This Privacy Policy (“Privacy Policy”) applies to information collected through any Turbett Surgical LLC (“Turbett”, “us” or “we”) website. It also applies to interactions with us in person or by telephone, text message, or other means.

Your privacy is very important to us and we have developed this Privacy Policy in order for you to understand how we collect, use, communicate and disclose information. This Privacy Policy governs information we receive from you or about you and explains how we may collect, use, and in some instances disclose this information.

Turbett may amend this Privacy Policy at any time. When we revise the Privacy Policy, we will post the new Privacy Policy on this page and change the effective date located at the end of the Privacy Policy. You should review this Privacy Policy before you interact with us.

Information we collect and how it is collected

1. Information you provide. Turbett collects personal information that individuals provide through voluntary submissions, such as email and online forms. Personal information means any information that may be used to identify an individual or household, including name and contact information. We may also collect limited financial information (primarily from organizations and not individuals) to complete transactions. The types and amount of personal information we collect may vary, depending on what information you choose to provide. Some of the ways in which we use this information are to:

• provide our products and services,
• provide you with content relevant to you,
• tailor your user experience,
• validate your identity,
• prevent fraud, and
• provide customer services including technical support.

2. Information from other sources. We may also collect personal information about you from other sources, such as other users of our products or services, our service providers and vendors, and other third party sources that you have permitted to share your information with us, in order to provide our services, more useful information, and a more personalized experience. We may also collect information from third-party marketing organizations.


3. Employment-Related Information. If you apply for a job, or are already employed with us, we may collect personal information in a number of circumstances. Personal information we may collect includes: name, address, telephone number and other contact information; educational or other credentials, employment history and experience, volunteer work, and other information necessary to evaluate a candidate’s suitability for employment; together with any other information we may collect with your consent or as required by applicable law.

4. Automatically Collected Information. Certain information is automatically collected when you visit our website. This can include the type of browser software you use, the operating system you’re running, the website that referred you, or your IP address.

We may also use cookies. A cookie is a text file that a web-service can store on your web browser and later retrieve. Cookies help our website remember information about your visit including your preferences and other information to help us enhance your user experience.

You may have the ability to change your browser settings to refuse to accept cookies. Please note, however, if you do not accept cookies, some features of the website may be unavailable to you. Additionally, your browser may have a “Do Not Track” feature. This lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Turbett does not currently respond to these signals.

What we use information for and when we may disclose it

We may use and/or share your information and information we collect in connection as follows:

• to improve our products and services;
• to disclose information to companies that provide support services to us (e.g. website hosts, software developers, researchers) that allow us to provide our products and services and that help us market our products and services, which companies may use information about you to perform their functions on our behalf;
• to communicate with you about our products and services;
• to process and manage your use of our products and services;
• to respond to your questions;
• if you participate in any social media or other online forum, we may disclose personal information that you post to others;
• with respect to the information you provide or information we collect about you in connection with our products and services, we may (i) analyze and disclose that information either in anonymized format that does not directly identify you or when aggregated with anonymized information from other users, (ii) use it to develop new products or services or to modify existing products or services, and (iii) include that information with similar information from other users and disclose it to third parties. When we use anonymized information, we will take steps to ensure we do not re-identify it. If we share anonymized or aggregated data with a third party, we obligate the third party contractually not to re-identify.

We also may use and disclose information (1) upon lawful request, in response to legal process, and when required to comply with laws, (2) to enforce our agreements, corporate policies, and terms of use or (3) to protect the rights, property or safety of our employees, agents, customers, other users of our products and services and other third-parties), (4) to investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (5) to investigate, prevent or take action regarding any violation of this Privacy Policy, (6) if doing so is appropriate to carry out a user’s request, reasonably necessary to offer the service, or reasonably believed to be legally required, or is in Turbett’s interest to protect its property or other legal rights or the rights or property of others and/or (7) to investigate and defend us against any third-party claims or allegations, or to protect the security or integrity of our products and services.

We may also provide information we receive from you to our subsidiaries, affiliated companies, or other trusted businesses or persons for the purpose of processing personal information on our behalf, facilitating our business, and for any other purpose identified above.

In connection with any sale of the assets or equity, a financing, or change-of-control of Turbett or its affiliates we may disclose, share and/or transfer personal information and data we have collected with third-parties involved in such transactions (for example, if we sell the Turbett Product to a third-party buyer, we will share and transfer information about you and other users with and to that buyer).

Turbett does not sell any personal information it collects.

Children

We do not knowingly request or collect personal information from anyone under the age of 16. Turbett’s website and its services are not intended for or designed to be used by anyone under 16 years of age.

Links

Turbett’s website may contain links to non-Turbett websites or content. We are not responsible for the privacy practices of other websites. We encourage our users to review the privacy terms of other websites.

Security

We use reasonable administrative, technical, and physical safeguards to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed. No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

Data Rights

Subject to applicable law, you may have the right to request and obtain information about, or copies of, your personal information that we process, where we obtained your information, the business or commercial purpose for collecting your information, and the third parties with whom your information is shared. You may also have the right to correct your personal information, or object to its processing. Lastly, you may ask us for information about when we typically delete stored information, or ask that information be anonymized or destroyed, depending on the situation and applicable laws. To enquire about any data rights you may have, please contact us at [email protected] or by phone at (585) 755-0133.

California law permits users that are residents of California to request the following information regarding our disclosure of your personal information to third parties for those third parties’ direct marketing purposes:

• a list of certain categories of personal information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year;
• the identity of certain third parties that received personal information from us for their direct marketing purposes during that calendar year; and
• where the nature of the third parties’ business is not reasonably determinable, examples of the products or services marketed (if we have that information).

If you are a California resident and would like to make such a request, please email us at [email protected].

Changes to this Privacy Policy

We may change this policy from time to time. In the event of any changes, we will make the updated version of the policy available on our website and may also notify you, at our discretion, through other reasonable means.

How to contact us

If you have any questions about this Privacy Policy or how we handle personal information, please email us at [email protected] or by mail at:

Turbett Surgical

ATTN: Privacy Manager

245 Summit Point Drive, #2A

Henrietta, NY 14467

 

Effective Date: May 2023