Free Flow Medical Privacy Policy
Last updated: April 23, 2024
This Privacy Policy (“Policy”) describes the manner in which Free Flow Medical, Inc. (“Free Flow”, “we,” or “us”), its affiliate Free Flow Medical GmbH, and our website at www.freeflowmedical.com (the “Site”) collect and use data from individuals.
Personal data (referred to as “data”) will only be processed to the extent necessary and for the purpose of providing a functional and user-friendly website, including its contents, and the services offered.
Per Art. 4 No. 1 of Regulation (EU) 2016/679, i.e. the General Data Protection Regulation (hereinafter referred to as the “GDPR”), “processing” refers to any operation or set of operations such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction performed on personal data, whether by automated means or not.
This privacy policy is intended to inform you about the type, scope, purpose, duration, and legal basis for processing data either under our own control or in conjunction with others. It also informs you about third-party components we use to optimize our website and improve the user experience which may result in said third parties also processing data they collect and control.
Our privacy policy is structured as follows:
I. Information about us as controllers of your data
II. The rights of users and data subjects
III. Information about the data processing
I. Information about us as controllers of your data
The party responsible for this website (the “controller”) for purposes of data protection law is:
Free Flow Medical, Inc.
44380 South Grimmer Boulevard
Fremont, CA 94538
United States
II. The rights of users and data subjects
With regard to the data processing to be described in more detail below, users and data subjects have the right to:
- confirmation of whether data concerning them is being processed, information about the data being processed, further information about the nature of the data processing, and copies of the data (cf. also Art. 15 GDPR);
- correct or complete incorrect or incomplete data (cf. also Art. 16 GDPR);
- the immediate deletion of data concerning them (cf. also Art. 17 DSGVO), or, alternatively, if further processing is necessary as stipulated in Art. 17 Para. 3 GDPR, to restrict said processing per Art. 18 GDPR;
- receive copies of the data concerning them and/or provided by them and to have the same transmitted to other providers/controllers (cf. also Art. 20 GDPR);
- file complaints with the supervisory authority if they believe that data concerning them is being processed by the controller in breach of data protection provisions (see also Art. 77 GDPR).
In addition, the controller is obliged to inform all recipients to whom it discloses data of any such corrections, deletions, or restrictions placed on processing the same per Art. 16, 17 Para. 1, 18 GDPR. However, this obligation does not apply if such notification is impossible or involves a disproportionate effort. Nevertheless, users have a right to information about these recipients.
Likewise, under Art. 21 GDPR, users and data subjects have the right to object to the controller’s future processing of their data pursuant to Art. 6 Para. 1 lit. f) GDPR. In particular, an objection to data processing for the purpose of direct advertising is permissible.
III. Information about the data processing
Your data, processed when using our website, will be deleted or blocked as soon as the purpose for its storage ceases to apply, provided the deletion of the same is not in breach of any statutory storage obligations or unless otherwise stipulated below.
Server data
For technical reasons, the following data sent by your internet browser to us or to our server provider will be collected, especially to ensure a secure and stable website: These server log files record the type and version of your browser, operating system, the website from which you came (referrer URL), the webpages on our site visited, the date and time of your visit, as well as the IP address from which you visited our site.
The data thus collected will be temporarily stored, but not in association with any other of your data.
The basis for this storage is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the improvement, stability, functionality, and security of our website.
The data will be deleted within no more than seven days, unless continued storage is required for evidentiary purposes. In which case, all or part of the data will be excluded from deletion until the investigation of the relevant incident is finally resolved.
International Transfers of Information
We may share your information, including personally-identifying information, between the Free Flow entities. This will involve transferring your data outside the European Union (EU).
We also may engage with external third parties who are outside the EU so their processing of your personally-identifying information will involve a transfer of your data outside the EU.
Wherever we transfer your personal data outside of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection by the European Commission.
We require our third party service providers to use contracts incorporating the European Commission’s pre-approved contractual terms.
For US providers, we may transfer information to them if they are part of Privacy Shield which requires them to provide a similar level of protection to information shared between the US and EU.
Cookies
a) Session cookies
We use cookies on our website. Cookies are small text files or other storage technologies stored on your computer by your browser. These cookies process certain specific information about you, such as your browser, location data, or IP address.
This processing makes our website more user-friendly, efficient, and secure, allowing us, for example, to display our website in different languages or to offer a shopping cart function.
The legal basis for such processing is Art. 6 Para. 1 lit. b) GDPR, insofar as these cookies are used to collect data to initiate or process contractual relationships.
If the processing does not serve to initiate or process a contract, our legitimate interest lies in improving the functionality of our website. The legal basis is then Art. 6 Para. 1 lit. f) GDPR.
When you close your browser, these session cookies are deleted.
b) Third-party cookies
If necessary, our website may also use cookies from companies with whom we cooperate for the purpose of advertising, analyzing, or improving the features of our website.
Please refer to the following information for details, in particular for the legal basis and purpose of such third-party collection and processing of data collected through cookies.
c) Disabling cookies
You can refuse the use of cookies by changing the settings on your browser. Likewise, you can use the browser to delete cookies that have already been stored. However, the steps and measures required vary, depending on the browser you use. If you have any questions, please use the help function or consult the documentation for your browser or contact its maker for support. Browser settings cannot prevent so-called flash cookies from being set. Instead, you will need to change the setting of your Flash player. The steps and measures required for this also depend on the Flash player you are using. If you have any questions, please use the help function or consult the documentation for your Flash player or contact its maker for support.
D) Contact Form
If you send us inquiries via our contact form, we store the information from the form and the contact details you provide. This is for the purpose of processing your request and possible follow-up questions. This information will not be passed on without your consent.
The data provided in the contact form is processed exclusively on the basis of your consent in accordance with Article 6(1)(a) of the General Data Protection Regulation (GDPR). This consent can be revoked at any time. An informal notification by email is sufficient for this. The lawfulness of the processing of data up to the time of revocation remains unaffected by this.
We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after we have finished processing your request). This does not affect mandatory statutory retention obligations, such as retention periods.
To send your request via our contact form, we use SendLayer, an SMTP e-mail delivery service that complies with data protection regulations. Please also read SendLayer’s privacy policy: https://sendlayer.com/privacy-policy/.
In order to comply with data protection standards such as GDPR/DSGVO, email content is not stored on SendLayer servers. The following information is stored in the SendLayer email logs (https://sendlayer.com/docs/checking-the-email-log/)
- Timestamp
- From email
- Reply to email
- TO/CC/BCC emails
- Subject
- Email size
Currently (Status as of April 2024), the log retention period is up to 30 days.
If you prevent or restrict the installation of cookies, not all of the functions on our site may be fully usable.
Updates to this Policy
Free Flow may update this Privacy Policy periodically. We will notify you of significant changes to the Privacy Policy by placing a prominent notice on this Site. It is your responsibility to review the most recent version of the Privacy Policy and remain informed about any changes to it. Personal data collected from you will be used by us for those purposes indicated in this Privacy Policy or on the Site at the time that the information was collected.
Contact
If you contact us via email, the data you provide will be used for the purpose of processing your request. We must have this data in order to process and answer your inquiry; otherwise we will not be able to answer it in full or at all.
The legal basis for this data processing is Art. 6 Para. 1 lit. b) GDPR.
Your data will be deleted once we have fully answered your inquiry and there is no further legal obligation to store your data, such as if an order or contract resulted therefrom.
Applicable Law
Any dispute arising between a customer and Free Flow will be settled in accordance with U.S. law.
