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Privacy Notice

This privacy notice is provided to the customers, visitors and suppliers, business partners and other individuals (hereinafter ‘you’ or the ‘user’ or the ‘data subjects’) of Medical Microinstruments, Inc., a Delaware Corporation, with headquarters at 1209 Orange Street, Wilmington, Delaware 19802, and secondary seat at via Egidio Giannessi 52/54/56 – 56121 Montacchiello (PI), Italy (hereinafter ‘Company’, or ‘we’ or ‘us’). Please read this privacy notice carefully before surfing this website operated by the Company relating to its products and services (‘site’) or submitting information to us. By accessing and navigating the present site and providing us with your personal information, you declare to have read and understood the practices described in this privacy notice and the privacy specifications of any country or region that may apply to you.

Note. During browsing, specific privacy notices may be made available whenever you are asked to provide personal data.

1. DEFINITIONS

  • ‘Personal 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.
  • ‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Note. The above definitions may be subject to change according to specific applicable regulatory requirements.

 

2. IDENTITY OF THE DATA CONTROLLER

The Company is the data controller of personal data and can be contacted at the e-mail addresses connect@mmimicro.com and legal.mmi@mmimicro.com.

 

3. DATA PROCESSED

The information we collect and how we handle it depends on the data type and what you do when you use our services and products, or otherwise interact with the Company. You should not provide the Company with any personal information that is not specifically requested. It is specified that the Company does not sell your personal data for monetary value.

Most information provided to us via our websites is not subject to the US Health Insurance Portability and Accountability Act of 1996 (‘HIPAA’) Privacy Rule. However, we may receive protected health information. We will comply with HIPAA and the service agreement when using such information.

 

a) Site users

When you interact with our site or engage with our services or products, we may collect the following types of data from you:

Type of data Examples of data
Identification information First name, last name
Contact information Email address, postal address, phone number
Relationship management information Requests for information / complaints (date, subject, action taken), other interactions with our products and services
Professional information Title, role, employer, professional specialty, professional interests, education/training, and professional identification number

 

Any other information you choose to provide to us. Where applicable, the site automatically collect the following data via cookies and other automatic means:

 

Type of data Examples of data Purposes
Internet or other electronic network activity information Date and time of the visit, IP address, device type, browser type, viewed pages, location based on IP address This data is necessary for the proper functioning of the site, or internal business analytics purposes such as audience measurement. For more information on cookies and other trackers, please see the cookie policy of the site.

 

b) System users

If you are a healthcare professional, medical student, proctor, or you otherwise use, have used, or may use our products or services, we may collect the following types of personal information from you:

Type of data Examples of data
Identification information First name, last name, birthdate, geolocation
Contact information Email address, postal address, phone number
Personal characteristics Travel and meal preferences
Data related to your exchanges with the Company Exchanges with our services and/or products (date, time, subject, content)
Data related to our products, including training systems Data related to the use of and interactions with our products (date, time, training pathway and records, procedure related information, kinematics), ergonomic and other user-defined system settings associated with a user-defined identifier
Financial data Payment and bank account details
Recordings Photos, still images, audio, video
Relationship management information Requests for information / complaints (date, subject, action taken), other interactions with our products and services
Professional information Title, role, employer, professional specialty, professional interests, resume, professional memberships, education, training

 

Any other information you choose to provide to us. You are not required to provide your personal information to us, although some information may be provided by you, your employer or a hospital or healthcare facility at which you have privileges and we with which have a contract. However, not providing your information may impact our ability to support your or your employer/hospital’s use of certain product features or functionality, including the use of relevant training materials or metrics.

 

c) Others

If you are an employee, director, officer, agent, consultant, advisor of our customers, suppliers, service providers, consultants, distributors, regulatory agencies and others (‘Third Party’), with a professional relationship with the Company, or an interest related to the Company’s or related products or services, we may collect the following types of personal information from you:

Type of data Examples of data
Identification information First name, last name, birthdate
Contact information Email address, postal address, phone number
Personal characteristics Travel and meal preferences
Data related to your exchanges with The Company Exchanges with our services and/or products (date, hour, subject, content)
Financial data Payment and bank account details
Recordings Photos, still images, audio, video
Relationship management information Requests for information / complaints (date, subject, action taken), other interactions with our products and services
Professional information Title, role, employer, professional specialty, professional interests, resume, professional memberships, education, training, professional identification number

 

Any other information you choose to provide to us.

 

4. PURPOSES OF PERSONAL DATA PROCESSING

We only use the information required to provide the products and services requested and for the purposes to which you agreed, unless otherwise required by law. Where we are required by law to request and receive your consent prior to collection, use, transfer or other processing of your information, the Company is committed to seeking such consent.

We may use the information we collected for the following purposes:

Purpose Legal basis Retention period
Management of newsletter subscribers. The Company may use the data provided by you to send you commercial and promotional communications relating to its activities and services. Consent Two years from the collection of the consent
To enable the working of site functions requested by the user. The Company may use the data collected through cookies in order to ensure your greater experience of the site. Consent See cookie policy
Meal management in compliance with dietary restrictions in the context of the Company’s training, research and development activities for scientific purposes. Such personal data will be processed only if the data subject gives explicit consent in order to provide the most appropriate meals with respect to the needs of the data subject. Consent Until the end of the Company’s training, research and development activities for scientific purposes
Provision of requested services. The Company collects supply requests, which can also be sent via the ‘Contact us – Technical Support’ or ‘Contact us – Customer Service’ section, in order to deal with all such requests and with any suggestion in an appropriate and timely manner Contract or pre-contractual measures Ten years from (1) the latest pre-contractual request or (2) the end of the contractual relationship
Fulfillment of regulatory obligations to which the Company is subject. Personal data are processed in order to fulfill any legal obligations related to the services provided / activities performed (e.g., managing and tracking expenses and payments). Legal obligation Period of time set out by the relevant applicable law
Ensure the proper functioning of the site. The Company collects and uses your information to technically administer the site and to ensure that it functions properly. The Company may use the personal information you provide to respond to your reports or complaints regarding the proper functioning of the site. Legitimate interest The data processed will be kept (1) as set forth within the cookie policy – with regard to cookies – and/or (2) until the resolution of your report / complaint regarding the proper functioning of the site.
Training, research, and development activities for scientific purposes of the Company. The Company collects and uses your personal data to organize and manage the above and related activities (e.g., booking flights, stays, managing attendance at the Company’s offices, etc.). Legitimate interest Ten years after completion of training, research, and development activities.
If necessary, to protect contractual and pre-contractual rights or, in any case, any right arising from existing relationships. Legitimate interest Same retention periods as indicated above, depending on the specific reference purpose

 

Please note that the retention period for each of the purposes described herein may vary according to specific local regulatory requirements. If in doubt, please contact the Company using the contact details given in section 2. ‘IDENTITY OF THE DATA CONTROLLER.

Unless we have your consent or to the extent permitted by applicable law, we do not use your personal information for automated decision-making, including profiling, that produces legal effects or similarly significantly affects you. To the extent permitted by applicable law, we may create pseudonymized, deidentified or anonymous data for the purpose of helping us develop or improve our products and services. Should it be necessary to ascertain, exercise or defend the rights of the Company in court, the retention period may extend until the termination of the litigation. For questions or further information on the purposes and legal bases of the processing of personal data, please contact the Company using the contact details given in section 2. ‘IDENTITY OF THE DATA CONTROLLER.

 

5. NATURE OF PROCESSING

Related to the above purposes, we point out that:

  • Where the legal basis is your consent, the provision of your personal data is optional; if you do not give your consent, there will be no negative consequences for you, except for the non-performance of the relevant services.

Note. If you do not give us your explicit consent to process your personal data for meal management in compliance with dietary restrictions in the context of Company’s training, research and development activities for scientific purposes, you are aware that we cannot safeguard your needs and, therefore, prevent the realization of any food hazards.

  • In other cases, the provision of your personal data is necessary in order to execute the contract concluded with you, to take steps at your request prior to entering into a contract, to comply with applicable legal obligations and / or to properly manage the services / activities provided by the Company: in such cases, failure to provide your personal data may result in our inability to perform what you have requested (e.g., provide you with the services).

Note. What has just been stated does not apply to the use of technical (necessary) cookies, which, as indicated within the cookie policy, allow us to ensure the proper functioning of our site. It should be noted that if the functionality of these cookies had been restricted through the settings of the browser used, depending on different situations it may be difficult or impossible to browse properly.

 

6. TO WHOM DOES THE COMPANY DISCLOSE YOUR PERSONAL DATA?

The Company will disclose or grant access to personal information to third parties on a need-to-know basis and such disclosure or access will be authorized and limited to the personal information that is necessary to perform the specific purpose for which such access is granted or personal information is disclosed. Such third parties are legally and contractually required to protect your personal information, in accordance with our instructions or the applicable laws.

The following categories of personal information collected about you may be shared with the following recipients for the purposes listed below:

 

Recipients Purposes Categories of personal information shared

Note. Not every purpose requires the use of every category of personal information

The Company and its duly authorized employees or Company’s corporate affiliates
  • Management of newsletter subscribers.
  • To enable the working of site functions requested by the user.
  • Meal management in compliance with dietary restrictions in the context of the Company’s training, research and development activities for scientific purposes.
  • Provision of requested services.
  • Fulfillment of regulatory obligations to which the Company is subject.
  • Ensure the proper functioning of the site.
  • Training, research, and development activities for scientific purposes of the Company.
  • If necessary, to protect contractual and pre-contractual rights or, in any case, any right arising from existing relationships.
  • Internet or other electronic network activity information
  • Identification information
  • Contact information
  • Personal characteristics
  • Data related to your exchanges with the Company
  • Data related to our products, including training systems
  • Financial data
  • Recordings
  • Relationship management information
  • Meal management data
  • Professional information
  • Any other information you choose to provide to us
Company’s contractors (service providers, consultants, etc.)
  • Management of newsletter subscribers.
  • To enable the working of site functions requested by the user.
  • Meal management in compliance with dietary restrictions in the context of the Company’s training, research and development activities for scientific purposes.
  • Provision of requested services.
  • Fulfillment of regulatory obligations to which the Company is subject.
  • Ensure the proper functioning of the site.
  • Training, research, and development activities for scientific purposes of the Company.
  • Internet or other electronic network activity information
  • Identification information
  • Contact information
  • Personal characteristics
  • Data related to your exchanges with the Company
  • Data related to our products, including training systems
  • Financial data
  • Recordings
  • Relationship management information
  • Meal management data
  • Professional information
  • Any other information you choose to provide to us
Administrative or judiciary authorities If necessary, to protect contractual and pre-contractual rights or, in any case, any right arising from existing relationships.
  • Internet or other electronic network activity information
  • Identification information
  • Contact information
  • Personal characteristics
  • Data related to your exchanges with the Company
  • Data related to our products, including training systems
  • Financial data
  • Recordings
  • Relationship management information
  • Meal management data
  • Professional information
  • Any other information you choose to provide to us
  • Other data lawfully requested by such authorities
Lawyers and professional advisors If necessary, to protect contractual and pre-contractual rights or, in any case, any right arising from existing relationships.
  • Internet or other electronic network activity information
  • Identification information
  • Contact information
  • Personal characteristics
  • Data related to your exchanges with the Company
  • Data related to our products, including training systems
  • Financial data
  • Recordings
  • Relationship management information
  • Meal management data
  • Professional information
  • Any other information you choose to provide to us

 

Your personal data will not be subject to dissemination and will not be disclosed to third parties who are not authorized to process it. The complete and updated list of autonomous data controllers, data processors appointed by the Company and recipients of data in any capacity may be requested at our offices.

 

7. DATA SHARING AND INTERNATIONAL TRANSFERS

Your personal information may be transferred to countries where the local legislation provides a different level of protection for your personal information and rights compared with your country. If that is the case, we will ensure that appropriate legal and/or contractual safeguards (e.g., adequacy decisions, standard contractual clauses, transfer impact assessments) are in place for such transfers as required by your local legislation (where applicable). In particular, the information that we collect about you may be stored in the EU and the United States. For more information about the countries where your personal information is transferred and the safeguards implemented by the Company (where applicable), please contact the Company using the contact details given in section 2. ‘IDENTITY OF THE DATA CONTROLLER.

 

8. SECURITY

The security and confidentiality of your information is important to us. We process personal information with commercially reasonable information technology, and we may use cloud services. We have also implemented technical and organizational security measures to protect your personal information from loss, misuse or unauthorized access, disclosure, deletion or modification. It includes, among other mechanisms, secured back-up and archiving servers, access control, firewalls or encryption.

 

9. COOKIES AND TRACKERS

We or third parties on our behalf may use different types of cookies as part of data collection. Essential cookies are required for the proper functioning of the site and may be used to, for example:

  • Remember previous actions when navigating back to a page in the same session;
  • Manage and pass security tokens to different services within the website to identify a visitor’s status;
  • Maintain tokens for the implementation of secure areas of the website;
  • Route customers to specific versions/applications of a service, such as what might be used during a technical migration.

Non-essential cookies are not required for the proper functioning of the site, and may be used to, for example:

  • Track and store data about visits;
  • Track and store visitor information;
  • Record session details and page traffic;
  • Customize and retarget contacts based on behavioral and demographic data.

For more information about cookies and other tracking tools on the site, please see the cookie policy.

 

10. CHILDREN

We understand the need to protect children’s privacy online (we define ‘children’ as minors defined as such by the applicable law). We do not knowingly collect or use any personal information from children. We do not knowingly allow children to register with us, order our products, communicate with us, or to use any of our online services. If you are a parent or guardian of a child and you become aware that he or she has provided us with personally identifying information without your consent, you should contact the Company using the contact details given in section 2. ‘IDENTITY OF THE DATA CONTROLLER. If we become aware that a child has provided us with personally identifying information, we will delete this information.

 

11. DATA SUBJECT RIGHTS

Under the applicable data protection legislation/regulations, you have various rights in connection with the processing of your personal information. These rights may differ based on your region.

The Company shall strictly uphold your rights and is responsible for implementing adequate procedures and policies to effectively protect your rights and monitoring compliance with applicable data protection laws and regulations. We will respond and provide information upon request without undue delay and in any event within the legally required timeline for your jurisdiction. That period may be extended where possible by local law.

Please note that we will have to identify you in order to fulfill your request. We will retain archival copies of the information you have requested. Until our backups are overwritten, we will retain the information, but make no further use of your personal information. Please contact the Company using the contact details given in section 2. ‘IDENTITY OF THE DATA CONTROLLER.

As a data subject, your rights may include the following, depending on your jurisdiction and applicable laws:

a) EU/EEA, Japan, South Korea, Switzerland and UK privacy rights

If you are a resident of the European Union, European Economic Area, Japan, South Korea, Switzerland or the United Kingdom, the disclosures set out below apply to you in addition to the disclosures set out in the general sections of this Privacy Notice.

To exercise your rights, to obtain details of our data transfer safeguards, or for any other questions related to personal information, you may contact the Company using the contact details given in section 2. ‘IDENTITY OF THE DATA CONTROLLER. When necessary, we may request identifying information from you to confirm your identity. We will respond to requests in accordance with applicable data protection law. Where data transfers are not covered by the EU-US Data Protection Framework, the UK-US Data Bridge or the Swiss-US DPF and where applicable, we have implemented international data transfer agreements based on standard contractual clauses covering onward transfers where applicable; a copy of these clauses can be obtained by contacting the Company using the contact details given in section 2. ‘IDENTITY OF THE DATA CONTROLLER.

 

The data subject, in relation to the personal data provided, is entitled to exercise at any time and in accordance with the provisions of the applicable legislation the rights set out therein and listed below:

  • Right to withdraw consent: right to withdraw the consent given.

Note. withdrawal of consent does not affect the lawfulness of the processing based on the consent given before the withdrawal.

Note No. 2. If you withdraw your explicit consent to process your personal data for meal management in compliance with dietary restrictions in the context of the Company’s training, research and development activities for scientific purposes, you are aware that we will no longer be able to safeguard your needs and, therefore, prevent the realization of any food hazards.

  • Right of access: right to obtain from the Company confirmation as to whether or not personal data is being processed and, if so, also to obtain access to such data and further information, such as purposes of processing, categories of data processed, recipients of communications and/or transfers of data (including their copy in intelligible form).
  • Right to rectification: right to have inaccurate personal data relating to the data subject rectified.
  • Right to erasure (‘right to be forgotten’): right to erasure of personal data regarding the data subject.

Note. if the data has already been disseminated (made available to an unspecified number of recipients – e.g. by publication on the Company’s social networks), it may be impossible for the Company to delete/destroy it; therefore, in such situations the Company will inform the data subject of the reasons why it is impossible to proceed with the erasure and will pursue the right to be forgotten.

  • Right to restriction: right to obtain restriction of processing, e.g. in case of contesting the accuracy of data or in case of unlawful processing.
  • Right to data portability (not applicable in South Korea): right to receive in a structured, commonly used and machine-readable format personal data concerning the data subject provided to the Company, and the right to transmit such personal data to another data controller without hindrance by the Company if the processing is carried out on the basis of consent or a contract and is conducted by automated means.
  • Right not to be subjected to automated decision-making: right not to be subjected to a decision based solely on automated processing that produces legal effects or similarly significantly affects the data subject.
  • Right to object: the data subject has also the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her if it is based on legitimate interest.
  • Right to lodge a complaint: if the data subject believes that his or her rights have been compromised or infringed, or that the processing of his or her data is contrary to the applicable legislation on the protection of personal data, he or she has the right to lodge a complaint with the territorially competent supervisory authority in accordance with the procedures defined by it.

 

b) Israel and Taiwan privacy rights

If you are in Israel or Taiwan, the disclosures set out below apply to you in addition to the disclosures set out in the general sections of this privacy notice.

  • Right to access. You are entitled to obtain confirmation from the Company as to whether any personal information concerning you is processed by it. You have the right to access such personal information, to obtain a copy.
  • Right to rectification. You have the right to obtain without undue delay the rectification of inaccurate, incomplete or outdated personal information concerning you.
  • Right to erasure. You have the right to obtain without undue delay the erasure of your personal information in certain cases and subject to certain limitations.
  • Right to restriction. You have the right to request that we restrict the use, collection or processing of data under certain circumstances.
  • Right to withdraw consent. Where the processing of your personal information is based on consent, you have the right to withdraw such consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
  • Right to lodge a complaint. You also have the right to lodge a complaint with the competent supervisory authority.

To exercise your rights, you may contact the Company using the contact details given in section 2. ‘IDENTITY OF THE DATA CONTROLLER’. When necessary, we may request identifying information from you to confirm your identity. We will respond to requests in accordance with applicable data protection law. You will never be discriminated against if you exercise your rights.

 

c) Canada privacy rights

If you are in Canada, the disclosures set out below apply to you in addition to the disclosures set out in the general sections of this privacy notice.

  • Right to access. You are entitled to obtain confirmation from the Company as to whether any personal information concerning you is processed by it. You have the right to access such personal information, to obtain a copy.
  • Right to rectification. You have the right to obtain without undue delay the rectification of inaccurate, incomplete or outdated personal information concerning you.

To exercise your rights, you may contact the Company using the contact details given in section 2. ‘IDENTITY OF THE DATA CONTROLLER’. When necessary, we may request identifying information from you to confirm your identity. We will respond to requests in accordance with applicable data protection law. You will never be discriminated against if you exercise your rights.

 

d) California privacy rights

California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of certain categories of personal information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact the Company using the contact details given in section 2. ‘IDENTITY OF THE DATA CONTROLLER. This request may be made no more than twice in a 12-month period and we reserve our right not to respond to requests submitted other than to the email or mailing addresses specified above. Note that we do not currently share personal information with third parties for those third parties’ direct marketing purposes.

 

In addition, California residents have the following privacy rights:

  • The right to know. You have the right to request to know (i) the categories of personal information we have collected about you in the last 12 months, (ii) the specific pieces of personal information we have about you, (iii) the categories of sources from which that personal information was collected, (iv) the categories of your personal information that we sold or disclosed in the last 12 months, (v) the categories of third parties to whom your personal information was sold or disclosed in the last 12 months, and (vi) the purpose for collecting and selling your personal information.
  • Right to correct. You have the right to obtain without undue delay the correction of inaccurate, incomplete or outdated personal information concerning you.
  • The right to deletion. You have the right to request that we delete the personal information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected. If we deny your request for deletion, we will let you know the reason why.
  • The right to limit. You may have the right to request restricted processing of your personal information which, if applicable, we will limit the processing if you dispute the accuracy of the personal information, your personal information was processed unlawfully and you request a limitation on processing, rather than the deletion of your personal information, we no longer need to process your personal information, but you require your personal information in connection with a legal claim, or you object to the processing pending verification as to whether an overriding legitimate ground for such processing exists. You may also have the right to ask us to limit our processing of your sensitive personal information to what is necessary to our relationship with you. While the Company’s practices are to restrict processing of your sensitive personal information to what is strictly necessary at all times, you are welcome to make a request by contacting us using the contact details given in section 2. ‘IDENTITY OF THE DATA CONTROLLER.
  • Right to opt-out the ‘sale’ or ‘share’ of your personal information (as defined in the CCPA and CPRA respectively). The Company does not ‘sell’ or ‘share’ your personal information for monetary value. However, some third-party cookies and other trackers placed on our site may be considered a ‘sale’ or a ‘share’ when used for our ‘targeted’ or ‘cross-contextual’ advertising campaigns. If you opt-in to targeting cookies, we allow trusted parties to collect via cookies certain information about you when you interact with our site to provide you with targeted advertising. You can opt-out of these cookies as detailed in section 9. COOKIES AND TRACKERS by changing your cookie preferences. Alternatively, you can rely on an opt-out preference signal to tell us you wish to opt out of us ‘selling’ or ‘sharing’ your personal information. We will recognize the opt-out preference signal in a ‘frictionless’ manner. We will not (i) charge you for using it, (ii) change your experience with our products and services, or (iii) display pop-ups or other notifications in response to your opt-out signal other than a status indicator.
  • The right to equal service. If you choose to exercise any of these rights, the Company will not discriminate against you in anyway. If you exercise certain rights, understand that you may be unable to use or access certain features of our websites or services.

You may exercise your right to know twice a year free of charge. To exercise your rights, contact the Company using the contact details given in section 2. ‘IDENTITY OF THE DATA CONTROLLER’.

We will take steps to verify your identity before processing your request. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected personal information. We will only use the personal information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.

You may use an authorized agent to submit a request. When we verify your agent’s request, we may verify your identity and request a signed document from your agent that authorizes your agent to make the request on your behalf. To protect your personal information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

 

e) Notice to residents of Nevada

If you are a Nevada resident, you have the right to opt out of the sale of certain personal information, including your name and mailing address, to third parties. As of the date of this privacy notice, the Company does not sell any personal information to any third party. If that changes in the future, we will update this privacy notice.

12. CHANGES

The Company may also make changes and/or additions to this privacy notice as a consequence of any subsequent regulatory changes and/or additions. In such cases, the new version of this privacy notice will be communicated as soon as possible in such a way as to reach all the data subjects as quickly as possible. Any inquiry regarding our privacy notice can be contact the Company using the contact details given in section 2. ‘IDENTITY OF THE DATA CONTROLLER’.

The Symani Surgical System is authorized for use in the U.S. by the FDA and is a CE marked medical device. Clinical indications vary by geography. Refer to global indications for more information. © 2024 Medical Microinstruments, Inc. All Rights Reserved.

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