Last updated: July 17, 2020.
Types of Information We Collect
Use and Processing of Information
Sharing of Information
How We Protect Personal Information
California Information Sharing Disclosure
Types Of Information We Collect
We receive personal information from several sources including, but not limited to, our distributors, health care providers that use our products, and our employees and prospective employees. The following provides examples of the type of information that we collect in a variety of contexts and how we use that information.
|Examples of Types of Data||Examples of Types of Data||Primary Purpose for Collection
and Use of Data
|Information about Distributors||We collect, among other things, the name and contact information of our distributors and their employees or subcontractors with whom we interact.||We have a legitimate interest in communicating with our distributors concerning normal business administration.|
|Information about Employees||If you apply for a job, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment. If you are an employee seeking health-related benefits under certain programs, we may ask you to provide relevant medical and health information to assist in determining eligibility.||
|Information about Patients||We may receive information about the individuals that use our products. For example, if a health care provider contacts us concerning one of their patients that has used, or might use, our product we may receive information about a patient of the health care provider. We may also receive information for the purpose of correctly processing purchase orders and generating invoices sent to a provider or to one of our distributors.||We have a legitimate interest in the safety of our products and those who use them, and in receiving feedback concerning the performance of our products. We also may use your information in order to protect the vital interests of individuals that use our products or that may use our products. We also have a legitimate interest in processing invoices.|
|Information about Health Care Professionals||We may receive information about health care professionals, such as their name or NPI number, who attend one of our events or trainings, or provide us with services.||In some jurisdictions we may be required by law to collect and retain information about such health care professionals. We have a legitimate interest in complying with the laws in the jurisdictions in which we operate, and in understanding the types of individuals that attend our events or trainings or that provide us with services.|
|Information about Vendors and Service Providers||We may collect information about our vendors and their personnel, potentially including the names and roles of their employees.||We have a legitimate interest in managing our relationships with our vendors.|
|Email Interconnectivity||If you receive email from us, we use certain tools to capture data related to when you open or interact with our messages.||We have a legitimate interest in understanding how you interact with the communications that we send to you.|
|Feedback/Support||If you provide us feedback or contact us for support, we will collect your name and email address, as well as any other content that you send to us, in order to reply.||We have a legitimate interest in receiving, and acting upon, your feedback.|
|Public Health and Safety||In certain situations where a serious public health threat has been identified, we may collect information from employees, guests, and other individuals accessing our facilities. This may include medical and health information, such as body temperature, symptoms, and underlying health conditions. In some cases, we may also collect medical, health, and related information about an employee’s children, family member, or other individuals under the employee’s care.||We have a legitimate interest in protecting the health and safety of our employees and guests. In some jurisdictions we may be required by law or regulation to collect and retain information related to issues of public health and safety. We have a legitimate interest in complying with the laws in the jurisdictions in which we operate.|
|Social Media and Other Promotional Activities||If you choose to participate in our promotional activities using social media, we will collect information you choose to provide. This may include, among other things, your name, and image. We may ask you for your consent to use this information when you participate in these activities.||We have a legitimate interest in conducting promotional activities and engaging with those individuals that use our products or services.|
|Website Interactions||We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.||
|Web Logs||We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.||We have a legitimate interest in monitoring our networks and the visitors to our websites.|
In addition to the information that we collect from you, or from our customers directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.
Use and Processing of Information
In addition to the purposes and uses described above, we use information in the following ways:
- To identify you when you visit our websites.
- To provide products and services.
- To improve our services and product offerings.
- To conduct analytics.
- To respond to inquiries related to support, employment opportunities, or other requests.
- To send marketing and promotional materials.
- To improve the safety of our products.
- To manage our employees.
- For internal administrative purposes, as well as to manage our relationships.
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.
Sharing Of Information
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
- Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires our company, business, or our assets, we will also share information with that company.
- Other Disclosures with Your Consent.We may ask if you would like us to share your information with unaffiliated third parties who are not described elsewhere in this policy.
- Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, discovery requests, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
- From time to time we may ask if you would like to share your information as part of certain promotional activities, such as social media posts, publications, and presentations involving our products or business. If you choose to share your information in these situations, please note that such information may be publicly available.
- Service Providers.We may share your information with service providers. Among other things, service providers may help us to administer our website, conduct surveys, provide technical support, process payments, assist in the fulfillment of orders, and provide employee benefits.
You can make the following choices regarding your personal information:
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send you promotional materials. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
- Access to Your Personal Information. We will grant you, where required by law, reasonable access to the personal information that we have about you. You may request access to your personal information by following the instructions described below.
- Changes to Your Personal Information. You can contact us by following the instructions described below in order to request that your information be modified.
- Deletion of Your Personal Information. We typically retain personal information that we collect on our own behalf for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may request information about how long we keep a specific type of information, or request that we delete your personal information, by following the instructions described below.
- Revocation of Consent or Objections. You may revoke consent to processing (where our processing is based upon consent), or object to our processing (where our processing is not based upon your consent) by contacting us at the address described below. If you revoke your consent or object, we may no longer be able to provide you services.
- Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
How to Submit a Request
To submit a request to access, modify, or delete your personal information, please contact us by email at email@example.com, or by phone at 1-833-350-0323. In order to process your request, we must be able to verify your identity to make sure you are the person about whom we have collected personal information or an authorized representative. Depending on the type of request, we may conduct the verification process by email or phone using information that matches our records. The information you must provide as part of the verification process may include: name, contact information (such as email address or phone number), relationship with us, and residency. We may also ask for additional information as needed based on your relationship with us. If you are a California resident, you may designate an authorized agent to submit a request on your behalf to access or delete your personal information. To do so, you must (1) provide that authorized agent written, signed, and notarized permission to submit such request, and (2) verify your own identity directly with us.
If you are submitting a request on behalf of another person, please email us at firstname.lastname@example.org, or call us at 1-833-350-0323. You must provide written and notarized proof that you have been authorized by the individual to act on his or her behalf. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized to submit such request.
Review of Requests
In some cases, we may limit or deny your requests to access, modify, or delete your information, or to revoke consent or object. This may occur because the law permits or requires us to do so, or if we are unable to adequately verify your identity.
How We Protect Personal Information
No method of transmission over the Internet, or method of electronic storage, is fully secure. We use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure which are appropriate to the risks and sensitivity of the information. Despite these provisions, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to, changes to, or deletion of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
The following additional information relates to our privacy practices:
- Transmission of Information to Other Countries. By submitting your personal information to us online you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our application of the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.
- Information for California Residents. California Civil Code sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are collected, “sold,” or disclosed for an organization’s “business purpose” (as those terms are defined under California law). We do not “sell” information as that term is defined under California Law. You can find a list of the categories of information that we collect and share for a business purpose here. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. We do not discriminate against California consumers who exercise any of their rights described in this policy.
If you have any questions, comments, or complaints concerning our privacy practices, please contact us using the information below. We will endeavor to respond in a timely manner.
Mail: SeaSpine Orthopedics Corporation
Attn: Privacy Information
5770 Armada Drive
Carlsbad, CA 92008
Toll-Free Phone: (833) 350-0323
If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.