Privacy Policy

Introduction

Cirtec Medical Corp., as well as its affiliates and subsidiaries, (hereafter collectively referred to as “Cirtec”) attaches great importance to the protection of personal data and is committed to protecting the data of people who visit our websites. Cirtec processes personal data collected during visits to our website in accordance with the laws on data protection and data security and is the data controller in this respect. This privacy policy tells you how Cirtec handles information that is collected on the Cirtec website.

Information We Collect

Personal data is any information relating to an identified or identifiable natural person such as your name, your e-mail address or your postal address. Unless you have agreed otherwise with Cirtec, Cirtec only collects personal identification information that is necessary for our business relationship. Namely, Cirtec will collect your name, company name, email address, and phone number. Cirtec will only collect these personal data where you choose to provide us with them, including through forms such as our “Contact Us” form, registration forms, email sign-ups, download forms, and career inquiries. Cirtec only collects this personal data directly from you and not from other third parties¹.  

When you visit this website, our web server, using Google Analytics, automatically records non-identifiable analytics details about your visit, including IP address, browser type and version, time zone setting, operating system, date and time of browsing, pages visited, response times, and time of visits to certain pages. The legal basis is your consent, if you have accepted all cookies in the cookie banner. If you use several end devices or browsers, you must revoke this consent for each individual end device in each individual browser. Please see below for more information on cookies.

How We Use Your Information

Cirtec will use your personal data to respond to your inquiry, to process your order, or to provide you access to special information or offers you have requested from us. For example, if you fill out an online “Contact Us” form, Cirtec will use this information to contact you regarding your interest in the services².  

Cirtec will also use your personal data for technical administration, research and development of this website, to conduct research and analysis with regard to our business relations, for fraud prevention and detection, to comply with any legal obligations (e.g. tax, accounting and administrative obligations), to maintain business relationships, to inform you about our events, services, products and news when you visit this website or when you subscribe to our newsletter or mailing lists, to facilitate compliance with securities laws and regulations, and to comply with any other legal obligations (e.g. tax, accounting and administrative obligations). We inform you where we require your consent to process your personal data. Otherwise, we process your personal data to meet our legitimate and necessary business interests or where it is needed to comply with a legal obligation³.

Cirtec would like to use your personal data for marketing purposes, if necessary, insofar as you have expressly consented to it⁴.  In this case, Cirtec will use the information you provide to contact you to discuss your interest in services and to send you information about the company and its subsidiaries and affiliates, such as promotions or events. For this purpose, it will also be necessary for Cirtec to pass on your data to group companies or external service providers within the scope of commissioned data processing. For example, Cirtec will need to share customer information for customer relationship management purposes. Such group companies and external service providers include the following:

• SalesForce

If you have agreed to receive marketing, you may always opt out at a later date. Cirtec will not sell or otherwise market your personal data to third parties or pass it on for their advertising purposes. Insofar as you have expressly consented to it, Cirtec shall pass on your data to its subsidiaries and partner companies so that they can contact you directly⁵.  These partner companies are:

• Vascotube GmbH
• NovelCath, Inc.
• Cardea Cathater Innovations

Cookies and Tracking Technologies

Cookies and similar technologies are used on this website. A cookie is a small piece of data that is stored on your computer or mobile device and allows the website to "remember" your actions or preferences over time. In the cookie, information is stored that arises in each case in connection with the specific end device used. This does not mean, however, that we thereby gain immediate knowledge of your identity.  We use cookies to ensure the proper function of our website and to facilitate your access to it by collecting information on your device and preferences (e.g. your device and your browser). Additionally, we collect information on how you interact with our services.

On its websites, Cirtec collects only the personal data that you voluntarily provide in online forms or that you otherwise allow us to collect according to the cookie preferences you selected when you first accessed our website⁶.  You have the right to withdraw your consent at any time.

There are a number of different types of cookies. Our website uses the following:

• Session Cookie (or “temporary cookie”): A session cookie allows us to store your action during your browser session. Session cookies are erased when you close your browser or exit our website.
• Persistent Cookie (or “tracking cookies”): A persistent cookie is stored on your device in between browser sessions. These cookies help us to remember your preferences or actions every time you visit our website until the expiry date of the cookie. These cookies are also used to keep you logged onto our website. As soon as the cookie is deleted, you need to enter your login credentials again.
• Third-Party Cookie or Targeting Cookie: These cookies are set by a third party separate from our website, for example to provide advertisements like banners for third-party products or social media buttons.
• Strictly Necessary Cookie:  These cookies are required for the website to function and cannot be disabled on our systems.  These cookies do not store any personally identifiable information.
• Performance Cookie: These cookies allow us to count visits and traffic sources in order to measure and improve website performance.  All the information that these cookies collect is aggregated and therefore anonymous.  If these cookies are not allowed, there will be no record of when you visited the site.
• Advertising: Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

You can set up your browser so that it does not store our cookies on your end device. The help function in the menu bar of most web browsers explains how to prevent your browser from accepting new cookies, how to have your browser notify you when you receive a new cookie, or even how to delete all cookies you have already received and block them for all further ones. However, in a few cases, some of our website features may not function as a result.

When you save your cookie settings, they should also apply to your future visits to this website. However, for technical reasons beyond our control, this cannot be guaranteed. For example, if you reset your browser, delete your cookies or access this website from another browser or device, your cookie settings may be lost. To comply with applicable laws and regulations, in some countries you may be asked to confirm your cookie settings when you first visit this website. If you are in a country where you are automatically required to set your cookie settings, you may be asked to set them again on a future visit.

Data Security

Cirtec securely stores your data. We have implemented reasonable technical and organizational security measures to protect your personal data collected by us via our website against unauthorized access, falsification, manipulation, misuse, loss or destruction.

Our security measures include:

• Physical Safeguards: Access to our facilities is restricted to authorized personnel only. We employ security measures such as locked file cabinets, secure storage rooms, and surveillance systems to protect physical records containing personal information.
• Organizational Safeguards: We have established policies and procedures to ensure that personal information is handled securely within the organization. All employees receive regular training on privacy and data protection to maintain awareness and understanding of their responsibilities.
• Technological Safeguards: We use advanced technological solutions to protect electronic data. This includes encryption, firewalls, secure access controls, and intrusion detection systems. Regular audits and assessments are conducted to ensure the effectiveness of these measures.
• Access Controls: Personal information is accessible only to employees who require it to perform their job duties. We implement role-based access controls and authentication mechanisms to ensure that access is granted appropriately and securely.
• Incident Response: In the event of a data breach or security incident, we have a comprehensive incident response plan in place. This includes immediate containment measures, notification procedures, and steps to mitigate any potential harm.
• Third-Party Security: When engaging third-party service providers, we ensure they adhere to equivalent security standards. Contracts and agreements generally include provisions for data protection and confidentiality.
• Continuous Improvement: We regularly review and update our security measures to reflect evolving threats and technological advancements. Feedback from audits and assessments is used to enhance our security posture.
• Residents of California: The California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide consumers (California residents) with specific rights regarding their personal information. The section below describes these rights.

Cirtec retains personal data for as long as it is relevant to the contractual relationship, necessary to achieve the purposes for which it was collected, necessary to fulfill our legal obligations, or to the extent permitted by law to protect our legitimate business and legal interests, for example, to defend legal claims. Afterwards, Cirtec will delete your personal data.

For European Consumers: Your data will be processed in European countries, as well as in countries outside the European Union, including the United States (i.e. in so-called third countries). If data processing takes place in third countries, this will take place insofar as you have expressly consented to this or if it is necessary for our provision of services to you or if it is provided for by law⁷.  Your data will only be processed in third countries if certain measures are taken to ensure that an adequate level of data protection is in place.

Your Rights

Every user has the right to each of the following: 1) access information about your personal data stored by us and to learn the origin of the data, the purposes and means of the processing, the details of the data controller(s), and the data processor(s) and the parties to whom the data may be disclosed, 2) object to us processing your personal data, or ask us to stop processing it (including for purposes of direct marketing), 3) file a complaint with us and/or the relevant data protection authority, 4) correct, complete, or update information you believe is inaccurate or incomplete, 5) request that Cirtec transfer this data to another organization or to you directly, and 6) request that Cirtec delete or erase from our records any data no longer needed for the purposes indicated.

You can request a copy of the data we have stored about you. Cirtec reserves the right to charge you a small fee for this if you exercise this right disproportionately often.

You may exercise their rights herein, or consult any question related to the processing of their personal data, by using the information contained in the section “Contact Us”, below.

Cirtec is committed to respecting the privacy rights of individuals and ensuring that personal information is collected, used, and disclosed in accordance with applicable regulations. We obtain consent through both express and implied consent. Express consent is obtained when individuals explicitly agree to the collection, use, or disclosure of their personal information, typically through written communication. Implied consent may be inferred from actions or circumstances, such as when individuals provide information voluntarily for a specific purpose. You can revoke your consent at any time with effect for the future. Revocation of consent shall not affect the lawfulness of the processing carried out on the basis of the consent.

The California Consumer Privacy Act (CCPA) provides consumers (California residents) with the following rights regarding their personal information. Under the CCPA, personal information includes any information which can be used to identify an individual, their family, or their home address.

• Right to Know and Access Specific Information, and Data Portability Rights: You have the right to request that Cirtec disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you the following, in a portable format: The categories of personal information we collected about you, the categories of sources from which we collected the personal information about you, our business or commercial purposes for collecting, using, or selling that personal information, the categories of third parties with whom we share that personal information, the categories of information that Cirtec sells or discloses to third parties, and the specific pieces of personal information we collected about you. To exercise this right, please use the information provided in the section below entitled “Contact Us”. You may also request any right by contacting us. You also have the right to request an easily readable copy (in a commonly used format) of the specific personal information we hold.

Contact Us Form

• Deletion and Correction of Information: You have the right to request the deletion of your information which you believe is inaccurate. The right to deletion does not apply where the retention of personal information is needed to perform any of the following: provide goods or services to you, detect or resolve security or functionality-related issues, comply with the law, conduct research in the public interest, safeguard the right to free speech, or carry out any actions for internal purposes that you might reasonably expect. You also have the right to ask to correct information you believe is inaccurate. To exercise these rights, please use the information provided in the section below entitled “Contact Us”.
• Non-Discrimination: Cirtec cannot discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: deny you goods or services, charge you different prices or rates for goods or services (including through granting discounts, rebates, or other benefits, or imposing penalties), provide you a different level or quality of goods or services, or suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.
• Right to Opt-Out of Sale: Cirtec does not sell and has not sold in the past 12 months any personal data of visitors to its websites.
• Right to Limit: You can direct Cirtec to only use your sensitive personal information for limited purposes, such as providing you with the services you requested. You may request that we limit the use at the link titled “Limit the Use of My Sensitive Personal Information” on the home page of the Website.
• Automated individual decision making: You have the right not to be subject to a decision solely on automated processing, including profiling, which includes legal or similarly significant effects on you, except as allowed under applicable data protection laws.
• Users under 16 years old: Cirtec does not knowingly collect or sell any information from or about children under the age of sixteen.

Third Parties

Cirtec engages trusted third parties to perform specific functions and provide services to us; including, but not limited to, hosting and maintenance, error monitoring, debugging, performance monitoring, billing, customer relationship, and database storage and management. We may share personal information with these third parties, but only to the extent necessary to perform these functions and provide these services. We require nonaffiliated third parties to with whom we share your personal information to take appropriate measures to protect such data and impose contractual obligations to that end.  Other third-parties with whom we may share personal information, and the reason for doing so, are:

• Airtable - Data collaboration platform for website performance and customer relationship management
• SalesForce - Customer relationship management platform for customer and prospect communications

The Cirtec website contains links to other unaffiliated websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

Changes to This Privacy Policy

This privacy statement was last updated in May of 2025. If this privacy policy is changed, the change will be noted in this privacy policy.

Contact Us

In order to exercise your above mentioned rights (Including those under the CCPA), please send us a description of the data concerned and indicate your name, customer number (if applicable) and your birthday. Cirtec may require you to provide further proof of your identity to protect your personal information from unauthorized access. The contact form can be found here.

• 9200 Xylon Avenue North
  Brooklyn Park, MN 55445
• Phone: 763.493.8556
• Email: info@cirtecmed.com
• Designated Data Protections Officer: Steve Baker (Steve.baker@cirtecmed.com)

If you are of the opinion that we do not comply with the legal provisions when processing your data or that your data protection rights have otherwise been violated in any way, you can contact the data protection supervisory authority responsible for your country⁸.

Policy References

¹ Legal Basis: Art. 6 (1), sec. a) and b) GDPR.

² Legal Basis: Art. 6 (1) sec. b) GDPR.

³ Legal Basis: Art. 6 (1) sec. c) and f) GDPR.

⁴  Legal Basis: Art. 6 (1) sec. a) GDPR.

⁵  Legal Basis: Art. 6 (1) sec. a) GDPR.

⁶ Legal Basis: Art. 6 (1) sec. a) GDPR

⁷ Legal Basis: Art. 49 GDPR

⁸ Pursuant to Art. 77 (1) GDPR

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