Spatz Adjustable Gastric Balloon

Privacy Policy

SPATZ FGIA INC.

LAST UPDATE: [03/03/2024]

Spatz FGIA Inc. and its affiliates (“Spatz”, “we”, “our”, and “us”) respect your concerns about privacy and personal data protection and value our relationship with you.  This Privacy Policy (the “Policy”) applies solely to personal information collected through the Spatz website, online services, any applications, and web pages that post, specifically reference, and incorporate this Policy (all of the foregoing, collectively, the “Site”), whether accessed via computer, mobile device or other device (collectively, “Device”).  

This Policy describes the types of personal information we collect through the Site and how that personal information may be used and/or with whom it may be shared.  This Policy also describes how you can reach us to update your personal information, access and control the use of the personal information, or get answers to questions you may have about our privacy practices at this Site.  Please read this Policy carefully, because by accessing and using this Site you are acknowledging that you understand and agree to the terms of this Policy.  In addition, please review our Terms of Use, which governs your use of this Site. 

By accessing, browsing, or otherwise using the Site, by accepting or entering into our Terms of Use, you agree on behalf of yourself and any organization or company that you represent (together, “you”) that you have read and understand this Policy and that you consent to our collection, use, and disclosure of your personal information and other collected information pursuant to the terms of this Policy. If you do not agree with this Policy, do not access or use the Site.

The contents of the Site, such as text, graphics, images, and other materials created by Spatz or obtained from Spatz’s licensors, and other materials contained on the Site (collectively, “Content”) are for informational purposes only. The Content is not intended to be a substitute for professional medical advice, diagnosis, or treatment. Always seek the advice of your physician or other qualified health provider with any questions you may have regarding a medical condition. Never disregard professional medical advice or delay in seeking it because of something you have read on the Site! If you think you may have a medical emergency, call your doctor, go to the emergency department, or call 911 immediately. Spatz does not recommend or endorse any specific tests, physicians, products, procedures, opinions, or other information that may be mentioned on the Site. Reliance on any information provided by Spatz, Spatz employees, contracted writers, or medical professionals presenting content for publication to Spatz is solely at your own risk. None of the Content nor any information you share through the Site constitutes protected health information, and while we will protect your information in accordance with our Policy, this Site and Spatz are not subject to any HIPAA requirements. 

1.CONSENT

Consent to Data Collection and Processing

You hereby agree with and consent to the collection and processing of your personal information as described in this Policy.

Consent to International Data Transfers

Your personal information may be collected, processed and stored by Spatz or its services providers in the United States and other countries where our servers reside.  Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. You hereby agree with and consent to the transfer of your personal data to the United States and other countries where Spatz operates.

Withdrawal of Consent

You may have the right, at any time but only to the extent provided under the law of the jurisdiction in which you are located and if such law is applicable to Spatz’s processing of your personal information, to withdraw your consent to Spatz’s collection and processing of your information, or to the transfer of your personal data to the United States and other countries where Spatz operates. You may withdraw your consent by emailing Spatz at [email protected].

2.COLLECTION AND USE OF PERSONAL INFORMATION

As you interact with Spatz, there may be opportunities for you to provide us with your information. Additionally, we may collect certain information about your as further described below.

You may provide us with information about you through a number of sources: Spatz websites, applications, product and related events, surveys, social media platforms, and through our customer contact centers.

The categories of information that Spatz collects about you may include, but are not limited to:

  • Identifiers/Contact information (such as name, address, city, state and ZIP code, email address, telephone number, unique personal identifier, online identifier, IP address, or other similar identifiers)

  • Demographic information (such as gender, date of birth, marital status, and household composition)

  • Approximate geolocation data (i.e., IP addresses)

  • Information about your connected devices (such as mobile phone, computer, or tablet) and how you interact with our products, services, apps, and websites (such as IP address, browser type, unique device identifier, cookie data, and associated identifying and usage information)

  • Marketing profile information

  • Inferences drawn from other personal information (such as personal preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes)

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

  • Directly from you as described herein;

  • Indirectly from you. For example, through information we collect in the course of providing services and products.

  • Directly and indirectly from activity on this Site.

  • From third parties that interact with us in connection with the services and products we provide.

The information Spatz collects about you and your devices may be used:

  • To provide products and services and maintain customer relationships

  • To improve the quality, safety, and security of our products and services

  • To operate our websites and applications, including online registration processes

  • To autofill data fields on our websites or applications to improve your online experience

  • To develop new products and services

  • To provide customer support and service

  • To provide information and product updates

  • For research, evaluation of use, and troubleshooting purposes

  • For marking and analytics purposes

  • To customize and improve communication content 

  • To comply with legal, regulatory, or contractual requirements

Communications with you in connection with these uses may be via mail, telephone, e-mail, text message, social medial, or other electronic messages, or via our websites and applications.

Personal Information You Provide

The privacy and security of the personal information that Spatz collects from you is a priority.  When you visit this Site you may be asked or choose to provide personal information that could reasonably be used to contact you or to identify you personally including, but not limited to: your name, address, telephone number, birth date, and email address.

You may choose to receive certain communications from Spatz via your email address upon interaction with the Site.  From time to time Spatz may include surveys, information requests, or other features on the Site that ask you to provide personal information such as your name, telephone number, email address or mailing address. Any information you may provide will be used by Spatz to allow you to participate in the particular feature being offered. Spatz may also retain any information you provide in order to send you information about Spatz’ products and services that may be of interest to you. Spatz will provide you with the opportunity to opt-out of receiving such communications. We may use one or more service providers to administer these messages, but we do not share your email address with spammers or any other third parties without your permission.  Please note that, even if you opt out of receiving promotional communications from Spatz, you may still receive administrative communications from us with respect to your account and use of the Site.

You will be informed what personal information is required and what information is optional when asked to submit personal information to us.  By submitting personal information to Spatz at this Site, you hereby consent to Spatz’s collection, use and disclosure of such personal information.  

We may combine the personal information you submit directly through this Site with other personal information we have collected from you, whether on- or offline.  We may also combine it with information we receive about you from other sources, such as other companies, publicly available information sources (including information from your publicly available social media profiles), and other third parties.

Health Data

When you use Site and our services, you may voluntarily provide us with information about your health. For example, you may share with us your medical history, including history of past surgeries and procedures, as well as what medications you have taken and currently take. We use your health data as set forth in the “Sensitive Personal Information” section below. 

Sensitive Personal Information

Certain jurisdictions provide special categories of personal information that are considered sensitive under applicable law. As discussed in this Policy above, we collect and use the following special categories of personal information when you voluntarily provide them:

  • Health data, for example, your medical history and what mediations you have taken and currently take.

We collect and use your sensitive personal information for the following legitimate business purposes:

  • to carry out our obligations under applicable law;

  • for the performance of an agreement with you and to provide services requested by you and as reasonably expected in the context of such performance;

  • to protect our legal interests and to ensure the physical safety of ourselves and other individuals; 

  • as otherwise required by law; and

  • For other purposes, with your prior consent.

Passive Information Collection and Use

As you navigate around this Site, certain information can be passively collected (that is, gathered without you actively providing the information), using various technologies.  We passively collect and use information in a variety of ways, including:

  • Through your browser and Device:  Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version.  We collect Device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your Spatz account.

  • Cookies:  Cookies are pieces of information stored directly on the computer you are using.  Cookies allow us to collect information such as browser type, time spent on this Site, pages visited, and language preferences.  We, and our service providers, use the information for security purposes, to facilitate navigation, and display information more effectively.  In addition, we use cookies to gather statistical information about Site usage in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it. The Site may use both cookies that we implement and cookies implemented by our suppliers and other third parties. “First-party” cookies allow your browser to talk to the actual website that you are visiting, whereas “third-party” cookies allow your browser to talk to third-party websites, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. Our suppliers may use cookies and tracking technologies to track Site users across the Internet to understand how you get to the Site and for the analytics purposes disclosed in this Policy. We do not have access or control over these cookies and this Policy does not cover the use of third-party cookies. Click here for information on the cookies used by Meta. Click here and here for information on the cookies used by Google. The types of information collected by a cookie and the purposes for which that information is used depends on the type of cookie. By way of illustration, the types of cookies used, the types of information collected by those cookies, and the purposes for which that information is used are described below. We may combine information collected by cookies with other collected information.

    • Operationally necessary cookies (also called essential cookies). These are cookies that are required for the operation of the Services. For example, these cookies are required to identify irregular website behavior, prevent fraudulent activity, and improve security. They also allow users of the Site to make use of its functions. Without these cookies, features and services you have requested will not be able to be provided.

    • Functional cookies. These cookies allow us to offer you enhanced functionality when accessing or using the Site. This may include to remembering choices you make, for example, remembering your preferences or settings, remembering if you reacted to something on or through the Site so that you are not asked to react to it again, remembering if you have used any feature of the Site before, and enabling social media components. If functional cookies are disabled, various functions of the Site may be unavailable to you or may not work the way you want them to.

    • Performance cookies (also called analytical cookies). These cookies assess the performance of the Site, including as part of our analytic practices to help us understand how visitors use and interact with the Services, for example, which pages on our websites users visit most often. These cookies also enable us to personalize content and remember your preferences. These cookies help us improve the way our websites work and provide a better, personalized user experience.

    • Advertising or targeted cookies. These cookies record your visits to the Site, the pages you visit on our websites, and the links you have clicked. They gather information about your browsing habits and remember that you have visited a particular website. Spatz and its third-party advertising platforms or networks may use this information to make the Site and its content more relevant to your interests (this is sometimes called “behavioral” or “targeted” advertising and is further discussed above). These cookies are also used to limit the number of times you see an advertisement and to help measure the effectiveness of advertising campaigns. To find out more about interest-based ads and your choices, please visit the Digital Advertising Alliance, the Network Advertising Initiative, the Interactive Advertising Bureau (IAB) Europe, http://www.allaboutcookies.org, and http://www.youronlinechoices.com.

For more information about cookies, including about advertising cookies and your choices regarding cookies, we suggest you visit the following websites: https://www.consumer.ftc.gov/articles/0042-online-tracking; http://www.allaboutcookies.org; and http://www.youronlinechoices.eu. You can choose to accept or decline cookies.  Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer.  If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies.  If you set your browser to reject cookies, part of the Site may not work for you. Changing your cookie preferences in one browser will not necessarily carry over to other browsers, so you may need to adjust your preferences each time you get a new device, install a new browser, upgrade an existing browser, or alter or delete a browser’s cookie file.

  • Pixel tags, web beacons, clear GIFs, or other similar technologies:  These may be used in connection with some Site pages to, among other things, track the actions of Site users and compile statistics about Site usage and response rates.

  • IP Address:  Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider.  An IP Address is identified and logged automatically in our server log files whenever a user visits this Site, along with the time of the visit and the page(s) that were visited.  Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites.  We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering this Site.

  • Do Not Track Requests:  Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes.  The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively management the settings on your browser or Device to delete and disable cookies and other tracking/recording tools.  Please note, depending on your type of Device or browser, it may not be possible to delete or disable all tracking mechanisms on your Device. However, residents of certain U.S. states may opt out of certain activities (to the extent applicable) that are considering “selling” or “sharing” personal information for targeted advertising purposes by broadcasting an Opt-Out Preference Signal as defined under applicable law, including the Global Privacy Control (GPC), depending on which browsers and/or browser extensions you use that may support such a signal. To look at extensions and browsers supporting the GPC browser signal, visit here: https://globalprivacycontrol.org/. Note that if you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Advertising and Remarketing

We permit third-party advertising partners to use the foregoing tracking technologies to collect information about your browsing activities over time and across different websites when you use the Site.  For example, we use advertising services providing by third-party ad partners, such as Google, to market our service to you on other websites and online services.  Through a process called “retargeting,” each service places a cookie on your browser when you visit the Site so that they can identify you and serve you ads on other sites around the web based on your browsing activity.  To avoid use of this information for advertising by these third-party ad partners, you can change your browser settings to reject cookies or to notify you when cookies are set and you could select the Do Not Track option on your browser, though we have no control over and cannot confirm whether these third-party ad partners honor the Do Not Track browser signal.  

Through Google Ads, Google uses your Internet searches, cookies, and similar identifiers (e.g., pixel tags) to collect information about your visits to the Service and your interaction with our products and services to generate targeted advertisements to you on other websites that you visit across the Internet.

To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Service.

For certain Meta advertising services, Meta Ireland is a Joint Controller (as defined in the GDPR) and that information required under the GDPR related to such processing can be found at https://www.facebook.com/about/privacy. We work with Meta and use their advertising services to measure and improve our ads and marketing efforts, as well as to display more relevant advertising to you. For further information on how Meta Ireland processes your personal information, including the legal basis, and the ways to exercise your rights, please visit https://www.facebook.com/about/privacy. If you have a Meta account but do not wish Meta to collect data relating to you via the Services, we suggest that you take the steps outlined below under “Social Media.”

To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, please visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Please remember that changing your settings with individual web browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads from time to time. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.

Analytics

We utilize Google Analytics on the Site. Google Analytics is a website analysis service provided by Google, Inc. (“Google”). Google utilizes the data collected to track and examine the use of this Site, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. For more information on Google’s Privacy Policy go to https://policies.google.com/privacy and Google’s page on How Google uses data when you use our partners’ sites or apps. Users can opt-out of Google Analytics tracking at https://tools.google.com/dlpage/gaoptout.  Some additional Google Analytics features that Spatz uses are:

  • Google Analytics Demographics and Interest Reporting – allows Spatz to see the age, gender and interests of website visitors to better understand them and personalize advertising.

  • Google Display Network Impression Reporting – for banner ads.

  • Remarketing through Google Analytics for Display Advertising – allows personalization of ads on our ad networks.

  • User ID Extension for Google Analytics – allows Spatz to connect multiple devices, sessions and engagement data.

For more information about how Google Analytics uses cookies to measure user interactions on websites, visit Google Analytics Cookie Usage on Websites. We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website. Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

How We Use and Disclose Information

We may disclose personal information that we collect or you provides as described in this Policy. The information may be disclosed to a third party for a business purpose to the following categories of third parties:

  • To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

  • To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.

  • To our affiliates for related business purposes.

We use and disclose personal information you provide to us as described to you at the point of collection, such as when you (1) register for a user account, (2) submit your name and e-mail address to receive updates and marketing information, and (3) send e-mail messages or feedback, or transmit other information by e-mail.  When you elect to engage in such activities, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), e-mail address, and mobile telephone numbers.

We also use and transfer personal information from or about you:

  • to respond to your inquiries and fulfill your requests, such as to send you documents you request or e-mail;

  • to send you important information regarding our relationship with you or regarding this Site, changes to our terms, conditions, and policies and/or other administrative information; and

  • for our business purposes, such as marketing new products and services, data analysis, audits, developing new products or services, enhancing our Site, improving our products and services, identifying Site usage trends, and determining the effectiveness of our Site.

  • to our third party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, infrastructure provision, IT services, e-mail services, marketing services, auditing services, and other services, in order to enable them to provide services;

  • to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); and

  • when we otherwise have your consent.  For example, if you sign up for programs offered by our partners, we may share certain information with the partner.  This could include, but is not limited to, enrollment information and the activation status of your device.  Your consent is required to allow these exchanges on your behalf and you can change your mind at any time.

In addition, we use and disclose personal information collected through this Site as we believe to be necessary or appropriate: (a) as permitted by applicable law, including laws outside your country of residence; (b) to comply with any legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our Terms of Use; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use and disclose personal information collected through this Site in other ways, with your prior consent.

We also use and disclose information we collect passively as described above, under “Passive Information Collection and Use,” and for any other purpose, except where we are required to do otherwise under applicable law (for example, if we are required to treat such information as personal information). In addition, we may use and disclose information that is not in personally identifiable form (such as anonymized, masked or de-identified information) for any purpose. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.

In the last 12 months, we have disclosed these categories of personal information about consumers for a business purpose:

  • Personal identification information such as real name, postal address, online identifier, IP address, email address, and account number.

  • Internet or other electronic network activity, including but not limited to, browsing history, search history, and information regarding your interaction with the Site.

Use of Information for Marketing Purposes

Spatz and our affiliates may send you regular promotional communications about our products, services, events and promotions. Such promotional materials may use the “Spatz” brand and may be sent to you via different channels, such as: email, phone, SMS text messages, postal mailings, and third party social networks.

In order to provide you with the best personalized experience, sometimes these communications may be tailored to your preferences (for example, as you indicate these to us, as we may have inferred from your Site visits, or based on the links you click in our emails).  When required by applicable law, we will obtain your consent before starting these activities.  In addition, you may withdraw your consent (opt-out) at any time. If you opt-in to receiving text messages (SMS and MMS) on the Site when prompted, Spatz may send you autodialed and other text messages at the telephone number you provide relating to your use of the Site. Consenting to receiving text messages is not required to buy goods or services or to otherwise do business with us. Message and data rates may apply.

In particular, you can opt-out from receiving marketing-related emails by following the unsubscribe instructions provided in each email.  You can also contact us using the contact details provided below to opt-out from receiving marketing-related communications.

Please note that even if you opt-out from receiving marketing communications, you might still receive administrative communications from us, such as technical updates of our products, order confirmations, notifications about your account activities, and other important notices.

Social Media

The Site may implement widgets, tools, or applications provided by social media platforms and the Site may otherwise allow for interaction, integration, or content sharing with third-party social media platforms and companies. We may be required to implement cookies, plug-ins, and APIs provided by those social media platforms in order to facilitate those communications and features. By choosing to use any third-party social media platform or choosing to share content or communications with any social media platform, you allow us to share information with the designated social media platform. Interactions, integrations, and content sharing with a social media platform and their features may require or allow the social media company to collect information from or about you, whether through cookies, registration information, or otherwise. Social media companies may track your online activity even when you do not choose to interact with the social media platform or its widgets or other features. We encourage you to review the privacy policy of any social media platform that you use or visit in connection with the Site, as those platforms’ respective privacy policies will govern their collection, use, and disclosure of information they collect from you. We cannot control any policies or terms of such third party platform. As a result, we are not responsible for any use or disclosure of your information or content by third-party platforms, which you use at your own risk.

The Site may also use the advertising services and networks offered by social media platforms to deliver advertising content. Use of these services requires social media platforms to implement cookies or pixel tags to deliver ads to you while you are logged into the applicable social media platform.

If you do not want social media platforms to collect information relating to you via the Site or to link information collected via the Site to your social media accounts, we suggest that you: (a) do not connect to or share information with social media platforms using the Site; (b) hide social media platform plug-ins using an ad blocker; (c) always log off completely from social media platforms before visiting the Site or other websites and delete all related cookies; and, (d) where the option is made available by a social media platform, disable the advertising Site and networks operated by that platform. You hereby acknowledge that Spatz makes no guarantee that exercising the foregoing options is guaranteed to prevent applicable social media platforms from tracking you and, further, you acknowledge that Spatz is not responsible for a social media platform’s tracking of you.

Embedded Content

The Site may incorporate content, including feeds, scripts embedded in the Site’s code, and visible content (e.g., videos), provided by third parties. In some cases, those third parties collect data about how you interact with their content. For example, Vimeo may collect or otherwise have access to usage data on videos embedded on the Site as described in the Vimeo.com Privacy Policy. The Site may also include Google Maps features and content. Google Maps features and content is subject to the then-current versions of Google Maps/Google Earth Additional Terms of Service at https://maps.google.com/help/terms_maps.html and Google Privacy Policy at https://www.google.com/policies/privacy/

Our Site may use YouTube to make content in video format available to you. By accessing a part of the Site where videos are available, watching an embedded video, or otherwise interacting with any content made available through YouTube, you signify your agreement with YouTube’s terms and conditions. YouTube collects and otherwise has access to usage data (e.g., what videos you accessed and watched) through videos embedded in the Site as further described in YouTube’s Privacy Notice. YouTube adheres to Google’s privacy policies and principles, part of which allow you to control certain privacy settings and which data are collected. For more information, please visit https://www.youtube.com/howyoutubeworks/user-settings/privacy/.

3.GENERAL PRINCIPLES FOR THE PROCESSING OF PERSONAL INFORMATION

Personal information will be collected, stored, processed and transmitted in accordance with Spatz’s established policies and applicable federal, state, local and foreign laws, rules and regulations.  

The principles of Spatz with respect to the processing of personal information are as follows:  (1) personal information will be processed fairly and lawfully, (2) personal information will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes, (3) personal information collected by Spatz will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and processed, (4) personal information collected by Spatz will be accurate and, where necessary, kept up to date to the best of our ability, (5) personal information collected by Spatz will be retained as identifiable data for no longer than necessary to serve the purposes for which the personal information was collected, and (6) personal data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

If Spatz engages in the processing of personal information for purposes other than those specified in this Policy, Spatz will provide notice of these changes, the purposes for which the personal information will be used, and the recipients of personal information.

4.THIRD PARTY SITES AND SERVICES

This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any application) that is available through this Site or to which this Site contains a link.  The availability of, or inclusion of a link to, any such site or property on this Site does not imply endorsement of it by us or by our affiliates.

Third parties may offer products and services on the Sites and collect information about you by requesting certain information necessary to provide a particular product or service (including, for example, insurance coverage for your Spatz products or reports of insurance claims). Spatz may also obtain certain information about its users from third party customer research groups (e.g., demographic information) which Spatz uses to learn more about its customers. Spatz does not control the policies and practices of third parties in relation to the use and disclosure of any information about users collected by third parties on the Site or in market research programs conducted by such third parties and any use or disclosure of such information by third parties is not governed by this Policy.

5.CHOICES AND ACCESS

We give you choices regarding our use and disclosure of your personal information. Spatz provides you with the opportunity to receive information by email, regular mail or telephone calls from Spatz, or third parties which may be of interest to you, including information relating to new products and services offered on the Site by Spatz, or other third parties.  If you do not want to receive any information by email, regular mail or telephone calls, you may opt-out of further communications provided by Spatz at any time by: (i) sending Spatz an email at [email protected]; or (ii) writing to Spatz at 1801 S Perimeter Road STE 130 Fort Lauderdale, FL 33309, Attention: Information Technology Department. Please note that Spatz can only comply with requests relating to email, regular mail or telephone communications provided by Spatz. If you no longer wish to receive further information by email, regular mail or telephone from any third party, you will need to contact such third party directly to opt-out of further communications being provided to you.  We will seek to comply with your request(s) as soon as reasonably practicable.  

Additionally, some U.S. states and other jurisdictions outside of the U.S. provide you with privacy or personal information related options and rights to their residents. 

Depending on the laws applicable to Spatz’s processing of your personal information and the location in which you reside, you may have the ability to exercise the rights listed below and in this section of the Policy. Subject to foregoing, in addition to all application limitations, exemptions, or exceptions—regarding our collection and use of your personal information—these rights may include, to the extent applicable:

  • Right to Access: You have the right to request access to any of your personal information that we hold. Specifically, you have the right to request the disclosure of (1) what personal information has been collected; (2) the categories of sources from which the personal information was collected; (3) the business or commercial purpose for collection or selling personal information; (4) the categories of third parties with whom we share personal information; and (5) the specific pieces of personal information we have collected about you.

  • Right to Data Portability: You have the right to receive all such personal information about you from Spatz in a structured, commonly used and machine-readable format, and also to require us to transmit it to another entity where this is technically feasible.

  • Right to Deletion: You have the right to request the deletion of your personal information that we have collected.

  • Right to Collection: You have the right to request the correction of your personal information that we collected.

  • Right to Withdraw Consent: In the event your personal information is processed on the basis of your consent, you have the right to withdraw consent at any time with effect for the future.

To exercise these rights, please see the “Exercise Your Rights” section of the Policy below. Additionally, if you have any concerns, complaints, or other issues with regard to our collection, use or other processing of your personal information, please contact us via the means set forth under the “Contacting Us” section of the Policy below.

6.ACCURACY

It is your responsibility to provide Spatz with accurate personal information.  Except as otherwise set forth in this Policy, Spatz shall only use personal information in ways that are compatible with the purposes for which it was collected or subsequently authorized by you.  To the extent necessary for these purposes, Spatz shall take reasonable steps to ensure that personal information is accurate, complete, current and relevant to its intended use.

7.ADDITIONAL INFORMATION FOR INDIVIDUALS LOCATED IN THE EEA

The following section of this Policy only applies to those residents of the European Economic Area and Switzerland (“Europe”). In Europe, “Personal Data” is defined very broadly and includes any information about a natural person, who can be identified, directly or indirectly, from data that we hold about them or from data that is combined with other information. European data protection law requires us to have a legal basis before processing any Personal Data about you.  The legal basis for us processing your Personal Data for the above purposes may be because: (i) you have provided your consent; (ii) it is necessary to for the performance of a contract with you; (iii) the processing is necessary for our compliance with a legal obligation; or (iv) the processing is in our legitimate interests. To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your Personal Data. In some circumstances, withdrawing your consent to Spatz use or disclosure of your Personal Data will mean that you cannot take advantage of certain Spatz products or services.

We may transfer your Personal Data outside Europe to the United States or any country that Spatz or its service providers may have operations. Such countries do not have the same data protection laws as Europe. Any transfer of your personal information will be subject to a European Commission approved contract (as permitted under the General Data Protection Regulation and such other laws governing such transfers in the European Economic Area, including, without limitation, the United Kingdom’s Data Protection Act and Switzerland’s Federal Data Protection Act) that is designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. To obtain a copy of such safeguards please contact us.

Under such European data protection laws (such as the General Data Protection Regulation), you may have a number of important rights free of charge, including, those set forth in the “Choices and Access” section of this Policy. In addition to those rights set forth in the “Choices and Access” section of this Policy, your rights may include rights to:

  • fair processing of your personal data and transparency over how we use your personal data;

  • object at any time to processing of personal data concerning you for direct marketing;

  • object to decisions being taken by automated means that produce legal effects concerning you or similarly significantly affect you;

  • object in certain other situations to our continued processing of your personal data; and

  • otherwise restrict our processing of your personal information in certain circumstances

Please note that your rights are subject to all applicable exceptions and exemptions granted under such applicable laws, and that those rights are only exercisable by you to the extent applicable.

8.ADDITIONAL INFORMATION FOR CERTAIN US STATE RESIDENTS

Certain U.S. states require additional disclosures and provide users residing in such U.S. states with additional choices and rights. This section of the Policy only applies to individuals located in such U.S. states and where such U.S. state data protection laws apply to Spatz’s processing of your personal information.

Rights

Applicable laws in your jurisdiction may grant you certain rights—subject to all applicable limitations, exemptions, or exceptions—regarding our collection and use of your personal information. In addition to those rights set forth in the “Choices and Access” section of the Policy above, these rights may include, to the extent applicable and to the extent granted under applicable law:

  • The right to opt-out of the automated profiling of your personal information in furtherance of decisions that produce legal or similarly significant effects concerning you;

  • The right to opt-out of targeted advertising and the sharing of personal information that is shared for cross-contextual behavioral advertising purposes;

  • The right to opt-out of the sale of your personal information;

  • The right to limit our processing (or completely opt-out, if allowed under applicable law) of sensitive personal information to what is necessary; and

  • The right to not be discriminated against due to your exercise of your rights under applicable law. We do not discriminate against users for exercising the rights granted to them under applicable law.

The above rights are only exercisable by you where the applicable law grants you the right being exerted and where no exception or exemption under applicable law applies. You may also have a registered agent (if and only as permitted under applicable law) that you authorize to act on your behalf. If you have a registered agent act on your behalf, we have the right to authenticate such agent’s authority to act. To exercise the rights described herein (only to the extent applicable), you may submit a verifiable request to us by through the methods set forth under the “Exercise Your Rights” section below. 

We do not use your personal information to profile you in furtherance of decisions that produce legal or significantly similar effects (as may be defined under applicable law).

Selling and Sharing

We do not sell your personal data as the concept of “selling” is traditionally understood as being the exchange of something for money. However, we sell your personal data to, and share your personal data with, third parties for the purpose of cross-contextual behavioral advertising purposes (e.g., targeted advertising and remarketing). Applicable U.S. state data protection laws hold such disclosures and sharing to be considered “selling” or “sharing”. Therefore, you have the right to opt out of such selling and sharing. In the preceding 12 months, we have sold or shared the following categories of personal data with the following categories of third parties and for the following purposes:

Category of Personal Data Sold or Shared

Category of Third-Party Recipient 

Purpose

Identifiers

Analytics, marketing, advertising, and remarketing partners and service providers

Analytical and targeted advertising purposes (including, without limitation, cross-contextual behavioral advertising).


Specifically, to target advertisements for goods and services and to display those advertisements on other websites.

Internet or other electronic network activity information

Analytics, marketing, advertising, and remarketing partners and service providers

Analytical and targeted advertising purposes (including, without limitation, cross-contextual behavioral advertising).


Specifically, to target advertisements for goods and services and to display those advertisements on other websites.

You have the right to opt out of the selling or sharing of your personal data as described herein. You may exercise this right to opt out by contacting use through the methods set forth below under the “Exercise Your Rights” section of the Policy, or by clicking the “DO NOT SELL OR SHARE MY PERSONAL INFORMATION link.

We do not knowingly sell or share for cross-contextual behavioral advertising purposes, the personal data of anyone under the age of 16 years old. See the “use of Site by Minors” section of this Policy below for more information.

9.EXERCISING YOUR RIGHTS

To exercise your rights as described in this Policy, you may submit a verifiable consumer request to us (which shall include, at a minimum, (1) enough information to identify you; (2) proof of your identity and address; and (3) the information to which your request relates) by either contacting us via the contact methods provided in the CONTACTING US section below or through the following methods:

Only you or a registered agent (if and only as permitted under applicable law) that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. If you have a registered agent act on your behalf, we have the right to authenticate such agent’s authority to act. 

Spatz will not discriminate in any way against any users of the Site that exercise their rights provided by law. 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.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

We will respond to your request within the applicable timeframe required under applicable law. If we deny your request, you can appeal such denial by emailing us at [email protected].

10.RETENTION PERIOD

We retain your personal information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.

11.SECURITY

Spatz has implemented security measures designed to protect personal information provided by you against unauthorized access and use. Please be aware, however, that no data transmission over the Internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the CONTACTING US section below.

12.USE OF SITE BY MINORS

We do not intentionally collect information from individuals under the age of 16. We request individuals under the age of 16 not provide personal information through this Site.

13.COMPLIANCE WITH LOCAL LAWS

This Policy is meant to guide Spatz with respect to personal information collected from or about you at this Site.  While this Policy applies to personal information generally, the local laws, rules and regulations of jurisdictions that are applicable to Spatz (“Local Laws”) may require standards which are stricter than this Policy and, in such event, Spatz will comply with applicable Local Laws.  Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions. All the information you provide may be transferred or accessed by entities around the world as described in this Policy. Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Site or by providing consent to us (where required by law), you specifically acknowledge and consent to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules, and a lower standard of required protection, than in your country. Irrespective of which country your personal data is transferred, we would only share your personal data under a ‘need to know’ basis.  In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by organizational, technical, contractual and/or other lawful means.

14.UPDATES TO THIS PRIVACY POLICY

We may change this Policy.  Please review the LAST UPDATE legend at the top of this page to see when this Policy was last revised.  Any changes to this Policy will become effective when we post the revised Policy on this Site.  Your use of this Site following these changes means that you accept the revised Policy.

15.COMPLIANCE

Spatz will use a self-assessment approach to verify compliance with this Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible. 

If you believe that your personal information has been processed or disclosed in violation of this Policy, Spatz encourages you to raise any concerns using the contact information provided in this Policy.  Spatz will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information. 

16.YOUR RIGHT TO COMPLAIN

If you have a complaint as to our use of your information, you may file a complaint with us, the GDPR supervisory authority, the California Attorney General, the California Privacy Protection Agency, any other applicable governmental agency, and/or a judicial body. 

A complaint may be submitted directly to Spatz:

  • In writing by sending an email to [email protected];

  • In writing by sending a letter to 1801 S Perimeter Road STE 130 Fort Lauderdale, FL 33309; or

  • Orally by directly contacting +1 516 303 0613

17.CONTACTING US

If you have any questions about this Policy, please contact as provided below.

Our contact information is as follows:

Spatz FGIA Inc.

1801 S Perimeter Road STE 130 Fort Lauderdale, FL 33309. 

+1 516 303 0613 (Monday to Friday, 8am – 5pm EST)

[email protected]


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