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Privacy & Policy

Privacy Policy

Last updated: May 16, 2022

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the Service and informs you of your privacy rights and how the law protects you.

We use your personal information to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

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Interpretation and Definitions

Interpretation

Words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning, regardless of whether they appear singular or plural.

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Definitions

For purposes of this Privacy Policy:

  • means a single account created for you to access our Service or portions of our Service.

  • for purposes of the California Consumer Privacy Act (CCPA), refers to Company as a legal entity that collects personal consumer information and determines the purposes and means of processing personal consumer information, or on whose behalf such information is collected and which alone or jointly with others determines the purposes and means of processing personal consumer information, doing business in the State of California.

  • (referred to as "The Company", "We", "Us" or "Our" in this Agreement) refers to SURGERY POINT, INEVITABLE- UNIPESSOAL L ESTIMATED, NIF 516857134, CAMINHO DAS ALFARROBEIRAS Bloco A 1 ANDAR N3, 8125 VILAMOURA, QUARTEIRA.

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For purposes of the RGPD, the Company is the Data Controller.

  • for purposes of the California Consumer Privacy Act (CCPA), a natural person who is a California resident. A resident, as defined in the Act, includes (1) each individual who is in the U.S. for other than a temporary or transitory purpose, and (2) each individual who is domiciled in the U.S. who is outside the U.S. for a temporary or transitory purpose.

  • are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.

  • refers to: Portugal

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Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person who, alone or jointly with others, determines the purposes and means of processing of Personal Data.

  • means any device that can access the Service, such as a computer, cell phone or digital tablet.

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Do Not Track (DNT) is a concept that has been promoted by US regulators, in particular the US Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism to allow Internet users to control the tracking of their online activities through websites.

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Facebook Fan Page is a public profile called Surgerypoint.com specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/Surgerypointcom-105823158763177/?ref=pages_you_manage

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Personal Data is any information that relates to an identified or identifiable individual.

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For purposes of the GDPR, Personal Data means any information relating to You, such as name, identification number, location data, online identifier or one or more factors specific to physical, physiological, genetic, mental, economic, cultural or social identity.

For purposes of the CCPA, Personal Data means any information that identifies, relates to, describes, or is capable of being associated with, or that can reasonably be linked, directly or indirectly, to You.

  • for purposes of the California Consumer Privacy Act (CCPA), means to sell, rent, release, disclose, make available, transfer, or communicate orally, in writing, or by electronic or other means, the personal information of a consumer to another business or a third party for monetary or other valuable consideration.

  • refers to the Site.

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Service Provider: any natural or legal person who processes data on behalf of the Company. Refers to third party companies or individuals employed by the Company to facilitate the Service, provide the Service on behalf of the Company, perform services related to the Service, or assist the Company in analyzing how the Service is used. For the purposes of the GDPR, Service Providers are considered to be Processors of Data.

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Third Party Social Media Service refers to any website or social networking site through which a User may log in or create an account to use the Service.

 

Usage Data refers to automatically collected data, either generated by use of the Service or by the Service infrastructure itself (for example, the duration of a page visit).

  • refers to the Point of Surgery, accessible from www.surgerypoint.com.

  • means the individual accessing or using the Service, or the company, or other legal entity on whose behalf that individual is accessing or using the Service, as applicable.

Under the GDPR (General Data Protection Regulation), you may be referred to as The Data Subject or as User, as you are the individual using the Service.

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Collection and use of your personal data

Types of Data Collected

Personal Information

When using Our Service, We may ask you to provide certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

Email address

First name and last name

Phone number

Company Name

Address, State, Province, Postal/Postal Code, City

Bank account information to pay for products and/or services within the Service

Usage Data

When you pay for a product and/or a service by wire transfer, we may ask you to provide information to facilitate this transaction and verify your identity. Such information may include, without limitation:

  • Date of birth

  • Passport or national identity card

  • Bank card statement

  • Other information that links you to an address

  • Usage Data

Usage Data is collected automatically when you use the Service.

Usage Data may include information such as your device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service on or through a mobile device, we may automatically collect certain information, including, but not limited to, the type of mobile device you use, your unique mobile device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service on or through a mobile device.

Third-Party Social Media Services Information

The Company allows you to create an account and log in to use the Service through the following third-party Social Media Services:

  • Google

  • Facebook

  • Twitter

  • LinkedIn

If you choose to register through or otherwise grant us access to a Third Party Social Media Service, we may collect personal information that is already associated with Your Third Party Social Media Service account, such as your name, your email address, your activities, or your contact list associated with that account.

You may also have the option to share additional information with Company through the Third Party Social Media Service account. If you choose to provide such information and Personal Data, during registration or otherwise, you are giving the Company permission to use, share and store it in a manner consistent with this Privacy Policy.

Cookie Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track activity on Our Service and store certain information. The tracking technologies used are beacons, tags and scripts to collect and track information and to improve and analyze Our Service. The technologies we use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless You have adjusted Your browser setting so that it refuses Cookies, Our Service may use Cookies.

  • Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about your preferences or your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for browser cookies. For more information on how to delete Flash Cookies, please read "Where can I change the settings to disable or delete local shared objects?" available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_.

  • Web Beacons. Some sections of our Service and emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that allow Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (e.g., to record the popularity of a particular section and to check system and server integrity).

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Cookies can be either "Persistent" or "Session" cookies. Persistent Cookies remain on your personal computer or mobile device when you are offline, while Session Cookies are deleted as soon as you close your web browser. You can learn more about cookies here: Cookies by TermsFeed Generator.

We use both session and persistent cookies for the purposes below:

Necessary / Essential Cookies

Type: Session Cookies

Managed by: We

Purpose: These Cookies are essential to provide you with the services available through the Website and allow you to use some of its features. They help to authenticate users and prevent fraudulent use of users' accounts. Without these Cookies, the services you have requested cannot be provided, and we only use these Cookies to provide these services to you.

Cookie Policy / Acceptance of Warning Cookies

Type: Persistent Cookies

Managed by: We

Purpose: These Cookies identify whether users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Managed by: Us

Purpose: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences each time you use the Website.

Tracking and Performance Cookies

Type: Persistent Cookies

Managed by: Third Party

Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information collected through these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookie Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use personal data for the following purposes:

To provide and maintain our Service, including monitoring the use of our Service.

To manage Your Account: to manage your registration as a user of the Service. The Personal Data You provide may give You access to different features of the Service that are available to You as a registered user.

To perform a contract: the development, performance and commitment of the contract to purchase the products, items or services that You purchased or any other contract with Us through the Service.

To contact You: to contact You by email, telephone calls, SMS or other equivalent forms of electronic communication, such as push notifications from a mobile application regarding updates or informational communications related to the contracted features, products or services, including security updates, when necessary or reasonable for their implementation.

To provide you with news, special offers and general information about other goods, services and events we offer that are similar to those you have already purchased or inquired about, unless you have opted out of receiving such information.

To manage your orders: To fulfill and manage your orders for us.

To deliver targeted advertising to You: We may use Your information to develop and display content and advertising (and work with third party vendors who do so) tailored to Your interests and/or location and to measure its effectiveness.

For business transfers: We may use Your information to evaluate or effect a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceedings, in which Personal Data held by Us about our Service users is among the transferred assets.

For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Service, Products, Services, Marketing and your experience.

We may share your personal information in the following situations:

  • With Service Providers: We may share your personal information with service providers to monitor and analyze the use of our Service, to advertise on third party websites to You after You have visited our Service, for payment processing, to contact you.

  • For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing or acquisition of all or part of our business to another company.

  • With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or are under common control with Us.

  • With business partners: We may share your information with our business partners in order to offer you certain products, services or promotions.

  • With other users: When you share personal information or otherwise interact in public areas with other users, that information can be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a Third Party Social Media Service, your contacts on the Third Party Social Media Service may see your name, profile, pictures and descriptions of your activity. Similarly, other users will be able to see descriptions of your activity, communicate with you and view your profile.

  • With your consent: We may disclose your personal information for any other purpose with your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only as long as necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen security or to improve the functionality of Our Service, or we are legally required to retain this data for longer periods of time.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and any other locations where parties involved in the processing are located. This means that this information may be transferred to - and maintained on - computers located outside of Your state, province, country, or other governmental jurisdiction where data protection laws may differ from those of Your jurisdiction.

Your consent to this Privacy Policy, followed by Your submission of such information, represents Your agreement to such transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will be made to an organization or country unless adequate controls are in place, including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide advance notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Fulfilling a legal obligation

  • Protect and defend the Company's rights or property

  • Prevent or investigate possible infringements related to the Service

  • Protect the personal safety of Service Users or the public

  • Protect against legal liability

Security of Your Personal Data

The security of your Personal Data is important to us, but please remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Detailed Information about the Processing of Your Personal Data

The Service Providers that we use may have access to Your Personal Data. These third party providers collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use third party service providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to monitor and track the use of our Service. This data is shared with other Google services. Google may use the data collected to contextualize and personalize ads in its own advertising network.

You can exclude your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The addon prevents Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visitor activity.

For more information about Google's privacy practices, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt out of receiving any, or all, of these communications from us by following the link or subscription instructions provided in any email we send or by contacting us.

We may use email service providers to manage and send emails to You.

 

Mailchimp is an email marketing sending service provided by Rocket Science Group LLC.

For more information about Mailchimp's privacy practices, please visit their Privacy Policy: https://mailchimp.com/legal/privacy/

__wix __

Their Privacy Policy can be viewed at https://en.wix.com/about/privacy

Payments

We may provide paid products and/or services within the Service. In that case, we may use third party services for payment processing (e.g. payment processors).

We will not store or collect your payment card information. This information is provided directly to our third party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards established by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands such as Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

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Your Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

When you use Our Service to pay for a product and/or service by bank transfer, We may ask you to provide information to facilitate this transaction and verify your identity.

Behavioral Remarketing

The Company uses remarketing services to advertise to You after You have accessed or visited Our Service. We and our third party vendors use cookies and non-cookie technologies to help us recognize your Device and understand how you use our Service so that we can improve our Service to reflect your interests and serve ads that are likely to be of interest to You.

These third party vendors collect, store, use, process and transfer information about your activity on Our Service in accordance with their Privacy Policies and allow us to:

Measure and analyze traffic and browsing activity on Our Service

Show advertisements for our products and/or services to You on third-party websites or apps

Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not allow you to block such technologies. You may use the following third-party tools to opt-out of the collection and use of information for the purpose of serving your interest-based advertising:

NAI's opt-out platform: http://www.networkadvertising.org/choices/

The EDAA opt-out platform http://www.youronlinechoices.com/

The DAA opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

You can opt out of all personalized advertising by enabling privacy features on your mobile device, such as Limit Ad Tracking (iOS) and Opt out of Ads Personalization (Android). Please refer to your mobile device's help system for more information.

We may share information, such as email addresses (if available) or other online identifiers collected on Our Service with these third party vendors. This allows our third-party vendors to recognize and deliver ads from You across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please see the Privacy Policy for each vendor listed below.

The third-party vendors we use are:

Google Ads (AdWords)

The Google Ads (AdWords) remarketing service is provided by Google Inc.

You may opt-out of Google Analytics for display advertising and personalization of Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends that you install the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. The Google Analytics Opt-out Browser Add-on provides visitors the ability to prevent their data from being collected and used by Google Analytics.

For more information about Google's privacy practices, visit the Google Privacy & Terms web page: https://policies.google.com/privacy

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The Facebook remarketing service is provided by Facebook Inc.

You can learn more about Facebook interest-based advertising by visiting this page: https://www.facebook.com/help/516147308587266

To opt-out of Facebook's interest-based ads, please follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the US http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information about Facebook's privacy practices, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

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Its Privacy Policy can be viewed at https://www.instagram.com/about/legal/privacy/before-january-19-2013/

GDPR Privacy

Legal Basis for Processing Personal Data under the GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given your consent to the processing of Personal Data for one or more specific purposes.

  • Performance of a contract: The provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations of the same.

    Legal Obligations: The processing of Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

    Vital Interests: The processing of Personal Data is necessary to protect the vital interests of you or another natural person.

  • Public Interest: The processing of Personal Data is related to a task that is performed in the public interest or in the exercise of official authority vested in the Company.

  • Legitimate Interests: The processing of Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly assist you in clarifying the specific legal basis that applies to the processing, in particular whether the provision of Personal Data is a legal or contractual requirement, or a necessary requirement to enter into a contract.

Your rights under the GDPR

The Company is committed to respecting the confidentiality of Your Personal Data and to ensuring that You can exercise Your rights.

You have the right under this Privacy Policy, and by law if within the EU, to:

  • To request access to Your Personal Data. The right to access, update or delete the information we hold about you. Where possible, you can access, update or request deletion of Your Personal Data directly from the settings section of your account. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Information that we hold about You.

  • Request correction of the Personal Data we hold about you. You have the right to have any incomplete or inaccurate information we have about you corrected.

  • Object to the processing of Your Personal Data. This right exists where we are relying on a legitimate interest as a legal basis for our processing and there is something about your particular situation which makes you want to object to our processing of Your Personal Data on this ground. You also have the right to object where we are processing Your Personal Data for direct marketing purposes.

  • Request the erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.

  • Requesting the transfer of Your Personal Data. We will provide You, or a third party you have chosen, with Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you initially gave consent for us to use or where we used the information to perform a contract with You.

  • Withdraw your consent. You have the right to withdraw your consent to the use of your Personal Data. If you withdraw your consent, we may not provide you with access to certain specific features of the Service.

Exercising Your GDPR Data Protection Rights

You can exercise your rights of access, rectification, cancellation and opposition by contacting us. 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 have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

Facebook Fan Page

Data Controller for Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected during the use of the Service. As the operator of the Facebook Fan Page https://www.facebook.com/Surgerypointcom-105823158763177/?ref=pages_you_manage, the Company and the social network operator Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that set out the terms of use of the Facebook Fan Page, among other things. These terms are primarily based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Please visit Facebook's Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and based on the GDPR in order to obtain anonymized statistical data about our users.

For this purpose, Facebook places a Cookie on the device of the user who visits Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years unless deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when you visit Facebook services, services that are provided by other members of the Facebook Fan Page and services of other companies using the Facebook services.

For more information about Facebook's privacy practices, please visit Facebook's Privacy Policy here: https://www.facebook.com/privacy/explanation

CCPA Privacy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and applies exclusively to all visitors, users and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular Consumer or Device. The following is a list of categories of personal information that we may collect or may have collected from California residents in the last twelve (12) months.

Please note that the categories and examples provided in the list below are as defined in the CCPA. This does not mean that every example of that category of personal information has been collected by Us, but reflects our good faith belief, to the best of Our knowledge, that some of that information in the applicable category can be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to Us.

Category A: Identifiers.

Examples: Real name, alias, mailing address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number or other similar identifiers.

Collected: Yes.

Category B: Categories of personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category C: Classification characteristics protected under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including family genetic information).

Collected: No.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identify information, such as, fingerprints, facial prints and voice prints, iris or retinal scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertising.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Occupational or employment-related information.

Examples: Current or past employment history or performance evaluations.

Collected: No.

Category J: Non-public education information (in accordance with the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or a party acting on its behalf, such as notes, transcripts, class rosters, student schedules, student identification codes, student financial information, or student disciplinary records.

Retrieved: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting preferences, characteristics, psychological tendencies, predispositions, behavior, attitudes, intelligence, abilities, and skills.

Collected: No.

Under the CCPA, personal information does not include:

  • Publicly available information from government records

  • De-identified or aggregated consumer information

  • Information excluded from the scope of the CCPA, such as:

  • Medical or health information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data

  • Personal information covered by certain industry-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or the California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from the forms you fill out on our Service, the preferences you express or provide through our Service, or your purchases on our Service.

  • Indirectly from you. For example, from observing your activity on our Service.

    Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.

  • From Service Providers. For example, third party vendors for monitoring and analyzing your use of our Service, third party vendors for delivering targeted advertising to You, third party vendors for payment processing, or other third party vendors that we use to provide the Service to You.

Use of Personal Information for Commercial or Business Purposes

We may use or disclose personal information that we collect for "business purposes" or "commercial purposes" (as defined in the CCPA), which may include the following examples:

  • To operate our Service and provide you with our Service.

  • To support you and answer your questions, including to investigate and address your concerns and to monitor and improve our Service.

  • To fulfill or comply with the reason you provided the information. For example, if you share your contact information to ask a question about our Service, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery.

    To respond to law enforcement requests and as required by applicable law, court order, or government regulations.

    As described for You when collecting your personal information or as otherwise stated in the CCPA.

  • For internal administrative and auditing purposes.

  • Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activities, including, when necessary, prosecuting those responsible for such activities.

Please note that the examples above are illustrative and not intended to be exhaustive. For more details about how we use this information, please see the "Use of Your Personal Information" section.

If we decide to collect additional categories of personal information or use the personal information we collect for materially different, unrelated or incompatible purposes, we will update this Privacy Policy.

Disclosure of Personal Information for Business or Commercial Purposes

We may use or disclose and may have used or disclosed in the past twelve (12) months the following categories of personal information for commercial or business purposes:

  • Category A: Identifiers

  • Category B: Categories of personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

  • Category D: Business Information

  • Category F: Internet or other similar network activity

Please note that the categories listed above are as defined in the CCPA. This does not mean that all examples of that category of personal information have in fact been disclosed, but reflects our good faith belief, to the best of our knowledge, that some of that information in the applicable category can be and may have been disclosed.

When we disclose personal information for business or commercial purposes, we enter into a contract that describes the purpose and obligates the recipient to keep that personal information confidential and not to use it for any purpose except to perform the contract.

Sale of Personal Information

As defined in the CCPA, "sell" and "selling" mean selling, leasing, releasing, disclosing, disseminating, making available, transferring, or communicating orally, in writing, or by electronic or other means, a consumer's personal information by us to a third party for valuable consideration. This means that we may have received some type of benefit in exchange for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are as defined in the CCPA. This does not mean that every example of that category of personal information has actually been sold, but reflects our good faith belief, to the best of our knowledge, that some of that information in the applicable category can be and may have been shared for value in exchange.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

  • Category A: Identifiers

  • Category B: Categories of personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

  • Category D: Business Informations

  • Category F: Internet or other similar network activity

     

Sharing of Personal Information

We may share your personal information identified in the categories above with the following categories of third parties:

Service Providers

Payment Processors

Our Subsidiaries

Os nossos parceiros de negócio

Third party vendors to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you

Sale of Personal Information from Minors Under 16

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third-party sites we link to may do so. These third-party sites have their own terms of use and privacy policies, and we encourage parents and legal guardians to monitor their children's Internet use and to instruct their children never to provide information on other sites without their permission.

We do not sell the personal information of Consumers that we know are under the age of 16 unless we receive affirmative consent (the "opt-in right") from either the Consumer between the ages of 13 and 16, or the parent or guardian of a Consumer under the age of 13. Consumers who opt-in to sell personal information may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request by contacting us.

If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient details to allow us to delete that information.

Your rights under the CCPA

The CCPA provides California residents with specific rights over their personal information. If you are a California resident, you have the following rights:

  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data are being used.

  • The right to request. Under the CCPA, you have the right to request that we disclose to you information about our collection, use, sale, disclosure for commercial purposes, and sharing of Personal Information. Once we receive and confirm your request, we will disclose it to you:

  • The categories of personal information we collect about You

  • The categories of sources for the personal information we collect about You

  • Our business or commercial purpose for collecting or selling that personal information

  • The categories of third parties with whom we share that personal information

  • The specific personal information we collect about You

  • If we sell your personal information or disclose your personal information for commercial purposes, we will disclose to You:

  • The categories of categories of personal information sold

  • The categories of categories of personal information disclosed

  • The right to say no to the sale of Personal Information (opt-out). You have the right to direct us not to sell your personal information. To submit an opt-out request please contact us.

  • The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our Service Providers to delete) Your Personal Information in our records, unless an exception applies. We may deny your request for deletion if retention of the information is necessary for us or our Service Providers to

  • Complete the transaction for which we collected the personal information, provide a good or service you requested, take reasonably anticipated actions in the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activities, or prosecute those responsible for such activities.

  • Debug products to identify and repair bugs that compromise existing intended functionality.

  • Exercise freedom of speech, ensure the right of another consumer to exercise his or her free speech rights, or exercise any other right provided by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).

  • Engage in peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when suppression of the information could likely make it impossible or seriously impair the conduct of the research if you previously provide informed consent.

  • Allow exclusively internal uses that are reasonably in line with consumer expectations based on Your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and legal uses of that information that are compatible with the context in which You provided it.

  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer rights, including:

  • Denying goods or services to You

  • Charging different prices or rates for goods or services, including using discounts or other benefits or imposing penalties

  • Providing a different level or quality of goods or services to You

  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

  • Exercising your ccpa data protection rights

  • To exercise any of your rights under the CCPA, and if you are a California resident, you may contact us:

  • By email: info@surgerypoint.com

  • By visiting this page on our website: www.surgerypoint.com

  • By telephone number: +35191911947599

  • Only you, or a person registered with the California Secretary of State who authorizes us to act on your behalf, may make a verifiable request related to your personal information.

  • Your request to us must:

  • Provide sufficient information to allow us to reasonably verify That you are the person about whom we collect personal information or an authorized representative

  • Describe your request in sufficient detail to allow us to understand, evaluate and respond appropriately

  • We cannot respond to your request or provide you with the necessary information if we cannot:

  • Verify your identity or authority to make the request

  • And confirm that the personal information relates to You

  • We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once for an additional 45 days when reasonably necessary and with notice.

  • Any disclosures we provide will only cover the 12 month period prior to receipt of the verifiable request.

  • For data portability requests, we select a format for providing your personal information that is easily usable and allows you to transmit the information from one entity to another entity without hindrance.

  • Not selling my personal information

  • You have the right to opt-out of the sale of your personal information. Once we receive and confirm a verifiable consumer request from You, we will stop selling your personal information. To exercise your right to opt-out, please contact us.

  • Service Providers with whom we partner (for example, our analytics or advertising partners) may use technology in the Service that sells personal information as defined by CCPA law. If you wish not to use your personal information for interest-based advertising purposes and these potential sales as defined by CCPA law, you may do so by following the instructions below.

  • Please note that any opt-out is specific to the browser you use. You may need to opt out for all the browsers you use.

  • Website

  • You may opt out of receiving personalized ads as served by our Service Providers by following our instructions presented on the Service:

  • NAI's opt-out platform: http://www.networkadvertising.org/choices/

  • The EDAA opt-out platform http://www.youronlinechoices.com/

  • The DAA opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

  • The opt-out will place a cookie on your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies stored by your browser, you will need to opt out again.

  • Mobile Devices

  • Your mobile device may give you the ability to opt-out information about the applications you use to serve ads that are targeted to your interests:

  • "Opt out of interest-based ads" or "Opt out of Ad Customization" on Android devices

  • "Limit Ads" on iOS devices

You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.

Do Not Track Policy" as required by the California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third-party websites do track your browsing activities. If you are visiting these sites, you can set your preferences in your web browser to tell the sites 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.

Children's Privacy

Our Service is not directed to anyone under the age of 13. We do not collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and become aware that your child has provided us with personal information, please contact us. If we learn that we have collected Personal Information from children under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires parental consent, we may require your parent's consent before collecting and using that information.

Your California Privacy Rights (California's Shine the Light law)

Pursuant to Section 1798 (California's Shine the Light law), California residents with an established business relationship with us may request information once a year about the sharing of their Personal Data with third parties for third party direct marketing purposes.

If you would like to request more information under the California Shine the Light law, and if you are a California resident, you may contact us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows 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 that they have publicly posted.

To request the removal of such data, and if you are a California resident, you may contact us using the contact information provided below and include the email address associated with your account.

Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not allow or require their removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If you click on a third party link, you will be directed to the third party's website. We strongly encourage you to review the Privacy Policy of each site you visit.

We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will inform you by email and/or a prominent notice on Our Service before the change becomes effective and update the "Last Updated" date at the top of this Privacy Policy.

You are advised to periodically review this Privacy Policy for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, you may contact us:

By email: info@surgerypoint.com

By visiting this page on our web site: www.surgerypoint.com

By phone number: +35191911947599

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