Privacy Policy

This privacy policy (the “Privacy Policy”) is designed to inform you about the use of Personal Data that you provide to Seno Medical Instruments, Inc. (“Seno,” “we,” or “us”). Your privacy is very important to us.

This Privacy Policy covers the treatment of personally directly or indirectly identifiable information (“Personal Data”) gathered when you are using our services and products. This Privacy Policy is meant to help you understand what Personal Data we collect, why we collect it and what we do with it. This Privacy Policy should be read carefully. It may be printed or downloaded at any time. The Privacy Policy will be stored at:senomedical.com/privacypolicy

Our Privacy Policy explains:

What information we collect and why we collect it.
How your information is used.
How you can access and update your information.

We have tried to keep the wording of our Privacy Policy as clear as possible.

Collection and use of Personal Data

We collect Personal Data from you when you voluntarily choose to provide us with such information, most importantly when you 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 and any other information that is submitted to us by you. We collect this Personal Data to provide you with our products and services and to answer any questions you may about our products and services.

We also collect Personal Data from when you visit our website. This Personal Data contains information such as your IP address, search preferences and queries through our cookies. We use your Personal Data to provide, maintain, protect and improve our services and to protect our website and our customers. We maintain such Personal Data for internal purposes only, as well as to ensure that you receive any information that you may request from Seno, and to provide you with information on our products and services.

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. Seno does not sell, rent, share or otherwise disclose Personal Data unless mentioned in this Privacy Policy. Seno does not endorse nor participate in any unsolicited commercial e-mail (a.k.a. SPAM) activities. We may use your email address to inform you about our services, such as letting you know about upcoming changes or improvements to our products and services after you subscribe to this.

We will ask for your explicit and informed consent before using information for a purpose other than those set out in this Privacy Policy.

Storage

Seno does not store the Personal Data longer than necessary for the purposes for which the Personal Data was collected. At any time you have the right to change how we use/collect your Personal Data (see how to opt-out) unless we are required to retain this Personal Data by law or to comply with our regulatory obligations.

Legal Basis for the Processing of Personal Data from EEA Residents

If you reside within the European Economic Area (EEA), our processing of your Personal Data will be legitimized as follows:

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.
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).
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.
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 detect fraud.

Disclosure of Personal Data

As a general matter, we do not sell, trade, or otherwise disclose to third parties your Personal Data. We will only share your Personal Data with companies, organizations or individuals outside of Seno with your explicit and informed consent to do so.

This does not apply to trusted third parties so designated by Seno, who assist us in operating the website, conducting our business, or servicing you (“Trusted Third Parties”). We may transmit your Personal Data to Trusted Third Parties. We will only transmit your Personal Data to Trusted Third Parties following their agreement and commitment to keep all Personal Data confidential. This Personal Data is given to Trusted Third Parties based on our instructions and in compliance with our Privacy Policy and any other confidentiality and security measures.

We may also release your Personal Data when we believe 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.

Transfer of Personal Data outside the EU

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.

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 absolutely guarantee the security of your Personal Data.

Opting-out and the 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 below.

Opt-out from mailings only: From time to time, you may receive periodic e-mail messages if you have subscribed to this. If at any time you wish to stop receiving emails from Seno please unsubscribe from the mailing list. You may also send us an email at lbichsel(at)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 mails 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 update to our Privacy Policy).

Users have the right at any time, to know whether their Personal Data has been stored and can consult Seno to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, 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. Requests should be sent to Seno at the contact information set out below.

Users have the right to request to obtain and reuse their Personal Data for their own purposes across different services. Requests should be sent to Seno at the contact information set out below.

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, and in any event in less than 30 days. Seno will be glad to honor such a request, unless we are required to retain this Personal Data by law or to comply with our regulatory obligations.

Users have the right to lodge a complaint against Seno with a supervisory authority.

More details concerning the collection or processing of Personal Data may be requested from Seno at any time. Please see the contact information at the end of this Privacy Policy.

Changes to our Privacy Policy

We may need to amend or update our Privacy Policy from time to time. Should we make any material changes to our Privacy Policy, we will notify you accordingly by posting them to the website, and to other places that we deem appropriate. We encourage you to check the website regularly and to read our Privacy Policy regularly in order to stay updated.

Should you object to any of the changes to this Privacy Policy, this would mean that you must cease using our services and can ask us to erase your Personal Data.

All prior versions of this Privacy Policy will be kept in an archive for your review upon request.

Contact information

Seno is responsible for this Privacy Policy.

Please contact: Lisa Bichsel at 210-615-6501 or via email: lbichsel(at)senomedical.com.

Updated on [Jun 6, 2018]