Privacy Policy

Last Updated: October 2023

At Recor Medical Inc. (“Recor,” “us,” “we,” or “our”), we understand that privacy is important to our consumers (“consumer,” “you,” or “your”). This Privacy Policy (“Policy”) provides you with information about the types of personal information we collect when you visit this web site (the “Site”) or write to Recor as a consumer (versus job applicant, contract worker, or business contact) and not related to a Recor branded product or service (see below for where privacy policies relating to those categories can be found), how we collect and use such personal information and to whom and under what circumstances we disclose it.  Please read this Policy carefully so that you understand your rights in relation to your personal information, and how we will collect, use, process and disclose your personal information.

This Policy does not cover information we may collect from job applicants, (whether they apply through this Site or otherwise), contract workers, or business contacts (again whether they come through this Site or otherwise). For our privacy policy for business contacts see [LINK Business Contact Privacy Policy]. For our privacy policy for job applicants, current and former contract workers, and for former employees, see our [LINK Applicant, Contract Worker, and Former Employee Privacy Policy].

Please note that the services offered via www.recormedical.com (the “Site”) are intended only for consumers who reside in the United States. If you visit this Site from outside the United States, please note that the United States has data protection laws that may not be consistent with those of other countries and that information collected about you in connection with your visit to this Site will be processed in accordance with United States law.

If you do not agree with the practices we have described in this Policy, please do not share your personal information with us. By sharing your personal information with us, by reaching out to us by email or postal mail, or by accessing or using our Site, you agree to our use of your information as described in this Policy.

OUR INFORMATION COLLECTION PRACTICES
We collect information about you in many ways from many places. We may collect information from you through this Site, phone, mail, email, fax, or mobile application interactions you have with us or our service providers or business partners. The information collected may vary depending upon what specific products or services you are requesting or obtaining from us.

Some of the information we collect may include information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your device (“Personal Information”).

Personal Information does not include (and therefore is not covered by this Privacy Policy): (i) publicly available information or lawfully obtained, truthful Information that is a matter of public concern, or (ii) de-identified or aggregated consumer information.

CATEGORIES OF PERSONAL INFORMATION COLLECTED

We and our service providers may have collected and processed the following categories of your Personal Information in the past 12 months for the business purposes described in this Policy. We expect to collect and process in the future the following categories of your Personal Information for the business purposes described in this Policy.

We retain each of the categories of Personal Information listed above for the period reasonably necessary to provide goods and services to you and for the period reasonably necessary to support our business operational purposes listed under “Purposes for Collection.”

PURPOSES OF COLLECTION

We may use the Personal Information we collect, including information that we combine from your interactions with our Site, from you and your device, service providers or third parties to conduct our business and to provide you with our quality products, services, and experiences.
Here are ways we use your Personal Information:

• To provide you access to the Site.
• To personalize your experiences with us, including to remember your interests and preferences, personalize our Site and the content we make available to you through the Site, facilitate interactions with us, track and categorize your activity and interests on the Site, including identifying and linking the different devices you use, and to enrich your experience on the Site.
• To provide information, including information about the Site or required notices.
• For analytics, including understanding how you use our Site, products, and services.
• To improve and develop, such as improving and further developing our products, services, and our Site content, features, performance, and support.
• To provide user support.
• To communicate with you, including to obtain information about you; to respond to your inquiries, concerns, and requests; or to provide other legal or service-related notices about our Site.
• For marketing and advertising, such delivering marketing communications, promotional materials, or advertisements about Recor Medical or third-party products or services that may be of interest to you, including to display targeted ads to you elsewhere online (see your options related to marketing and advertising in the Your Rights section below).
• For business purposes, including to operate and improve our business and business activities; to administer the Site; for research; to maintain our programs, accounts, and records; to understand your satisfaction with our products and services including the Site; to authenticate the information you provide us; to protect the security and integrity of our Site and information technology infrastructure; to detect, prevent and respond to fraud, misuse of our services, intellectual property infringement,  violations of law, or other misuse of the Site or our products and services; and for any other business purpose permitted by law.
• For legal and safety purposes, including to defend or protect us, you, or customers, or third parties, from harm or in legal proceedings; to protect our rights or the rights, property, and safety of others; to comply with legal obligations;  to maintain the security of our customers, employees, and property; to pursue remedies available to us and limit our damages; to respond to court orders, lawsuits, subpoenas, and government requests; to comply with judicial proceedings, court orders, legal processes or lawful requests from government authorities; to address legal and regulatory compliance; and to notify you of product recalls or safety issues.

We may combine or aggregate any information we collect for any of these purposes.  We may also anonymize your Personal Information in such a way that you may not reasonably be re- identified by us or any other organization and may use such anonymized information for any purpose.

DISCLOSURES TO SERVICE PROVIDERS AND THIRD PARTIES

Disclosures to Service Providers

In the past 12 months we may have disclosed, and we may disclose in the future, each of the categories of Personal Information described above to our service providers for business purposes. These business purposes include the following: to provide customer service; to communicate with you; to provide advertising or marketing services: to provide analytic services; to support internal research; to verify service quality; to address online fraud and security; to support our business; and/or to provide similar services on our behalf. If we disclose your Personal Information to a service provider, we do so pursuant to a written contract that prohibits the service provider from retaining, using, or disclosing the Personal Information for any purpose other than for the specific purpose of performing the services specified in the contract, or as otherwise permitted by applicable law.

Disclosures to Third Parties for Monetary or Other Consideration or For Cross-Contextual Behavioral Advertising

We are required to describe certain disclosures of Personal Information as “sales” where we receive valuable consideration. No money is paid in exchange for your Personal Information. In the past 12 months, we may have shared, and we may share in the future, each of the above-listed categories of information:

• With business partners, such as ad networks, who may deliver marketing communications, promotional materials, or advertisements that may be of interest to you. These business partners may engage in cross-contextual behavioral advertising on our behalf; and
• With subsidiaries, who may deliver marketing communications, promotion material, or advertisements that may be of interest to you regarding their brands; and
• With third parties when you engage in or interact with co-branded or co-sponsored content or activities.

Additionally, we may disclose in the future each of the above-listed categories of information to third parties:

• Upon your request or approval, though we may not be able to accommodate all requests.
• As reasonably necessary to facilitate a merger, acquisition, sale, joint venture or collaboration, reorganization, divestiture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), or other types of strategic business transactions.  
• To law enforcement, government entities, including regulatory agencies and courts, as reasonably necessary for our business operational purposes, to assert and defend legal claims, and otherwise as permitted or required by law.

SOURCES OF INFORMATION

We obtain Personal Information from the following categories of sources as further explained below:

• Directly from you. For example, from forms you complete. You may choose not to provide us with your Personal Information. If you choose not to provide us with this information, you may still access and use portions of the Site. However, you may not be able to use portions of the Site which require you to provide Personal Information, such as the contact us page.
• Indirectly from you. For example, through information we collect while providing services to you and from observing your actions on the Site.
• Automatically from you. As you navigate through the Site, information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies. More specifically, this is collected through device identifiers (e.g., IP address, MAC address, other device IDs), IP address demographics (location, language, country of origin, etc.), technical device data (e.g., domain server, type of device, type of web browser) and activity information (e.g., access times, pages visited, search history, referring web site addresses, interactions with Site features).
• Service providers and other third parties. We have previously collected and may continue to collect Personal Information from outside sources, including, advertising networks, online social networks: internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, and data brokers.  We have relationships with these third parties who may collect or receive information and use this to assist in analyzing our business and customers.

USES AND DISCLOSURES OF SENSITIVE PERSONAL INFORMATION

We do not collect or use Sensitive Personal Information from visitors to this Site. As a reminder, this Policy does not cover information we may collect from job applicants, (whether they apply through this Site or otherwise), contract workers or business contacts (again whether they come through this Site or otherwise). For our privacy policy for business contacts see [LINK TO BUSINESS CONTACTS PRIVACY POLICY]. For our privacy policy for current and form job applicants, current and former contract workers, and for former employees, see our [LINK TO APPLICANT, CONTRACT WORKER, AND FORMER EMPLOYEE PRIVACY POLICY].

HOW WE PROTECT THE INFORMATION WE COLLECT

We build security into our system to help protect data from unauthorized access, disclosure, alteration, and destruction. We’re always looking for threats and take reasonable steps to respond to those threats, protecting the information users share with us.  Of course, no method of Internet transmission or data storage can provide guaranteed protection to your information.  If anything should ever happen to your information, we’ll let you know as soon as we can and try our best to make it right.

CHILDREN UNDER THE AGE OF 13

We do not knowingly collect any Personal Information from children under the age of 13 without parental consent, unless permitted by law. If we learn that a child under the age of 13 has provided us with Personal Information, we will delete that information in accordance with applicable laws.

CHILDREN UNDER THE AGE OF 16

Our Site is not intended for children under 16 years of age. No one under age 16 may provide any Personal Information on the Site. We do not knowingly collect Personal Information from children under 16, nor do we knowingly disclose Personal Information of children under 16 to third parties for valuable consideration or for cross-context behavioral advertising. If you are under 16, do not use or provide any information on the Site. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at https://www.recormedical.com/about-contact/. 

YOUR PRIVACY RIGHTS AND CHOICES

The following describes your rights with respect to your Personal Information and explains how to exercise those rights. 

RIGHT TO KNOW

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information.  The information you have the right to request is:

• The categories of Personal Information we have collected about you.
• The specific pieces of Personal Information we have collected about you.
• The categories of sources of the Personal Information we have collected about you.
• Our business purposes for collecting the Personal Information.
• Our business purposes for disclosing the Personal Information, as well as the categories of third parties to whom we have disclosed the information.

Please note that you can only make a verifiable request for access twice within a 12-month period.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Sites that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please complete the webform or calling us at our toll-free number (877) 780-7801or write us at our address listed on our webpage.

RIGHT TO CORRECT

You have the right to request that we correct any inaccurate Personal Information we maintain about you. 

RIGHT TO OPT-OUT

You have the right to opt-out from the sharing of information to third parties for advertising purposes. 

RIGHT TO DELETE

You have the right to request that we delete any of your Personal Information that we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

Examples of circumstances in which we may deny a deletion request are (including if retaining the information is necessary for us or our service provider(s) to):

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Help to ensure the security and integrity of our Site.
• Use for medical research in public interest in compliance with relevant ethics and privacy laws
• Enable solely internal uses that are reasonably aligned with consumer expectations based on the consumer’s relationship with us.
• Comply with a legal obligation.

EXERCISING YOUR RIGHT TO KNOW, RIGHT TO CORRECTION, OR RIGHT TO DELETION

To exercise your right to know, right to correction, or right to deletion as described above, please submit a verifiable consumer request to us by completing the webform or calling our toll-free number (877) 780-7801. Only you, or you authorized agent, may make a verifiable consumer request related to your Personal Information.

To submit a request, we require that you explain your relationship with us, specify your request type, and provide your name, email address, country, home address, the details of your request, and your date of birth. We use this information to identify responsive records and to verify your identity. Your request should include sufficient detail that allows us to properly understand, evaluate, and respond to it. Please note that we may require additional information from you to verify your identity and process your request.

If you choose to use an authorized agent to submit a request on your behalf, you must provide the agent written permission to do so and the agent must verify their own identity directly with us, in addition to the steps we would take if we processed your request directly. If the agent does not submit proof that they have been authorized by you to act on your behalf, we may deny the request. In order to process your request, you or your authorized agent will need to provide our toll-free number (877) 780-7801  such authorization or send such authorization to our data privacy department at DPO@RecorMedical.com.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

RIGHT TO OPT-OUT OF SALES AND SHARING

You have the right to direct us to not sell your Personal Information or to share your Personal Information for cross-context behavioral advertising (the “right to opt-out”). As indicated above, we do not sell or share the Personal Information of consumers we actually know are less than 16 years of age. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us through the Site.

Visitors to the Site that select the link titled “Your Privacy Choices” may submit their request to opt-out on the webform. 

If you would like to exercise these rights, please complete this webform or contact us at our toll-free number  (877) 780-7801. 

CHOICES CONCERNING COOKIES AND OTHER TRACKING TECHNOLOGIES

Cookies

We use cookies to enhance your browsing experience, serve personalized ads or content, and analyze the usage of our Site. You can turn off targeting cookies by toggling off targeting cookies on this webform. Most web browsers automatically accept cookies, but you usually can change your browser to prevent the browser from accepting cookies.  If you reject cookies, you may still use the Site, but your ability to use some areas and features/functions of the Site may be limited. 

Browser Opt-Out Preference Signals

We will consider your user-enabled privacy controls, such as a browser plugin or privacy setting or other mechanism, to signal your choice to opt-out of the sale and sharing of your Personal Information. Such signals are brand, browser, and device specific.

RIGHT TO NON-DISCRIMINATION

We will not discriminate against you for exercising any of your rights as set forth in this Privacy Policy. Unless permitted by the law, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this Privacy Policy at our discretion and at any time. This Privacy Policy will be reviewed at least once every 12 months and will reflect the date it was last updated.

LINKS TO THIRD-PARTY WEBSITES; SOCIAL MEDIA SITES

We may link to third-party websites and services that we do not operate and are outside of our control. We are not responsible for the security or privacy of any information collected by other websites or other services. Please exercise caution and review the privacy statements applicable to the third-party websites and services you use.

We may offer social sharing features or other integrated tools, which let you share actions you take with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that provide these features.

CONTACT US

If you have any questions or concerns regarding our Policy or any questions about the security at our Site, please contact us at DPO@RecorMedical.com or call our toll-free number (844) 441-9869 to submit your questions or concerns.