the subject line to help Activ Surgical direct you to the correct associate.

VIII. Processing.

To the extent that Activ Surgical may be considered a “Controller” of data belonging to any Activ Surgical user that is located in the European Economic Area, Activ Surgical may utilize the services of a third-party Processor as defined under the GDPR. Further, Activ Surgical may be required to transfer personal information to countries outside the EEA. Countries outside the EEA may not provide an adequate level of protection for your personal information. Accordingly, Users located in the EEA assume such risks by utilizing Activ Surgical’s services on www.Activsurgical.com. You may request that Activ Surgical not transfer such information or utilize the services of a Processor. However, please note that such requests may result in the inability to use Activ Surgical services or its website. Please send any requests to Activ Surgical to PRIVACY@Activsurgical.com.

IX. Consent.

By using our website, you consent to our collection and use of personal information as described herein.

X. Changes to Privacy Policy.

If our Privacy Policy or procedures change, we will immediately post those changes to our website. Any such changes will be effective immediately upon being posted, unless otherwise stated in the change.

XI. Effective Date.

This Privacy Policy is effective as of September 17, 2020.

XII. Tracking Policy.

Third parties are not permitted to collect personally identifiable information about an individual user’s online activities on our website.

XIII. Questions about the Privacy Policy.

Privacy and security are important to us. If you have any questions about this Privacy Policy please contact Activ Surgical at PRIVACY@Activsurgical.com.

Updated: 9/18/2020

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