Privacy Policy

1. Introduction

   1.1 We are committed to safeguarding the privacy of our website visitors.
   1.2 This policy applies where we are acting as a data controller with respect to the personal
   data of our website visitors; in other words, where we determine the purposes and means of the
   processing of that personal data.
   1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for
   the provision of our website, we will ask you to consent to our use of cookies when you first visit
   our website.
   1.4 Our website incorporates privacy controls which affect how we will process your
   personal data. By using the privacy controls, you can specify whether you would like to receive
   direct marketing communications and limit the publication of your information. You can access
   the privacy controls via https://ten20medical.com/.
   1.5 In this policy, “we”, “us” and “our” refer to Ten20 Medical, LLC. For more information
   about us, see Section 13.]

2. Credit

   2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

   3.1 In this Section 3 we have set out:
   (a) the general categories of personal data that we may process;
   (b) in the case of personal data that we did not obtain directly from you, the source
   and specific categories of that data;
   (c) the purposes for which we may process personal data; and
   (d) the legal bases of the processing.
   3.2 We may process data about your use of our website (“usage data”). The usage data
   may include your IP address, geographical location, browser type and version, operating
   system, referral source, length of visit, page views and website navigation paths, as well as
   information about the timing, frequency and pattern of your service use. The source of the
   usage data is Google Analytics. This usage data may be processed for the purposes of
   analyzing the use of the website and services. The legal basis for this processing is our
   legitimate interests, namely monitoring and improving our website and services.
   3.3 We may process information contained in any enquiry you submit to us regarding goods
   and/or services (“enquiry data”). The enquiry data may be processed for the purposes of
   offering, marketing and selling relevant goods and/or services to you. The legal basis for this
   processing is consent via the form submittal.
   3.4 We may process information relating to our customer relationships, including customer
   contact information (“customer relationship data”). The customer relationship data may
   include your name, your contact details, and information contained in communications between
   us and you. The source of the customer relationship data is you. The customer relationship data
   may be processed for the purposes of managing our relationships with customers,
   communicating with customers, keeping records of these communications and promoting our
   products and services to customers. The legal basis for this processing is consent and/or our
   legitimate interests, namely the proper management of our customer relationships.
   3.5 We may process information that you provide to us for the purpose of subscribing to our
   email notifications and/or newsletters (“notification data”). The notification data may be
   processed for the purposes of sending you the relevant notifications and/or newsletters. The
   legal basis for this processing is the performance of a contract between you and us and/or
   taking steps, at your request, to enter into such a contract.
   3.6 We may process information contained in or relating to any communication that you
   send to us (“correspondence data”). The correspondence data may include the
   communication content and metadata associated with the communication. Our website will
   generate the metadata associated with communications made using the website contact forms.
   The correspondence data may be processed for the purposes of communicating with you and
   record-keeping. The legal basis for this processing is the proper administration of our website
   and business and communications with users.
   3.7 In addition to the specific purposes for which we may process your personal data set out
   in this Section 3, we may also process any of your personal data where such processing is
   necessary for compliance with a legal obligation to which we are subject, or in order to protect
   your vital interests or the vital interests of another natural person.
   3.8 Please do not supply any other person’s personal data to us, unless we prompt you to
   do so.

4. Providing your personal data to others

   4.1 We may disclose your personal data to our insurers and/or professional advisers insofar
   as reasonably necessary for the purposes of obtaining or maintaining insurance coverage,
   managing risks, obtaining professional advice, or the establishment, exercise or defence of legal
   claims, whether in court proceedings or in an administrative or out-of-court procedure.
   4.2 In addition to the specific disclosures of personal data set out in this Section 4, we may
   disclose your personal data where such disclosure is necessary for compliance with a legal
   obligation to which we are subject, or in order to protect your vital interests or the vital interests
   of another natural person. We may also disclose your personal data where such disclosure is
   necessary for the establishment, exercise or defence of legal claims, whether in court
   proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

   5.1 In this Section 5, we provide information about the circumstances in which your personal
   data may be transferred to countries outside the European Economic Area (EEA).
   5.2 The hosting facilities for our website are situated in United States of America.
   5.3 You acknowledge that personal data that you submit for publication through our website
   or services may be available, via the internet, around the world. We cannot prevent the use (or
   misuse) of such personal data by others.

6. Retaining and deleting personal data

   6.1 This Section 6 sets out our data retention policies and procedure, which are designed to
   help ensure that we comply with our legal obligations in relation to the retention and deletion of
   personal data.
   6.2 Personal data that we process for any purpose or purposes shall not be kept for longer
   than is necessary for that purpose or those purposes.
   6.3 We will retain your personal data as follows:
   (a) Your usage data, as gathered by Google Analytics, will be retained for a
   maximum period of 26 months.
   6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data
   where such retention is necessary for compliance with a legal obligation to which we are
   subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Amendments

   7.1 We may update this policy from time to time by publishing a new version on our website.
   7.2 You should check this page occasionally to ensure you are happy with any changes to
   this policy.
   7.3 We may notify you of significant changes to this policy by email or through the private
   messaging system on our website.

8. Your rights

   8.1 In this Section 8, we have summarized the rights that you have under data protection
   law. Some of the rights are complex, and not all of the details have been included in our
   summaries. Accordingly, you should read the relevant laws and guidance from the regulatory
   authorities for a full explanation of these rights.
   8.2 Your principal rights under data protection law are:
   (a) the right to access;
   (b) the right to rectification;
   (c) the right to erasure;
   (d) the right to restrict processing;
   (e) the right to object to processing;
   (f) the right to data portability;
   (g) the right to complain to a supervisory authority; and
   (h) the right to withdraw consent.
   8.3 You have the right to confirmation as to whether or not we process your personal data
   and, where we do, access to the personal data, together with certain additional information.
   That additional information includes details of the purposes of the processing, the categories of
   personal data concerned and the recipients of the personal data. Providing the rights and
   freedoms of others are not affected, we will supply to you a copy of your personal data. The first
   copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
   You can access your personal data by contacting us at: https://ten20medical.com/.
   8.4 You have the right to have any inaccurate personal data about you rectified and, taking
   into account the purposes of the processing, to have any incomplete personal data about you
   completed.
   8.5 In some circumstances you have the right to the erasure of your personal data without
   undue delay. Those circumstances include: the personal data are no longer necessary in
   relation to the purposes for which they were collected or otherwise processed; you withdraw
   consent to consent-based processing; you object to the processing under certain rules of
   applicable data protection law; the processing is for direct marketing purposes; and the personal
   data have been unlawfully processed. However, there are exclusions of the right to erasure. The
   general exclusions include where processing is necessary: for exercising the right of freedom of
   expression and information; for compliance with a legal obligation; or for the establishment,
   exercise or defense of legal claims.
   8.6 In some circumstances you have the right to restrict the processing of your personal
   data. Those circumstances are: you contest the accuracy of the personal data; processing is
   unlawful but you oppose erasure; we no longer need the personal data for the purposes of our
   processing, but you require personal data for the establishment, exercise or defence of legal
   claims; and you have objected to processing, pending the verification of that objection. Where
   processing has been restricted on this basis, we may continue to store your personal data.
   However, we will only otherwise process it: with your consent; for the establishment, exercise or
   defence of legal claims; for the protection of the rights of another natural or legal person; or for
   reasons of important public interest.
   8.7 You have the right to object to our processing of your personal data on grounds relating
   to your particular situation, but only to the extent that the legal basis for the processing is that
   the processing is necessary for: the performance of a task carried out in the public interest or in
   the exercise of any official authority vested in us; or the purposes of the legitimate interests
   pursued by us or by a third party. If you make such an objection, we will cease to process the
   personal information unless we can demonstrate compelling legitimate grounds for the
   processing which override your interests, rights and freedoms, or the processing is for the
   establishment, exercise or defence of legal claims.
   8.8 You have the right to object to our processing of your personal data for direct marketing
   purposes (including profiling for direct marketing purposes). If you make such an objection, we
   will cease to process your personal data for this purpose.
   8.9 You have the right to object to our processing of your personal data for scientific or
   historical research purposes or statistical purposes on grounds relating to your particular
   situation, unless the processing is necessary for the performance of a task carried out for
   reasons of public interest.
   8.10 To the extent that the legal basis for our processing of your personal data is:
   (a) consent; or
   (b) that the processing is necessary for the performance of a contract to which you
   are party or in order to take steps at your request prior to entering into a contract,
   and such processing is carried out by automated means, you have the right to receive
   your personal data from us in a structured, commonly used and machine-readable
   format. However, this right does not apply where it would adversely affect the rights and
   freedoms of others.
   8.11 If you consider that our processing of your personal information infringes data protection
   laws, you have a legal right to lodge a complaint with a supervisory authority responsible for
   data protection. You may do so in the EU member state of your habitual residence, your place of
   work or the place of the alleged infringement.
   8.12 To the extent that the legal basis for our processing of your personal information is
   consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the
   lawfulness of processing before the withdrawal.
   8.13 You may exercise any of your rights in relation to your personal data by written notice to
   us.

9. About cookies

   9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a
   web server to a web browser and is stored by the browser. The identifier is then sent back to the
   server each time the browser requests a page from the server.
   9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will
   be stored by a web browser and will remain valid until its set expiry date, unless deleted by the
   user before the expiry date; a session cookie, on the other hand, will expire at the end of the
   user session, when the web browser is closed.
   9.3 Cookies do not typically contain any information that personally identifies a user, but
   personal information that we store about you may be linked to the information stored in and
   obtained from cookies.

10. Cookies that we use

    10.1 We use cookies for the following purposes:
    (a) authentication – we use cookies to identify you when you visit our website and as
    you navigate our website.
    (b) status – we use cookies to help us to determine if you are logged into our
    website;
    (c) personalization – we use cookies to store information about your preferences and to
    personalise the website for you.
    (d) security – we use cookies as an element of the security measures used to protect
    user accounts, including preventing fraudulent use of login credentials, and to protect
    our website and services generally
    (e) advertising – we use cookies to help us to display advertisements that will be
    relevant to you
    (f) analysis – we use cookies to help us to analyze the use and performance of our
    website and services; and
    (g) cookie consent – we use cookies to store your preferences in relation to the use
    of cookies more generally

11. Cookies used by our service providers

    11.1 Our service providers use cookies and those cookies may be stored on your computer
    when you visit our website.
    11.2 We use Google Analytics to analyze the use of our website. Google Analytics gathers
    information about website use by means of cookies. The information gathered relating to our
    website is used to create reports about the use of our website. Google’s privacy policy is
    available at: https://www.google.com/policies/privacy/.

12. Managing cookies

    12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods
    for doing so vary from browser to browser, and from version to version. You can however obtain
    up-to-date information about blocking and deleting cookies via these links:
    (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
    (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-websitepreferences (Firefox);
    (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
    (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorerdelete-manage-cookies (Internet Explorer);
    (e) https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11
    471/ (Safari); and
    (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
    (Edge).
    12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
    12.3 If you block cookies, you will not be able to use all the features on our website.

13. Our details

    13.1 This website is owned and operated by Ten20 Medical, LLC.
    13.2 Our principal place of business is at 4300 Sigma Drive, Suite 120 Dallas, TX 75244
    13.4 You can contact us:
    (a) by mail, to the postal address given above;
    (b) by using our website contact form;
    (c) by telephone, on the contact number published on our website; or
    (d) by email, using the email address published on our website from time to time.