Privacy Policy

Effective June 20, 2012

Welcome to www.reducetrial.com (the “Website”). The Website is owned by ReShape Medical, Inc. Your personal privacy is important to us, and this Privacy Policy is designed to tell you about our practices regarding collection, use, and disclosure of information that you may provide when visiting and using the Website. Please be sure to read this entire Privacy Policy before using or submitting information to this Website. Use of this Website constitutes your consent to our Privacy Policy.

Your Consent

By using this Website, you agree to the terms of this Privacy Policy. Whenever you submit information via this Website, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not access or use the Website.

When do we collect information?

We may collect information about you anytime you interact with the Website, such as when you (i) access or browse the Website, (ii) communicate with us through the website, by e-mail, over the telephone or in any other manner, (iii) fill out surveys, questionnaires or provide feedback on the website, (iv) elect to purchase any of our products or participate in any of our product promotions and (v) request information about our products and services.

What information do we collect?

Information we collect is generally of two types – personally identifiable information and non-personally identifiable information.

Personally identifiable information comprises any information that can help us identify or locate an individual, including, without limitation, an individual’s name, address, e-mail address, telephone number or credit card number.

Non-personally identifiable information comprises information that does not by itself identify an individual. This information generally includes anonymous information about an individual’s use of the Website that includes, among other things, information concerning date and time of visit, the pages of the Website visited, path through the Website, IP address, the type of browser and operating system used.

How do we collect your personal information? And why?

General
We do not collect personally identifiable information, except when you specifically and knowingly disclose such information. This information is generally collected when you, order or request information regarding our products, fill out surveys and/or questionnaires, provide feedback on the Website, enter promotional events or correspond with us in any other manner. If you disclose your personal information, we will only store and use such information that we need to meet your requests and our legitimate business objectives.

Personal Contact Information
We use your contact information to provide quotes at your request, support your purchases, to facilitate and improve your use of the Website, to communicate with you and to comply with any requirements of law. We also use this information to respond to any questions you might have and to provide you with information about specials offered through the Website. This information may be disclosed to our staff and to third parties involved in providing you with a quote, completing your transaction, delivering your order or supporting your use of the Website.

Online Surveys
In order to improve our products, we may use your personal information to send information about online surveys. These surveys help us to know more about your experience with our products and services. Your responses to these surveys are treated as confidential information. If you do not wish to participate in a survey, you may simply decline when asked. You may also choose to opt-out of participating in any future surveys. If you do so, we will not send you any survey requests in the future.

Online Questionnaires
In order to determine whether you may qualify for our United States clinical trial, you will be required to complete an online questionnaire, which will require you to provide personally identifiable information. In connection with your potential involvement in our clinical trial, the personally identifiable information provided in such questionnaire will be shared with our recruitment agency partner and our clinical sites, who shall provide a level of protection with respect to personally identifiable information no less than the level of protection provided in this Privacy Policy. If you do not wish to provide such information, please do not complete and submit the questionnaire.

Product Updates and Promotional E-mails
We may send product updates and promotional e-mails as a service to our existing customers. Only if you elect to receive these e-mails, will we use your personal information to send you newsletters and e-mails periodically listing current specials, promotions and information. If you have elected to receive these e-mails and wish to discontinue receiving in the future, please follow the opt-out instructions provided on the e-mails or log into your account on the Website and follow the instructions to make the appropriate changes.

Correspondence
If you contact us via the Website, by telephone, e-mail or letter to provide feedback, comments or inputs or for any other reason, we may keep a record of that correspondence and collect your personal information to process your inquiries, respond to your requests and improve our services.

How do we collect your non-personal information? And why?

General
We will automatically collect certain non-personally identifiable information each time you visit the Website. For this purpose, we may use cookies, clear gifs, frames, server log analysis and other technology. We collect anonymous information about our users so that we can understand how people are using the Website and improve the overall quality of our users’ online experience.

Cookies
The Website may contain “cookies.” Cookies are bits of electronic information generated by web servers and stored on your hard drive when you visit practically any website on the Internet. Cookies are often used to differentiate users, store user preferences and track user trends in general. We may use cookies to improve the quality of the Website and to better understand how users interact with the Website. We do not use cookies to retrieve individual personally identifying information about you from your computer unless you knowingly and willingly provide such information. You can adjust your web browser security settings to refuse all cookies or to indicate when a cookie is being sent. However, if you disable the use of cookies in your web browser, some features of the Website may not function properly.

Log Files
Log files record internet protocol (IP) addresses, browser types, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the Website, track a user’s movement in the aggregate, and gather broad demographic information for aggregate use. You do not have to register with us before we can collect this anonymous information.

Navigational Data
As you browse the Website, we may gather navigational data that shows what pages are visited and how long various features are used. This information will not reveal your identity or be linked to you personally. We use this information to complete, support and analyze users’ purchases from the Website; to facilitate and improve use of the Website; to comply with any requirements of law; to serve, or have a third party serve, specialized or relevant advertising content and/or recommendations to you on the Website; and for our internal purposes. We may from time to time supply the owners or operators of third party sites from which it is possible to link to the Website with information relating to the number of users linking to the Website from their sites. You cannot be identified from this information.

IP Addresses and System Specifications
When you access the Website, our servers may record your IP address. We may use IP addresses for system administration and troubleshooting, ensuring user compliance with our terms of service, investigating security breaches and compiling anonymous non-personal information, such as how many users visited the Website. Additionally, your system specifications such as operating system, system configuration, etc. may be collected by us for the purposes of analyzing and optimizing your experience and customer service.

How do we share the information that we collect?

General
Personal information which we collect for a particular purpose will only be saved and used for that purpose, unless you have agreed to allow us to use it for some other purpose, as described in this Privacy Policy. We sometimes share non-personal information with third parties about our user base, but that information does not include any personally identifiable information. Except as set forth in this Privacy Policy, we do not trade, share, rent, sell or give away information concerning you to unrelated third parties.

Our Affiliates
We may share your personally identifiable information with legal entities that, directly or indirectly, control, are controlled by, or are under common control with, us. These affiliates may use your personally identifiable information only in accordance with this Privacy Policy.

Our Service Providers and Strategic Partners
We may disclose your personally identifiable information to our service providers and strategic partners. These third party service providers and partners will have access to personal information needed to perform their functions but may not use it for other purposes. Such related third parties shall provide at least the same level of privacy protection as this Privacy Policy.

Enforcement
We may disclose your personally identifiable information or otherwise use such information to communicate with you if required or permitted to do so by law or in the good-faith belief that such action is necessary to: (i) conform to legal requirements or comply with legal process or any governmental request; (ii) protect and defend our rights or property and our affiliates, licensors or licensees; (iii) enforce our applicable service agreements; or (iv) protect the personal safety or interests of our employees and consultants, other users of the Website, or members of the public in urgent circumstances. We may also disclose any of your personal information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, or as otherwise may be required by applicable law, or, as we deem necessary in our sole discretion, in order to protect our legitimate legal and business interests.

Aggregated General Information
We may share aggregated general information about the Website with our corporate partners, investors, advertisers or others. Aggregate general information includes, without limitation, the number of users of the Website, revenue (including payments by Website users), usage statistics and user feedback. Aggregated general information does not include any personally identifying information that could be used to contact or identify you.

Change of Control
In the event that another company acquires all or substantially all of the assets related to the Website, or if we experience some other change of control event such as a merger, insolvency, bankruptcy or receivership, we reserve the right to include any or all user-related information among the assets transferred to the acquiring company. We cannot guarantee that any entity receiving such information in connection with any of these transactions will comply with all the terms of this policy.

Children’s Privacy

The Website complies with the Children’s Online Privacy Protection Act and all other applicable laws and regulations protecting children’s privacy on the Internet. The Website is not directed to children under the age of 18 and we do not allow persons under 18 years of age to use the Website. Therefore, except as may be required by law, the Website does not knowingly collect, maintain, or disclose any personal information from children under the age of 18. If you are under the age of 18, please do not: (i) access or use the Website, (ii) complete a survey or questionnaire, (iii) request a quote for our products, or (iv) buy anything through the Website.

Links to Other Web Sites

This Website may contain links or references to other websites. Please be aware that we do not control the content or accuracy of information provided on other websites nor do we control the privacy policy of other websites. This Privacy Policy does not apply to such websites. We encourage you to read the privacy policy of each and every website you visit.

Security

We take reasonable steps to protect your personally identifiable information as you transmit your information from your computer to our Website and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from this Website may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Moreover, where you use passwords, ID numbers, or other special access features on this Website, it is your responsibility to safeguard them.

Integrity

To keep your personally identifiable information accurate, current, and complete, please contact us as specified below. We will provide you with access to your information so that you may update, correct, amend, delete or remove information that is inaccurate or misleading, unless the rights of a person other than you would be violated by such access.

Changes to Privacy

We may change our policy at any time by posting a new version of it on the Website. We encourage you to check the Website regularly for information about revisions to this Privacy Policy. In the event that we change our Privacy Policy, such changes will affect all of the information we collect after any such change. If you object to the change to our Privacy Policy, then you must contact us in writing regarding your objection.

How to Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or the information practices of this site, please contact us as follows:

ReShape Medical, Incorporated
100 Calle Iglesia
San Clemente, CA 92672 USA
info@reshapemedical.com
Tel: 949-429-6680
Fax: 949-429-6684

We have established independent recourse mechanism so that any dispute or complaint can be investigated and resolved appropriately.