Sofregen Medical Inc. and its subsidiaries (hereafter “Sofregen” or the “Company”) collects personal information in order to serve you and communicate with you. This Privacy Statement explains how Sofregen uses and discloses your personal information and answers specific questions that you may have regarding privacy and security. If you have additional questions, please contact us at info@sofregenmedical.com.

This Privacy Statement applies mainly to the operation of the Company’s U.S. website and other applications that directly link to this statement when you click on “Privacy Policy” in the website footer. Sofregen’s subsidiaries may have additional privacy statements which are specifically tailored to the laws in those countries. Those privacy statements may be available when you click on “Privacy Policy” in the footer of the Company’s various websites.

1. Types of Personal Information

This Privacy Statement explains the Company’s practices with regard to “Personal Information.” Personal Information is any information that can be used to identify, locate or contact you. It also includes other information that may be associated with such Personal Information. Examples of types of Personal Information:

  • Contact Information that allows us to communicate with you, such as your name, email address, mailing address, email address or phone numbers;
  • Relationship Information that helps us understands your interests, including information about products, treatments and health conditions that are of interest to you;
  • Information about how you interact with Sofregen, including, but not limited to, inquiries, and information about how you use the Company’s websites and applications;
  • Geo-location Information, as may be transmitted to us by your smart phone or other location-aware devices; and
  • Job Applicant Information, to process your job application, such as your Contact Information, resume, previous work experience, education, transcript and information relating to references.

2. How Sofregen Collects Personal Information

In many cases, we collect Personal Information directly from you. We will ask you for Personal Information when you interact with us, such as registering on our websites, using any interactive features or applications, signing up to receive a newsletter or a rebate, or applying for employment, or (as applicable) making a direct purchase. We may collect additional information from third party data suppliers who enhance our files or from social media sites such as Facebook, if you like our pages or join our communities.

If you interact with us online, we use cookies and other technological tools to collect information about your computer and your use of our website and applications. We treat this information as Personal Information only when it is associated with your Contact Information. For more information about cookies and other technologies, please see the section Cookies and Other Data Collection Technologies below.

3. How Sofregen Uses Personal Information

Sofregen may use your Personal Information for its business purposes, such as to:

  • To respond to your requests for information, products, services, including managing your online accounts with us and providing warranty service for certain products;
  • To provide you with general health information (such as information on certain health conditions) as well as information about our products and services to the extent permissible by law;
  • Provide you with marketing communications and offers for products and services if you have authorized us to do so;
  • To administer promotional programs, such as sweepstakes, rewards and rebate programs if you have authorized us to do so;
  • To determine if you are eligible for certain products, services or programs;
  • If you have a business or professional relationship with Sofregen, to develop our business relationship with you;
  • If you apply for a job via our career center, to consider you for employment;
  • For our research and development efforts if you have agreed to this use;
  • To anonymize data so that it is no longer Personal Information;
  • For product safety, such as adverse event reporting or to communicate product safety information to you; and
  • For other everyday business purposes, such as payment processing and financial account management, product development, contract management, website administration, fulfillment, analytics, fraud prevention, corporate governance, reporting and legal compliance.

4. Why Personal Information Is Disclosed by Sofregen

Sofregen does not use or sell, share or otherwise distribute your Personal Information with third parties for their marketing purposes. Sofregen will share your Personal Information only in compliance with any obligations under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and other applicable laws. For example, we will share your Personal Information as follows:

  • We may share your Personal Information with your consent or as you direct. For example, we may share information with your doctor as part of programs in which you agree to participate;
  • We may share your Personal Information with our service providers, who are bound by law or contract to protect your Personal Information and only use your Personal Information in accordance with our instructions. For example, we may share your Personal Information with vendors who provide data processing or fulfillment services for us;
  • We may also disclose Personal Information where needed to affect the sale or transfer of business assets, to investigate legal issues, enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed support external auditing, compliance and corporate governance functions;
  • We may also disclose Personal Information when requested under legal process or otherwise required by law, such as in response to a subpoena, including to law enforcement agencies and courts in the United States and other countries where we operate; or
  • Please note that we may also disclose information about you that is not personally identifiable. For example, we may publish reports that contain aggregated and statistical data about our customers. These reports do not contain any information that would enable the recipient to contact, locate or identify you.

5. Disclosure to Subsequent Owner or Operator

If all or part of Sofregen is sold or merged into another entity, the information we have about you may be transferred to a third party as part of that transaction. We will try to assure that no personally identifiable information that is transferred will be used or shared in a manner inconsistent with this Privacy Statement without your consent. However, in the event of a sale or merger, your continued use of this site signifies your agreement to be bound by the privacy statement and other applicable terms of the subsequent owner or operator.

6. Consent to Processing in the United States and Elsewhere

This site is owned and operated by Sofregen in the United States, but the information you provide will be accessible to our affiliates, vendors, and suppliers in other countries. Furthermore, if you are visiting this site from another country, other than the United States, your communication with us will necessarily result in the transfer of information across international boundaries. The level of legal protection for personal information is not the same in all countries. However, we will take the security measures described in this Privacy Statement in an effort to keep your information secure. By using this site, you consent to the collection, storage, and processing of your information in the United States and in any country to which we may transfer your information in the course of our business operations.

7. Cookies and Other Data Collection Technologies

When you visit our website or use our mobile applications, we collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons.

For example, when you visit our website, we place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud.

Sofregen may now or in the future choose to use Flash Cookies (also known as Local Stored Objects), Microsoft Silverlight and similar technologies to personalize and enhance your online experience in compliance with Network Advertising Initiative standards. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation. Flash cookies (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies, but these are managed through a different interface than the one provided by your web browser. To manage Flash cookies, please see Adobe’s website at http://kb2.adobe.com/cps/526/52697ee8.html or visit www.adobe.com. To manage Silverlight cookies, see Microsoft’s privacy statement at http://www.microsoft.com/getsilverlight/get-started/install/privacy.aspx or visit www.microsoft.com.

Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions.

We collect many different types of information from cookies and other technologies. For example, we may collect information about the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to Sofregen and the website you visit after you leave our site.

In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Information. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns.

In some cases, we do associate the information we collect using cookies and other technology with your Personal Information. This Privacy Statement governs how we use all of this information when we associate it with your Personal Information.

Sofregen may have relationships with third party advertising companies to place advertisements on this website and other websites, and to perform tracking and reporting functions for this website and other websites. These third party advertising companies may place cookies on your computer when you visit our website or other websites so that they can display targeted advertisements to you. These third party advertising companies do not collect Personal Information in this process, and we do not give any Personal Information to them as part of this process. However, this Privacy Statement does not cover the collection methods or use of the information collected by these vendors. For more information about third party advertising, please visit the Network Advertising Initiative (NAI) at www.networkadvertising.org.

8. Social Media Plugins

This website, from time to time, uses social medial plugins (e.g., the Facebook “Like” button, “Share to Twitter” button) to enable you to easily share information with others. When you visit our website, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our site. If you are logged into the social media website (e.g., Facebook, Twitter) while browsing on our website, the social plugins allow that social media websites to share information about your activities on our website with other users of their social media website. For example, Facebook Social Plugins allows Facebook to show your Likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allows you to see your friends’ Facebook activity on our website. Sofregen does not control any of the content from the social media plugins. For more information about social plugins from other social media websites you should refer to those sites’ privacy and data sharing statements.

9. Do-Not Track Signals and Similar Mechanisms

Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. Websites linked to this Privacy Statement do not currently respond to these “do-not-track” signals.

10. Tell-A-Friend Functions

Sofregen may now or in the future offer “tell-a-friend” functionality on our websites. If you choose to use this function, we will collect Contact Information for your friend. We will automatically send your friend a one-time email with the information you specified or inviting him or her to visit the site. Sofregen uses this information for the sole purpose of sending this one-time email and does not retain the information.

You can always limit the information you provide to Sofregen. You can also limit the communications that the Company sends to you by following a simple opt-out process. If you have authorized us to send you marketing materials and decide to opt out, simply follow the instructions in our emails to opt-out of receiving future marketing communications.

Please note that even if you opt-out of promotional emails, we may still need to contact you with important transactional information about your account or your equipment. For example, even if you opt-out of emails, we will still send you a confirmation when you purchase something from our website as well as product safety communications.

You can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the help section of your browser to learn about cookie preferences and other privacy settings that may be available.

You can opt-out of being targeted by those third party advertising companies that are NAI members online at www.networkadvertising.org/consumer/opt_out.asp.

11. Your Choices

Sofregen respects your right to access and correct your Personal Information. You may update your Personal Information at any time by contacting us via email at info@sofregenmedical.com, or directly by logging into on your online account, should you have one. You can also write us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and detailed information about the change you would like to make.

12. Access and Correction

13. Information Security

Sofregen has implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard your Personal Information from unlawful use and unauthorized disclosure.

14. Privacy Policies of Third Parties

This Privacy Statement only addresses the use and disclosure of information by Sofregen. We may provide links to outside websites or advertisements for third parties that have their own privacy policies and data collection, use and disclosure practices. Our independent dealers, suppliers and business partners have their own privacy statements too. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.

15. Children’s Privacy

The Sofregen website and applications are not intended to attract children, and we do not knowingly collect any Personal Information of anyone under the age of 13. If you are under 13, please do not provide us with any Personal Information. If you believe your child is using our website, please contact us at info@sofregenmedical.com so we can investigate and delete any inappropriate information.

16. Forums, Product Reviews and Other Public Areas

Our websites may now or in the future contain forums and other areas where you can publicly post product reviews, communicate with others, and submit media content. Prior to posting in these areas, please read our Terms of Use carefully. You have no privacy rights in public postings. All the information you post will be accessible to anyone with Internet access, and any Personal Information you include in your posting may be read, collected, and used by others. For example, if you post your email address along with a product review, you may receive unsolicited messages. Please use caution when posting any Personal Information.

17. Changes to this Privacy Statement

We will only use Personal Information in the manner described in this Privacy Statement in effect when the information was collected from you. However, we reserve the right to change the terms of this Privacy Statement at any time by posting revisions to our site. If we make any material changes to this Privacy Statement, we will either notify you or place a prominent notice on our website. If at any point, we decided to use Personal Information in a manner different from that stated at the time it was collected, you will be given a choice to allow or disallow any additional uses or disclosures of your Personal Information beyond that which was stated in this Privacy Statement at the time your information was collected.

Any portions of this policy are void to the extent they are prohibited by applicable law.

18. Changes to this Privacy Statement

Please contact us if you have any questions or comments about our privacy practices, your privacy choices, or this Privacy Statement. You can always reach us online at mailto:info@sofregen.com. You can reach us via mail at the address below. If you send us a letter, please provide your name, address, email address, and information about the communication that you do not want to receive.

Sofregen Medical Inc. | Attention: Privacy Office | 200 Boston Avenue, Suite 1100 | Medford, MA 02155 USA

19. Job Applicants

If you have applied for employment with Sofregen, the Personal Information submitted with your job application will be used to process and consider your job application. Sofregen will not sell the information on your application to unaffiliated third-parties for their marketing purposes. We may share the information on your applications with recruiters, consultants, attorneys, background services and our affiliates. The information on your application may also be used for certain regulatory, compliance and legal purposes, consistent with this Privacy Statement.

To the extent the Personal Information you provide contains details of your: racial or ethnic origin; political opinions or beliefs; religious beliefs; membership in a trade union or political party; physical or mental health condition; sexual life; commission (or alleged commission) of an offence or related proceedings; job evaluations or educational records, you expressly authorize Sofregen to handle such details for the purposes of your job application and for the other purposes described herein.

By submitting information to us online, you are sending it to the United States, where it will be subject to the protections afforded under US laws that may be different from the laws in your country and which your country may consider not to provide adequate privacy protections. If you do not agree that your submission of your application information will be governed solely by United States law, Sofregen will not accept your application.

20. California Privacy Rights

As described above, Sofregen will not sell, share or otherwise distribute your Personal Information with third parties for their marketing purposes. However, if you are a California resident and an individual customer of Sofregen, California Civil Code Section 1798.83 permits you to request certain information regarding our disclosures of Personal Information to third parties for their direct marketing purposes. To make such a request please email us at info@sofregen.com, or write to:

Sofregen Medical Inc. | Attention: Privacy Office | 200 Boston Avenue, Suite 1100 | Medford, MA 02155 USA

Be sure to include your name and address. You can include your email address if you want to receive a response by email. Otherwise, we will respond by postal mail within the time required by law.

21. Sensitive Information Protection Policy

Sofregen may collect sensitive personal information in the ordinary course of its business. Sofregen has implemented reasonable technical, physical and administrative safeguards to help protect the sensitive personal information from unlawful use and unauthorized disclosure.