Farapulse, Inc. Privacy Notice
Effective Date: July 23, 2021
Farapulse, Inc. (“Farapulse”) is a medical device company based in Menlo Park, California. We collect and process personal data by respecting your privacy as part of our commitment to ethical, compliant and responsible practices. We process personal data collected for conducting our day-to-day business, including in clinical studies.
This Privacy Notice provides you information on what we gather and do with the data you provide when you interact with us in a business or clinical context.
EU’s General Data Protection Regulation, EU 201/679 (GDPR), (EU 2016/679) was enacted in 2018 to protect the privacy and security of personal data transferred out of the EU. This Privacy Notice has been written in compliance with that regulation and applies to personal data collected by Farapulse in the course of our business activities. This includes information from our business partners, suppliers, their personnel and other health care professionals, or researchers and data subjects that participate in studies or clinical trials that we sponsor.
PERSONAL DATA WE COLLECT
Personal data in this Privacy Notice means all information that can directly or indirectly identify you or other individuals. We collect different types of personal data depending on your interactions with Farapulse.
Farapulse collects the following types of personal data:
HOW WE USE YOUR PERSONAL DATA
The purposes for which we collect and use your personal data varies depending on your relationship or how you interact with us, such as if you are a clinical trial or study participant or applying for an open job position.
DISCLOSURE OF PERSONAL DATA
At times, Farapulse engages third party contractors or service providers to help us accomplish our business objectives. There are other circumstances where we are required by law to disclose personal data to third parties such as public bodies or judicial authorities.
Disclosures to Third Parties Assisting in Our Operations. We engage with contractors and service providers for email solutions or cloud hosting services, as well as agents, legal contacts, regulatory bodies, auditing organizations, and other professional and business advisors. Such recipients may be located in the United States (US) or in other jurisdictions such as the European Economic Area (EEA). If the engagement involves the transmission of personal data, we require the service provider to sign a data processing agreement consistent with this notice before any data is disclosed. These companies do not have any independent right to share or use this information.
Disclosures required by law. We may provide information about you, to respond to subpoenas, court orders, search warrants, legal processes or governmental regulations or inquiries, or to establish or exercise our legal rights or defend against legal claims.
Other Parties with Your Consent or at Your Direction. In addition to the disclosures described in this Privacy Notice, we may share information about you with third parties when you consent to or request such sharing.
Business Transfers. We may share your personal data with another business entity in connection with the sale, assignment, merger, or other transfer of all or a portion of Farapulse’s business to such business entity.
You may review and request changes to your personal data that Farapulse has collected, including the removal of your personal data from Farapulse’s databases where it can be verified or validated in order to prevent receipt of future communications, by contacting us at firstname.lastname@example.org.
Farapulse does not currently send promotional or marketing emails, and as such we do not have a method to “unsubscribe” individuals from emails sent by Farapulse.
TRANSFERS OF PERSONAL DATA OUTSIDE OF YOUR LOCAL JURISDICTION
If you are located outside the United States and you provide us personal data, then your personal data may be transferred to the United States or to other jurisdictions. However, we provide appropriate safeguards to ensure the same level of protection of your personal data.
We may transfer your personal data to the United States (US) when you interact with us. If you are located in the European Economic Area (EEA) or Switzerland, please note that the US has not obtained adequacy status from the European Union, and therefore, the level of protection of your personal data is not deemed equivalent to the protection provided data in Europe. In the context of our studies or clinical trials, your personal data can be transferred to other jurisdictions with less stringent data privacy laws. However, we provide appropriate safeguards to ensure the same level of protection of your personal data including the use of standard contractual clauses (data transfer agreements), that can be provided to you on request.
DATA PROTECTION RIGHTS
If you reside or otherwise find yourself in the territory of the European Economic Area (EEA) or Switzerland, we are committed to facilitate the exercise of your rights granted by the data protection laws of these territories.
For the purposes of the European Data protection law, any personal data you provide to Farapulse directly or Farapulse is the sponsor of a clinical study, Farapulse is considered the controller of your personal data. You can contact our Data Protection Officer at email@example.com or our EU Data Representative at firstname.lastname@example.org with any inquiries you may have regarding the processing of your personal data.
Farapulse assigns a legal basis for each data collection and use:
Farapulse recognizes your Data Privacy Rights:
Data Privacy Rights requests should be submitted as follows:
DATA PROTECTION OFFICER AND EU DATA REPRESENTATIVE
Farapulse has appointed a Data Protection Officer and an EU Data Representative in the European territory.
For any inquiries with regard to this notice or about our handling of your information, you can contact our Data Protection Officer at email@example.com or our EU Data Representative at firstname.lastname@example.org.
CHILDREN'S PRIVACY PROTECTION
You should be at least 18 years old to contact Farapulse or provide us with any information.
Farapulse does not knowingly collect personal data directly from minors. Any information we collect from minors is always with the consent of a parent or guardian. If you are under 18 years old, do not provide any information by contacting Farapulse directly.
Farapulse retains personal data for the length of time required to fulfill the purpose for which the data was collected.
According to our retention policy, we only keep personal data in our records as long as they are necessary for the purposes they have been processed. After the retention period expires, the personal data is deleted. The retention periods are established considering the purposes defined in this Privacy Notice, all relevant legal requirements, and the context in which we process your personal data.
Farapulse understands that storing our data in a secure manner is essential. We take reasonable precautions to keep all information secure against unauthorized access and use.
Farapulse stores personal data by using reasonable physical, technical, and administrative safeguards to secure data against foreseeable risks, such as unauthorized use, access, disclosure, destruction, or modification.
In addition, our information security team has developed policies, standards, and procedures to support and enforce preventive and detective operational controls to ensure the confidentiality, integrity, and availability of all data collected and managed by Farapulse.
CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice may be revised from time to time as we add new features, as laws change, and as industry privacy and security best practices evolve.
If we update the Privacy Notice, we will let you know about any changes that we consider material by placing a note on the Farapulse website
(http://www.farapulse.com). The most current version of the Privacy Notice will always be available on the website. You can check the "effective date" posted to see when the Privacy Notice was last updated.
If you have any questions about this Privacy Notice or about our handling of your information, please contact Farapulse at email@example.com.
Farapulse, Inc. (att: Legal Department)
3715 Haven Ave., Suite 110
Menlo Park, CA 94025
Mon - Friday 9am - 6pm (GMT +2)
3715 Haven Ave, Suite 110
Menlo Park, CA 94025