Last Updated December 27, 2023 We at FEMSelect Ltd. (“we”, “us”, and “our”), the developers of EnPlace, a minimally invasive and mesh-free system for pelvic floor ligament fixation (“Product”), respect your privacy and put great efforts into securing personal information and in processing it lawfully.
This Privacy Notice(“notice”) explains our privacy practices for processing personal information related to you when: (A) when you visit our website (“Website Visitor”) located at https://femselect.com/ or any other additional or alternative URL (“Website”); or, (B) when you contact with our call center (“Caller”) to get more information about the product (the “Call Center”).
In this notice:
- The term “Services” collectively refers to the Website and the Call Center;
- The term “you” collectively refers to Website Visitors and Callers; and,
- The term “personal information” refers to information that identifies an individual or relates to an identifiable individual. The term personal information will also include the term “personal data” and any similar or equivalent term under applicable laws and regulations governing the protection of privacy and personal information (“Applicable Privacy Laws”). For example, personal information includes personal details such as your name, email address and telephone number.
Please take the time to read the full privacy notice. If you do not agree to the terms of this privacy notice, please do not access, or otherwise use our Services.
The summary of this notice provided below will give you a quick and clear view of our practices. Additionally, the first 6 headings in the summary also serve as a ‘notice at collection’, where required under the U.S Privacy Laws.
| NOTICE AT COLLECTION AND A SUMMARY OF THE NOTICE | ||
|---|---|---|
| NOTICE AT COLLECTION | Categories of personal information that you provide us and we collect | We receive and store any personal information and documents that you provide us when you use our Website or contact our Call Center. Such Information includes identity information, contact information, documents and usage information. Read more |
| Categories of sensitive personal information | Our Services are not intended to collect sensitive personal information, we do not knowingly collect it, and we require that you not provide us with such information.
However, as a Caller, the fact that you have contacted us in connection with inquiring about a medical device may be considered sensitive personal information, as it may infer information about your health. We will only use such information to refer you to a local doctor that provides medical treatments by using our Product. |
|
| What do we do with personal information related to you | We use personal Information to provide you with the Services, send you notifications related to your use of the Services and marketing related messages, solicit your feedback and provide support, maintain the Services, and continue developing and making the Services better. Read more | |
| Sharing personal information with others | We disclose personal Information related to you to certain employees of our staff, external consultants or doctors who use the product, our affiliates, our service providers acting as sub-processors, or as otherwise instructed by you.
All such parties are subject to this privacy notice or are contractually bound to keep personal information related to you confidential and appropriately secure. Read more |
|
| Personal information retention | We retain personal information for different periods of time, depending on the purposes for processing the information, our legitimate business purposes, and pursuant to legal requirements under applicable law Read more | |
| Your rights and choices | You have choices and control over how we use personal information related to you in connection with providing you with the Services. You have the following rights:
|
|
| Exercising your rights | You can stop using the Services at any time, and thereafter, we will stop collecting personal information related to you, and you can contact us to request to exercise any of the rights detailed in this notice by contacting us at the email address detailed at the bottom of our privacy notice. Read more | |
| Personal information transfer | We use cloud-based services to store, process, and access personal information. These service providers provide us adequate privacy, security, and confidentiality commitments. Read more | |
| Cookies and similar technologies | We use cookies or similar technologies in connection with our Website. Read more | |
| Aggregated and analytical data | We use anonymous, statistical, or aggregated information and will share it with our partners for legitimate business purposes. It has no effect on your privacy because there is no reasonable way to extract information from the aggregated information that we or others can associate specifically with you. Read more | |
| Information security | We implement systems, applications, and procedures to secure personal information related to you, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. Read more | |
| Changes to this privacy notice | We will update our notice from time to time after giving proper notice. Read more | |
| Contact us | If you have any questions about this privacy notice, or if you believe that your privacy rights are compromised, please contact us at: admin@femselect.com | |
THE PRIVACY NOTICE
Categories of personal Information that you provide us
As a website visitor, we receive and store any information you enter on our Website or give us in any other way, for example:
- If you contact us to become an ‘EnPlace Center’, we will collect contact information such as your name, email address, zip code, and/or telephone number.
- When you contact us via the ‘Contact Us’ form on our Website, we collect the following information: your full name, email address, phone number and any other information you choose to provide us.
- When you comment on our blog, we will collect your name and email address. Please note that content uploaded to the blog is public and will be accessible to other users of our Website.
As a caller, we will receive and store any information you provide us in connection with your call, for example:
- When you inquire about our call via our Website or online landing pages, we will collect you full name and contact information, including your phone number and email address.
- During you call with the Call Center, we will collect any personal information you may provide us with during the call. Such information includes your phone number, email address, and physical address. Such information may also include sensitive personal information, as the fact that you have contacted us in connection with inquiring about a medical device (our Product) may be considered information about your health. Additionally, we will also record the call, and retain the recording for quality assurance.
Categories of personal information that we collect
As a website visitor, like many websites, we use “cookies” or similar technologies.
We will collect, including by using third parties’ web analytics, usage information about the time, type, and manner of use of the Services. This information may include, inter alia, parameters which are automatically provided by your browser, such as Internet Protocol (IP) address, your browser’s type and version, your device type and your used language.
Other examples of usage information that we collect are your activity events, non-personal usage statistics (e.g., time of usages, number of clicks on each link, etc.), crash reports, information regarding your browsing history and web activities, and other information regarding the use of the Services.
We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such people to register.
If you are under 18, please do not attempt to register or send any information about yourself to us, including your name, address, telephone number, or email address.
If you believe that we might have any information from or about a child under 18, please contact us at admin@femselect.com.
As a Caller, we only collect information that you provide us, as detailed above under the chapter titled “Categories of Personal Information that You Provide Us”.
Categories of sensitive personal information
Our Services are not intended to collect sensitive personal information (within the meaning of Applicable Privacy Laws). We do not knowingly collect sensitive personal information, and we require you not to provide us with any such information.
However, note that as detailed above, as a Caller, the fact that you have contacted us in connection with inquiring about a medical device may be considered sensitive personal information, as it may infer information about your health. We will not make any use, or process such information, other than to, subject to your consent, refer you to a local doctor the provides medical treatment by using our Product.
For the purpose of Applicable Privacy Laws, sensitive personal information means:
- Social security, driver’s license, state identification card, or passport number.
- Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
- Precise geolocation.
- Racial or ethnic origin, religious or philosophical beliefs, or union membership.
- Contents of your mail, email, and text messages unless we are the business that is the intended recipient of the communication.
- Genetic data about you.
- Processing biometric information for the purpose of uniquely identifying you.
- Personal information collected and analyzed concerning your health.
- Personal information collected and analyzed concerning your sex life or sexual orientation.
What do we do with personal information related to you?
As a Website Visitor, we use the information we collect through the Website for the following purposes:
- To respond to requests for information and to communicate with you;
- To administer and improve our Website;
- To better understand Website Visitors’ needs from our Website and create content that is relevant for them;
- For marketing and market research purposes;
- To generate statistics and de-identified information;
- To personalize content related to Website Visitors;
- To notify Website Visitors of any changes to our Website;
- For historical, statistical, or business planning purposes;
- To prevent fraud and investigate potential misconduct; or
- To comply with law and legal process and to protect our legitimate interests.
As a Caller, we use the information we collect for the following purposes:
- To respond to your inquiries during the call, and in any follow-up calls.
- To improve our response to Caller’s inquiries.
- To comply with law and legal process and to protect our legitimate interests.
- To refer you to a local doctor that may provide medical treatment with the Product, if you consent.
As a Caller, we and our service provider that provides the Call Center will also use the retained recording of the Call for service improvement and quality assurance.
If you are a registered user of the Website and have supplied your email address, FEMSelect may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with FEMSelect and/or our services. We primarily use our various blogs to communicate this type of information, so we expect to keep this type of email to a minimum.
Sharing personal information with others
We will share personal information related to you only subject to the terms of this notice, or subject to your prior consent.
We do not sell, rent, or lease personal information related to you.
We will share personal information related to you with service providers and other third parties, if necessary to fulfill the purposes for collecting the information and provide the Services.
We will need to disclose personal information related to you, as we believe to be necessary or appropriate:
- under applicable law, including laws outside your country of residence;
- to comply with legal process;
- to respond to requests from public and government authorities, including public and government authorities outside your country of residence;
- to enforce our terms and conditions;
- to protect our operations or those of any of our Affiliates;
- to protect our rights, privacy, safety, interests, or property, and/or that of our affiliates, you, or others;
- if we are involved in any discussions related to the sale of all or part of our business; and,
- To allow us to pursue available remedies or limit the damages that we can sustain.
We share personal information related to you with certain employees, as well as external consultants or doctors who use the product, and with our affiliates, who are all governed by this notice. In addition, we also share personal information related to you with our business partners.
A merger, acquisition, or any other structural change will require us to transfer personal information related to you to another entity, as part of the structural change, provided that the receiving entity will comply with this privacy notice.
As a Caller, we will also share the personal information you provide us during the call, subject to your consent, with the office of a local doctor that may provide you with medical treatment by using the Product.
We will also share personal information with our trusted service providers, such as the service provider that provides us with the Call Center (i.e., the service provider whose personnel answer your call).
Personal information retention
We retain different types of personal information for different periods, depending on the purposes for processing the information, our legitimate business purposes as well as pursuant to legal requirements under U.S Privacy Laws.
We will maintain your contact details, to help us stay in contact with you. At any time, you can contact our privacy team at: admin@femselect.com and request to delete your contact details. Note that we may keep your details without using them unless necessary, and for the necessary period, for legal matters.
We will keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the information.
In any case, as long as you use the Services, we will keep information about you, unless the law requires us to delete it, or if we decide to remove it at our discretion, according to the terms of this notice.
Your rights and choices
Below is a list of certain rights and choices that you are eligible for under Applicable Privacy Laws.
If you wish to know if you are entitled to any certain right and if you wish to exercise any of your rights in relation to personal information, including exercising your choices or opt-out rights, please contact us at: admin@femselect.com.
We will process your request and respond as required and permitted by law, by answering your request favorably or by rejecting it, in whole or in part.
- Access to specific personal Information and Information portability rights – you have the right to request that we disclose certain information to you about our collection and use of personal information related to you over the past 12 months. Upon verification of your request, we will disclose to you:
- The categories of personal information that we have collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of personal information that we disclosed for a business purpose, and the categories of third parties with whom we disclosed that particular category of personal information.
- The specific pieces of personal information that we collected about you.
- If we disclose personal information related to you for a business purpose, we will provide you with a list which will identify the personal information categories that each category of recipient obtained.
- Deletion rights – you have the right to request that we delete any personal information related to you. Upon confirmation of your request, we will delete personal information related to you from our records, unless an exception applies.
- Opt-out of selling or sharing – you have the right to opt-out of the sale or sharing of personal information related to you, or otherwise the use of such Information for targeted advertising or profiling for the purpose of making decisions that produce legal or similarly significant effects concerning you. As detailed above, we engage service providers that provide us with analytics and related services. They do not pay us for collecting such information, but the right granted to them to collect personal information can be considered as disclosure for the purpose of sale or sharing for cross-context behavioral or targeted advertising by certain U.S. regulators. At any time, you can opt out of the collection of personal information by such service providers by contacting us.
- Non-discrimination – you also have a right not to be discriminated against for exercising your rights under Applicable Privacy Laws.
- Right to correct – you may ask us to correct inaccurate information that we have about you.
Exercising Your Rights
Only you or a person authorized to act on your behalf, subject to providing a proof that agent is permitted to do so, may make a request related to personal information related to you.
A request for access can be made by you only twice within a 12-months period.
We cannot respond to your request or provide you with the requested personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use the personal information provided in your request to verify your identity or authority to make the request.
We will do our best to respond to your request within 45 days of its receipt. If we require more time (up to additional 45 days), we will inform you of the reason and extension period in writing. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures that we provide will only cover the 12-month period preceding receipt of your request.
The response we provide will also explain the reasons for our inability to comply with your request, if applicable.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before processing further your request.
We will not require that you create an account in order to exercise your rights under this notice and we will not increase the cost, or decrease the availability, of our Services based solely on the fact that you have chosen to exercise one of your rights under Applicable Privacy Laws.
After receiving our reply, you may appeal our decision by contacting us. We will review your appeal and provide you with our answer and our explanation of the reasons for our decision(s) within 60 days of receiving it. We will also provide you with a link (to the extent available) where you may submit a complaint with the relevant competent supervising authority.
Personal information transfer
We process information, including personal information, either directly or using third parties, such as cloud hosting service providers.
If the laws that apply to the processing of personal information related to you require your consent to the transfer of such information to another jurisdiction, then you provide us your freely given, express, specific, and unambiguous consent to such transfer.
If such laws require additional safeguards, then we will apply those safeguards, for example, by relying on a formal decision of adequacy of personal information processing under the laws of the country of destination, or by engaging the entity to which we transfer the information to under appropriate contracts designed to protect your privacy rights and the security and confidentiality of personal information.
You can obtain a copy of the suitable safeguard that we use when transferring personal information as described above by contacting us at admin@femselect.com.
Cookies and similar technologies
Cookies are small files that a web server sends to a user’s device, when the user browses online.
Your device removes session cookies when you close your browser session. Persistent cookies last for longer periods. You can view the expiry date of each cookie, through your browser settings.
We use both types. We use persistent cookies to remember your log-in details and make it easier for you to log-in the next time you access the Services. We use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools and to improve the user’s experience with our Services.
Every browser allows you to manage your cookies preferences. You can block or remove certain cookies, or all of them through your browser settings. Please bear in mind that blocking or removing cookies will influence your user experience with our Services. For example, disabling or blocking our cookies will require you to re-enter your log-in details, or even prevent you from using features of the Services.
We also use clear gifs which are tiny graphics with a unique identifier (but do not retain any personal information), which are used to count user or visitor visits/clicks to web pages while using the Services.
You can find more information about cookies and other online tracking technologies through the US Federal Trade Commission and the EU Commission websites at one of the following URLs:
- https://www.consumer.ftc.gov/articles/0042-online-tracking.<
- http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm.<
If you wish to learn more about the types of cookies that we and our service providers use, and the ways these cookies are used, please contact us at: admin@femselect.com.
Aggregated and analytical information
We use anonymous, statistical, or aggregated information and will share it with our partners for legitimate business purposes. It has no effect on your privacy because there is no reasonable way to extract information from the aggregated information that we or others can associate specifically with you.
Information security
We maintain the confidentiality of personal information related to you, and we take reasonable steps to ensure that such information is accurate, complete, current, and reliable for its intended use.
We take reasonable measures to protect personal information from loss, misuse, unauthorized access or disclosure, alteration, or destruction.
We limit access to personal information related to you to those employees, agents, contractors and other third parties who have a need to know. We require them to only process personal information related to you on our instructions and as allowed by applicable law.
These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that Services will be immune from cyber-attacks, malicious activities, malfunctions, honest mistakes, or other types of abuse and misuse.
Changes to this privacy notice
From time to time, we will need to update this privacy notice. If the updates have minor if any consequences, they will take effect 7 days after we post a notice about the change on the Website. Substantial changes will be effective 30 days after we initially post such notice.
Until the new privacy notice takes effect, you can choose not to accept it and refrain from using our Services. Using our Services after the new privacy notice takes effect means you agree to the new privacy notice.
Note that if we need to adapt to legal requirements, the new privacy notice will become effective immediately or as required.
Contact us
We do periodical assessments of our data processing and privacy practices, to make sure that we comply with this privacy notice, to update it when we believe that we need to, and to verify that we display the privacy notice properly and in an accessible manner.
If you have any questions about this privacy notice, or if you believe that your privacy rights are compromised, please contact us at: admin@femselect.com.
We will look into your query and make good-faith efforts to resolve any existing or potential dispute with you.