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Privacy Policy

Introduction

obp Surgical Corporation and its Affiliates (“obp” “we,” “our” or “us”) take your (“you,” “your,” or “your company”) privacy seriously, especially when it comes to data you provide us. This Privacy Policy outlines our information-sharing practices to help you understand how we protect your privacy when we collect and use information about you, and the measures we take to protect the confidentiality of that information. This Privacy Policy also explains obp’s policy for personally identifiable information and other information we collect from both users and visitors to this website (obpsurgical.com) and other websites or mobile applications owned or operated by us (collectively, the “Websites”), through the use of social media pages that we control, if any (“Social Media Pages”), through email messages and other electronic communications that we send to you (“Email”), and through the provision of our products through the Websites (collectively, including the Websites, Social Media Pages, and Email, the “Services”).

This Privacy Policy only applies to information collected through the Services. It governs how we receive and handle information. This Privacy Policy does not apply to:

  • Data collection that happens offline or outside of the Services.
  • The data practices of third parties who may interact with our Services.
  • Any unauthorized or unofficial integrations that our customers may create.

Please note that this Privacy Policy may be supplemented by other privacy notices tailored to our specific relationship with you, including privacy notices that are sent as required under applicable laws and regulations.

We have done our best to write this in clear language. If any part of this Privacy Policy is unclear, we are happy to guide you; please contact info@obpsurgical.com.

You should also review our Terms of Use, found here.

Other websites and services of our affiliates and subsidiaries may contain different privacy policies, and you should review the privacy policy available on each applicable website.

By using the Services, you consent to our Privacy Policy and Terms of Use. You also consent to our collection, use, and sharing of your information, data, and other activities, as described below.

What information do we collect?

Information you give us

As you use the Services, we may ask you or your company for personally identifiable information and other sensitive information, which can include but is not limited to any individual’s or your company’s name, mailing address, telephone number, email address, credit card number, other payment information, driver’s license number, bank account and routing number, social security number, tax identification number, credit score, credit history, payment information, current or previous policy or claim information, and other information enabling us to provide products and services (“Personal Information”). We may collect Personal Information through forms and other interactions on the Services. This includes places like contact forms, order forms, and other forms available through the Services.

You do not have to provide us with any Personal Information to visit the Websites. We may request Personal Information from you on our Websites in order to deliver requested materials and products to you and deliver other information about obp and its products.

If you submit any Personal Information relating to other people to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Information collected as you use the Services

We automatically collect and store information when you interact with the Services (“Usage Information”). By default, we limit Usage Information access to obp and its third-party service providers (e.g., hosting). Usage Information includes things like:

  • Ways to identify your device, such as your IP address, UUID, or other unique identifier.
  • Your device functionality (e.g., browser, operating system, hardware, and mobile network).
  • How you found the Services (e.g., referring website).
  • Your activity in the Services, including what pages you visit and the time you spend with us.
  • Your device’s location.
  • General information about your device (e.g., characteristics, date, time of day, etc.).

We use Usage Information to help us learn what parts of our Websites are most popular and among which audiences. We may also use them to help us optimize our user interface, analyze site usage statistically, improve content, and customize our Websites’ content and layout. We analyze Usage Information to track trends and behaviors. We are interested in our audience size, return visit and product order rate, and similar data on an aggregate basis. In short, we use Usage Information to allow us to tailor the Websites and to meet your needs better.

Tracking Technology

We or our vendors may use a few methods to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set and change settings on your device.

One of the ways we do this is through “cookies.” A cookie is a small file our Service gives your device when it is accessed. We use cookies to enable functionality, improve our Services usage analytics, and market the Services. Another example is as a security measure to prevent fraudulent activity with your accounts. You can disable cookies on your device, but parts of the Services may not be functional without them.

We and our vendors may also use tools like web beacons (“clear gifs”), scripts, and images to help manage site content and usage.

These technologies help us understand the performance and usefulness of content in the Services. We use these insights to improve the content, products or services offered through the Services.

Tracking Technologies used by our service providers are not covered by this policy. We don’t have control over them but do screen them to make sure they have acceptable policies before integrating.

Tracking Consent

We get your consent to our storage and collection Tracking Technologies in several ways:

  • Giving you transparent information in this Privacy Policy.
  • Giving you the opportunity to choose to disable cookies.

We are not required to get consent for Tracking Technology that is strictly necessary to the Services. For example, using cookies as a way to improve security through fraud prevention.

Third-Party Tracking

obp may use other Tracking Technologies (some which may not exist yet) in connection with the Services in the future.

Third parties (including vendors) may also use Tracking Technologies in connection with our Services. They may collect information about your online activities across third-party websites or services. We may not control those Tracking Technologies and we are not responsible for them. You consent to encountering third-party Tracking Technologies as you use our Services. You also accept that our Privacy Policy does not apply to Tracking Technologies or practices of third parties.

“Do Not Track”

Some third parties have ways (e.g. browser do-not-track signals) for users to control how online services collect their information. We don’t currently take any action or respond based on these signals, however, this may change in the future.

Information Third Parties Provide About You

We may combine information collected directly from you on our Services with third-party records. This information allows us to give you a better experience. Unless disclosed otherwise, combined information becomes Personal Information and this Privacy Policy will apply.

Aside from the above, this Privacy Policy does not apply to information we receive about you from third parties. This includes if they have used our technology to collect and share information with us.

Interactions with Third-Party Services

Parts of the Services may include certain interactions with third-party websites or applications. This functionality may involve the third-party operator giving us certain information, including Personal Information. If we offer and you choose to use this functionality in our Services, the third party may send your Personal Information to us. We will treat it as Personal Information under this Privacy Policy because we collect it as a result of you using our Services.

We may also provide third-party sites’ interfaces or links in the Services to help you send communications. For example a social media share button via the Services. These third parties may keep the information used or provided in communications and other activities. These third parties’ practices are not subject to our Privacy Policy. obp may not control or have access to your communications through these third parties.

When you use third-party services, they are responsible for their practices. We can only vouch for our services and policies, and cannot be responsible for their practices. Be sure to review third-party policies before using their tools on our Services.

How We Handle Payments

We use vetted third-party vendors for credit card transactions and billing. All credit card transactions are handled separately through their servers. They do not share complete financial account information with obp. You can find our current vendor’s privacy policy here.

How We Use Information We Collect

We may use Personal or Usage Information that we collect about you:

  • To make decisions about products and services which we offer, and to respond to your inquiries, fulfill your requests and complete your transactions.
  • To communicate with you as part of our business.
  • To give you information, services, or process transactions you request or agree to receive. This includes sending email or promotional materials on behalf of us or approved third parties.
  • To enable you to use the Services’ features.
  • To process any forms in connection with the Services, including verifying that your information is active and valid.
  • To create new service offerings, and to customize your experience and content on the Services.
  • To contact you about our products and your use of the Services. This includes (at our discretion) changes to any of the Services and/or any of the Services’ policies.
  • To send marketing emails about third party products and services when you have indicated your consent to receive such emails.
  • To help us prevent fraud and other crimes and comply with applicable laws.
  • To perform research and analysis.
  • For internal business purposes.
  • For purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.
  • As otherwise allowed by law.

Inquiries

When you contact us, we will use that information only for reasons connected with your request. Not all information submitted on the Services via a “contact us” form or other similar inquiry method may receive a response.

When We Share Information with Third Parties

There are certain situations where we may share information we have collected about you with third parties. For example, when you provide your payment information. This includes Personal Information as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. We do not share Personal Information collected through the Services with third parties for their direct marketing purposes.  We also may share non-Personal Information, such as aggregated user statistics, with third parties.

We may also disclose your information as follows:

  • Requested Third Parties: We may send (or give access to) certain information to third parties, including but not limited to distributors, sales agents, administrators, and other intermediaries and business partners. Our Services may also present options to receive certain information or marketing from third parties. Your Personal Information and other information may be disclosed to those third parties. All information you disclose will be subject to the third party privacy policies and practices.
  • Service Providers: We may use third-party vendors to perform certain services on behalf of us or the Services. A few examples include hosting the Services, payment processing, analytics, and other administrative services. It may also be reasonably necessary to provide certain information to third parties to enable them to perform services for us, such as the detection of fraud or material representations. We may provide these vendors with access to information, including Personal Information and device information, to carry out the services they are performing for you or for us. Third party analytic service providers, such as Google Analytics and other service providers, may set and access their own Tracking Technologies on your device and they may otherwise collect or have access to information about you, potentially including Personal Information. We are not responsible for those third party technologies or activities arising out of them, nor are we responsible for the effectiveness of or compliance with any third parties’ opt-out options.
  • Legal Requirements: To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of obp or third parties (including through the enforcement of this Privacy Policy, our Terms of Use, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, without notice to you.
  • Business Transfers: We may share your Personal Information with our subsidiaries, if any, and our affiliated entities (“Affiliates”). We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during the course of any due diligence process.

Third Party Content and Services

The Services may contain content that is supplied by a third party, and those third parties may collect Usage Information and device information when pages from the Services are served to you. In addition, when you are on the Services you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the content or accuracy of information provided by third parties. We are also not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you click on a link, the click may take you off the Services onto a different site; these other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave our Services and review the third party privacy policies of all third party websites and exercise caution in connection with them.

Changing Information and Communication Preferences

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. The Services may allow you to review, correct or update Personal Information you have provided through the Services, and you may provide updates and changes by contacting us at info@obpsurgical.com. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).

Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information, information that you remove may persist internally for obp’s administrative purposes. You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails or in some cases by changing your communication preferences. Please note that we reserve the right to send you certain communications relating to your account or use of our Services, such as administrative announcements, and these transactional messages may be unaffected if you choose to opt-out from receiving our marketing communications.

International Users

Our Services are operated in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States.

If you request a sample product or place an order for products through the Services for delivery outside of the United States, we will forward your request or order to our international distributor for your applicable area or jurisdiction. By submitting any such request or order, you consent to our sharing the details of your request or order with the applicable distributor.

By using the Services or providing us with any information, you consent to the transfer to, and processing, usage, sharing, controlling and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

Children and COPPA

We are a general audience service and do not use the Services to knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent. In fact, if you are under eighteen (18) years of age, you are not permitted to use the Services and should not send any information about yourself to use through the Services.

In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with personal information without COPPA-required consent, please contact us by email at info@obpsurgical.com.

Security

We make every effort to use commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can guarantee to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Services and provide us with your information at your own risk.

Certain features may be encrypted to encode information that you share. By contrast, be aware that email messages sent in clear text over the Internet can be observed by an unintended third party. Non-encrypted Internet email communications may be accessed and viewed by other Internet users without your knowledge and permission while in transit to us. If you wish to keep your information private, please do not use email to communicate information to us or request information from us that you consider to be confidential and/or proprietary. If you wish, you may contact us instead via telephone at 1-978-291-6853 or at info@obpsurgical.com.

Social Security Protection Policy Statement

obp seeks to protect the confidentiality of social security numbers (“SSNs”) by maintaining physical, electronic, and procedural safeguards. We limit access to SSNs to help protect against their loss, misuse or unlawful disclosure. We do not disclose SSNs to third parties except where required or permitted by law.

Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for their direct marketing purposes. To request a list of the names and addresses of third parties to whom we disclosed such information during the preceding calendar year along with a list of the categories of information disclosed, please send an email to: info@obpsurgical.com or write to us at the following address:

obp Surgical Corporation

360 Merrimack Street

Lawrence, Massachusetts 01843

Attention: Matthew Traub

Contacting obp

If you have any questions about this Privacy Policy or the practices described in it, you should contact us at info@obpsurgical.com or at our mailing address:

obp Surgical Corporation

360 Merrimack Street

Lawrence, Massachusetts 01843

Attention: Matthew Traub

Changes to Our Privacy Policy

We reserve the right to change this privacy policy at any time, and we encourage you to review this Privacy Policy periodically for any updates or changes. Any changes will be effective immediately upon the posting of the revised privacy policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent.

Last Updated: October 26, 2021