Privacy Policy

Last modified:  April 17, 2020

The following privacy policy applies to the Website: SurgiFi.com.

Your use of the Website constitutes your acceptance of, and agreement to, the following Privacy Policy. SurgiFi.com reserves the right to modify, alter, amend or update its Website, and Privacy Policy at any time. This Privacy Policy is subject to change without notice. If you do not agree with or do not accept any part of this Privacy Policy, you must not use the Website.

WHAT INFORMATION DO WE COLLECT AND HOW IS IT USED?

HOW YOUR INFORMATION MAY BE USED

The Website may use the information collected in the following ways:

• To operate and maintain the Website;
• To send you promotional information, such as newsletters. Each email promotion will provide information on how to opt-out of future mailings;
• To send you administrative communications, such as administrative emails, confirmation emails, technical notices, updates on policies, or security alerts;
• To respond to your comments or inquiries;
• To provide you with user support;
• To track and measure advertising on the Website; or,
• To protect, investigate, and deter against unauthorized or illegal activity.

THIRD-PARTY USE OF PERSONAL INFORMATION

The Website may share your information with third parties when you explicitly authorize us to share your information. Additionally, the Website may use third-party service providers to service various aspects of the Website. Each third-party service provider’s use of your personal information is dictated by their respective privacy policies. The Website currently uses the following third-party service providers:

• Google Analytics – this service tracks Website usage and provides information such as referring websites and user actions on the Website. Google Analytics may capture your IP address, but no other personal information is captured by Google Analytics. You may access Google Analytics’ privacy policy here.

Your personal information is not shared with any other third-party applications. This list may be amended as needed in the Website’s sole discretion.

Except when required by law, SurgiFi.com will not sell, distribute, or reveal your email addresses or other personal information without your consent.

PUBLICLY AVAILABLE INFORMATION

The Website may include interactive sections such as commenting areas. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information. 

ANONYMOUS DATA

From time to time, SurgiFi.com may use anonymous data, which does not identify you alone, or when combined with data from other parties. This type of anonymous data may be provided to other parties for marketing, advertising, or other uses. Examples of this anonymous data may include analytics or information collected from cookies.

COOKIES

The Website uses cookies to store visitors’ preferences, record user-specific information on what pages users access or visit, ensure that visitors are not repeatedly sent the same banner ads, customize content based on visitors’ browser type or other information that the visitor sends. Cookies may also be used by third-party services, such as Google Analytics, as described herein.

What are cookies?

A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website.  The Cookie will collect information relating to your use of the Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at the Website via a link from third party site, the URL of the linking page. 

In addition to Cookies, the Website may use web beacons.  Web beacons allow us to count the number of users who have visited or accessed the Website and to recognize users by accessing our cookies. We may employ web beacons to facilitate Website administration and navigation, to track the actions of users of the Website, to compile aggregate statistics about Website usage and response rates, and to provide an enhanced online experience for visitors to the Website. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. A web beacon is often invisible because it is only 1 x 1 pixel in size with no color.  A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF and tracker GIF. 

What are the different types of cookies and how do we use them?

Essential – These are Cookies which are essential for the running of the Website. Without these Cookies, parts of the Website would not function.  These Cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.

Examples of how we may use essential Cookies include:

• Setting unique identifiers for each unique visitor, so that website numbers can be analyzed.

Functional – These Cookies are used to remember your preferences on the Website and to provide enhanced, more personal features. The information collected by these Cookies is usually anonymized, so we cannot identify you personally.  Functional Cookies do not track your internet usage or gather information which could be used for selling advertising.

Examples of how we may use functional Cookies include:

• Gathering data about visits to the Website, including numbers of visitors and visits, length of time spent on the site, pages clicked on or where visitors have come from
• Eliminating the need for returning users to re-enter their login details.

Analytical Performance – Analytical performance Cookies are used to monitor the performance of the Website, for example, to determine the number of page views and the number of unique users our the Website has. We use this information to improve user experience or identify areas of the Website which may require maintenance.  The information is anonymous (i.e. it cannot be used to identify you and does not contain personal information such as your name and email address) and it is only used for statistical purposes.

Examples of how we may use analytical Cookies include:

• Measuring users’ behavior 
• Analyze which pages are viewed and how long for and which links are followed to better develop the Website

Advertising – Behavioral advertising Cookies, which may be placed on your device by us or our trusted third-party service providers, remember that you have visited a website and use that information to provide you with advertising which is tailored to your interests. This is often called online behavioral advertising and is done by grouping together shared interests based upon web browsing history. Your web browsing history can be used to infer things about you (e.g. your age, gender etc.), and this information may also be used to make advertising on websites more relevant to you.  Although behavioral advertising Cookies can track your activity around the internet, these Cookies cannot identify you personally.  

Examples of how we may use advertising Cookies include:

• Manage online advertising.  the Website may use Cookies together with web beacons to provide advertising to you and to enable us to manage our relationship with those advertisers by, for example, tracking how many unique users have seen a particular advertisement or followed a link in an advertisement.

Third Party Cookies – You may notice on some pages of the Website that Cookies have been set that are not related to us. When you visit a page with content embedded from, for example, YouTube or Facebook, these third party service providers may set their own Cookies on your device. We do not control the use of these third party Cookies and cannot access them due to the way that Cookies work, as Cookies can only be accessed by the party who originally set them. Please check the third party websites for more information about these Cookies.

We also may use DART cookies for ad serving through Google’s DoubleClick, which places a cookie on your computer when you are browsing the web and visit a site using DoubleClick advertising (including some Google AdSense advertisements). This cookie is used to serve ads specific to you and your interests. The ads served will be targeted based on your previous browsing history.  DART uses “non personally identifiable information”. It does NOT track personal information about you, such as your name, email address, physical address, telephone number, social security numbers, bank account numbers or credit card numbers. You can opt-out of this ad serving on all sites using this advertising by visiting https://www.doubleclick.com/privacy/dart_adserving.aspx

Users may, at any time, prevent the setting of cookies, by the Website, by using a corresponding setting of your internet browser and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. However, if users deactivate the setting of cookies in your Internet browser, not all functions of our Website may be entirely usable.

How can you manage or opt-out of cookies?

Cookies, including those which have already been set, can be deleted from your hard drive. You can also change the preferences/settings in your web browser to control Cookies. In some cases, you can choose to accept Cookies from the primary site, but block them from third parties. In others, you can block Cookies from specific advertisers, or clear out all Cookies. Deleting or blocking Cookies may reduce functionality of the Website. To learn more about how to reject Cookies, visit www.allaboutcookies.org or go to the help menu within your internet browser. If you experience any problems having deleted Cookies, you should contact the supplier of your web browser.

Opting out of Analytical Performance Cookies

If you would like to opt out of Analytics Cookies, please do so by clicking on the links below:

Google Analytics: https://tools.google.com/dlpage/gaoptout

Opting out of Behavioral Advertising Cookies

If you would like more information about how to opt out of interest-based advertising in desktop and mobile browsers on a particular device, please visit https://optout.aboutads.info/#/ and https://optout.networkadvertising.org/#. You may download the AppChoices app at https://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.  

ADVERTISING

Display Ads

• The Website does not currently display ads, however reserves the right to display ads consistent with the Website.

Retargeting Ads

• The Website reserves the right to possibly engage in remarketing efforts with third-party companies, such as Google, Facebook, Reddit, Snapchat, Quora or Instagram, in order to market the Website. These companies use cookies to serve ads based on someone’s past visits to the Website.   You may opt-out of this data collection by visiting the provider’s website and adjusting your privacy settings.

Sponsored Content Tracking Pixels

• This Website may engage in sponsored campaigns with various influencer networks, brands, and agencies. All sponsored content is duly disclosed in accordance with the FTC’s requirements. From time to time, these sponsored campaigns utilize tracking pixels (aka web beacons), which may contain cookies to collect data regarding usage and audience. This information is collected by the sponsoring company to track the results of the campaign. As stated above, these pixels may capture your IP address on behalf of the content sponsor. No personally identifiable information collected by the Website is used in conjunction with these tracking pixels.

Affiliate Program Participation

• The Website may engage in affiliate marketing, which is done by embedding tracking links into the Website. If you click on a link for an affiliate partnership, a cookie will be placed on your browser to track any sales for purposes of commissions.  

RIGHTS RELATED TO YOUR PERSONAL INFORMATION

• Opt-out – You may opt-out of future email communications by following the unsubscribe links in our emails. You may also notify via our Removal Page to be removed from our mailing list.

• Access – You may access the personal information we have about you by submitting a request to contact@surgifi.com.

• Amend – You may contact us contact@surgifi.com to amend or update your personal information.

• Forget – In certain situations, you may request that we erase or forget your personal data. To do so, please submit a request to contact@surgifi.com.

• Please note that we may need to retain certain information for record keeping purposes or to complete transactions, or when required by law.

CALIFORNIA RESIDENTS

California Residents:   Pursuant to the California Consumer Privacy Act of 2019 (“CCPA”), you have certain rights with respect to your personal information.  For the purposes of this section, personal information is used as defined in the CCPA. SurgiFi.com reserves the right to verify all requests made pursuant to the CCPA.     

Access and Disclosure

You may make a verifiable request that we disclose the categories of personal information we have collected about you, the categories of sources of the personal information we collected about you, the business or commercial purpose for collecting or selling the personal information, the categories of third parties with whom we share your personal information, our use of the personal information and if the personal information was disclosed or sold to third parties, including the categories of personal information sold or disclosed.  You also have the right to make a verifiable request for a copy of the personal information collected about you for the twelve (12) months prior to the date of your request.

Deletion Request Rights

You have the right to request that SurgiFI.com delete any of your personal information that we collected from you and retained, subject to certain exceptions.  We may deny your deletion request if retaining the personal information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

SENSITIVE PERSONAL INFORMATION

At no time should you submit sensitive personal information to the Website. This includes your social security number, information regarding race or ethnic origin, political opinions, religious beliefs, health information, criminal background, or trade union memberships. If you elect to submit such information to us, it will be subject to this Privacy Policy.

CHILDREN’S INFORMATION

The Website does not knowingly collect any personally identifiable information from children under the age of 16. If a parent or guardian believes that the Website has personally identifiable information of a child under the age of 16 in its database, please contact us immediately at contact@surgifi.com and we will use our best efforts to promptly remove such information from our records.