This Privacy Policy describes how your personal information is collected, used, and shared by Atraverse Medical, Inc. (“Atraverse”) when you visit or make a purchase from atraversemedical.com (the “Site”).

Information We Collect

Types of information Atraverse may collect include the following categories:

• Identity data: first and last names, date of birth, gender, etc.
• Contact details: email address, phone number, postal address, etc.
• Professional data: profession, title, position in the company, interests, location, information about your company (company name, company size, business type, etc.), professional ID number or registration, medical specialty, professional affiliations, publications, etc.
• Information about your preferences: testimonials, site survey responses, responses to market studies in which you have participated etc.
• Financial information: payment-related information for payments we may need to perform (account details, bank information, tax-related information, amount to be paid, etc.)
• Information from your use of our Sites: IP address, the device(s) you are using, your usage of our Sites, etc.

How is information collected?

Atraverse collects information about you and your device when you use the Site. You provide some of this data directly to Atraverse, while we also collect data about your interactions, use, and experiences with the Site.

We may obtain personal information about you such as device and online identifiers and internet or other network activity information via automated means through your use of technology, such as when you visit our websites or use our mobile applications or services, or click on advertisements or links in emails you receive from us.

Also, depending on your device’s settings, we may collect precise geolocation information. You can control our ability to do this by adjusting the location-sharing settings on your mobile device at any time. You also may adjust your mobile device’s Bluetooth settings to disable the sharing of Bluetooth location-related data.

Our sites and mobile application(s) include social media features, such as the Facebook, Instagram, and YouTube widgets. These features may collect information about you such as your IP address and which page you are visiting on our site. They may set a cookie or employ other tracking technologies to accomplish this. Social media features and widgets may be hosted by a third-party. Your interactions with those features are governed by the privacy policies of the companies that provide them.

How do we use personal information?

Atraverse uses the data we collect to provide you with products, improve our business and products, and advertise and market to you.

We also use information we collect for reporting and analysis purposes. We examine metrics such as how you are shopping on our website, the performance of our marketing efforts, and your response to those marketing efforts.

For example, we may use personal information in the following ways:

• Deliver targeted advertising, emails, mobile phone SMS messages, and social media notifications.
• Administer promotions, surveys, and focus groups.
• Improve your experiences on the Site.
• Conduct research and business analytics.
• Respond to requests for information about our products and services on the Site.
• Help to ensure security and integrity and prevent fraud.
• Undertake activities to verify or maintain the quality or safety of the Site and our services.
• Fulfill our legal functions and obligations.

How is information shared?

We may share the types and categories of personal information collected with the categories of third parties below.

Vendors for Business Operations: We disclose personal information about you to vendors to perform services on our behalf. These vendors include without limitation, shipping vendors, billing and refund vendors, payment card processors, and companies that help us improve our products and services. These companies may need information about you in order to perform their functions. We limit information shared with service providers to what is necessary to fulfill the services.

Advertising, Marketing, and Other Related Technology Partners: We work with various advertising, marketing, data processing, and other related technology partners so we can both market our products to you and provide advertising services to other companies.

Legal Requirements: We may disclose information we collect when we believe disclosure is appropriate to comply with the law; to enforce or apply applicable terms and conditions and other agreements; to facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or disposal of all or part of our business or assets; or to protect the rights, property, or safety of our company or others.

Elsewhere at Your Direction: At your direction or request, or when you otherwise consent, we may share your information.

Sharing Non-identifiable or Aggregate Information with Third Parties: We may share non-identifiable or aggregate information with third parties for lawful purposes.

Business Transfers: If we plan to merge, sell, or reorganize our business, we may disclose your personal information, along with personal information of other customers as part of the business arrangement. (This may also include transfers of personal information made as a part of insolvency or bankruptcy proceedings). We will use reasonable measures to help ensure your information is handled in accordance with this Privacy Policy.

How Long Do We Retain Your Personal Information?

We will keep the personal information we collect about you for as long as necessary to carry out the purposes set forth in this Privacy Policy or any other notice provided at the time of data collection, but no longer than as required or permitted under applicable law or internal Atraverse policy. We dispose of the personal information we collect in accordance with Atraverse’s retention policies and procedures.

How is Your Personal Information Protected?

We maintain reasonable administrative, technical, and physical safeguards to protect your personal information. However, no e-commerce solution, website, mobile application, database, or system is completely secure or “hacker proof.” You are also responsible for taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.

California Consumer Privacy Act Notice

California consumers have a right to knowledge, access, correction, and deletion of their personal information under the California Consumer Privacy Act of 2018 (“CCPA”). California consumers also have a right to opt out of the sale or sharing of their personal information by a business, and a right not to be discriminated against for exercising their California privacy rights. Atraverse does not sell or share the personal information of California consumers as those terms are defined under California law, and does not discriminate in response to privacy rights requests. Atraverse also does not use or disclose sensitive personal information for any purposes that would require a user to exercise a right to limit according to California law.

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our clients or their agents. For example, from information our clients provide to us related to the services for which they engage us.
• Directly from you. For example, through information we ask from you when our clients or their agents subscribe and engage our services.
• Directly and indirectly from you when using our services or visiting our website. For example, usage details collected automatically in the course of your interaction with our platform or website.

Sensitive personal information is a subtype of personal information consisting of specific information categories. While we collect information that falls within the sensitive personal information categories listed in the table below, the CCPA does not treat this information as sensitive because we do not collect or use it to infer characteristics about a person.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category F: Internet or similar network activity.

We disclose your personal information for a business purpose to the following categories of third parties:

• Our agents and service providers
• Our affiliates
• Third parties to whom you or your agents authorized us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you;
• Our business or commercial purpose for collecting that personal information;
• The categories of third parties with whom we share that personal information; and
• The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights

You have the right to request that we delete any of your personal information we collected from you and retained, 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.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you request, take actions reasonably anticipated within the context of our ongoing business relationships with you, or otherwise perform our contract with you.
   
   
2. Detect security incidents, protect against malicious deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
   
   
3. Debug products to identify and repair errors that impair existing intended functionality.
   
   
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
   
   
5. Comply with the California Electonric Communications Privacy Act (Cal. Penal Code § 1546 seq.).
   
   
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
   
   
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
   
   
8. Comply with a legal obligation.
   
   
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at [email protected].

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require to you create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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 good 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 Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, you may contact us via email at [email protected].