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privacy policy

NEUSPERA PRIVACY POLICY

Neuspera Medical Inc. (collectively, “Neuspera,” “we,” “our,” or “us”) are committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used, and disclosed by Neuspera. This Privacy Policy applies to our website, www.Neuspera.com (the “Site”). By accessing or using our Site, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy.

For the purposes of EU data protection laws (“GDPR“), Neuspera is a data controller (i.e., Neuspera is responsible for, and controls the processing of, your personal data).

 

1. WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?

 

The categories of personal information we collect can include:

  • Information you provide to us directly. We may collect personal and business information, such as your name and email address when you contact us using the “Contact Us” functionality on our Site or otherwise communicate with us. We may also collect any communications between you and Neuspera and any other information you provide to Neuspera.
  • Data collected through the use of the Site. We may collect information about how you use the Site, your actions on the Site, and content you post to the Site, including but not limited to content you provide using the “Contact Us” functionality on the Site (“User Content”). Please remember that Neuspera may, but has no obligation to, monitor, record, and store User Content in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. By using the Site, you consent to the recording, storage, and disclosure of such communications you send or receive for these purposes.

We use this information to operate, maintain, and provide to you the features and functionality of the Site, as well as to communicate directly with you, such as to send you email messages and permit you to communicate with us. We may also send you Site-related emails (e.g., regarding updates to features of the Site and technical and security notices). For more information about your communication preferences, see “Control Over Your Information” below.

 

2. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION

 

What we collect using cookies

We, and our third-party partners, may automatically collect certain types of usage information when you visit our Site. We may collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “tracking technologies”). For example, we may collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, and other similar information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Site and to understand more about the demographics of our users.

How we use that information

We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide and monitor the effectiveness of our Site; (c) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Site; (d) diagnose or fix technology problems; and (e) otherwise to plan for and enhance our Site.

Your choices

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Site, as some features and services on our Site may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

You can learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy here.  You Can also view Google’s currently available opt-out options here.

We support the self-regulatory principles for online advertising (Principles) published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info/. If you want to “opt out” of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices, or http://www.networkadvertising.org/choices/ to place an“opt-out”cookie on your device indicating that you do not want to receive interest-based advertisements.  Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt-out of interest-based advertisements across all your browsers and devices, you will need to opt-out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt-out again.

If you want to “opt out” of receiving online interest-based advertisements on your mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.

Please note that when you “opt-out” of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on the Site.  It means that the online ads that you do see from DAA program participants should not be based on your particular interests.  We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use tracking technologies to collect information about your use of the Site, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

 

3. SHARING OF YOUR INFORMATION

 

We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Control Over Your Information” section below.

We may share your personal information with:

  • Other companies owned by or under common ownership as Neuspera. These companies will use your personal information in the same way as we can under this Privacy Policy;
  • Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, providing mailing services, providing tax and accounting services, web hosting, or providing analytic services;
  • Other parties in connection with a Neuspera transaction, such as a merger, sale of Neuspera assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another Neuspera or third party, or in the event of a bankruptcy or related or similar proceedings; and
  • Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce this Privacy Policy or to protect the security or integrity of our Site; and/or (c) to exercise or protect the rights, property, or personal safety of Neuspera, our visitors, or others.

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

 

4. LEGAL BASIS FOR PROCESSING IN THE EU

 

In the EU, the purposes for which we process your personal data are:

  1. the provision of personal data by you may be necessary for the performance of any contractual relationship we have with you;
  2. where it is necessary for compliance with our legal obligations laid down by EU law;
  3. where in our legitimate interests (provided these are not overridden by your interests and fundamental rights and freedoms – this includes our own legitimate interests and those of other entities and branches in our group of companies) such as:
    a) to contact you and respond to your requests and enquiries;
    b) for business administration, including statistical analysis;
    c) to provide the Site to you; and
    d) for fraud prevention and detection; and
    e) to comply with applicable laws, regulations or codes of practices.

We may also process your personal data on the basis of your freely given, specific, informed and unambiguous consent. You should be aware that you are entitled under GDPR to withdraw your consent where that has been given, at any time. If you do this and we have no alternative lawful reason to process your personal data, this may affect our ability to provide you with rights to use the Services.

 

5. CONTROL OVER YOUR INFORMATION

 

If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your information from our Site, you can contact us directly using the details set out at the end of this Privacy Policy. We may not be able to modify or delete your information in all circumstances.

 

6. HOW WE STORE AND PROTECT YOUR INFORMATION

 

Data storage and transfer: Your information collected through our Site may be stored and processed in the United States or any other country in which Neuspera or its affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and we will take all steps reasonably necessary to ensure that any personal data are treated securely and in accordance with this Privacy Policy. Such transfers are made pursuant to appropriate safeguards. If you wish to enquire further about these transfers, please contact us using the details set out at the end of this Privacy Policy.

Data retention: We will retain your personal information only for as long as reasonably necessary to maintain the Site, to meet legal and accounting obligations, and for the purposes described in this Privacy Policy. We may anonymize and/or aggregate personal information and store it in order to analyze aggregate metrics and trends.

Keeping your information safe: We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Site. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

For individuals based in the EU or Switzerland, we store personal data for as long as necessary to fulfill the purposes for which we collect the data, except if required otherwise by law.

 

7. CHILDREN’S PRIVACY

 

Our Site is not directed to children under the age of 13, and we do not intentionally or knowingly collect or solicit personal information in connection with the Site from children under the age of 13. If you are under the age of 13, do not use this website or provide us with any Personal Information in connection with this website either directly or by other means. If a child under 13 has provided Personal Information to us in connection with this website, we encourage the child’s parent or guardian to contact us to request that we remove the Personal Information from our systems. If we learn that any Personal Information we collect in connection with this website has been provided by a child under the age of 13, we will promptly delete that Personal Information

 

8. LINKS TO OTHER WEB SERVICES AND SERVICES

 

The Site may contain links to and from third-party web services of our business partners and our users may post links to third-party webservices. If you follow a link to any of these web services, please note that these web services have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the webservices of third-party services.

 

9. FOR RESIDENTS IN THE EU AND SWITZERLAND

 

If you are located in the EU or Switzerland, you have the following rights in respect of your personal data that we hold:

a. Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. You can object to marketing activities for any reason whatsoever.

b. Right of access. The right to obtain access to your personal data.

c. Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.

d. Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.

e. Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.

f. Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 

10. FOR RESIDENTS OF CALIFORNIA

 

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to the address listed below.

 

11. HOW TO CONTACT US

 

If you have any questions about this Privacy Policy or the Site, please contact us at info@neuspera.com.

Alternatively, inquiries may be directed to:

Neuspera
51 Daggett Drive
San Jose, CA 95134
888-846-8332

 

12. CHANGES TO OUR PRIVACY POLICY

 

We will update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the “Last Modified” date at the end of this Privacy Policy. If we make material changes to this Privacy Notice, we will notify you by email to the email address we have on file for you, by prominent posting on our Site, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

 

Last Modified: October, 2019