Last Updated: January 2021

This Privacy Policy describes how information is collected, used and disclosed by Spectra Medical Devices, LLC (“Spectra”) when you use or access our online or mobile websites or services (collectively, the “Services”). Capitalized terms used herein but left undefined shall have the meanings prescribed to them in Spectra’s Terms and Conditions of Use, which can be found at https://www.spectramedical.com/terms-and-conditions-of-use/.

WHAT INFORMATION IS COLLECTED
Spectra’s Services are intended to be used by Spectra’s customers, business associates and partners, and other interested parties for business and informational purposes only. We collect and use the following information to provide, improve and protect the Services for our customers and business associates as described herein:

1.1 Your Account / Services.

We collect information when you register with Spectra for an account or modify such account, including your name, physical address, e-mail address and phone number. When you access and use the Services, we store, process and transmit information related to the Services in order to provide you with the features and functionality of the Services, including purchase history and browsing history.

1.2 Usage.

We collect information from and about the devices you use to access the Services. This includes things like IP addresses, access times, the type of browser and device you use, the web page you visited before coming to our sites, and identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to the Services. We also monitor user activity of the Services and may collect information about the Services and features you use.

1.3 Cookies and Other Technologies.

We use Google Analytics and technologies like cookies and pixel tags to provide, improve, protect and promote the Services. Cookies are small data files stored on your hard drive or device memory that help customize your experience and preferences, allow you to access the Services without re-entering your e-mail and/or password, and help us understand which areas and features of the Services are the most popular. More information about cookies and how they work is available at: www.allaboutcookies.org/. You can set your browser to not accept cookies, but this may limit the functionality of the Services. Pixel tags are electronic images that may be used in the Services or in e-mails that help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an e-mail has been opened and acted upon. To learn more about the use of cookies by Google Analytics and to exercise choice regarding cookies provided by Google generally, please visit the Google Analytics Opt-out Browser Add-on. For information and guidance about managing and disabling cookies on your web browser generally, please refer to: www.allaboutcookies.org/manage-cookies.

USE OF INFORMATION
We use the information we collect from you to provide, improve, maintain, protect and promote the Services, including to:

Provide and deliver the Services and features you request, process and complete transactions;
Personalize and improve the Services;
Send you notices, including updates and news about new Spectra products, technical notices and other relevant alerts;
Provide you news about Spectra’s business;
Monitor and analyze usage, trends and activities in connection with the Services;
Monitor, investigate and prevent fraudulent use of the Services, unauthorized access to the Services and any other illegal activities; and
Respond to your questions, comments, suggestions and requests and other customer service and support.
SHARING OF INFORMATION
We may share information as discussed below, but we won’t sell it or give it away to advertisers or other third parties.

3.1 Vendors, Consultants and other Service Providers Working with Spectra.

We use certain trusted third parties to help us provide, improve, protect, and promote the Services. These third parties will access your information only to perform tasks on our behalf and in compliance with this Privacy Policy. We use a third-party service to process your credit card transactions and that third party will have your information, which will be subject to their privacy policy. Your credit card information (including your e-mail, mailing address, phone number, credit card number and expiration date) is collected and shared with such third party in order to process transactions using the Services, but we do not store or keep this information on any of our servers or otherwise.

3.2 Legal Compliance.

We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request; (b) enforce our agreements, policies and Terms of Service, (c) protect any person from death or serious bodily injury; (d) prevent harm, fraud or abuse of Spectra, our users or the public or to protect the same from any other illegal activity; or (e) protect Spectra’s property rights.

3.3 Business Transactions.

We may share or transfer your information in connection with, and during negotiations of, a sale of any or all of Spectra’s assets or ownership interests, a merger, financing or other business combinations or reorganizations.

3.4 Aggregate Data.

We may share aggregated or anonymized information with third parties that does not directly identify you.

WHERE IS INFORMATION STORED
To provide you with the Services, we may store, process and transmit information in locations around the world, including those outside of the United States. Information may also be stored locally on the devices you use to access the Services. By accessing or using the Services, you consent to the processing and transfer of information into and out of the United States and other countries and territories that may have different privacy laws from your country of residence.

SECURITY
While no service can be completely secure, we have implemented reasonable safeguards to keep your information secure and test for vulnerabilities and we continually work on features to keep your information safe. Spectra takes reasonable measures to help protect your information from loss, theft, misuse and unauthorized access. We cannot guarantee that any personal, sensitive or confidential information stored on our systems will be maintained at levels of protection to meet your specific needs or obligations to a third party regarding such information.

Your account and the Services may only be accessed by entering your e-mail and password. You must keep your password confidential and should not disclose it to any other person. You should always log out and close your browser when you are finished using a session of the Services.

Our Website uses Secure Sockets Layering (SSL) to encrypt your personal information, including your credit card number, before it travels over the internet. SSL technology is the industry standard for secure online transactions. In order for SSL security to work, you must use a SSL enabled browser. Most browsers, such as Internet Explorer, Safari and Chrome, support SSL.

RETENTION
Spectra retains the information you store on the Services for as long as we need it to provide you the Services. If you delete your account, we may or may not also delete this information (please see the Terms of Services regarding the termination of your account). We may retain certain information if we believe it is necessary to comply with our legal obligations, resolve disputes, enforce our agreements and other legitimate business purposes. In addition, there may be some time lag in deleting this information from our servers and back-up storage.

DATA COLLECTION OPT-OUT
Individuals who have an established business relationship with Spectra may choose to opt out of Spectra’s disclosure of personal information about them to third parties for direct marketing purposes. If you choose to opt out at any time, please e-mail info@spectramedical.com or mail your request to Attn: Data Privacy, 299 Ballardvale Street, Wilmington, MA 01887.

CHANGES
We may revise this Privacy Policy from time to time. We will date and post the most current version of this Privacy Policy on the Spectra website. Any changes will be effective upon posting, so we suggest that you check the website regularly to see if any updates have been posted. If in our sole discretion we deem a revision to this Privacy Policy to be material, we will notify you by sending a message to the e-mail address associated with your account. By continuing to use or access the Services after the revisions come into effect, you consent to such revisions.

CONTACT
If you have any questions or concerns about Spectra, the Services or this Privacy Policy, please contact us via email at info@spectramedical.com or by mail at Attn: Data Privacy, 299 Ballardvale Street, Wilmington, MA 01887.