Privacy Notice for California Residents

Last modified on: February 10, 2020

This Privacy Notice for California Residents supplements the information contained in the Privacy Policy and solely applies to all individuals who reside in the State of California (“you” and “your”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. This notice describes the privacy practices in connection with the www.realsystem.com websites (“Site(s)”).

Section 1. Information We Collect

This Site collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, household, or device (“personal information“). In particular, this Site has collected the information below within the last twelve (12) months:

  1. Identifiers. We may collect: your real name, alias, postal address, job title, company or organization name, phone numbers, professional specialties or areas of expertise, professional license numbers, other types of professional identifiers, or other types of unique personal identifiers that are voluntarily provided by you through the Site. The Site may also collect an online identifier, browser type, operating system information, service provider information, your screen resolution, Internet Protocol address, email address or other similar identifiers. We also collect any information you voluntarily provide to us. For example, the information you provide in forms on the Site and the information you provide when you contact our customer service team.
  2. Customer records (California Customer Records statute Cal. Civ. Code § 1798.80(e)). We may collect: a real name, an alias, a postal address, email address, telephone number, credit card or debit card numbers, bank account numbers or any other financial information necessary for the purchase of our products. Some personal information included in this category may overlap with other categories.
  3. Protected classification characteristics under California or federal law. We collect information about your website traffic which may include reports containing information about your gender, age, and your interests.
  4. Commercial information. We may collect your REAL System or other Penumbra product purchasing history. We may also collect records of products you have purchased, obtained or considered or other purchasing and consuming histories or tendencies on other websites.
  5. Internet or other similar network activity. We may collect your browsing history, search history, information regarding your interactions with this Site and other websites, applications, or advertisements. We may also collect information about your devices used to access our Site (e.g. your operating system, your name that may be associated with the device, geolocation data, screen resolutions, browser type and service provider.) We collect information about your website traffic which may include reports containing information about your language, location and your interests.
  6. Geolocation data. We may collect information about your physical location and movements from observing your actions on our Site or if this information is provided by you through the Site. For example, you may provide your physical location for us to deliver you products.
  7. Professional or employment-related information. We may collect information about your previous or current employers and institutional affiliations you might have.
  8. Sensory data. We may collect your electronic signature.
  9. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). We may collect information about your educational institution(s) and when you graduated.
  10. Inferences. We may collect your purchasing history, consumer preferences, inquiries with us, information about how and where you use our products, and other information about your experience with our products. We may also collect information about your consumer preferences and interests from your web traffic on other websites.

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

  • Directly from you. For example, from the forms you complete on the Site.
  • Indirectly from you. For example, from observing your actions on our Site and from your devices. We may use third-party cookies and other tracking technologies on our Site. Please reference the Privacy Policy for more information about cookies used on the Site.
  • From other service providers. For example, we use Google Analytics which provides us with information about your actions on other websites. Please note that you can visit Google Analytics’ currently available opt-outs for the web here: https://tools.google.com/dlpage/gaoptout/.

Section 2. Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  1. To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  2. To provide, support, personalize, and develop our Site and products.
  3. To create, maintain, customize, and secure your account with us.
  4. To verify your identity.
  5. To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  6. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  7. To personalize your Site experience and to deliver content and product offerings relevant to your interests or affiliations, including targeted offers and ads through our Site, third-party sites, emails or text messages.
  8. To help maintain the safety, security, and integrity of our Site, products, databases and other technology assets, and business.
  9. For testing, research, analysis, and product development, including to develop and improve our Site and products.
  10. For promoting and marketing the REAL System or other Penumbra products.
  11. For protecting or enforcing our rights and properties or the rights and properties of others.
  12. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  13. To evaluate or conduct 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 proceeding, in which personal information held by us about our Site users or customers is among the assets transferred.

Section 3. Sharing Personal Information

We do not sell any of the personal information described in Section 1. We may disclose your personal information described in Section 1 to a third party for the business purposes described in Section 2. We share your personal information with the following types of third parties:

  • Service providers, including Salesforce.com, Inc. which provide us with customer relationship management services, data analysis, and IT services.
  • Service providers that assist us with business operation services such as legal, financial, and auditing services.
  • Service providers that provide us with promotion and advertising services such as ad platforms, publishers and ad-retargeting services.
  • Affiliates, subsidiaries, and partners.
  • Other vendors that we believe are necessary or advisable for us to comply with applicable laws and regulations.
  • Internet cookie data recipients, including Google Analytics which includes Remarketing, Google Display Network Impression Reporting, Integrated Services and Google Analytics Demographics and Interest Reporting.

Section 4. Your Rights and Choices

This section describes your CCPA rights regarding personal information and explains how to exercise those rights.

A. Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Please see the Exercising Access, Data Portability, and Deletion Rights section below for instructions to submit such a request.

B. Deletion Request Rights

You have the right to request that we delete your personal information that we collected from you and retained, subject to certain exceptions. Please see Exercising Access, Data Portability, and Deletion Rights below for instructions to submit such a request.

C. Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, you (or your authorized agent) can submit a verifiable consumer request by either:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.

D. Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information easily.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Section 5. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. However, please note that some parts of the Site may not function as intended if some of Your personal information cannot be accessed.

Section 6. Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Site and update the notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

Please email privacy@realsystem.com for any CCPA related questions you might have.