Privacy Policy

Privacy is important to us and we understand it is also important to you as our customer. Thank you for visiting instrusafe.com, a website of Summit Medical Inc. (“Summit”). This Privacy Policy describes our practices in connection with information that we collect through websites, mobile sites, applications, widgets and other features that link to instrusafe.com or summitmedicalusa.com (collectively, “Sites”). At Summit, we know that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly.

We want you to understand how and why we collect, use and disclose the personal information about you on our Sites. We may update this Policy from time to time, so please check this Policy periodically for changes.

Personal Information We Collect

We gather customer information needed to provide you with superior service, communicate information that we believe will be of interest to you, and administer our business.

We do not collect any personal information about you at our Sites unless you choose to provide it to us voluntarily. We define “personal information” as information that is unique to you, and might include your name, user name, email address, mailing address, phone number (including home and mobile numbers).

We ask that you not send us, and not disclose, any sensitive personal information such as Social Security Number, criminal background, trade union membership, information related to your ethnic origin, religion or other beliefs, health, or political opinions, or any other information that you would consider sensitive in nature.

We may ask you to voluntarily provide personally identifiable information when you:

• Choose to provide us with your preference information (such as interests, product preferences and items purchased).
• Enter a sweepstake, promotion, game, or contest.
• Contact us for inquiries, make requests, or submit questions or comments.
• Place orders, make purchases, process payments, or require customer service communications.
• Request updates, announcements regarding our products, programs, and promotions, or advertising information.
• Send messages or share information with a friend. By entering another person’s name and email address, you confirm that you are entitled to use and provide us with this information.

Generally, we need this basic information about you to communicate with you. Other instances when we may use or disclose your personal information include the following:

• To send you important information about the Sites, changes in policies, terms, or conditions, or other important information.
• To provide our services to you and use services and vendors that may enable us to provide services to you, such as website hosting, data analysis, payment processing, order fulfillment, IT services, customer service, infrastructure provision, email delivery, credit card processing, auditing, and any other reasonable use.
• To personalize your experience on the Sites and present offers and products tailored to you.
• To re-contact you if we have not heard from you in a while.
• to enhance our website, improve our services and products, identify usage trends, conduct marketing or data aggregation, analyze and manage our businesses, conduct audits of the Sites, determine the effectiveness of advertising and promotional campaigns, tailor the Sites and content based on your previous activities on the Sites, determine customer satisfaction.
• To provide customer service and troubleshoot in connection with customer issues.
• To process sweepstakes, instant win promotions, contests, games, and otherwise in accordance with the applicable rules. In the event of a conflict between the terms and conditions of this Policy and the terms and conditions of a sweepstake, promotion, contest or game, the latter shall prevail.
• To identify you to anyone to whom you send messages through the Sites.
• To enter into a corporate reorganization, merger, acquisition, transfer, joint venture, sale, assignment, or consolidation; to enter into special relationships and strategic partnerships; and to dispose of all or any portion of our assets, including in connection with any bankruptcy or similar proceeding.
• To comply with applicable laws worldwide; to respond to requests for information from public and government authorities; to enforce our terms and conditions; to protect our businesses and operations and those of our affiliates; to protect our rights, property, privacy, or safety and that of our affiliates, you or others; and to allow us to defend our interests, pursue remedies, or limit the damages that we may incur.

Third Party Use of Personal Information

Summit will not share your personal information collected from the Sites with an unrelated third-party without your permission, except as otherwise provided in this Privacy Statement. In the ordinary course of business, we will share some personal information with companies that we hire to perform services or functions on our behalf. For example, we may use different vendors or suppliers to ship you products that you order from Summit Medical. In these cases, we provide the vendor with information to process your order such as your name and mailing address. In all cases in which we share your personal information with a third-party, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.

We will not sell, exchange or publish your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition.

We may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting website visitors who violate our rules or engage in behavior which is harmful to other visitors (or illegal). We may disclose your personal information to third parties if we feel that the disclosure is necessary to:

• enforce this Privacy Statement and the other rules about your use of this website
• protect our rights or property
• protect someone’s health, safety or welfare
• comply with a law or regulation, court order or other legal process

Please note: In addition to the ways that we may keep, disclose, and use information described in this Privacy Statement, we also may keep, disclose, and use personally identifiable information that you give us through this website in ways that we believe are consistent with FDA and other governmental guidance, directions, regulations, and laws.

The Sites contain links to other websites. Some of those websites may be operated by Summit Medical, Inc. and some may be operated by third parties. We provide links for your convenience, but we do not maintain responsibility (control nor monitoring) the privacy practices of these sites.

If you click a link on our site that leads you to a third-party site, we encourage you to check the privacy policy of that site. We are not responsible for the privacy, information, or other policies of any third parties, including any third party operating any site to which the Sites contain a link. The inclusion of a link on the Sites does not imply endorsement of the linked site by us or our affiliates.

California law (CalOPPA) requires that Summit Medical, Inc. let you know how we respond to web browser “Do Not Track (DNT) signals”. We currently do not possess a system to automatically respond to DNT signals. Therefore, if you are a California resident, you may ask us to refrain from sharing your information (whether collected online or offline) with third parties for their marketing purposes. Please tell us your preference by contacting us as indicated in the “Contacting Us” section of this Policy.

We Do Not Collect Information From Children

We are strongly committed to preserving online privacy for all of our Sites visitors, including children. The Sites are designed for use only by adults and children age 13 and older with the consent of their parents. Consistent with the Children’s Online Privacy Protection Act, we will not knowingly collect any information from children under the age of 13. Furthermore, we may restrict entries to any contests, sweepstakes or promotions to entrants who are at least 18 years of age.

Profiles and Screen Names; Social Media

To take advantage of certain interactive features of our Sites, you may be required to register as a member. As part of the registration, you may be able to create a profile with an associated screen name of your choosing. You acknowledge that if you choose to use your real name or something like it as your screen name, you voluntarily may be relinquishing some of the privacy that your screen name might afford you.

Additionally, we may provide you with access to social media links, message boards, chats, profile pages, blogs, and other third-party functionalities that may permit you to post content to your social media account(s). Any information that you provide through use of social media functionality is governed by the applicable third party’s privacy policy, and not by this Policy. We have no control over, and shall not be responsible for, any third party’s use of personal information that you provide through use of the social media functionality.

Google AdWords Disclaimer and Opt Out

This website uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. We may advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an inquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the InstruSafe.com. Any data collected will be used in accordance with our own privacy policy and Google’s privacy policy. You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if up can opt out of third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.

Confidentiality and Security

We restrict access to personal information collected about you at our Sites to our employees, our affiliates’ employees or others who need to know that information to provide services to you or in the course of conducting our normal business operations. While no Sites can completely guarantee security, we maintain reasonable physical, electronic and procedural safeguards to protect your personal information collected via the Sites.

We do not guarantee that any information you provide will not be intercepted by a third party during transmission over any public networks or otherwise. You bear the risk of communicating with us electronically and we are not responsible for any resulting loss or damage. In particular, email sent to or from the Sites may not be secure, and you should therefore take special care in deciding what information you send to us via email.

The Right to Verify the Accuracy of Information We Collect

Keeping information accurate and up-to-date is important to us. You may be able to personalize your use of our Sites by becoming a registered user, and by doing so, we may be better able to assist you with your specific needs. Once registered, you can review and maintain your account information at any time. Your account information is secure and is accessible by using a password that you select. Do not share your password with anyone.

Use of “Cookies” or Other Data Collection Tools

A “cookie” is a piece of information which a web server may place on your computer when you visit a website. Many cookies last only through a single Sites session or visit. Others may have an expiration date or may remain on your computer until you delete them.

We use cookies and other technologies to, among other things, improve your user experience, maintain continuity during a user session, gather data about the usage of our Sites for research and other purposes, store your preferences for certain kinds of information and marketing offers, or store a user name or encrypted identification number so that you do not have to provide this information every time you return to our Sites.

Our cookies will track your online activity on the Sites and allow us to capture and aggregate information collected from you during multiple visits to our Sites. Our cookies do not gather personally identifiable information, though they may allow us to connect your Sites’ visit to your personally identifiable information.

You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies, you may not be able to use certain of our online products and services or Sites features.

We may occasionally use other companies to set cookies on our Sites and gather cookie information for us. In some cases, we may also use another company to operate web servers or process credit card purchases for our Sites. We use the cookie information gathered by these companies in the same manner as stated above.

We may use third-party cookies as part of remarketing activities we conduct with third-party vendors, to help provide you with relevant promotional offers as you use the Internet. As part of these remarketing activities, these third-party cookies may record your visits to the Sites and other websites visited prior to using the Sites. Such cookies can then be used to serve advertisements to you on other Sites. You may choose to be exempt from the use of third-party remarketing cookies at the third-party advertising privacy page. Alternatively, you may opt-out of remarketing on the third-party network and similar networks at the Network Advertising Initiative opt out page. Opting out will not prevent advertisements from being served to you on the Internet; it will only affect advertisements that utilize remarketing cookies to serve advertisements on the specified advertising networks. We are not responsible for the activities of other parties that may not comply with your opt-out requests.

This website uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Any data collected will be used in accordance with our own privacy policy and Google’s privacy policy. You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if up can opt out of third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.

In addition to the information we collect from cookies, we also obtain information which you provide to us online or through other communication with us. In some cases, we retain both the cookie information and the information you provide to us online. In other cases, we retain only the cookie and/or online information you give us if you request us to do so for your use in subsequent sessions.

An “IP address” is a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet. When you visit our Sites, we may view the IP address of the device you use to connect to the Internet. We use this information to determine the general physical location of the device and understand from what regions of the world our Sites visitors come. We also may use this information to enhance our Sites or to determine your eligibility to participate in promotions (such as one per IP address).

Certain pages on our Sites contain “web beacons” (also known as Internet tags, pixel tags and clear GIFs). These web beacons allow third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third party.

Promotional Emails

If we send you any promotional emails, and you no longer would like to receive such emails, please simply follow the “Unsubscribe” instructions on those emails. Your email address will be removed from our marketing list. Please allow us a reasonable period of time in order to satisfy your request.

Visiting Our Sites From Outside of the United States

If you are visiting our Sites from outside the United States, please be aware that your information may be transferred to, stored or processed in the United States, where some of our servers are located. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Policy.

Changes to Our Site’s Privacy Policy

We may change this Policy at any time and from time to time. The most recent version of the Policy is reflected by the version date located at the bottom of this Policy. This Policy is not intended to and does not create any contractual or other legal right in or on behalf of any party.

Contacting Us

If you have any questions about this Policy or would like to learn more about how we protect privacy, please contact us as directed on our website at https://www.instrusafe.com/contact/.

Effective Date: June 12, 2015