1. Personal Information We Collect
We may collect Personal Information about you directly from you and from third parties, as well as automatically through your use of the Sites. In this Policy, “Personal Information” means any information relating to an identified or identifiable individual.
Information Provided by You
- Registration Information. When you register for our newsletter or to download materials from the Sites, you may provide us with Personal Information, such as name, email address, mailing address, and mobile phone number, specialty, institution, country, and specific areas of interest.
- Correspondence and other communications. When you contact us via a contact form, email, or by other means, you may provide us with Personal Information, such as name, email address, mailing address, and the contents and nature of your correspondence with us.
Information Collected via Automated Means
Information Collected from Third Parties
- Information from Other Sources. We may obtain information, including Personal Information, from third parties and sources other than the Sites, such as our partners and advertisers. If we combine or associate information from other sources with Personal Information that we collect through the Sites, we will treat the combined information as Personal Information in accordance with this Policy.
2. How We Use Personal Information
We use Personal Information we collect on the Sites as necessary for the following purposes:
- Providing the Sites. We use Personal Information to operate, maintain, enhance and provide features of the Sites.
- Understanding usage and improving the Sites. We use the information that we collect on the Sites to understand and analyze the usage trends and preferences of our users, to improve the Sites, and to develop new products, services, feature, and functionality.
- Communicating with you. We may use your email address or other Personal Information we collect on the Sites as necessary to contact you for administrative purposes such as to provide services and information that you request, and to respond to comments and questions.
- Marketing. We may use your email address and other Personal Information to send marketing communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with. Generally, you have the ability to opt-out of receiving any promotional communications as described below under Your Rights and Choices. Where required under applicable law, we will only send you promotional emails with your opt-in consent.
- Aggregation. We may also aggregate or otherwise anonymize Personal Information and use the resulting information for other business purposes.
Below is an overview of the types of cookies we and third parties may use to collect Personal Information.
- Functional cookies. Some cookies are strictly necessary to make our Sites available to you. For example, to provide the chat and login functionality, and to remember your consent and privacy choices. We cannot provide you with the Sites without this type of cookies.
- Advertising cookies. We work with third-party advertising companies to show you ads we think may interest you. For example, we may show you ads about Vesper Medical on third party websites and apps, or ads about third parties’ products and services on our website and app. To do so, we and our advertising partners may place and access cookies through our Sites and otherwise collect or access Personal Information collected over time and across different online services. For example, we may use HubSpot, and Google Analytics Advertising Features, such as Remarketing with Google Analytics.
Our Use of European Personal Information
If you are located in the European Economic Area, we only process your Personal Information when we have a valid “legal basis”, including when:
- We need your Personal Information to provide you with the Sites, for example to respond to your inquiries.
- We have a legal obligation to use your Personal Information, for example to comply with tax and accounting obligations.
- We or a third party have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Sites. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.
3. When We Disclose Information
Except as described in this Policy, we will not disclose your information that we collect on the Sites to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
- Any information that you voluntarily choose to post to a publicly accessible area of the Sites, will be available to anyone who has access to that content, including other users.
- We work with third party service providers to provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions on our behalf, and we require them to agree to maintain the confidentiality of such information.
- We may make certain information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Sites. Where required under applicable law, we will only use anonymized or aggregated information for these purposes.
- We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
- We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Sites and any facilities or equipment used to make the Sites available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
- Information about our users, including Personal Information, may be disclosed and otherwise transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
- We may share Personal Information with our affiliates, subsidiaries and branch offices to which it is reasonably necessary or desirable for us to disclose Personal Information in order to carry out the above-mentioned information processing purposes.
4. Your Rights and Choices
You may, of course, decline to share certain Personal Information with us, in which case we may not be able to provide to you some of the features and functionality of the Sites. If you wish to access, amend, or delete any other Personal Information we hold about you, you may contact us using the contact details at the end of this Policy. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so, as permitted under applicable data protection law.
If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by contacting us using the contact details at the end of this Policy. We may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us in user account functionality on the Sites.
Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Sites.
Your Cookie Choices
- Google cookies. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout or via Google’s Ads Settings or Ad Settings for mobile apps.
- NAI and DAA. Some of our advertising partners are members of the Network Advertising Initiative or the Digital Advertising Alliance. If you prefer to not receive targeted advertising, you may be able to opt out of some network advertising programs by visiting the Digital Advertising Alliance Opt-Out Page and the Network Advertising Initiative Opt-Out Page. Please note that even if you choose to remove your information, you will still see advertisements. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive.
- Do Not Track. We do not specifically respond to Do Not Track (“DNT”) signals. However, some third party websites do keep track of your browsing activities, including across other websites on the Internet, which enables these websites to tailor what they present to you. Your browser may allow you to set a DNT signal on your browser so that these third parties know you do not want to be tracked.
Your European Privacy Rights
If you are located in the European Economic Area, you have additional rights described below.
- You may request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
- You may withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
You may exercise these rights by contacting us using the contact details at the end of this Policy. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
5. International Visitors
The Sites are hosted in the United States and are intended for visitors located within the United States. If you choose to use the Sites from regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the United States for storage and processing, which does not have the same data protection laws as your jurisdiction. When we transfer your Personal Information to the United States, we take steps to comply with applicable data protection law, in particular legal requirements regarding adequate protection for data transfers. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Sites. By providing any information, including Personal Information, on or to the Sites, you consent to such transfer, storage, and processing.
If you are located in the European Economic Area, we will comply with applicable EEA data protection law when transferring your Personal Information outside of the EEA. We may transfer your Personal Information to countries which have been found to provide adequate protection by the EU Commission (e.g., Switzerland, Canada), use contractual protections for the transfer of Personal Information, or transfer to recipients who have certified to the Privacy Shield or adopted Binding Corporate Rules. For more information about how we transfer Personal Information outside of the EEA, or to obtain a copy of the contractual safeguards we use for such transfers, you may contact us as specified below.
6. Children’s Privacy
Our Sites are for general audiences and are not directed to children under the age of 13, and we do not knowingly collect Personal Information from children under the age of 13 without obtaining parental consent. If you are under 13 years of age, then please do not use or access the Sites at any time or in any manner. If we learn that Personal Information has been collected on the Sites from persons under 13 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age has obtained an account on the Sites, then you may alert us using the contact details at the end of this Policy, and request that we delete that child’s Personal Information from our systems.
We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. We generally do not retain Personal Information for longer than 6 years. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.
8. Third-Party Services
The Sites may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Sites. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Sites. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
9. Data Security
We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of Personal Data that we collect and maintain. We cannot, however, ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk.
10. Changes and Updates to this Policy
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through the Sites, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Sites for the first time after such material changes are made. Your continued use of the Sites after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of this Policy.
11. Our Contact Information
Unless otherwise indicated, Vesper Medical, Inc. is entity responsible for the processing of your Personal Information as described in this Policy. Please contact us with any questions or comments about this Policy, your Personal Information, our use and disclosure practices, or your consent choices by email at email@example.com.
Vesper Medical, Inc.
1285 Drummers Lane, Suite 105
Wayne, PA 19087