Effective date: December 7, 2023
Your ConsentBy using this Site, you are consenting to the collection, use, disclosure, and transfer of your information as described in this Policy (and any Privacy Notices that apply to you). If you do not consent to the collection, use, disclosure and transfer of your information as described in this Policy (and any Privacy Notices that apply to you), you may not use this Site. If you have questions about this Policy, or any Privacy Notice, please contact us using the information provided below. You may revoke your consent for the collection, use, disclosure, and transfer of your information as described in this Policy (and any Privacy Notices that apply to you) by contacting us directly.
Changes to this PolicyAttune Medical reserves the right to update or modify this Policy and any Privacy Notice, at any time and without prior notice, by posting the revised version of the Policy or Privacy Notice on this Site. These changes will only apply to the information we collect after we have posted the revised Policy or Privacy Notice on this Site. Your use of this Site following any such change constitutes your agreement that all information collected from or about you after the revised Policy is posted will be subject to the terms of the revised Policy. You may access the current version of this Policy at any time by clicking on the link marked “Privacy” at the bottom of each page of the public areas of this Site.
Information We CollectPersonal Data means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal Data You Manually Provide. Attune Medical collects the information you manually provide (using your keyboard, mouse, or touchpad) when you use this Site, for example, we collect the information you provide if you choose to complete a pre-screening questionnaire entitled, “Am I a Candidate?” or similar questionnaire, contact us with questions, or otherwise interact with this Site. Some of the information you may choose to manually provide will be Personal Data including but not limited to:
- Contact data: such as name, title, address, phone number, mailing address, and email.
- Other identifiers: such as device ID or serial number, various types of personal health information (e.g., health insurance information, medical information, and the like), online identifiers, and other similar identifiers.
- Communication data submitted by you: such as questions and feedback.
- Demographic data: such as language, age, and gender.
- Marketing preferences: such as e-mail subscription and frequency preferences.
- Product use and application data (including date and time of your visit)
- IP address
- The browser you are using (including name and version)
- Your location and other geographic data
- The website you came from and the website you visit after leaving
- Pages viewed on the Site
- Links clicked on the Sit
- Time spend on a particular page of the Site or the Site as a whole
- Site data used to facilitate the use of the Site such as login and technical data
- Collect information about the ways visitors use this Site—which pages they visit, which links they use, and how long they stay on each page
- Support the features and functionality of this Site—for example, to save you the trouble of reentering information already in our database or to prompt the settings you established on previous visits
- Personalize your experience when you use this Site; and
- Improve our marketing efforts, including through use of targeted advertising.
Our Legal Basis for Processing Personal DataWe may process the Personal Data we collect/receive under the following legal bases:
- In some cases we will only process your information where you have given your consent. For example, if you sign up for email communications, provide your phone number for phone communication, or where you may be providing special categories of personal data. Please note that we may have a different legal basis for processing (e.g., legitimate interest) so that consent is not needed. When our use and sharing is not readily apparent when you provide your information, we will provide additional information at the time we collect the information regarding our purposes and use of the information.
- Legitimate interest. We can process your personal data if (i) we have a genuine and legitimate reason; and (ii) are not harming any of your rights and interests. We will use your personal data in order to help us provide you with our services and to give you the most appropriate information, products and services and to provide you with the best experience when dealing with us. Whenever we process your personal data for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection law.
- To fulfill our obligations to you under a contract. If you purchase a product from us, we may process your personal data in order to fulfill our contract with you.
- As required by law. Where we are required to comply with our legal obligations, or to establish and defend our legal rights, or to prevent and detect crimes such as fraud.
How We Use Your InformationWe may use the information we collect through this Site for various purposes, including the but not limited to:
- To provide you with access to this Site.
- To respond to your requests.
- To personalize your access to our Site.
- To develop records (including records of your Personal Data).
- To contact you with pertinent information about products, clinical trials, or important safety information, and about products and services of ours and of others.
- For analytical purposes and to research, develop, and improve programs, products, services, and content.
- To remove your personal identifiers. Once we have de-identified information, it is considered non-Personal Data and we may treat it like other non-Personal Data.
- To enforce this Policy and other rules about your use of this Site.
- To protect someone’s health, safety, or welfare.
- To protect our rights or property.
- To comply with a law or regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
How We Protect your InformationAttune Medical takes reasonable precautions to provide a level of security appropriate to the sensitivity of the information we collect. Although we use reasonable measures to help protect your information against unauthorized use or disclosure, we cannot guarantee the security of information provided over the Internet or stored in our databases and will not be responsible for breaches of security beyond our reasonable control.
Retention of Your InformationAttune Medical retains the Personal Data collected on this Site as long as necessary to fulfill the purpose for which it is collected or as permitted by applicable law.
Children’s PrivacyThis Website is not targeted to children under the age of 16 and we do not knowingly collect or solicit Personal Data about such children. If we discover that a child has provided us with Personal Data online through this Website, we will take delete this information as quickly as possible. If you believe we may have received Personal Data from a child under the age of 16, please contact us immediately.
Your rights (US Citizens)You may revoke your consent for the receipt of communication that we send to you at any time by using the “unsubscribe” functionality included in our emails to you or by contacting us directly. You should note that this will not affect all communications from us, for example, we are legally required to provide notices such as notification of a data breach in which case you should expect to receive a notification via email. It is important that the Personal Data we hold about you is accurate and current. Please keep let us know if your Personal Data changes. You may make a request to access, correct, or delete your Personal Data or otherwise object to our processing of such Personal Data by contacting us directly. We will respond to reasonable requests in accordance with applicable law and subject to legal and contractual restrictions. We will not discriminate against you for exercising these rights. There may be times where we cannot grant you access to the Personal Data we hold. For example, if such disclosure would interfere with the privacy of others or if it would result in a breach of confidentiality. We will provide written explanation for our refusal to grant access. California residents, please see the respective Privacy Addendums to understand your rights.
- Request access to your Personal Data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Data we hold about you.
- Request correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
- Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of your Personal Data. We will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.
- To file a complaint to a Supervisory Authority. You have the right to complain to a Supervisory Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local Supervisory Authority in the EEA.
- By email: email@example.com
- By mail: 180 N. Wabash Ave. #601, Chicago, IL 60601
Addendum: California Residents Privacy Notice
Categories of Personal Information we collectWe collect Personal Information as defined by the California Consumer Privacy Act. We have collected the following categories of Personal Information from our California consumers within the last twelve (12) months from the sources listed in the Privacy Statement:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name , signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Service providers;
Your rightsBy law if you are a resident of California, you have the following rights:
- The right to notice. You must be properly notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.
- The right to access / the right to request. You have the right to request certain information about our collection and use of your Personal Information over the past 12 months. In response, we will provide you with the following information:
- The categories of Personal Information that we have collected about you.
- The categories of sources from which that Personal Information was collected.
- The business or commercial purpose for collecting or selling your Personal Information.
- The categories of third parties with whom we have shared your Personal Information.
- The specific pieces of Personal Information that we have collected about you.
- The right to say no to the sale of Personal Information. Please note that we do not sell your Personal Information.
- The right to know about your Personal Information. You have the right to request and obtain from us information regarding the disclosure of the following:
- The categories of Personal Information collected
- The sources from which the Personal Information was collected
- The business or commercial purpose for collecting or selling the Personal Information
- Categories of third parties with whom we share Personal Information
- The specific pieces of Personal Information we collected about you
- The right to delete Personal Information. You have the right to request that we delete the Personal Information that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Information to provide you with the Website or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
- The right not to be discriminated against. We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Website as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Information that we receive from you.
Exercising Your RightsTo exercise the rights described above:
- Your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Information, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Information provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
- Email us at: firstname.lastname@example.org
- Submit a form at this address: https://www.attune-medical.com/contact/
Do Not Sell My Personal InformationWe do not sell Personal Information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that “sells” Personal Information as defined by the CCPA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below. Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.
WebsiteYou can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Website:
- From our “Cookie Consent” notice banner
- Or from our “CCPA Opt-out” notice banner
- Or from our “Do Not Sell My Personal Information” notice banner
- Or from our “Do Not Sell My Personal Information” link
Mobile DevicesYour mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
- “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
- “Limit Ad Tracking” on iOS devices