Route 92 Medical, Inc. (“Route 92”, “we”, “us”, or “our”) conducts business within the United States and various countries globally, including in the European Union. We understand the importance of privacy to our customers, visitors, suppliers, business partners, employees and other individuals. We are committed to protecting and respecting your privacy.
This Route 92 privacy policy (“Policy”) is used to inform Website visitors regarding our policies with the collection, use, and disclosure of personally identifiable information, Log Data and Cookies and applies only to information collected through the website on which it is posted (“Website”) and any software applications, events, newsletters, communications, or services provided by or on behalf of Route 92 that link or reference this Policy (“Services”). It does not apply to third-party platforms or to other Route 92-operated websites or other Route 92-operated platforms where it is not linked or referenced. This Policy may be supplemented or amended from time to time by additional privacy notices (“Privacy Notices”), provided at the time we collect your information. For example, certain pages of this Website may contain Privacy Notices providing more details about the information we collect on those pages, why we need that information, and choices you may have about the ways we use that information. In other cases, specific Privacy Notices may be required to comply with the privacy laws of one of the countries, provinces, or states in which we do business.
If you use our Website, then you agree to the collection and use of information in relation with this Policy. The personally identifiable information that we collect is used for providing and improving the Website, products and services of Route 92. We will not use or share your information with anyone outside of Route 92 except as described in this Policy.
Unless otherwise defined in this Policy, the terms used in this Policy have the same meanings as in our Terms of Use, which is accessible at www.route92medical.com/terms-of-use and by a link which is provided at the bottom of each page of this Website.
If you have a disability, you may request access to this Policy in an alternative format by contacting [email protected].
Your acknowledgment of this Policy
By using this Website, including your choices regarding cookie settings, or using the Services, you are acknowledging and agreeing to the collection, use, disclosure, and transfer of your information as described in this Policy (and any additional Privacy Notices that apply to you). If you do not agree 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 Website or the Services. If you have questions about this Policy, or any Privacy Notice, please contact us using the information provided below.
Where any of your Personal Information is processed based on your consent, you may revoke your consent to 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.
Complete agreement for use of the Website
This Policy is part of the Terms of Use that govern your use of this Website. A link to our Terms of Use is provided at the bottom of each page of this Website.
Except as written in any other disclaimers, policies, or other notices on this Website, this Policy and the Terms of Use are the complete agreement between you and Route 92 with respect to your use of this Website. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use. There may be additional terms that apply to particular materials on or sections of this Website.
What is Personal Information?
Personal Information means any information relating to an identified or identifiable natural person. 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.
How do we collect your Personal Information?
How we collect Personal Information will depend upon the nature of your dealings with us. We collect and use non-Personal Information differently from Personal Information. Whenever it is reasonable and practical to do so, we will collect your Personal Information directly from you. We may also collect Personal Information from third parties, including in the course of providing products to you such as from our distributors, your healthcare practitioners, your caregiver/family member, guardian, publicly available information and databases supplied by third parties.
If you are one of our suppliers, distributors or a healthcare professional that uses our products, your Personal Information may be collected from you, your employer, other employees, or third parties. Similarly, if you are a prospective employee, we may collect information through third parties such as recruiters.
If you choose not to provide some Personal Information to us, this may affect our ability to provide products or services to you.
Information We Collect
Generally, Personal Information we collect may include but is not limited to:
Product Users
If you are someone who uses our products including clinical trial participants: we may collect additional specific information about your use of our products and you, such as your gender, date of birth, your medical history and conditions, treatment, device information, family and social history, medical inquiries you or your physician make, and adverse events you report. We may receive some of this information from third parties, such as our distributors or your health care professional. Some of this information may be, but is not always, anonymized, or de-identified. If you are a clinical trial participant, your information will be used in accordance with the informed consent and applicable law.
Suppliers, Customers or Other External Stakeholders
If you are a supplier, customer, distributor, or a healthcare professional that purchases and/or uses our products: we may collect additional specific information including information about your professional details, practice specialty and areas of interest, membership of professional associations, product usage and your dealings with us.
If you are an employee, contractor or applicant: we may collect additional specific information including your gender, date of birth, contact details, information collected in our employment records, including tax file number, job application, reference checks, curriculum vitae/resume, records of training, documentation of performance appraisals and disciplinary matters, employment terms, and medical condition or history. We may receive some of this information from third parties such as recruiters or from reference checks.
Personal Information You Manually Provide through this Website
Route 92 collects the information you manually provide (e.g., using your keyboard, mouse, or touchscreen) when you use this Website. 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 Website. Some of the information you may choose to manually provide will be Personal Information 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.
Information Automatically Collected through this Website
Route 92 collects information through this Website that is sent to us automatically by your web browser or mobile device. This information may include but is not limited to:
• 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 Website
• Links clicked on the Sit
• Time spent on a particular page of the Website or the Website as a whole
• Website data used to facilitate the use of the Website such as login and technical data
The information we receive may depend on your browser or device settings as well as your cookie settings. The information we receive from your web browser and device typically is not, in and of itself, personally identifiable. However, we may combine it with other information that either does, or may, identify you.
Information Collected by Cookies and Other Technologies through this Website
We use “cookies” and other technologies to collect information and support certain features of this Website. For example, we may use these technologies to:
• Collect information about the ways visitors use this Website—which pages they visit, which links they use, and how long they stay on each page
• Support the features and functionality of this Website—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 Website; and
• Improve our marketing efforts, including through use of targeted advertising.
The information we collect using cookies and similar technologies is not, in and of itself, personally identifiable, but we may link it to Personal Information that you provide. If you do not wish to receive cookies, you may choose to reject cookies in your cookie settings when you visit our Website. You may also set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit this Website, you may be unable to use all of the functionality of this Website if you or your browser rejects cookies.
Information Collected by Third-Party Cookies through this Website
In addition to the cookies Route 92 delivers to your computer or mobile device through this Website, certain third parties (Tracking and Performance Cookies) may deliver cookies to you for a variety of reasons. For example, we may use a web analytics tool that helps us understand how visitors engage with our Websites.
Other third parties may deliver cookies to your computer or mobile device for the purpose of tracking your online behaviors over time and across nonaffiliated websites and/or delivering targeted advertisements either on this Website or on other websites.
You have choices about the collection of information by third parties on our Websites. You may use the cookie pop-up banner on the Website to decline non-essential cookies. Additionally, you may download an Opt-out Browser Add-on to opt-out of Google Analytics by clicking here. Similarly, to opt-out of cookies used for interest-based advertising by similar services globally, click here or here.
You will be directed to an industry-developed website that contains mechanisms for choosing whether each listed entity may collect and use data for online behavioral advertising purposes. It may be that some of the third parties that collect interest-based information on this Website do not participate in the industry-developed opt-out website, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies. Please note that the industry-developed opt-out mechanisms are device and browser specific. If you wish to opt-out from having interest-based information collected by participating entities across all devices and browsers, you need take the steps outlined above from each device and browser.
Collected through this Website
We may use the information we collect through this Website for various purposes, including but not limited to:
• To provide you with access to this Website.
• To respond to your requests.
• To personalize your access to our Website.
• To develop records (including records of your Personal Information).
• 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 may be considered non-Personal Information and if so we may treat it like other non-Personal Information.
• To enforce this Policy and other rules about your use of this Website.
• 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.
Our Legal Basis for Processing Personal Information
We may process the Personal Information we collect/receive under the following legal bases:
How We Transfer or Share Your Information
Our headquarters are in the United States and we may have offices, use service providers, and have distributors in other jurisdictions. We may disclose your information to other companies in our corporate group, or to databases or servers overseas which may be provided to us by our third-party service providers. As a result, your Personal Information is sometimes shared with others and transferred and processed outside of your home country. We may share your Personal Information with:
We will not sell, share, or otherwise distribute Personal Information about you to any person, except as provided in this Policy and in accordance with applicable law and regulation. The circumstances in which we may disclose that information include where:
We may employ third-party companies and individuals due to the following reasons:
We want to inform our Website users that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.
For Residents of Europe and the United Kingdom
The European Commission and the UK Information Commissioner’s Office (ICO), have the power to determine, based on the General Data Protection Regulation (“GDPR”) or UK GDPR respectively, whether a country offers an adequate level of data protection by making an ‘adequacy decision’. Neither the European Commission nor the UK ICO have adopted a currently active adequacy decision regarding the United States. Instead, with respect to any transfers of information to the United States, we rely on other legal bases to lawfully transfer personal data. We will implement appropriate measures to protect and secure your Personal Information when it is transferred outside of your home country, in accordance with applicable data protection and privacy laws, including in the case of EU residents, with your consent or through the use of approved model standard contractual clauses along with supplementary measures, where determined necessary. The European Commission has determined that the transfer of Personal Information pursuant to the Standard Contractual Clauses along with supplementary measures provides for an adequate level of protection of your Personal Information. Similarly, the UK has adopted International Data Transfer Agreements. Under these standardized agreements, you have similar rights as if your Personal Information was not transferred.
You may request more information about our data transfer methods by contacting us through the methods below.
How We Use Your Information
Collected through this Site
We may use the information we collect through this Site for various purposes, including 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 Information).
• 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 may be considered non-Personal Information and if so we may treat it like other non-Personal Information.
• 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.
Collected through our Services
Generally, the purpose for which we collect Personal Information will be apparent from the way in which we collect it or will be disclosed before or at the time of collection. We may use your information, including Personal Information to:
Log Data
We want to inform you that whenever you visit our Website, we collect information that your browser sends to us that is called Log Data. This Log Data may include information such as: your computer’s Internet Protocol (“IP”) address, browser version, device id, internet service provider, pages of our Website that you visit, the time and date of your visit, the time spent on those pages and other statistics. Some of this information is considered personally identifiable in certain jurisdictions.
Retention of Your Information
We will always keep Personal Information for the period required to comply with applicable laws, regulations, guidance, codes of conduct, product approvals, license requirements, ethical and safety requirements. We may also maintain your information as required to comply with any contract of which we are a party. Otherwise, we keep your Personal Information:
Where you have contacted us with a question or request, for as long as necessary to allow us to respond to your question or request.
Your Rights (US residents)
You may revoke your consent to commercial emails 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.
You may make a request to access, correct, or delete your Personal Information or otherwise object to our processing of such Personal Information 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 Information 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 California Privacy Addendum to further understand your rights.
European Union, United Kingdom, and European Economic Area
Route 92 undertakes to respect the confidentiality of your Personal Information and to guarantee you can exercise your rights. You have the right under this Policy, and by law to:
Exercising of Your GDPR Data Protection Rights (For residents of Europe or United Kingdom)
You may exercise your rights of access, rectification, cancellation and opposition by contacting us:
Contact:
Route 92 Medical, Inc.,
155 Bovet Road, Suite 100
San Mateo, CA 94402
Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.
You can additionally contact your local supervisory authority for more information about your privacy rights.
Security
We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee the absolute security of any Personal Information in our possession.
Links to Other Websites
Our Website may link you to other sites on the Internet or otherwise include references to information, documents, software, materials and/or services provided by other parties. These other websites and parties are not under our control, and you acknowledge and accept that we are not responsible for the accuracy, copyright compliance, legality, decency, or any other aspect of the content of such sites, nor are we responsible for errors or omissions in any references to other parties or their products and services. The inclusion of such a link or reference is provided merely as a convenience and does not imply endorsement of, or association with, the Website or party by us, or any warranty of any kind, either express or implied.
Children’s Privacy
Our Website is not intended for use by anyone under the age of 18. We do not knowingly collect personal identifiable information from children under 18. In the case we discover that a child under 18 has provided us with personal information, we immediately delete this from our servers. If you are aware that a child has provided us with personal information, please contact us so that we will be able take all necessary actions regarding their personal information.
International Data Transfer & Controlling Your Information
We store, collect, transfer, and process your Personal Information primarily in the United States, and other countries from time to time. The data protection and other laws of countries to which your information may be transferred may be different in your country. If you have any questions or concerns about the processing of your personal information, you may contact us as outlined in the “Contact Us” section below.
Changes to This Policy
We may update our Policy from time to time. Thus, we advise you to review this page periodically for any changes. Notification of any changes is provided by posting the new Policy on this page. These changes are effective immediately upon being posted on this page.
Contact Us
If you have any questions or suggestions about our Policy, do not hesitate to contact us.
Route 92, Inc.,
155 Bovet Road, Suite 100, San Mateo, CA 94402
Addendum: California Residents Privacy Notice
Effective May 8, 2024
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Website does not respond to Do Not Track (“DNT”) signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
California’s Shine the Light law
Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Information with third parties for the third parties’ direct marketing purposes.
If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided in this Policy.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, you can contact us using the contact information provided in this Policy and include the email address associated with your account.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.