Personal Data is typically data that directly or indirectly identifies an individual or relates to an identifiable individual. The definition of personal data (used interchangeably with “personal information”) depends on the applicable law based on your physical location. Only the definition that aapplies to your physical location will apply to you under this Privacy Policy.

This Privacy Policy applies to all Personal Data that we collect when you: interact with our website located at https://senomedical.com/ and any other websites, pages, features, or content we own or operate (collectively, the “Site(s)”); attend one of our events or interact with us at an event; or interact with other products or services that direct you to this Privacy Policy (collectively, the “Service(s)”). This Privacy Policy does not apply to: information covered by the Health Information Portability and Accountability Act collected and stored in our provision of Services to healthcare providers and billing companies; or any personal information we process about California employees or job applicants.

This Privacy Policy should be read carefully. By continuing to use our Sites and Services, you knowledge that your Personal Data will be used in accordance with this Privacy Policy. We may make changes to this Privacy Policy from time to time. We will notify you of any material changes and will update the Last Updated date at the end of this Privacy Policy. We encourage you to look for updates and changes to this Privacy Policy when you access our Sites and Services.

1. Collection and Use of Personal Data

Seno collects certain Personal Data about you and your use of our Sites and Services. The Personal Data that we collect depends on your interactions with us, and the choices you make.

Information You Voluntarily Provide to Us. We collect Personal Data from you when you voluntarily choose to provide us with such information when you fill out our contact form, sign up for the Seno University platform, subscribe to Seno Spotlight, access certain Site collateral, register for events, or otherwise communicate with us via email or by any other means. The Personal Data that we may collect contains information such as your name, email address, employment information, and any other information that is submitted to us by you.

Information We Automatically Collect. To the extent permitted under applicable law, we may collect certain types of information automatically, such as when you interact with our Sites or use our Services. For instance, when you browse our Sites, we may automatically collect usage and log data such as your web request, Internet Protocol (“IP”) address, pages viewed, search preferences and queries, and other diagnostic data. When you use our Services, we may infer the approximate physical location and geographic regions of your device from your IP address.

How We Use Your Information. We use your Personal Data to provide with you the Services you request and to respond to your inquiries or other communications. If you contact Seno, we keep a record of your communication to help solve any issues you might be facing or questions that you may have. We may also use your Personal Data for the following business and commercial purposes:

1. To Maintain Legal and Regulatory Compliance. Our Services are subject to certain laws and regulations which may require us to process Personal Data. For example, we process your personal information to fulfill our business obligations, to manage risk as required or permitted under applicable laws and regulations, or to respond to requests by judicial process or governmental agency.
2. To Enforce Compliance with Our Agreements and Policies. We may process your personal information for compliance purposes, such as carrying out our obligations and enforcing our agreements and policies, including our Terms of Use, or other legal rights.
3. To Detect and Prevent Fraud and Security Risks. We may process your personal information to help monitor, prevent and detect fraud and abusive use of our Services, monitor unauthorized access, enhance system security, and combat spam, malware, malicious activities or other security risks.
4. To Provide Marketing or Promotional Communication. We may collect your email address or other contact information that you voluntarily provide to us, such as when you subscribe to our marketing communications, and we will use such information to send you information about Seno Services, such as letting you know about upcoming changes or improvements to our products and services.
5. To Research and Develop of Our Services. We may process Personal Data and derive analytical and statistical data to better understand the way you use and interact with our Services. For instance, analyzing aggregate Site usage data may help us improve our existing Services and to build new Services. Please see the “Cookies and Other Tracking Technologies” Section for more information.
6. To Facilitate Corporate Acquisitions, Mergers and Transactions. We may process any information regarding your account and your use of our Services as is necessary in the context of corporate acquisitions, mergers or other corporate transactions.
7. With Your Consent. For any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the services or other related services requested, with your permission or upon your direction.

2. Disclosure of Personal Data

As a general matter, we do not sell, trade, or otherwise disclose to third parties your Personal Data. Seno does not endorse nor participate in any unsolicited commercial e-mail (a.k.a. SPAM) activities. In limited circumstances, as described below, we may share Personal Data within our organization and with third parties, and as required by laws, rules and our policies:

1. Within Our Corporate Organization. We may share your personal information within our organization, such as with our Board of Directors, advisory board, corporate affiliates, or other companies under common control with us, to provide you with the Services and to take actions based on your request. We may permit these organizational entities to use your information for their own marketing or promotional purposes.
2. With Trusted Third Parties. We may share your personal information with medical providers, such as your treating radiologist, and service providers acting on our behalf to help us operate our Services (collectively, “Trusted Third Parties”). For instance, we may provide diagnostic testing results and images with your radiologist for further consultation and treatment. We may also report on adverse health events and provide relevant feedback to medical boards and peer review committees. Trusted Third Parties also provide us with support services such as website hosting, data analytics, marketing, and network maintenance. These Trusted Third Parties may have access to or process your personal information for the purpose of providing services for us.
3. During Business Transaction or Other Asset Transfers. In the event of an acquisition, merger, sale, liquidation, or transfer of all or a portion of Seno’s business or assets, we may disclose and transfer Personal Data to buyers, service providers, advisors, potential transactional partners or other third parties in connection with the corporate transaction. By engaging with us or using our Services, you understand and agree to our assignment or transfer of rights to your personal information.
4. For Legal Compliance & Safety. We may access, preserve, and disclose information about you if we such release is necessary to comply with applicable laws, enforce our policies, or protect Seno’s legal rights, property, or safety, or those of third parties.
5. With Your Consent. We may share your personal information with other third parties if you give us permission or direct us to share your information.

3. Cookies and Other Tracking Technologies

We and our third-party partners and service providers (such as advertisers and analytics providers) may use cookies and similar digital tracking technologies (such as pixels, web beacons, and tags) (collectively “cookies”) on our Sites and other online services to gather information when you interact with our Sites and Services.

Why We Use Cookies. We use cookies to enable basic functioning of our Sites, web analytics to improve our Sites, or to fix any technical issue through gathering relevant technical data. We may also use cookies to identify whether you already visited our Sites, store information about your preferences, and serve targeted information to you based on your recorded preferences.

Managing Cookies. You may customize your cookie settings by selecting your preferences on our cookie banner or changing your browser settings accordingly. Your browser’s ‘help’ function will tell you how to do this. If you do not want the benefit of cookies, there is a simple procedure to manually delete your cookies at https://www.allaboutcookies.org/manage-cookies/stop-cookies-installed.html, but please visit the links below to opt-out of marketing cookies from over 50+ major third-party behavioral advertising providers:

• Network Advertising Initiative: www.NetworkAdvertising.org/choices/
• Digital Advertising Alliance: www.aboutads.info/choices/

Please remember that cookies are often used to enable and improve certain functions on our Sites. If you choose to switch certain cookies off, it may affect the user experience.

Analytics. We may use third-party service providers to monitor and analyze the use of our Sites, such as Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports website traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.

Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.

4. Third Party Links

This Privacy Policy does not cover the privacy practices of third parties. Our Sites may include links to websites and/or applications operated and maintained by third parties. We have no control over the privacy practices of websites or applications that we do not own and cannot guarantee that such third parties will adhere to the same privacy practices as us. We encourage you to review the privacy policies of those third parties.

5. Retention of Personal Data

We will retain your information for as long as your account is active (for applicable users), as needed to provide you Services or for other purposes stated in this Policy. Seno does not otherwise store Personal Data longer than necessary for the purposes for which the information was collected and is no longer necessary for legal or business purposes. At any time, you have the right to access and request modifications to how we use/collect your Personal Data (see Opting Out and Rights of Users) unless we are required to retain this Personal Data by law, to comply with our regulatory obligations, resolve disputes, or enforce our agreements.

6. Security

We use a variety of security measures to maintain the safety of your Personal Data. We take great care to ensure that your Personal Data is stored securely, and we follow standards generally accepted in the industry to protect Personal Data submitted to us.

It is important to note, however, that no method of transmission or storage is 100% secure, and thus we cannot guarantee the security of our databases or the databases of the third parties with which we may share such Personal Data, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet.

7. Opting Out and Rights of Users

You may revoke any consent given to us with regard to the collection, processing and use of your Personal Data at any time for the future and also generally request Seno to stop using and collecting your Personal Data. A withdrawal should be sent to Seno at the contact information set out at the end of this Privacy Policy.

Opt-out from mailings: From time to time, you may receive periodic emails or other messages if you have subscribed to Seno’s marketing or promotional communications. If at any time you wish to stop receiving these communications, please unsubscribe from the mailing list. You may also send us an email at digitalmarketing@senomedical.com with the phrase “Privacy Opt-out: Seno Mailings” in the subject line, or write to us at the address provided below, and we will be glad to remove you from Seno’s mailing list. Please note that this opt-out does not apply to communications that are pertinent to products and services that you have requested or participate in or where we are required to provide you with notifications (such as a notice of material updates to our Privacy Policy).

Your Data Choices: You may assert certain rights with respect to your Personal Data in accordance with applicable law. For instance, you may have the right to know whether their Personal Data has been stored and may consult Seno to learn about their contents and origin, to verify their accuracy, or to ask for your information to be supplemented, deleted, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Under certain circumstances, you may have the right to receive personal information we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal information to another entity and across different services. Requests should be sent to Seno at the contact information set out at the end of this Privacy Policy.

Under applicable law, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act, certain users also have the right to opt out of the sale and sharing of your information for targeted advertising. While we do not sell your personal information for money, like many websites, we use cookies, pixels, and similar technology, and we share certain information, such as your IP address or device identifiers, to certain third-party advertisers in order to improve your user experience and to optimize our marketing activities. Under California privacy law’s broad definition of “sell”, this could be considered a sale, and it would be considered sharing of your personal information for targeted, behavioral advertising purposes. You have the right to direct us not to sell your personal information, and to direct us not to share or use your personal information for targeted advertising purposes. To exercise your right to opt-out, please submit a request at the contact information set out at the end of this Privacy Policy. Please note that you may still receive generalized ads after opting out of targeted advertising.

You may also have the right to ask us for a notice describing what categories of Personal Data we share with third parties or corporate affiliates for those third parties’ or corporate affiliates’ direct marketing purposes. That notice will identify the categories of personal information shared with third parties and used for direct marketing purposes and the name and address of the third parties that received such personal information.

Seno will take reasonable steps to verify the authenticity of such an abovementioned request prior to disclosing your Personal Data and disclose the minimum amount necessary to comply with the request. Seno will respond to your request in a reasonable timeframe in accordance with applicable law. Under applicable law, we may deny your request: (a) when denial of the request is required or authorized by law; (b) when granting the request would have a negative impact on another’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or vexatious, or for other reasons.

8. Additional Disclosure to California Residents

In the preceding 12 months, depending how you interact with our Services, we may have collected the following categories of Personal Data:

• Identifiers, such as your name, unique personal identifier, email, phone number, or similar identifiers.
• Internet or other electronic network activity information, such as technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and information about your visit.
• Geolocation information, to the extent such information can be inferred from your IP address.
• Employment information, specifically your current employer and job title, to the extent you provide them as part of a contact form.

9. Legal Basis for the Processing of Personal Data from EEA Residents

We only collect and process personal information where we have one or more lawful grounds to do so. If you reside within the European Economic Area (EEA), our processing of your Personal Data will be based on one or more of the following lawful bases:

1. Whenever we require your consent for the processing of your Personal Data such processing will be justified pursuant to Article 6(1) lit. (a) of the GDPR. This article in the GDPR describes when processing can be done lawfully.
2. If the processing of your Personal Data is necessary for the performance of a contract between you and us or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b). If this Personal Data is not processed, we will not be able to execute the contract with you (e.g., your purchase of our products and services).
3. Where the processing is necessary for us to comply with a legal obligation, we will process your information on basis of GDPR Article 6(1) lit. (c), for example complying with product safety.
4. And where the processing is necessary for the purposes of our legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f), for example to develop, administer and support our products and services; to operate, evaluate and improve our business; to support our recruitment activities; to benefit the public interest; detect fraud and illegal activity; or defend against claims and other liabilities.

Filing Complaints. If you reside in the EEA, you have the right to file a complaint with the supervisory authority of your customer state. Please refer to list of National Data Protection Authorities for further information: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080. If you reside in the United Kingdom, you may file a complaint with the Information Commissioner’s Office: https://www.gov.uk/data-protection/make-a-complaint.

10. International Data transfers

Your Personal Data may be transferred to and stored in servers located in the United States. When we share your Personal Data with our service providers, your Personal Data may be transferred to and/or made accessible from countries out of the European Economic Area (EEA). In such circumstances, we will enter into model contractual clauses as adopted by the European Commission. These model contractual clauses were adopted the European Commission to transfer Personal Data to non-EEA countries that do not provide an adequate level of data protection according to the European Commission. These model contractual clauses offer adequate safeguards for such a transfer. Otherwise, we rely on alternative legal bases such as the Privacy Shield. This EU-US Privacy Shield is a framework for transfers of Personal Data for commercial purposes between the EEA and the United States to provide companies with a mechanism to comply with data protection requirements. Where applicable, we rely on binding corporate rules where our service providers have adopted such internal policies approved by European data protection authorities. These binding corporate rules are a code for the transfer of data within our organizations and companies and provides for safeguards of your Personal Data.

11. Contact Information

Seno is responsible for this Privacy Policy. If you have questions about our policy or wish to submit a request regarding your Personal Data, please contact: Marketing at 210-615-6501 or via email at info(at)senomedical.com.

Last Updated on [August 9, 2024]