WEBSITE PRIVACY POLICY

This Privacy Policy (Policy) sets forth the Regen Lab SA (RGL, we, or us) policies regarding the collection and use of information relating to a RGL web site (Site) that links to this privacy policy. This policy also describes the choices available to you regarding our use of your personal data, the personal data of patients and how you can access and update this information. When we refer to RGL, we or us, we mean Regen Lab SA, including our affiliates and subsidiaries. This Policy was last updated on August 25th, 2015.

This notice describes RGL's privacy policy as it pertains to the services available on this Site or any other RGLs Site (the "Services"). By registering for the Services, using the Services, registering on any RGL website, using RGL services or tools, or visiting the Site, you acknowledge and accept this Privacy Policy. This Policy is applicable to all RGL users and visitors worldwide, including users in the United States and the European Union. This Privacy Policy together with the Terms of Use govern your use of the Site. To the extent this Privacy Policy differs between users in the European Union and the United States, we have indicated such differences below.

Certain areas of the Site contain information intended only for licensed medical professionals. Accordingly, RGL reserves the right to limit certain areas of the Site to those persons who register and meet the qualifications imposed by us. This Policy addresses our privacy practices relating to general and registered use of our Site by all visitors.

 

Web Site Privacy Policy Details

Information We Collect and How We Use It

Personal data is data that can be used to identify or contact you, such as your name, email address, telephone number or similar information. RGL only collects personal data that you choose to share with us, such as when (1) contacting us via the Site (or requesting information), (2) submitting your resume online in response to a job posting, (3) registering online for an event or course or, (4) upon registration for access to those areas of our Site intended only for licensed medical professionals.

We may also collect the following information from you:

       Information about your business such as company name, company size, business type

       Medical condition/Therapeutic indication

       History of treatments/applications

       Demographic information such as age, education, gender, interests and location

       Contact information such as email address and phone number

We use this information to:

     Provide the Services

       Send you requested product or service information

       Send you product updates

       Process and respond to your questions/inquiries

       Administer your account

       Conduct surveys or other research and analysis

       Send you a newsletter

       Send you marketing communications

       Improve our Site and marketing efforts, improve the Services, e.g., to determine which features are used most, to find and fix navigation problems, and to help guide future development, to enhance the user experience

     Display content based upon your interests, provide you with personalized content, e.g., storing your display and other preferences to help you customize your experience

       Enable you to post your resume, search job postings, and contact or be contacted by prospective RGL representative or agents

     For administration of the Site

     Alert you to new developments, features, special events and services with your consent or provide information to you about the Site

     For fraud prevention, and where necessary to safeguard legitimate interests of RGL or a third party or to prevent threats to state or public security or to prosecute crimes, provided this does not conflict the data subjects legitimate interest

     For other purposes so long as those purposes were clearly disclosed when the information was collected

     Enforce the Terms of Use, e.g., to contact you about an infraction of the Terms of Use or to initiate a legal complaint.

Any personal information transmitted to the Site is used solely for the stated purpose when the information was transferred and any of the above uses. The data will not be used for any other purpose without your express consent, provided, however, that RGL may disclose the information it collects about you to third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of RGLs business or operations (including without limitation in connection with bankruptcy or any similar proceedings).

Any information you submit is given voluntarily and with your consent.

Once you visit our Site, specific information will be stored anonymously in a protocol file. There will be an anonymous storage of e.g. the IP-address, operating system (e.g., Microsoft Windows, Mac OS), browser type (e.g., Firefox, Chrome, Internet Explorer, Safari) and browser settings, the date and time our Site has been accessed and from where our Site has been accessed and the domain name of your internet service provider. RGL collects the domain names and IP addresses of its visitors and users, along with usage statistics (see the Information about Google-Analytics within this policy). RGL will not combine this information with the personally identifiable and other information it collects. We use this anonymous information solely to improve the appearance, contents and functionality of the website.

 

Definition of "Personal Information" for Data Originating in the European Union

Personal information within the sense of the EU Data Protection Directive 95/46/EC, the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland and the German Federal Data Protection Act as applicable includes details related to personal or factual matters of a specified or specifiable natural person (data subject), such as your name, your address, your telephone number and your date of birth. References to "personally identifiable information" or "personal information" include "personal data".

 

Sharing and use of de-identified information originating in the United States

With the exception of encrypted Protected Health Information (PHI) as that term is defined in applicable U.S. federal, state and local statutes, regulations and rules relating to data privacy and security, including the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the privacy and security standards pursuant to the same, as amended, and the Health Information Technology for Economic and Clinical Health Act (HITECH Act) and regulations and guidance issued pursuant to the same, other types of information that are fully de-identified (stripped of any information that could be used to identify any person) may be used by RGL for any reason and shared freely with third parties in de-identified or aggregated form subject to HIPAA and other applicable regulations. We will not re-identify such data and we will ask our contracting parties to agree to keep the data in its de-identified form. PHI may be shared in compliance with HIPAA and HITECH.

 

Google Analytics

This Site may use Google Analytics, a web analytics service provided by Google, Inc. (Google). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyze how users use the Site. The information generated by the cookie about your use of the Site will be transmitted to and stored by Google on servers in the United States.

In case IP-anonymisation is activated on this Site, your IP address will be truncated within the area of Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the USA and truncated there. The IP-anonymisation is active on this Site. Google will use this information on behalf of the operator of this Site for the purpose of evaluating your use of the Site, compiling reports on Site activity for Site operators and providing them other services relating to Site activity and internet usage. The IP-address, that your Browser conveys within the scope of Google Analytics, will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this Site. You can also opt-out from being tracked by Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: http://tools.google.com/dlpage/gaoptout?hl=en   

 

Smartphone- and tablet-users have the possibility to refuse the use of Google Analytics by clicking on a link. An opt-out cookie will be set on the computer, which will prevent the future collection of your data when visiting this website.

 

Registered Users

If you are a licensed medical professional, to register, you must provide us with certain personal data which may include your name, profession, email address, postal mail address, telephone, title, Medical ID and clinical affiliation. We will use this personal data to review and verify your registration information. We may use your personal data to send periodic transactional, marketing, or promotional notices to you or notify you of any changes to this Policy. You can always opt-out of receiving marketing or promotional communications from us by following the "opt-out" procedures described below or on the specific marketing or promotional message.

Resume Submission

If your personal data is submitted through the Site when applying for a position with RGL, your personal data will be used solely for the purpose of evaluating and accepting you for the position. We may retain your personal data for a period of time, but only for the purpose of considering your application for current or future positions at RGL or as necessary to comply with the law. This information may be shared within RGL as well as with third parties contracted by us to assist RGL with talent acquisition related activities.

Surveys

We may provide you the opportunity to participate in surveys on our site. If you participate, we may request certain personal data from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and email address) and demographic information (such as city, state or country). We use this information to understand what type of information visitors look for on the site, whether or not they are able to find it, what additional content would be useful on the site, and other information that can be used to help optimize user experience.

We may use third parties to conduct these surveys or contests. The third party would be prohibited from using our users personal data for any purpose inconsistent with the management of such surveys or contests.

Testimonials

With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at support@regenlab.com.

Blogs

From time to time, the Site may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at support@regenlab.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Contacting RGL

If you contact RGL via the Site, we will only use your personal data contained in your email to respond to your specific inquiry, request, or comments in the email. We may retain your email for a period of time, but will not use any of your personal data for any purpose other than responding to your email, unless such additional use is required or permitted for us to comply with the law.

General Information and Accuracy

Any information you provide to RGL must be true, accurate, current, non-misleading, and consistent and relevant for the purpose for which you are providing the information. If you are a registered user, you must have the authority to provide the information submitted to and through the Site, and understand and agree that we may from time to time verify such authority.

Usage Data

The Site may automatically track certain information about your behavior while visiting the Site. The information gathered includes the URL from which you accessed this Site, and which URL you visit next. We collect and store this aggregate information in order to measure the Site's performance and improve the Site's design and functionality. We may also share this aggregate information with third parties to illustrate how the Site is used and for other marketing purposes.

If you are a registered user, we may use your Usage Data with or without your personal data, in order to measure the Site's performance and improve the Site's design and functionality. We may share aggregate Usage Data with third parties to illustrate how the Site is used and for other marketing purposes. See also "Cookies", below.

Cookies

RGL may use both "session" and "persistent" cookies on this Site. A cookie is a small piece of information that is sent to your browser and stored in your computer's hard drive. The purpose of a cookie is to remember certain user inputs on the Site. Personalization features also use cookies to identify groups of users and deliver appropriate Site content and services, as well as feedback related to marketing and email campaigns.

Session cookies are temporary bits of information that are erased once you exit your web browser or turn off your computer. Persistent cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. They store information on your computer for a number of reasons, such as retrieving certain information you have previously provided (i.e., username and password), helping to determine what areas of the Site you find most valuable, and customizing the Site based on your preferences on an ongoing basis. Persistent cookies placed on your computer by this Site may hold personal data, but only if you are a registered user or have otherwise consented to the provision of personal data in accordance with the terms of this Policy. Personal data would be used for things like simplifying the login process or serving personalized content on the site. Otherwise, the Site's server only knows that an unidentified visitor with your cookies has returned to the Site. In addition to customization, persistent cookies will be used to provide you with better service on the Site, to compile and analyze statistics and trends, and to otherwise administer and improve the Site for your use. Subject to applicable law and in accordance with the terms of this Policy, information gathered through the use of persistent cookies on the Site may also be shared with third parties who assist us with the management or optimization of our Sites and the delivery of enhanced user experience.

Cookies do not damage your computer. You can set your browser to notify you when a cookie is being sent to your computer. This will notify you whether or not you are required to accept the cookie in order to view certain Site content, and allows you to decide if you want to accept the cookie or not. You can also set your browser to accept all cookies or to refuse cookies altogether. If you do prevent your computer from accepting cookies, you will still be able to fully access the Site, although you may lose some additional functionality and convenience provided through the use of cookies. To learn more about cookies, please search for "cookie" in the Help portion of your web browser.

3rd Party Tracking

The use of cookies by our third parties is covered by our privacy policy. We may not always have access or control over these cookies, however the third parties act on our behalf. Our third parties use session ID cookies to track certain information about your behavior while visiting the Site, to facilitate surveys, and to identify groups of users and deliver appropriate Site content and services, as well as feedback related to marketing and email campaigns. Our third parties employ clear gifs (a.k.a. Web Beacons/Web Bugs), images, and scripts that help them better manage Usage Data. We do not tie the information gathered to your personal data.

Social Media Widgets

Our Site may include widgets, such as the Share this button or interactive mini-programs that run on our site. This feature may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with this feature are governed by the privacy policy of the company providing it.

Clear Gifs

The Site may also use clear gifs (also known as web beacons) in combination with cookies, in order to help Site operators understand how visitors interact with the Site. A clear gif is typically a transparent graphic image (usually 1 pixel by 1 pixel in size) that is placed on the Site, which allows the Site to measure the actions of a visitor who opens the page that contains the clear gif. RGL uses clear gifs to measure traffic and related behavior, and to improve your experience when visiting the Site. We also use clear gifs to manage the content available on the Site. Clear gifs are not tied to personal data.

Flash LSOs

We may use local shared objects, also known as Flash cookies, to store your preferences such as volume control, or display content based upon what you view on our site to personalize your visit. Third parties, with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity, use Flash cookies to collect and store information.

Flash cookies are different from browser cookies. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies, go to www.macromedia.com.

Behavioral Targeting / Re-Targeting

We may partner with a third party ad networks to either display advertising on our Site or to manage our advertising on other sites. Our ad network partner shall use cookies and Web beacons to collect non-personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt out by contacting RGL at support@regenlab.com. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

Disclosure

In addition to the disclosures described throughout this Policy, and subject to applicable law, we and our third parties may disclose your personal data:

       To unaffiliated third parties that are under contract to perform services for or on behalf of RGL. Examples of such services are third parties 1) maintain our computer databases; and 2) perform marketing activities;

       To other persons as permitted by applicable law or regulation; and

       To law enforcement personnel and agencies, or as part of a legal process, in order to protect our property or in furtherance of an investigation regarding a breach of the Site rules and policies, unauthorized access to or use of the Site or any other illegal activities.

Any access to such information will be limited to the purpose for which such information was provided to our affiliate, subsidiary or third party. Our affiliates, subsidiaries and third parties may be located throughout the world. Accordingly, information may be sent worldwide to countries which provide varying levels of privacy protection. Nevertheless, the affiliates, subsidiaries and third parties are required to uphold and maintain RGLs policies with respect to privacy and the treatment of your personal data regardless of their locations or the laws of the countries they are based in.

Consent to Processing Outside Home Country

By using our Site, or providing information to RGL, you understand and unambiguously consent to the collection, use, disclosure and retention of information in Switzerland and other countries and territories, for the purposes set forth in this Policy. You hereby consent to the collection, use, disclosure and retention by RGL of your personal data as described under this Policy, including but not limited to the transfer of your personal data between RGL's third parties, affiliates and subsidiaries in accordance with this Policy. For further certainty, any consent relating to a right to transfer information referred to in this paragraph shall be deemed to include your consent to the transfer of the applicable personal data to a jurisdiction which may provide a different level of privacy protection than that available in your own country.

Transfer and Sharing of Personal Information

Personal health information and patient data may be transferred to affiliated companies and service providers of Regen Lab that have obligations to Regen Lab, e.g. IT providers, to perform our contractual obligations. Some of these affiliate companies and service providers are located outside Switzerland, the EU/EEA (e.g. United States, Canada, Brazil, Israel, China, India, Japan, Malaysia, Dubai, Singapore, Australia, Peru). Should third parties come into contact with your personal health information, we shall have made use of legal, technical and organizational measures and regular monitoring regarding such parties compliance with the relevant data protection regulations and with this Policy.

If you are in the European Union: Encrypted patient information will be stored exclusively in data centers within Switzerland and/or the European Union / European Economic Area. Encrypted personal information and personally identifiable information of users (master data), excluding patient data, may also be stored in data centers in the United States certified under the U.S.-EU Safe Harbor Program and on the basis of contractual agreements ensuring an adequate level of data protection in accordance with the EU Data Protection Directive 1995/46/EC and the Federal Data Protection, the Information Commissioner (FDPIC) of Switzerland  or the German Federal Data Protection Act as applicable.

If you are in the United States: Encrypted patient information will be stored exclusively in data centers within the United States. Encrypted personal information may also be stored in data centers within Switzerland, the European Union / European Economic Area and the United States. Regen Lab does not share personal information with third parties for their direct marketing purposes.

 

Processing of Personal Information on Behalf of Others

If you are in the European Union: As far as we and our service providers, which are bound by instructions, carry out inspections or maintenance of automated procedures or data processing systems and the possibility of access to personal information during such inspection and maintenance cannot be ruled out, the regulations of processing personal information on behalf of others with respect of the provisions of the EU Data Protection Directive 95/46/EG, the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland  and the German Federal Data Protection Act as applicable. If you need a data protection agreement pursuant to the provisions regarding processing personal information on behalf of others please contact RGL at support@regenlab.com.

 

Accountability for Special Categories of Personal Information / Patient Information

If you are in the European Union: Special categories of personal information in the meaning of the EU Data Protection Directive 95/46/EG, the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland  and the German Federal Data Protection Act as applicable refer to information for example on health (e.g. patient information such as name, date of birth, gender, medical condition/therapeutic indication, diagnoses, diagnostic imaging, history of treatments/applications).

The user, including the medical professional, of the Services under a RGL site (for example www.regenlab.com, www.cellularmatrix.info) or under any other RGL Site is solely responsible for any patient information. The user is particularly solely accountable for providing legal admissibility for selecting, processing and using personal information with respect to the applicable data protection regulations. The user is further required to follow the rules and regulations of the applicable professional law. In particular, doctors and other health professionals as well as their assistants and trainees are bound to medical confidentiality. Therefore, the user being subject to the medical confidentiality is responsible for that personal information of patients, which is collected, processed and used under www.regenlab.com or www.cellularmatrix.info or under any other RGL Site, is either to be anonymized or the patient has released the medical professional from medical confidentiality before. This written release from medical confidentiality has to refer to the processing of Protected Health Information (PHI) at RGL. It also has to comprise that for once a catastrophic event requires a data recovery and for necessary maintenance of the Service, PHI may be transferred to a Regen Labs subsidiary

We do not monitor, examine, supervise or otherwise control any exchange of data between users, nor content of user data and patient information.

If you are in the United States: If you are in the United States, you are solely responsible for using the Services, related content, and the Site in a manner consistent with all applicable federal and state privacy laws relating to the use and disclosure of medical or health information, including but not limited to HIPAA and the HITECH Act and regulations and guidance issued pursuant to the same. By utilizing the Services, you represent and warrant that your use and/or disclosure of personal information, including protected health information (PHI), fully complies with all such applicable federal and state privacy laws and regulations and professional and medical practice laws and regulations governing health care providers and practitioners and their designees. You also are solely responsible for obtaining all appropriate consents or authorizations, as necessary, from patients whose personal information will be used or disclosed on the Site or in connection with the Services or taking appropriate steps to de-identify PHI consistent with HIPAA and HITECH. By uploading content, using the Site, and/or in any way using the Services or other features available to you on the Site or with the Services, you expressly certify compliance with all such requirements and your use is deemed your acceptance of this Policy and the Terms of Use. You also remain solely responsible for any medical or professional advice or opinions you provide on this Site and are solely responsible for any actions you take in reliance on advice or opinions you receive from other users on the Site.

You understand that nothing on this Site constitutes a recommendation for specific medical care by the Site or Regen Lab, nor do we make any warranty or representation of any kind as to the accuracy or appropriateness of recommendations or advice you receive from other users of the Services or the Site. We assume no liability for any diagnosis, treatment decision, or action taken based on information found on the Site or any other Site linked to it and assume no responsibility for any consequences related directly or indirectly to any action or inaction you take based upon the information, material, advise or recommendations obtained on this Site.

 

Data Security

We have taken required, where applicable, or reasonable technical and operational precautions in order to protect personal information stored with us from unauthorized access, misuse or loss. Our security procedures are monitored regularly and updated in line with technological progress. Patient information collected, processed and used by the user will be encrypted immediately upon upload. The uploaded patient information is stored encrypted. 

No transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Regen Lab to intercept or access transmissions or private communications unlawfully. While we strive to protect personal information, neither Regen Lab nor our service providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is at your own risk.

 

Communications with You in the United States

If You are in the United States: You authorize Regen Lab to transmit email to you or telephone You to respond to your communications, and provide information to you about new developments, features, services, special events, inquiries, or the Site.

Please note that unsubscribe requests may take up to ten (10) days to become effective. You may not opt out of receiving communications regarding your dealings with the Site or technical information about the Site.

 

Opt-Out Choices

To "opt-out" of (1) having your Site provided personal data disclosed to third parties for marketing purposes, or (2) any other consent previously granted for a specific purpose concerning your personal data on this Site, send an e-mail to RGL at support@regenlab.com. To "opt-out" of receiving a particular marketing or promotional communication, follow the unsubscribe instructions included in the specific communication.

Access and Choice

If you are a registered user or have provided RGL with your personal data, you may request to review, change or delete information previously provided to us by modifying your profile at the Login Screen or by sending an e-mail to support@regenlab.com. Requests for changes to or deletions of your personal data should be made by you directly. We will respond to all access requests within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Other Web Sites

This Policy applies only to RGL Sites that link to this privacy policy. This Site includes links to both our affiliated sites and to non-RGL web sites, including access to content, products and services of such affiliated and non-affiliated sites (Other Sites). In some cases, these Other Sites are made available via "framing technology", and may appear to be part of this Site. Although some of the entities controlling these framed sites are under contract with RGL, we urge you to familiarize yourself with the individual privacy and other terms for each linked or framed site prior to providing your personal data. All RGL Sites that are governed by this privacy policy will have a link to this document.

Security

RGL takes seriously the security of the information it collects. RGL has therefore implemented technology and security policies and procedures intended to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to, such information, reasonably appropriate to the nature of the data concerned.

When you enter sensitive information (such as personal health information), we encrypt the transmission of that information. We follow generally accepted standards to protect the personal data submitted to us through our Sites, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at support@regenlab.com.

Minors

Our Site is not intended for use by individuals under the age of 18, and RGL does not knowingly collect personal data from those in this age group. If you are under 18, please discontinue the use of our Site. If we become aware that someone under the age of 18 has registered, we will expunge any related personal data from our records.

Updates to Privacy Policy

RGL may, in its sole discretion, update this Policy at any time and from time to time, by posting the amended Policy on this Site. The amended Policy shall be effective upon posting, and your access to or use of the Site following an update shall be deemed consent to the revised Policy. We urge each visitor to refer back to this page regularly and especially prior to providing or updating any personal data. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact, Questions, Comments, Complaints

If you would like to communicate with RGL regarding privacy issues or have questions, comments or complaints about this Policy or Site, please contact us at support@regenlab.com