Aviso de Privacidad

Bienvenido

Quadre Medical valora su privacidad y la protección de sus Datos Personales. Este Aviso de Privacidad de Quadre Medical  (“Aviso”) explica cómo recopilamos, usamos, compartimos, transferimos y procesamos la información recopilada de usted o sobre usted (“Datos Personales”) (como se define más adelante) por cualquier subsidiaria o afiliada de Quadre Medical (colectivamente “Quadre Medical ”, “nosotros”, “nuestro” o “nos”).

La filial o empresa afiliada de  Quadre Medical con la que usted, su profesional sanitario o su paciente interactúa, o que posee y gestiona el producto o servicio, es, cuando corresponda, la entidad responsable de la recopilación y el uso de sus datos personales (conocida en algunas jurisdicciones como responsable del tratamiento). Encontrará una lista de los responsables del tratamiento y sus datos de contacto en la sección «Contáctenos» y en el Anexo 1 de este Aviso.

Por favor, revise detenidamente este Aviso. Procesaremos los Datos Personales que recopilemos de conformidad con la legislación aplicable y según se explica en este Aviso(a menos que, como se explica a continuación, rija una política o aviso independiente). En algunos casos, si no desea proporcionarnos su información, es posible que ciertos Productos y Servicios no estén disponibles. En la medida en que lo permita la legislación aplicable, al proporcionarnos sus Datos Personales o interactuar con nosotros de cualquier otra forma, usted acepta este Aviso. Si no está de acuerdo con nuestras políticas y prácticas, puede optar por no utilizar nuestros Productos y Servicios ni interactuar con nosotros de ninguna otra forma.

Si proporciona datos personales de otra persona, tenga en cuenta que es responsable de cumplir con todas las leyes de privacidad y protección de datos aplicables antes de proporcionar esa información a Quadre Medical (incluida la obtención del consentimiento, si fuera necesario y requerido).

*Finalidad de este Aviso de Privacidad*

Este Aviso describe los tipos de Datos Personales que Quadre Medical puede recopilar o procesar, cómo podemos usar y divulgar dichos Datos Personales y cómo puede ejercer los derechos que le asisten en relación con el procesamiento de sus Datos Personales. Este Aviso se aplica a los Datos Personales que recopilamos o procesamos.

Algunos ejemplos de situaciones en las que recopilamos datos personales incluyen:

A través de las actividades y servicios en línea que ofrecemos (a través de este y otros sitios web, encuestas web, boletines informativos, aplicaciones, servicios o canales de mensajería en línea, incluidos los “chats” en línea con personas en vivo e inteligencia artificial (“IA”), redes sociales, nuestros centros de atención telefónica al cliente, correo electrónico o mensajes SMS/de texto, y de otra manera) (“Servicios en línea”);

A través de su cuenta y nuestros productos o servicios, ya sean proporcionados directamente a usted o a su paciente, o si usted es un paciente, a través de su médico, hospital, centro de tratamiento médico o de escaneo, u otro proveedor de atención médica (colectivamente, “Proveedor de Atención Médica”, que se refiere tanto a la institución, organización o empresa Proveedor de Atención Médica, como a las personas empleadas por o que trabajan para o con dicha organización);

En otras situaciones en las que usted interactúa con nosotros, incluyendo, pero no limitándose a, la interacción con nosotros al visitar nuestros sitios, oficinas o nuestros eventos (como ferias comerciales y conferencias) (“Eventos”) (nuestro Servicio en línea, Eventos y otros productos y servicios se denominan colectivamente en este Aviso como “Productos y Servicios”).

Relacionadas con las actividades que realizamos para reclutar participantes para ensayos clínicos o con las actividades relacionadas con la identificación y contratación de investigadores y su personal;

En relación con sucesos adversos, quejas e informes;

Cuando interactúas con nosotros en calidad profesional, por ejemplo, si eres un proveedor de atención médica o un empleado de una empresa con la que hacemos negocios o a la que proporcionamos productos y servicios;

Cuando realizamos actividades de reclutamiento de personal; o

En cualquier lugar donde se publique o se haga referencia a este aviso.

Quadre Medical puede tener otros avisos de privacidad específicos que se apliquen a ciertas situaciones, como avisos de privacidad para productos y servicios concretos. Si se le proporcionó un aviso o política de privacidad diferente, dichas políticas o avisos regirán nuestras interacciones con usted, no este.

Datos personales, recopilación, finalidades, origen y destinatarios

Los «Datos Personales» son cualquier información, registrada electrónicamente o de otra forma, que pueda utilizarse para identificar a una persona específica o que podamos vincular directamente con ella, como el nombre, la dirección, la dirección de correo electrónico, el número de teléfono, el número de tarjeta de crédito o la información sobre salud o tratamiento, según corresponda. En algunas jurisdicciones, los Datos Personales pueden incluir información que identifica indirectamente a una persona, como un número único asignado a un paciente por un profesional sanitario, incluso sin otra información que permita su identificación. Tenga en cuenta que, en el caso de los pacientes, como se describe a continuación, solemos recibir información sobre usted de su profesional sanitario.

Personal Data may include information considered sensitive in some jurisdictions, such as biometric information, genetic information, health information, financial account information, specific geolocation, ethnic or racial origin, information concerning your sex life or your sexual orientation, social security number, driver’s license number, state identification card number, passport number, and other similar information. Personal Data that could be considered sensitive Personal Data under applicable law is indicated with a caret (^) in the chart below.

The below table is a high-level summary of the types of Personal Data we may collect from you. Following that high-level summary is additional detail and information on how we collect, process, and use Personal Data and the potential sources and recipients of your Personal Data, now and over the past twelve months. Some jurisdictions require us to state the legal bases for processing your Personal Data, which is included below, but please note that not all jurisdictions may recognize all legal bases.  The types of Personal Data we collect and disclose depends on your relationship with Quadre Medical. Not all of the categories listed in the following charts may apply to you. If the nature of your relationship with Quadre Medical changes, additional categories of Personal Data may also apply.

Identity and Contact Information

Age, Gender and Other Characteristics

Video, Audio, and Recorded Information

Technical Information

Health Information

Commercial and Financial Information

Professional and Educational Information

Anonymized / De-Identified Data

Users of Online Services, Visitors to Our Websites and Physical Locations, and Senders of Inquiries

X^

X^

X

X

X^

X^

X

Patients and Users of Medical Devices

X^

X^

X^

X^

X^

X^

X

Healthcare Providers

X^

X^

X

X

X^

X^

X

Employment and Apprenticeship Candidates

X^

X^

X

X

X^

X

Business Partners and Their Employees, Agents, and Contractors

X^

X^

X

X

X^

X^

X

Attendees and Participants at  Quadre Medical Events

X^

X^

X

X

X^

X^

X

X

Clinical Investigators and Members of Investigator Teams

X^

X^

X

X

X^

X^

X

Clinical Study Candidates

X^

X^

X

X^

X^

X^

X

X

Children+

X^

X^

X^

X^

X^

X

X

Personal Data that may be considered sensitive is noted with a “^”. 

+Quadre Medical may process Personal Data of minors who are users of a Quadre Medical product. In those instances, Quadre Medical seeks consent from the minor’s parents or legal guardians to process their Personal Data. Quadre Medical does not knowingly collect, maintain, disclose, or otherwise process Personal Data from minors below the age of 16 in other circumstances, including through Online Services.

Users of Online Services, Visitors to Our Websites and Physical Locations, and Senders of Inquiries

We may process your Personal Data when you (1) visit, use, register for, and/or engage with our Online Services; (2) sign up for our newsletters or other informational or marketing materials; (3) submit inquiries to us both online (e.g., via email, via chatbot) or offline (e.g., by written letters); (4) contact our customer service centers through phone, email, SMS/text messages, chats, or otherwise; (5) complete a survey or other online questionnaire or form; and/or (6) participate in Events.

We process these types of Personal Data:

We obtain this Personal Data from:

We process this Personal Data for the following purposes:

We process this Personal Data under the following legal bases:

We may share this Personal Data with**:

Identity and Contact Information, such as:

·   first and last name or unique pseudonym

·   honorifics and titles, preferred form of address

·   employer/company

·   email address

·   postal address

·   phone number

·   username or code and password^, security answers^, and user preferences

·   contact information for related persons, such as authorized users of your account or designated representatives

·   customer number

·   company ID number such as account number

·   National Provider Identifier (NPI) number

Other Personal Information, such as:

·   age

·   gender

·   preferred language

·   marital status

·   disability^

·   date of birth

Video, Audio and Recorded Information, such as:

·   still images

·   video (including via CCTV)

·   voicemails

·   recordings of your interactions with our Online Services, including with our customer service, whether through phone, email, SMS/text message, or chat

Technical Information, such as:

·   Internet Protocol (IP) addresses  (which may identify your general geographic location or company)

·   browser type and browser language

·   device type

·   advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID))

·   date and time you use our Products and Services

·   Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services

·   Activity and online behavior while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read

·   data collected from cookies or other similar technologies

·   geolocation information****

Anonymized / De‑identified Data

Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws***

·   you directly

·   those authorized to provide on your behalf such as your caregiver or authorized representative

·   your devices

·   our security systems (including CCTV)

·   third parties that provide access to information you make publicly available, such as social media

·   companies conducting non-clinical research such as market research companies

·   business partners and other third parties that assist us in providing and improving our Products and Services

·   to provide you with our Products and Services

·   to communicate with you

·   to administer our relationship with your organization

·   to send you updates

·   to identify and authenticate you

·   to customize content for you and tailor your experience when using our Products and Services

·   to detect security incidents

·   to protect against malicious, fraudulent or illegal activity

·   to ensure the appropriate use of our Products and Services

·   to improve our Products and Services

·   for short-term, transient use

·   for administrative purposes

·   for, internal research, and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services

·   for quality assurance and to assist in training and development of our representatives

·   to determine and verify Products and Services eligibility and coverage

·   in connection with adverse event and complaint tracking and reporting

·   to procure third party products and services, including to manage and satisfy related third party contractual obligations

·   for marketing, advertising, and promotion, including to contact you regrading programs, Products and Services, and topics that may be of interest or useful to you

·   To improve customer experience and provide targeted marketing activities and interaction through AI services and tools

·   to comply with legal and regulatory obligations

·   to perform internal and external audit, investigations and other reviews

·   for the purposes of our legitimate interests

·   in preparation for or to perform a contract with you

·   to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights

·   to facilitate the provision of healthcare or treatment

·   for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices

·   in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*

·   Quadre Medical , our affiliates, subsidiaries, and related companies

·   Healthcare Providers

·   your company / employer

·   individuals or entities that you designate or instruct us to share your Personal Data with

·   authorized representatives, family members, and caregivers

·   third parties who assist with fraud prevention, detection, and mitigation

·   third parties who assist with our information technology and security programs and our loss prevention programs

·   Quadre Medical external lawyers, auditors, and consultants

·   partners that assist us in providing the Products or Services or help us improve our marketing or administration

Patients and Users of Medical Devices

We may process your Personal Data when you are the existing or prospective patient of a Healthcare Provider who is a  Quadre Medical customer and/or when you receive or use a Quadre Medical medical device (including, where applicable, mobile apps).

We process these types of Personal Data:

We obtain this Personal Data from:

We process this Personal Data for the following purposes:

We process this Personal Data under the following legal bases:

We may share this Personal Data with**:

Identity and Contact Information, such as:

·   first and last name or a unique pseudonym

·   honorifics and titles, preferred form of address

·   employer / company

·   email address

·   postal address

·   phone number

·   username or code and password,^ security answers^, and user preferences

·   contact information for related persons, such as authorized users of your account or designated representatives

Other Personal Information, such as:

·   age

·   gender

·   preferred language

·   marital status

·   disability^

·   ethnicity^

·   date of birth

Video, Audio and Recorded Information, such as:

·   still images

·   video (including via CCTV)

·   recordings of your calls with our customer service representatives

·   voicemails

·   recordings of your interactions with our Online Services, whether through email, SMS/text message, or chat

·   pictures and videos of diagnosis and treatment activities^

Technical Information, such as:

·   Internet Protocol (IP) addresses (which may identify your general geographic location or company)

·   browser type and browser language

·   device type

·   advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID))

·   date and time you use our Products and Services

·   Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services

·   activity and online behavior while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read^

·   data collected from cookies or other similar technologies

·   geolocation information****

Health Information, such as:

·   identification of pathologies/diseases^

·   identification number associated with your Products^

·   areas of interest in medical research^

·   treatment and surgery dates^

·   medical history and treatment information^

·   patient-reported outcome measures (e.g., responses to questionnaires and surveys about your health or treatment)^

·   DICOM images, X-rays, magnetic resonance imaging, and medical scans^

·   user activity^

·   therapy completion and use details^

·   communications with your Healthcare Provider , including audio video, or other recordings from telehealth sessions^

·   drug allergies, prescriptions and dosing ^

·   health values taken, such as heart rate and blood pressure, gait patterns or rhythms ^ 

·   adverse event information^

·   health insurance information and other information on payment for healthcare services^

·   pregnancy status^

·   contact information for designated recipients of your health information

·   location data^

·   pictures and videos of diagnosis and treatment activities ^

·   patient ID number^

Commercial and Financial Information, such as:

·   Products and Services purchased, obtained, or considered

·   Bank account number and details^

·   request documentation

·   customer service records

·   financial transaction history

·   financial account number^

·   other payment information

Anonymized / De‑identified Data

Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws***

·   you directly

·   Healthcare Providers

·   those authorized to provide Personal Data on your behalf, such as your caregiver or authorized representative

·   your devices

·   our security systems (including CCTV)

·   third parties that provide access to information you make available, such as social media

·   companies conducting non-clinical research such as market research companies

·   our business partners or other third parties that assist us in providing and improving our Products and Services

·   Your use of Quadre Medical  Products or Services

·   to provide you with our Products and Services

·   to communicate with you

·   to administer our relationship with you

·   to send you updates

·   to identify and authenticate you

·   to detect security incidents

·   to protect against malicious, fraudulent or illegal activity

·   to ensure the appropriate use of our Products and Services

·   to improve our Products and Services

·   for short-term, transient use

·   for administrative purposes

·   for quality assurance

·   to generate surgeon- specific performance analytics relating to their patients’ pre-operative, intra-operative, and post-operative insights and to further enable Healthcare Providers to  compare aggregated, deidentified performance analytics across other Healthcare Providers – either regionally or globally

·   for internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services

·   to determine and verify Products and Services eligibility and coverage

·   in connection with adverse event and complaint tracking and reporting

·   to procure third party products and services, including to manage and satisfy related third party contractual obligations

·   for marketing, advertising, and product promotion, including to contact you regarding programs, Products and Services, and topics that may be of interest or useful to you

·   to comply with legal and regulatory obligations

·   for the purposes of our legitimate interests

·   for medical diagnosis and the provision of healthcare or treatment

·   to comply with legal and regulatory obligations and to establish, exercise or defend our legal claims or rights.

·   in preparation for or to perform a contract

·   to protect vital interests or in the public interest

·    for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices

·   for scientific or historical research or statistical purposes

·   in circumstances where we have requested and received consent, including from Patients directly for their use of certain Products or Services, and for other purposes that may be required or allowed by law*

·   Quadre Medical , our affiliates, subsidiaries, and related companies

·   Healthcare Providers

·   individuals or entities that you designate or instruct us to share your Personal Data with

·   authorized representatives, family members, and caregivers

·   third parties who assist with fraud prevention, detection, and mitigation

·   third parties who assist with our information technology and security programs and our loss prevention programs

·   Quadre Medical external lawyers, auditors, and consultants

·   third parties with your consent

·   partners that assist us in providing the Products or Services or help us improve our marketing or administration

Healthcare Providers

We may process your Personal Data when you are a Healthcare Provider who is a current or prospective Quadre Medical  customer, uses Quadre Medical  Products and Services, or treats patients with Quadre Medical  Products and Services, including use of Quadre Medical online portals.

We process these types of Personal Data:

We obtain this Personal Data from:

We process this Personal Data for the following purposes:

We process this Personal Data under the following legal bases:

We may share this Personal Data with**:

Identity and Contact Information, such as:

·   first and last name or unique pseudonym

·   honorifics and titles, preferred form of address

·   employer / company

·   email address

·   postal address

·   phone number

·   username or code and password^, security answers^, and user preferences

·   contact information for related persons, such as authorized users of your account or designated representatives

·   customer number

·   company ID number such as account number

·   National Provider Identifier (NPI) number

·   Unique personal identifier

·   signature

Other Personal Information, such as:

·   age

·   gender

·   preferred language

·   marital status

·   disability^

·   date of birth

Video, Audio, and Recorded Information, such as:

·   still images

·   video (including via CCTV)

·   recordings of your calls with our customer service representatives

·   voicemails

·   recordings of your interactions with our Online Services, whether through email, SMS/text message, or chat

·   pictures and videos of treatment activities or training activities

Technical Information, such as:

·   Internet Protocol (IP) addresses (which may identify your general geographic location or company)

·   browser type and browser language

·   device type

·   advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID))

·   Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services

·   activity and online behavior while on our Products and Services and referring websites or applications including forms and other information submitted, videos watched, your clicks on our site pages, browsing time, and product descriptions read

·   data collected from cookies or other similar technologies

·   geolocation information****

Commercial and Financial Information, such as:

·   Products and Services purchased, obtained, or considered

·   Bank account number and details^

·   request documentation

·   customer service records

·   financial transaction history

·   financial account number^

·   other payment information

·   tax identification number^

Professional and Educational Information, such as:

·   job title or position

·   your employer, company with which you are associated, or principal

·   working location

·   National Provider Identifier (NPI)number

·   state medical license number

·   work skills

·   employment history

·   graduate degrees

·   certifications

·   professional memberships

·   specialized training

·   responses to surveys and questionnaires

·   enrollment and attendance history for our education and training events

·   records of collaborations with Quadre Medical , such as consulting and other engagements

·   information from references

·   background checks

Product Usage Information, such as:

·   technical and surgical data (pre-, intra-, and post-operative) and performance metrics derived from your use of certain Products or Services

·   date and time you use our Products and Services, including the Products and Services used

·   user preferences

·   purchasing tendencies

Anonymized / De‑identified Data

Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws***

·   you directly

·   Healthcare Providers

·   your employer, company with which you are associated, or principal

·   third party data repositories

·   your devices

·   your references and third parties that assist us in conducting background checks

·   our security systems (including CCTV)

·   third parties that provide access to information you make available, such as social media companies

·   companies conducting non-clinical research such as market research companies

·   your patients

·   clinical investigators and/or members of investigator teams

·   the use of Quadre Medical Products or Services

·   sales representatives

·   imaging centers

·   to provide you with our Products and Services

·   to communicate with you

·   to administer our relationship with your organization

·   to send you updates

·   to identify and authenticate you

·   to customize content for you and tailor your experience when using our Products and Services

·   to detect security incidents

·   to protect against malicious, fraudulent or illegal activity

·   to ensure the appropriate use of our Products and Services

·   to provide medical education

·   to improve our Products and Services

·   for short-term, transient use

·   for administrative purposes

·   for quality assurance

·   for internal research, and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services

·   for quality assurance

·   and to assist in training and development of our representatives: in connection with adverse event and complaint tracking and reporting

·   to procure third party products and services, including to manage and satisfy related third party contractual obligations

·   for marketing, advertising, and promotion, including to contact you regarding programs, Products and Services, and topics that may be of interest or useful to you

·   to improve customer experience and provide targeted marketing activities and interaction through AI services and tools

·   to comply with legal and regulatory obligations

·   to generate surgeon- specific performance analytics relating to their patients’ pre-operative, intra-operative, and post-operative insights and to further enable Healthcare Providers to  compare aggregated, deidentified performance analytics across other Healthcare Providers – either regionally or globally

·   for preoperative planning

·   to perform internal and external audit, investigations and other reviews

·   for the purposes of our legitimate interests

·   for the purposes of medical diagnosis and the provision of healthcare or treatment

·   to comply with legal or statutory obligations and to establish, exercise, or defend our legal claims and rights

·   in preparation for or to perform a contract

·   to protect vital interests or in the public interest

·   for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices

·   for scientific or historical research or statistical purposes.

·   In circumstances where we have requested and received consent, including for the use of certain Products and Services, and for other purposes that may be required or allowed by law*

·  Quadre Medical , our affiliates, subsidiaries, and related companies

·   Healthcare Providers

·   your company/employer

·   your patients

·   your references and third parties that assist us in conducting background checks

·   individuals or entities that you designate or instruct us to share your Personal Data with

·   authorized representatives, family members, and caregivers

·   third parties who assist with fraud prevention, detection, and mitigation

·   third parties who assist with our information technology and security programs and our loss prevention programs

·  Quadre Medical  external lawyers, auditors, and consultants

·   partners that assist us in providing the Products or Services or help us improve our marketing or administration

·   Ethics committees

·   Public authorities and governmental bodies

Employment and Apprenticeship Candidates

We may process your Personal Data when you apply or are a candidate for employment or apprenticeship at Quadre Medical .

We process these types of Personal Data:

We obtain this Personal Data from:

We process this Personal Data for the following purposes:

We process this Personal Data under the following legal bases:

We may share this Personal Data with**:

Identity and Contact Information, such as:

·   first and last name or unique pseudonym

·   honorifics and titles, preferred form of address

·   employer/company

·   email address

·   postal address

·   phone number

·   username or code and password^, security answers^, and user preferences

·   contact information for related persons, such as authorized users of your account or designated representatives

·   National Provider Identifier (NPI) number

·   Social Security Number (SSN)^

·   signature

Other Personal Information, such as:

·   Age

·   Preferred language

·   gender

·   marital status

·   disability^

·   ethnicity^

·   date of birth

Technical Information, such as:

·   Internet Protocol (IP) addresses (which may identify your general geographic location or company)

·   browser type and browser language

·   device type

·   advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID))

·   date and time you use our Products and Services

·   Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services

·   activity and online behavior while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read

·   data collected from cookies or other similar technologies

·   geolocation information****

Professional and Educational Information, such as:

·   job title or position

·   your employer, company with which you are associated, or principal

·   working location

·   National Provider Identifier (NPI) number

·   State medical license number

·   work skills

·   employment history

·   graduate degrees

·   certifications

·   professional memberships

·   specialized training

·   responses to surveys and questionnaires

·   information from references

·   background checks^

Anonymized / De‑identified Data

Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws***

·   you directly

·   your employer, company with which you are associated, or principal

·   your references and third parties that assist us in conducting background checks

·   those authorized to provide Personal Data on your behalf

·   your devices

·   our security systems (including CCTV)

·   third parties that provide access to information you make available, such as social media companies

·   companies conducting non-clinical research such as market research companies

·   our business partners or other third parties that assist us in providing and improving our Products and Services and in hiring employees and contractors

·   to communicate with you

·   to administer our relationship

·   to send you updated, including with respect to updates on new employment opportunities

·   to identify and authenticate you

·   to detect security incidents

·   to protect against malicious, fraudulent, or illegal activity

·   for short-term, transient use

·   for administrative purposes

·   for  internal research and development to evaluate the effectiveness or improve our Products and Services and to develop new products and services

·   to procure third party products and services, including to manage and satisfy related third party contractual obligations

·   for marketing, advertising and promotion, including to contact you regarding programs, Products and Services, and topics that may be of interest or useful to you

·   for the purposes of our legitimate interests

·   in preparation for or to perform a contract with you

·   to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights

·   in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*

·  Quadre Medical , our affiliates, subsidiaries, and related companies

·   your references

·   individuals or entities that you designate or instruct us to share your Personal Data with

·   third parties who assist with fraud prevention, detection, and mitigation

·   third parties who assist with our information technology and security programs and our loss prevention programs

·   third parties who assist us in hiring and conducting background checks.

·   Quadre Medical external lawyers, auditors, and consultants

·   partners that assist us in providing the Products or Services or help us improve our marketing or administration

Business Partners and Their Employees, Agents, and Contractors

We may process your Personal Data when you are a current or former business partner or an employee, agent, or contractor of a Quadre Medical  business partner, including collaboration partners, key opinion leaders, and vendors, suppliers of Quadre Medical.

We process these types of Personal Data:

We obtain this Personal Data from:

We process this Personal Data for the following purposes:

We process this Personal Data under the following legal bases:

We may share this Personal Data with**:

Identity and Contact Information, such as:

·   first and last name or unique pseudonym

·   honorifics and titles, preferred form of address

·   employer/company

·   email address

·   postal address

·   phone number

·   username or code and password^, security answers^, and user preferences

·   customer number

·   company ID number such as account number

·   National Provider Identifier (NPI) number

·   signature

Other Personal Information, such as:

·   age

·   gender

·   marital status

·   preferred language

·   disability^

·   date of birth

Technical information, such as:

·   Internet Protocol (IP) addresses (which may identify your general geographic location or company)

·   browser type and browser language

·   device type

·   advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID))

·   date and time you use our Products and Services

·   Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services

·   activity and online behavior while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read

·   data collected from cookies or other similar technologies

·   geolocation information****

Commercial and Financial Information, such as:

·   Products and Services purchased, obtained, or considered

·   request documentation

·   customer service records

·   financial transaction history

·   financial account number

·   bank account number and details^

·   other payment information

·   tax identification number^

Professional and Educational Information, such as:

·   job title or position

·   your employer, company with which you are associated, or principal

·   working location

·   National Provider Identifier (NPI) number

·   state medical license number

·   work skills

·   employment history

·   graduate degrees

·   certifications

·   professional memberships

·   specialized training

·   responses to surveys and questionnaires

·   enrollment and attendance history for our education and training events

·   records of collaborations with Quadre Medical , such as consulting and other engagements

·   information from references

·   background checks^

Anonymized / De‑identified Data

Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws***

·   you directly

·   your employer, company with which you are associated, or principal

·   your references and third parties that assist us with background checks

·   your devices

·   our security systems (including CCTV)

·   third parties that provide access to information you make available, such as social media companies

·   companies conducting non-clinical research such as market research companies

·   business partners or other third parties that assist us in providing and improving our Products and Services

·   Healthcare Providers

·   clinical investigators and/or members of investigator teams

·   patients

·   to provide you with our Products and Services

·   to communicate with you

·   to administer our relationship with your organization

·   to send you updates

·   to identify and authenticate you

·   to customize content for you and tailor your experience when using our Products and Services

·   to detect security incidents

·   to protect against malicious, fraudulent or illegal activity

·   to ensure the appropriate use of our Products and Services

·   to improve our Products and Services

·   for short-term, transient use

·   for administrative purposes

·   for internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services

·   for quality assurance and to assist in training and development of our representatives

·   in connection with adverse event and complaint tracking and reporting

·   for marketing, advertising, and product promotion, including to contact you regarding programs, Products and Services, and topics that may be of interest

·   to improve customer experience and provide targeted marketing activities and interaction through AI services and tools

·   to procure third party products and services, including to manage and satisfy related third party contractual obligations

·   to comply with legal and regulatory obligations

·   To conduct screenings against sanctions databases  to ensure compliance with applicable import and export regulations

·   to perform internal and external audit, investigations and other reviews

·   for the purposes of our legitimate interests

·   for medical diagnosis and the provision of healthcare or treatment

·   to comply with legal  and regulatory obligations and to establish, exercise, or defend our legal claims and rights

·   in preparation for or to perform a contract with you

·   for reasons of public health, including  ensuring high standards of quality and safety of healthcare and medical devices

·   for scientific or historical research or statistical purposes

·   in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*

·  Quadre Medical , our affiliates, subsidiaries, and related companies

·   Healthcare Providers

·   patients

·   your company / employer

·   your references

·   authorized legal representatives

·   third parties who assist with fraud prevention, detection, and mitigation

·   third parties who assist with our information technology and security programs and our loss prevention programs

·   third parties who assist us in hiring and conducting background checks.

·  Quadre Medical external lawyers, auditors, and consultants

·   partners that assist us in providing the Products or Services or help us improve our marketing or administration

Attendees and Participants at Quadre Medical Events

We may process your Personal Data when you attend or participate in professional and educational events or conferences we sponsor or hold.

We process these types of Personal Data:

We obtain this Personal Data from:

We process this Personal Data for the following purposes:

We process this Personal Data under the following legal bases:

We may share this Personal Data with**:

Identity and Contact Information, such as:

·   first and last name or unique pseudonym

·   honorifics and titles, preferred form of address

·   employer/company

·   email address

·   postal address

·   phone number

·   username or code and password^, security answers^, and user preferences

·   contact information for related persons, such as authorized users of your account or designated representatives

·   customer number

·   company ID number such as account number

·   National Provider Identifier (NPI) number

·   signature

Other Personal Information, such as:

·   age

·   gender

·   marital status

·   preferred language

·   disability^

·   date of birth

Video, Audio, and Recorded Information, such as:

·   still images

·   video (including via CCTV)

Technical Information, such as:

·   Internet Protocol (IP) addresses (which may identify your general geographic location or company)

·   browser type and browser language

·   device type

·   advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID))

·   date and time you use our Products and Services

·   Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services

·   Activity and online behavior while  on our Products and Services and referring websites or applications including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read

·   data collected from cookies or other similar technologies

·   geolocation information****

Commercial and Financial Information, such as:

·   Products and Services purchased, obtained, or considered

·   bank account number and details^

·   request documentation

·   financial transaction history

·   financial account number^

·   other payment information

·   tax identification number^

Professional and Educational Information, such as:

·   job title or position

·   your employer, company with which you are associated or principal

·   working location

·   National Provider Identifier (NPI) number

·   State medical license number

·   work skills

·   employment history

·   graduate degrees

·   certifications

·   specialized training

·   responses to surveys and questionnaires

·   enrollment history for our education and training events

·   records of collaborations with

Quadre Medical , such as consulting and other engagements  

Anonymized / De‑identified Data

Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws***

·   you directly

·   Healthcare Providers

·   your employer, company with which you are associated, or principal

·   those authorized to provide Personal Data on your behalf

·   your devices

·   our security systems (including CCTV)

·   third parties that provide access to information you make available, such as social media companies

·   companies conducting non-clinical research such as market research companies

·   our business partners or other third parties that assist us in providing and improving our Products and Services

·   to register you for the event or conference and other attendance-related purposes

·   to communicate with you

·   to administer our relationship with your organization

·   to send you updates

·   to identify and authenticate you

·   to detect security incidents

·   to protect against malicious, fraudulent, or illegal activity

·   for short-term, transient use

·   for administrative purposes

·   for internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services

·   for marketing, advertising, and promotion, including to contact you regarding programs, Products and Services, and topics that may be of interest or useful to you

·   to improve customer experience and provide targeted marketing activities and interaction through AI services and tools

·   to comply with legal and regulatory obligations

·   to perform internal and external audit, investigations and other reviews

·   for the purposes of our legitimate interests

·   in preparation for or to perform a contract with you

·   to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights

·   for scientific or historical research or statistical purposes

·   in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*

·  Quadre Medical , our affiliates, subsidiaries, and related companies

·   Healthcare Providers

·   Your company/employer

·   Other third parties attending the Event

·   individuals or entities that you designate or instruct us to share your Personal Data with

·   third parties who assist with fraud prevention, detection, and mitigation

·   third parties who assist with our information technology and security programs and our loss prevention programs

·  Quadre Medical external lawyers, auditors and consultants

·   Partners that assist us in providing or improving our Events,  Products and  Services or help us improve our marketing or administration

Clinical Investigators and Members of Investigator Teams

We may process your Personal Data if you are an existing or prospective clinical investigator or a member of an investigation team for a clinical study that Quadre Medical sponsors.

We process these types of Personal Data:

We obtain this Personal Data from:

We process this Personal Data for the following purposes:

We process this Personal Data under the following legal bases:

We may share this Personal Data with**:

Identity and Contact Information, such as:

·   first and last name or unique pseudonym

·   honorifics and titles, preferred form of address

·   employer / company

·   email address

·   postal address

·   phone number

·   username or code and password^, security answers^, and user preferences

·   contact information for related persons, such as authorized users of your account or designated representatives

·   customer number

·   company ID number such as account number

·   National Provider Identifier (NPI) number

·   Social Security Number (SSN)^

·   signature

Other Personal Information, such as:

·   age

·   gender

·   preferred language

·   disability^

·   date of birth

Visual, Audio, and Recorded Information, such as:

·   still images

·   video (including via CCTV)

·   voicemails

·   recordings of your interactions with our Online Services, whether through email, SMS/text message, or chat

·   pictures and videos of treatment activities

Technical Information, such as:

·   Internet Protocol (IP) addresses (which may identify your general geographic location or company)

·   browser type and browser language

·   device type

·   advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID))

·   date and time you use our Products and Services

·   Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services

·   activity and online behavior while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read

·   data collected from cookies or other similar technologies

·   geolocation information****

Commercial and Financial Information, such as:

·   bank account number and details^

·   customer service records

·   financial transaction history

·   financial account number^

·   other payment information

Professional and Educational Information, such as:

·   job title or position

·   your employer, company with which you are associated, or principal

·   working location

·   National Provider Identifier (NPI) number

·   state medical license number

·   work skills

·   employment history

·   graduate degrees

·   certifications

·   specialized training

·   responses to surveys and questionnaires

·   enrollment history for our education and training events

·   records of collaborations with Quadre Medical , such as consulting and other engagements

·   information from references

·   background checks^



Product Usage Information, such as:

·   Technical and surgical data (pre-, intra-, and post-operative) derived from your use of certain Products or Services

·   date and time you use our Products and Services, including the Products and Services used

Anonymized / De‑identified Data

Anonymized and/or de-identified data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws***

·   you directly

·   Healthcare Providers

·   your employer, company with which you are associated, or principal

·   your devices

·   those authorized to provide Personal Data on your behalf

·   your references and third parties that assist us in conducting background checks

·   our security systems (including CCTV)

·   third parties that provide access to information you make available, such as social media companies

·   companies conducting non-clinical research such as market research companies

·   business partners or other third parties that assist us in providing and improving our Products and Services

·   patients

·   other clinical investigators and/or members of investigator teams

·   to determine your suitability to the role

·   to assist us with running the clinical trial

·   to communicate with you

·   to administer our relationship with your organization

·   to send you updates

·   to identify and authenticate you

·   to customize content for you and tailor your experience when using our Products and Services

·   to detect security incidents

·   to protect against malicious, fraudulent, or illegal activity

·   to ensure the appropriate use of our Products and Services

·   to improve our Products and Services

·   for short-term, transient use

·   for administrative purposes

·   for internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services

·   for quality assurance and to assist in training and development of our representatives

·   in connection with adverse event and complaint tracking and reporting

·   to procure third party products and services, including to manage and satisfy related third party contractual obligations

·   to comply with legal and regulatory obligations

·   to perform internal and external audit, investigations and other reviews

·   for the purposes of our legitimate interests

·   in preparation for or to perform a contract with you

·   to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights

·   to protect vital interests or in the public interest

·   for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices

·   for scientific or historical research or statistical purposes

·   in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*

·  Quadre Medical , our affiliates, subsidiaries, and related companies

·   Healthcare Providers

·   other clinical investigators and/or members of investigator teams

·   your company / employer

·   your reference

·   individuals or entities that you designate or instruct us to share your Personal Data with

·   third parties who assist us in hiring and conducting background checks

·   third parties who assist with fraud prevention, detection, and mitigation

·   third parties who assist with our information technology and security programs and our loss prevention programs

·   Quadre Medical external lawyers, auditors, and consultants

·   Patients and their authorized representatives, family members, and caregivers

·   third parties that assist us in choosing clinical trial investigators

·   partners that assist us in providing the Products or Services or help us improve our marketing or administration

Clinical Study Candidates

We may process your Personal Data to determine whether you qualify for or would be interested in participating in a clinical trial and when you have been identified as a potential candidate for clinical studies sponsored by us.

If you are a participant in a clinical study or clinical trial, you should receive a separate privacy notice regarding the Personal Data we process for those purposes. That privacy notice—and not this Notice— governs our processing of such Personal Data once you are chosen for and participating in a trial.

We process these types of Personal Data:

We obtain this Personal Data from:

We process this Personal Data for the following purposes:

We process this Personal Data under the following legal bases:

We may share this Personal Data with**:

Identity and Contact Information, such as:

·   first and last name or unique pseudonym

·   honorifics and titles, preferred form of address

·   employer / company

·   email address

·   postal address

·   phone number

·   username or code and password^, security answers^, and user preferences

·   contact information for related persons, such as authorized users of your account or designated representatives

·   signature

Other Personal Information, such as:

·   age

·   gender

·   preferred language

·   marital status

·   disability^

·   ethnicity^

·   date of birth

Visual, Audio, and Recorded Information, such as:

·   still images

·   video (including via CCTV)

·   voicemails

·   recordings of your interactions with our Online Services, whether through email, SMS/text message, or chat

Technical Information, such as:

·   Internet Protocol (IP) addresses (which may identify your general geographic location or company)

·   browser type and browser language

·   device type

·   advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID))

·   date and time you use our Products and Services

·   Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services

·   activity and online behavior while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read^

·   data collected from cookies or other similar technologies

·   geolocation information****

Health Information, such as:

·   identification of pathologies/diseases^

·   areas of interest in medical research^

·   medical history and treatment information^

·   drug allergies^

·   health values taken, such as heart rate and blood pressure^

·   pregnancy status^

·   location data^

Commercial and Financial Information, such as:

·   Products and Services purchased, obtained, or considered

·   bank account number and details^

·   request documentation

·   customer service records

·   financial transaction history

·   financial account number^

·   other payment information

Anonymized / De‑identified Data

Anonymized and/or de-identified data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws***

·   you directly

·   Healthcare Providers

·   those authorized to provide Personal Data on your behalf

·   your devices

·   our security systems (including CCTV)

·   third parties that provide access to information you make available, such as social media companies

·   companies conducting non-clinical research such as market research companies

·   business partners or other third parties that assist us in providing and improving our Products and Services

·   clinical investigators and/or members of investigator teams

·   to determine your suitability and eligibility for participating in a clinical trial and to determine your interest in participating in a clinical trial

·   to communicate with you

·   to administer our relationship with you

·   to send you updates

·   to identify and authenticate you

·   to customize content for you and tailor your experience when using our Products and Services

·   to detect security incidents

·   to protect against malicious, fraudulent, or illegal activity

·   to ensure the appropriate use of our Products and Services

·   to improve our Products and Services

·   for short-term, transient use

·   for administrative purposes

·   for internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services

·   for quality assurance and to assist in training and development of our representatives

·   in connection with adverse event and complaint tracking and reporting

·   for marketing, advertising, and product promotion, including to contact you regarding programs, Products and Services, and topics that may be of interest or useful to you

·   to comply with legal and regulatory obligations

·   for the purposes of our legitimate interests

·   in preparation for or to perform a contract with you

·   to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights

·   to protect vital interests or in the public interest

·   for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices

·   for scientific or historical research or statistical purposes

·   in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*

·  Quadre Medical , our affiliates, subsidiaries, and related companies

·   Healthcare Providers

·   Clinical investigators and/or members of investigator teams

·   individuals or entities that you designate or instruct us to share your Personal Data with

·   partners that assist us in providing the Products or Services or help us improve our marketing or administration

Children

Quadre Medical may process Personal Data of minors who are users of a Quadre Medical  Product. In those instances, Quadre Medical seeks consent from the minor’s parents or legal guardians to process their Personal Data. Quadre Medical does not knowingly collect, maintain, disclose, or otherwise process Personal Data from minors below the age of 16 in other circumstances, including through Online Services or Interactions. The below relates solely to the use of Personal Data of children who are users of a Quadre Medical Product and whose parents or legal guardians have given consent.

We process these types of Personal Data:

We obtain this Personal Data from:

We process this Personal Data for the following purposes:

We process this Personal Data under the following legal bases:

We may share this Personal Data with**:

Identity and Contact Information, such as:

·   first and last name or unique pseudonym

·   honorifics and titles, preferred form of address

·   email address

·   postal address

·   phone number

·   username or code and password^, security answers^, and user preferences

·   contact information for related persons, such as authorized users of your account or designated representatives

Other Personal Information, such as:

·   age

·   gender

·   preferred language

·   disability^

·   ethnicity^

·   date of birth

Visual, Audio, and Recorded Information, such as:

·   still images

·   video (including via CCTV)

·   recordings of your calls with our customer service representatives

·   voicemails

·   recordings of your interactions with our Online Services, whether through email, SMS/text message, or chat

·   pictures and videos of treatment activities^

Technical Information, such as:

·   Internet Protocol (IP) addresses (which may identify your general geographic location or company)

·   browser type and browser language

·   device type

·   advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID))

·   date and time you use our Products and Services

·   Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services

·   activity and online behavior while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read^

·   data collected from cookies or other