De Novo Software Privacy Policy

INTRODUCTION

De Novo Software (“us,” “we,” or “DNS”) is committed to respecting the privacy rights of visitors to and users of our Sites located at denovosoftware.com and all subdomains of denovosoftware.com (collectively, “Sites”), of people who we interact with at events and tradeshows, and of people who use our products (“Services”). We created this Privacy Policy (“Policy”) to help you understand how we use information we obtain, including information that identifies you as an individual (“Personally Identifying Information” or “PII”), with whom we share it, and the choices and rights available to you regarding our use of the information.  We also describe measures we take to protect the security of this information, how to contact us about our privacy practices and how to exercise your rights.

INFORMATION COLLECTION PRACTICES

Information You Provide to Us

When you use our Sites

In operating our Sites, we may collect a variety of user-submitted PII such as names, email addresses, and other contact information. In addition, we may provide registration forms, bulletin boards, comment forms, online surveys, and other online forms that ask users to provide their names, e-mail addresses, and other contact information, as well as information related to the subject matter of the activities requiring registration, the surveys, and other online forms.

Our Sites may provide you with the opportunity to purchase products or services from us, and in connection with any such purchase (a “Transaction”), you may be required to provide us with a credit card number and other personally identifiable information necessary for us to complete the Transaction.

When you use our software

When you register DNS software, you enter information so that we can authenticate the software license.

When you use our software and it crashes, you have the option to automatically send to us information further described under “Information We Automatically Collect.”

When you use our other services

When you request technical support from us, we will request that you provide PII such as your name and email address.

Do Not Send Medical or Health Information to DNS

Please review any information that you send us to confirm that no medical or health PII is included in it.  When you request technical support from us, we occasionally ask that you send electronic files, which have the possibility of containing health PII.  If we discover that you have sent us any health PII, we will promptly and securely delete the file and notify you.

Information We Automatically Collect

When you use our Sites

When you visit our Sites, we collect certain information related to your device, such as your device’s domain name, IP address, and referring website. None of your PII is processed or revealed. Our Sites may also gather anonymous website traffic data that does not personally identify you, but that may be helpful for marketing purposes or for improving the services we offer.

When you use our software

When you use DNS software, information is returned to DNS.  When you log onto our software, your email address, the MAC address of your computer, and your IP address is sent to us. In the event of a software crash, if you have given us permission to do so, we will receive information such as your computer’s configuration at the time of the crash. Please refer to your software’s Terms of Use for further details on the information we automatically collect.

USE AND SHARING OF INFORMATION

What we do with collected information

Personally Identifiable Information

We will not share your PII with any third parties without your consent, except as necessary to provide you with access to our Sites and the services offered by us, to process any Transactions you initiate, or to comply with the law. We do not rent or sell your PII to anyone.  We do not provide your PII to any third parties so that they can directly market to you.

We use PII that we collect in connection with a Transaction to fulfill your order for our products or services, to process your payment, and to facilitate billing in connection with the Transaction. Your personally identifiable information provided for purposes of any Transaction will be used only in connection with the Transaction and for no other purpose.  We use a third party processor for credit card payments and we do not store your credit card information.

We may use your PII to verify your identity, or to follow up with inquiries or Transactions. We may also use your contact information to inform you of any changes to our Sites, or to send you additional information about us.

We may share your PII with third party vendors, consultants, and service providers only for the purposes of technical support.

We may also use the information you send to us to communicate with you via email and, possibly, other means, regarding products, services, offers, promotions and events we think may be of interest to you. However, you will always be able to opt-out of such communications at any time.

When you use DNS software, we will authenticate your license using your email address you provided to us.

Anonymous Information

We use anonymous information to analyze traffic on our Sites, but we do not examine this information for PII. In addition, we may use anonymous IP addresses to help diagnose problems with our servers, to administer our Sites, or to display content according to your preferences. Traffic and Transaction information may also be shared with business partners and advertisers on an aggregate and anonymous basis. These companies include companies that use cookies (e.g., Google Analytics).

If your software crashes, we may use anonymous information for product improvement purposes.  We may also use anonymous information regarding software use for product improvement purposes.

Use of Cookies

Cookies are a way we collect and use anonymous information about you. We may use cookies or similar tracking technologies, such as beacons, to deliver content specific to your interests, to save your user ID or password so you don’t have to re-enter it each time you visit our site, or for other purposes. Promotions or advertisements displayed on our site may contain cookies.

In HTML-based email announcements, we track and report on recipients that open the email and click on any links. This information is used to enable more accurate reporting on end-user interests, improve the effectiveness of our marketing, and make our Sites and services better for our users.

We utilize Google Analytics, a web analysis service provided by Google, to better understand your use of our Sites. Using cookies and beacons, Google Analytics collects information, such as how often you visit our Sites, what pages you visit, and what other sites you visited prior to visiting ours. Google uses this data to track and examine the use of our Sites, to prepare reports on its activities and share them with other Google services. Google may use the data collected on our Sites to contextualize and personalize the ads in its own advertising network. Google’s ability to use and share information collected by Google Analytics about your visits to our Sites is regulated by our agreement with the Google Analytics Terms of Service and Google’s Privacy Policy.

Information Sharing under Special Circumstances

Business Transfers: We may share and disclose information, including PII, about our customers in some limited circumstances.   In order to accommodate changes in our business, we may sell our company or portions of our company, including the information collected through our Sites. If DNS or or a substantial portion of its assets are acquired, customer information will be one of the assets transferred to the acquirer.

Protection of DNS and Others: We reserve the right to access, read, preserve, and disclose any information as necessary to comply with a law or court order; enforce or apply our agreements with you and other agreements; or protect the rights, property, or safety of DNS, our employees, our users, or others.

Disclosures for National Security or Law Enforcement: Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities, including meeting national security or law enforcement requirements.

SECURITY

DNS and our Sites have security measures in place to prevent the loss, misuse, and alteration of the information that we obtain from you.  DNS proactively safeguards PII through embedding privacy into the design and operation of our data management systems.  However, we make no assurances about our ability to prevent any such loss, misuse, or alteration, and we and our owners, partners and affiliates will have no liability to you or to any third party arising out of any such loss, misuse, or alteration.

In the event of any loss, misuse, or alteration of your information, we will take actions required by law, including notifying you, if we have your email address, if your PII was disclosed.

YOUR PRIVACY RIGHTS

Your Choices

You can opt not to disclose information to us, but some information may be needed to take advantage of some features of our Sites and Services.

Cookies

You can view the types of cookies that our Sites use and accept or reject cookies on our Sites by clicking Show Details on the pop-up that appears on your first visit to our Sites.  You can update your preferences by clicking the “Change Consent” button in our Cookie Preferences page. You can also do so by adjusting your web browser controls.  Note that some cookies are required for our Sites to function, and others facilitate your ease-of-use with our sites by, for example, reducing the number of times you need to re-enter the same information.

Google offers a means to opt-out of Google Analytics on any website through an add-on that functions with current versions of commonly-used browsers.

Marketing Communications

You can opt-out of receiving promotional or marketing communications from us at any time, by using the Unsubscribe link in the emails communications we send, or by completing our opt-out form.

EU DATA SUBJECT RIGHTS

Your Rights under the EU General Data Protection Regulation (GDPR)

EU data subjects have the following additional rights regarding the processing of their PII:

  • The right to request a copy of your PII that we have acquired,
  • The right to request whether your PII is being processed, and if so:
    • The purposes of the processing,
    • Whether any Special Categories of PII are processed. Note that DNS does not presently process and does not plan to process any Special Categories of PII, which are PII that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs; genetic data, biometric data for the purpose of uniquely identifying you, and data concerning health,
    • The types of recipients to whom the PII have been disclosed,
    • Where possible to determine, the envisaged period for which the PII will be stored, or the criteria used to determine that period,
    • The right to know if any PII not collected directly from you is the source of any of our information,
    • The right to know if any automated decision-making tools are used, including profiling.
  • The right to request that DNS correct or update PII if it is inaccurate or out of date,
  • The right to request that your PII is erased where it is no longer necessary for DNS to retain it,
  • The right to withdraw your consent to or restrict the processing of your PII at any time;
  • The right to request that DNS provide you with your PII in a portable format,
  • The right to delete your PII (“Right to Be Forgotten”),
  • The right to lodge a complaint with a Supervisory Authority.

How to update and access information

If you would like to access, review, update, correct, or delete any PII we hold about you, or exercise any other data subject right available to you, please contact us.  DNS will examine your request and respond to you as quickly as possible. If we cannot respond in 30 days or cannot honor your request, we will provide details on the reason and advise you of your right to lodge a compliant with your Supervisory Authority.

Exclusions

We may still use any anonymous PII that does not identify you or any individual, and may also retain and use your PII if necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Please note that as a seller of medical devices, we are required by United States and EU law to maintain some types of PII, such as company contact names, email addresses, physical addresses, and phone numbers, when customers purchase our medical device products.  We must maintain this PII in the event that we need to contact you regarding important product changes and recalls.

EU Supervisory Authorities

If you believe that our processing of your PII infringes on your rights under the GDPR, you have a legal right to lodge a complaint with a Supervisory Authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.

CALIFORNIA RIGHTS

California data subjects have the following additional rights regarding processing of their PII:

California requires DNS to indicate whether it honors “Do Not Track” signals or other browser mechanisms that provide consumers with the ability to exercise choices regarding the collection of PII. The “Do Not Track” standard is presently under development. As it is not yet finalized, DNS does not monitor, respond to, or honor Do Not Track browser requests.

We do not provide your PII to any third party for direct marketing purposes.

INTERNATIONAL DATA TRANSFERS

PII that you provide us will be primarily processed by us in the United States and potentially in other countries, on our servers, or on our hosted service providers’ cloud servers on our behalf. These countries may not have similar data protection laws to those in your country of residence. However, we will always protect your information in accordance with this Privacy Policy wherever it is processed.

our sites and services are not intended for or marketed to CHILDREN

Our Sites and Services are intended for use by adults, primarily individuals involved in the medical and scientific research communities; therefore, we do not direct any of our content specifically at children under 13 years of age. We do not knowingly collect or solicit personal information from anyone under the age of 13.  We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a user of our Sites or Services is under age 13, we will promptly delete any PII that might be stored in that user’s account. If you believe that a child under 13 may have provided us PII, please contact us.

AREAS BEYOND OUR CONTROL

Public Forums

Our Sites may include interactive forums such as message boards, comment areas and chat rooms. Any information that is disclosed in these areas becomes public information, so please exercise caution when using any of these public forums if you choose to disclose your PII. We have no control over the use of any PII disclosed in a public forum, and you are solely responsible for the effects of any such disclosure.

Linked Sites

For your convenience, hyperlinks may be posted on our Sites that link to other websites (the “Linked Sites”). We are not responsible for, and this Privacy Policy does not apply to, the Linked Sites or of any companies that we do not own or control. Linked Sites may collect information in addition to that which we collect on our Sites. It is your responsibility to review the privacy policies on the Linked Sites and to confirm that you understand and agree with their policies.  We are not responsible for the content contained on the Linked Sites.  In addition, in no event will we have any responsibility for the contents of the Linked Sites, and you visit and use those sites entirely at your own risk.

CHANGES TO THIS PRIVACY POLICY

As we regularly improve our Sites and Services, and laws regarding privacy often change, we may need to update this Privacy Policy. We will alert you to material changes when we are required to do so by applicable law by, for example, placing a notice on our Sites and/or by sending you an email, if you have provided your email to us. You can determine when the Privacy Policy was last updated by checking the date at the bottom of this page. It is your responsibility to review this Privacy Policy from time to time to know your current rights.

CONTACT INFORMATION

Privacy Officer
De Novo Software
400 N. Brand Blvd Suite 850
Glendale, CA 91203
Phone: 213 814 1240
Fax: 213 814 1240
privacy@denovosoftware.com

Effective 6/14/2019