EMPOWER MEDICAL DEVICES LLC
PRIVACY POLICY

INTRODUCTION

This website is owned and operated by Empower Medical Devices, LLC.
In this Privacy Statement, we describe how we protect and use information that we gather through this website as permitted or required by law. This web site and this Privacy Statement are subject to applicable U.S. laws and regulations.

This Privacy Statement was last updated in February 2019. We may change this Privacy Statement at any time and for any reason. If this Privacy Statement is revised, the most current statement will be posted on this web site. We encourage you to review this Privacy Statement each time you visit the website.

By using this web site, you agree to the terms of the most recent version of this Privacy Statement. Please read our Terms of Use to understand the general rules about your use of this web site. When we use the words we or our, we mean Empower.

WHEN DOES THIS PRIVACY STATEMENT APPLY?

This Privacy Statement applies when we collect and process personal information directly from the person who the data identifies, or indirectly from someone else (or company) that identifies another person. Therefore, when we use the word "you" , "me", and "I" in this Privacy Statement, we mean the individual whose personal information we are collecting and processing.

This Privacy Statement does not apply when we process information:

• Where we have given other disclaimers, policies, terms of use, or other notices indicating that this policy does not apply, or that a different policy or notice does apply
• That does not identify you as an individual person, including to personal information (which we define below) that we have de-identified, so that it no longer can be used to identify you

WHAT IS DATA PROCESSING?

Data processing is any set of operations involving personal information, whether or not by automatic means, including collecting, using, disclosing, adapting, altering, correcting, retrieving, combining, blocking, erasing, transferring, destroying, recording, organizing, storing, and using personal information.

We will always process personal information:

• Confidentiality and fairly
• Appropriately, according to the statements we make
• Lawfully, in accordance with applicable data protection laws, directives, regulations and principles

WHEN AND HOW DOES EMPOWER COLLECT PERSONAL INFORMATION?

Empower may collect personal information in a variety of ways. For example:

• We may collect personal information about you in the course of engaging in commercial transactions with
• In some places on our web sites you have the opportunity to send us personal information about For example, you may fill out a registration form, a survey or an e-mail form and you may elect to receive educational material about our products and therapies.
• You also may choose to allow us to personalize your visits to the web sites, in which case we will ask you for certain personal information to make your visits to our web sites more helpful to When this information is combined with the non-personal information that we collect through cookies, (defined below) we will be able to tell that you have visited our web sites before.

WHAT IS PERSONAL INFORMATION?

Personal information is information relating to you that we can use to specifically identify you, such as your:

• Name
• Telephone Number
• E-mail Address
• Address
• Financial information (such as credit card information)
• Any other information that identifies or could identify you and relates to you

HOW DOES EMPOWER PROCESS PERSONAL INFORMATION?

We may process your personal information:

• To perform a contract or for contract negotiations with or about you
• To respond to your requests and enquiries
• To contact you by mail (or in other ways with your permission) with information that might be of interest to you, including information about clinical trials and about our products and services and of others
• For analytical purposes and to research, develop and improve programs, products, therapies, services and content
• To remove your personal identifiers (your name, e-mail address, ). In this case, you would no longer be identified as a single unique individual. Once we have de-identified information, it is non-personal information and is not subject to this Privacy Statement
• To personalize your access to our web sites, for example, by telling you about new features that may be of interest to you
• To enforce this Privacy Statement and otherwise protect our rights or property
• To protect your vital interests or someone else's health, safety or welfare
• To comply with a law or regulation, court order, or other legal obligation
• For our other legitimate interests, unless such processing will unfairly prejudice your rights or freedoms
• In other ways to which you consent

WILL EMPOWER EVER USE PERSONAL INFORMATION TO CONTACT ME WITH MARKETING MESSAGES?

We may contact you periodically in person, by e-mail, by fax, by mail, or by telephone to provide information regarding programs, products, services and content that may be of interest to you, unless you advise us that you do not wish to receive marketing or market research communications from us. If applicable law requires that we receive your explicit consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your explicit consent.

DOES EMPOWER SHARE PERSONAL INFORMATION WITH THIRD PARTIES?

Empower will not share your personal information with an unrelated third party without your permission, except as otherwise provided in this Privacy Statement.

In the ordinary course of business, we will share some personal information with companies that we hire to perform services or functions on our behalf. For example, we may use different vendors or suppliers to ship our products. In these cases, we provide the vendor or supplier with information to process your order such as your name and mail address. In all cases in which we share your personal information with a third party, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.

We will not sell, exchange or publish your personal information, except if this required in conjunction with a corporate sale, merger, dissolution, or acquisition.

We may disclose your personal information in response to a court order, subpoena, if otherwise required by law, or to authorized public health officials (or a government agency collaborating with such officials) to carry out public health activities (e.g., government officials who are responsible for controlling disease, injury, or disability). We may also release your personal information to government agencies authorized to conduct audits, investigations, and inspections of our facilities or privacy practices. These government agencies can monitor the operation of the health care system, or compliance with government regulatory programs or civil rights laws.

We may disclose your personal information to third parties if we feel that the disclosure is necessary to:

• enforce this Privacy Statement
• protect our rights or property
• protect someone's health, safety or welfare
• comply with a law or regulation, court order, or other legal process

WHAT ABOUT THE SECURITY OF PERSONAL INFORMATION?

We use reasonable physical, administrative, and technical safeguards to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We also restrict access to your personal information to those employees and contractors who need to know that information to do their jobs. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

HOW LONG WILL EMPOWER MAINTAIN MY PERSONAL INFORMATION?

We will not keep information for any longer than is required. In many cases, personal information must be kept for considerable periods of time in order to make it available as and when questions or disputes arise. Retention periods will be determined for all personal information that is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable opportunity. We will continue to treat your personal information in accordance with this Privacy Statement so long as we retain it.

WHAT DOES EMPOWER DO WITH PATIENT INFORMATION THAT I MAY INPUT TO THE SITE?

We do not require you to submit patient information to process orders on this site, but we recognize that some customers may choose to enter patient information along with their orders. Empower will only use that information to assist you in the processing orders and payment, or to meet our legal or regulatory obligations. We will maintain and safeguard the patient information similar to your personal information, as described above.

LINKS

Our web site may contain links to web sites operated by other parties. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of web sites operated by others. We are not responsible for the performance of web sites operated by third parties or for your business dealings with them. Our web site may also contain links to other web sites operated by Empower. This Privacy Statement applies only to this web site, and there may be slight variations in the Privacy Statement as posted on other Empower websites. Therefore, whenever you follow a link from this web site to another web site, even to another site operated by Empower, we recommend that you review that web site's privacy practices.

COOKIES

Empower may use cookies on this web site. Cookies are text files we place in the browser files of your computer when you visit. The information that we collect using cookies is non-personal information. You are always free to decline our cookies if your browser permits, but some parts of our web sites may not work properly for you if you do so. We do not allow third parties to place cookies on our web sites.

Empower Medical Devices, LLC may use cookies for reasons including, but not limited to:

• Analyze our web traffic using an analytics
• Identify if you are signed into the
• Test content on the
• Store information about your
• Recognize when you return to the

Overall, cookies help us provide you with a better Website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Website.

OPT OUT

You may opt out of the collection of your personal information at any time by not providing your information in our Contact form, or by clicking Unsubscribe on our newsletter, or by contacting us at: info@empowermedicaldevices.com

HOW TO CONTACT EMPOWER MEDICAL DEVICES

We strive to keep our records of your information accurate. If you ever notice that your information is not complete, accurate or current, or if you have any questions or comments about this Privacy Statement, please contact the Empower Support Team at (989-731-3912) or send us an email at info@empowermedicaldevices.com

LAST UPDATED September 30, 2019.