Privacy Policy - REAL System

Privacy Policy

Website Privacy Policy. Last modified: October 15, 2019

Introduction

We respect the privacy of visitors to this website and are committed to letting you know how we will collect and use your information. This Website Privacy Notice (“Notice”) describes the privacy practices in connection with the www.realsystem.com websites (“Site(s)”). It also describes the options you have regarding your collection, use and disclosure of your personal information when accessing the Sites.

The Sites are owned and operated by Penumbra, Inc. (“Penumbra”)

Please read this Notice carefully to understand our policies and practices regarding your information and how we will treat it. By using our Sites and/or registering as a subscriber, you are accepting the privacy practices described in this Notice and consenting to our collection, use, and disclosure of your personal information as described below. If you do not agree with this Notice, please do not use the Sites.

We reserve the right to modify the terms of this Privacy Notice at any time. We will post any changes to our website. The date the Privacy Notice was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Notice to check for any changes. Your continued use of our Sites following the posting of changes will mean you accept those changes.

The Sites may contain links to external websites such as Facebook, LinkedIn, Twitter, and Lever. This Privacy Notice does not apply to those sites and you should review the privacy policies of these external sites.

Contents

Information We Collect

Information you provide to us: Our Sites include opportunities for visitors to submit personally identifiable information. These opportunities include submission of a contact us form, submission of candidate information through our career portal, including name, email, phone number, and the information you submit with your candidate information.

Additionally, our products are offered on a subscription basis and orders require you to register through the Sites as a REAL System subscriber and provide us with personally identifiable information, which includes your name, email address, delivery address, and phone number. To access the subscriber area of our Sites, you will also be required to create a subscriber user account with a username and password. This information allows us to authenticate your access to the subscriber areas of the Sites. When REAL System subscriptions are completed, payment account information (e.g. credit/debit card information, bank account number) is also collected to pay for the applicable subscription.

Information we collect automatically: We also may collect information that does not personally identify you, including among other things, Site visitation data that we gather and store about your visit to and navigation within the pages of the Sites, data and time of Site page history.

Information collected through cookies and other tracking technologies: Like many websites, we use “cookies,” to record your preferences and actions. We may also use web beacons (also known as “action tags,” “tracer tags,” or “single-pixel gifs”) to collect information about your use of a given website. We use these and other similar technologies for security, and to monitor traffic, improve the Sites, and make our Sites easier to use and more relevant to you. See our Cookie Policy below for more information.

Information collected from other sources: We may collect information about you that we receive from other sources, from email correspondence, or from our offline interactions with you to, among other things, enable us to verify or update information contained in our records and to better customize services for you. We may also combine information we receive from third parties with the information we receive based on your use of the Sites and any other interactions with us.

Why We Collect, Process, and Share

Engage in a contractual relationship with you; we utilize information provided by subscribers to provide content, products, and services including the operation, management, and billing support necessary to accomplish those business purposes. Additionally, we may use your information to communicate about account or transactions and send information about features, enhancements or optimization of our products or policies. Further, we may provide special offers or promotions or personalize content and experiences based on your preferences.
Comply with legal obligations applicable to the REAL System; use related to prevention and investigatory activities or administrative formalities, registration, declarations or audits; to satisfy legal requests from administrative or judicial authorities, and in accordance with applicable laws; comply with a subpoena, required registration, or legal process.
Protect the legitimate rights and interests of Penumbra; use to protect the health, safety, and security of our personnel and premises; in providing information about our products and or Sites including optimizing Site features including performing statistical or marketing analysis of nonidentifying Site data; to protect ourselves against possible fraudulent actions including website security including detection, investigation, and prevention of activities that may violate our policies or be illegal.
Provide prior consent; in applicable events, we will obtain consent from you to collect your data via a signed document. The consent document will include relevant information to allow you to be fully informed and permit voluntary consent to the processing described in that document; in the event that legislation of your country so requires, this Notice and/or those consents may be supplemented, where applicable, by mandatory information prescribed by local law.

We take steps to ensure your rights are not disproportionately infringed, including allowing you to change your information to make sure it is accurate, and making sure that we do not start to use your personally identifying information for new purposes without giving you prior notice. Where we rely on our legitimate interests to process your personally identifying information, you have the right to object to such processing, as described in more detail under ‘Your Rights and Contacts’ below.

How Data is Stored, Protected, and Retained

A variety of technological and organizational procedures and measures are designed to ensure the integrity, confidentiality, and availability of the personally identifiable information processed by the Sites. The design of the procedures and measures included evaluation of the likelihood, severity of risk of rights and freedoms of natural persons, as well as the state of the art, the costs of implementation and the nature, scope, context, and purposes of processing. Procedures and measures include technical and physical access controls including encryption, and pseudonymization and anonymization of personally identifiable information.

Information collected through the Sites is stored by Penumbra in its databases hosted by third parties located in the United States. Penumbra will ensure the implementation of adequate safeguards required by applicable data privacy regulations (including the European Commission’s Standard Contractual Clauses, as the case may be adapted to Switzerland, as applicable) to protect personally identifiable information collected through the Sites. To find more about the safeguards implemented by Penumbra, and to obtain a copy of them, please contact us by emailing privacy@realsystem.com.

Personally identifying information will be kept for the minimum time period necessary to fulfill the purposes described herein, except where a longer storage is necessary to comply with applicable law or to protect Penumbra’s rights and interests (i.e. where the processing is necessary for the establishment, exercise or defense of legal claims).

Where third-parties are engaged to process personally identifying information collected by the Sites, such third parties are required to comply with applicable privacy laws and this Notice; and must ensure adequate technical and organizational security measures designed to protect the confidentiality, integrity, and availability of the personally identifying information.

Your Account

You may create an account to access the subscription area of the Site. You are responsible for protecting and securing personal information you provided during your account creation. For more information, please see “Your Account” under the Site’s Website Terms of Use.

Subscription

If you wish to subscribe to our services, you will be asked to supply certain information relevant to your subscription, including your name, email address, delivery address, and billing information. The service may employ the use of third-party services for the purposes of facilitating payment and processing of subscriptions. For more information, please see “Subscription” under the Site’s Website Terms of Use.

REAL System Security Notice

Subscribers to the REAL™ Immersive System will receive a copy of the REAL System Security Notice including the applicable Business Associate Agreement in compliance with the Health Insurance Portability and Accountability Act of 1996.

Your Rights and Contacts

You can review and change your personal information by logging into the Sites and visiting your account profile page.

You may also send us an email at privacy@realsystem.com to request access to, correct or delete any personal information that you have provided to us. We may not be able to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

All questions, complaints, or comments about this Notice can be emailed to the Data Protection Risk Management Team at privacy@realsystem.com and we will use reasonable efforts to respond to you as soon as possible.

Children

The Sites are not intended for children under 13 years of age. No one under the age of 13 may provide any information to or on the Sites. We do not knowingly collect, use, or disclose personally identifiable information from anyone under 13 years of age. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13 without verification of parental consent, we will make reasonable efforts to delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@realsystem.com.

California Privacy Rights

If you are a California resident, California law permits you to request certain information from companies that share your personal information with other companies for those companies’ direct marketing purposes. Penumbra will not share your personally identifiable information with unaffiliated third parties to use for their own marketing purposes without obtaining your consent to do so. California customers who wish to request further information about the entities with which we have shared their personal information, if any, should email us at privacy@realsystem.com.

Do Not Track

Penimbra does not track Site visitors over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, Safari allows you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked. All About Do Not Track, a Future of Privacy Forum website has more information about DNT signals and is located https://allaboutdnt.com.

Cookie Policy

Like many websites, we use “cookies,” which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions. We may also use web beacons (also known as “action tags,” “tracer tags,” or “single-pixel gifs”), which are an invisible graphic on a web page that is programmed to collect information about your use of a given website. We use these and other similar technologies for security, and to monitor traffic, improve the Sites, and make our Sites easier to use and more relevant to you. Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Sites may not work or may not work as designed.

For more information on cookies and how to disable them, you can consult the information provided by visiting Interactive Advertising Bureau at www.allaboutcookies.org or Your Online Choices at http://www.youronlinechoices.eu.

In order to provide your consent to our placement of cookies other than Strictly Necessary Cookies (as described below), please click on the button on the pop up message. If you do not wish to provide your consent, or if you would like to make your individual choices and only accept some of our cookies, please click the “Cookie Settings” link and make your selections in the Privacy Preference Center. You can also use this tool to withdraw your consent and change your preferences at any time.

If you, or another user of your computer, wish to withdraw your consent at any time, you can also do so by altering your browser settings to decline cookies. You have the option to configure your browser to accept, reject, or delete cookies.

At this time, we only use strictly necessary cookies as listed below. This section concerning cookies will be timely updated as we update features and the need for cookies.

Strictly Necessary Cookies – These cookies are essential to enable you to move around the Site and use its features. These cookies cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.