Privacy Policy

Effective Date of Terms: September 16, 2021

Table of Contents

• INTRODUCTION
• WHAT INFORMATION DO WE COLLECT?
• HOW DO WE USE THE INFORMATION WE COLLECT?
• WHAT INFORMATION DO WE DISCLOSE TO THIRD PARTIES
• WHAT RIGHTS DO YOU HAVE REGARDING YOUR INFORMATION
• NOTICES FOR CALIFORNIA RESIDENTS
• NOTICE FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA ADDITIONAL POLICIES
• ADDITIONAL POLICIES

Introduction

This privacy policy is designed to inform users of our website and/or products (collectively, the "Service") about how we gather and use personal information collected by us in connection with use of the Service. We will take reasonable steps to protect user privacy consistent with the guidelines set forth in this policy and with applicable U.S. laws. In this policy, "user," “your” or "you" refers to any individual or entity using the Service, whether by browsing the Service, registering with us by creating an account, or participating in any other activities available through the Service. 

BY ACCESSING OR USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY AND OUR TERMS OF SERVICE. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT USE THE SERVICE.

WHAT INFORMATION DO WE COLLECT?

PERSONAL INFORMATION

We collect the following Personal Information in connection with the Service:

1. when you use the Service or submit any information through the Service, whether in your individual capacity or on behalf of an organization, we collect the personal information that is disclosed on our online registration form or otherwise submitted through the Service, such as your name, title, organizational affiliation, address, telephone, and email address; and
2. if you communicate with us by email, we will collect your email address.

All of this information is referred to in this Policy as "Personal Information".

WEB TRACKING INFORMATION

We may collect web tracking technologies such as cookies, web beacons, pixel tags and clear GIFs in order to operate the Service efficiently and to collect data related to your usage of and interaction with the Service. Such collected data ("Web Tracking Information") may include the address of the websites you visited before and after you visited the Service, your geographic location, the search terms you used, the date and time of your visit, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Service you visit and what links you clicked on, and whether you opened email communications we send to you. If you use a mobile device to access our Service, we may also collect information about the geographical location from which you accessed the Service. 

In order to collect Web Tracking Information and to make your use of the Service more efficient, we may store cookies on your computer. These cookies will be stored (1) until the user closes the browser, (2) until the user logs off the Service, or (3) until they expire.  For more information about cookies, visit www.allaboutcookies.org. 

We may also use web tracking technologies that are placed in web pages on the Service or in email communications to collect information about actions that users take when they interact with the Service or such email communications. Web Tracking Information may include data, such as IP address data, that is unique to you. You may be able to modify your browser settings to alter which web tracking technologies are permitted when you use the Service, but this may affect the performance of the Service. Likewise, most mobile devices allow you to disable the ability for geo-location to be collected from your mobile device, but this may also affect the performance of the Service. 

HOW DO WE USE THE INFORMATION WE COLLECT?

PERSONAL INFORMATION

We will use and store Personal Information for the purpose of delivering the Service, and to analyze and enhance the operation of the Service. We may also use Personal Information for the operational and administrative purposes of the Service.

We may use the Personal Information you provide or that we collect about you, as well as non-personally identifiable information, to fulfill your requests for our products, programs, and services, to respond to your inquiries about our offerings, and to offer you other products, programs or services that we believe may be of interest to you.  We sometimes use this information to communicate with you.  By posting messages, uploading files, inputting data, or engaging in any other form of communication through this service, you are granting us the license set forth in our Terms of Service.

WEB TRACKING INFORMATION

We use Web Tracking Information to administer the Service and to understand how well our Service is working, to store your user preferences, to develop statistical information on usage of the Services, and to analyze the productivity of users of the Service. This allows us to determine which features visitors like best to help us improve our Service, to personalize your user experience, and to measure overall effectiveness.

AGGREGATED INFORMATION

We will also create usage, statistical, anonymized and/or aggregated data (collectively, “aggregated data”) relating to our users and the Service for analytical purposes. Aggregated data includes data derived from Personal Information and also data collected by Gunze from other sources; in its anonymized or aggregated form, it does not relate to or identify any individual. This data is used to understand our customer and user base and to develop, improve and market our services.

LEGAL EXCEPTION

Notwithstanding the above, we may in any event use Personal Information, and any other information collected through the Service to the extent required by law or legal process, to resolve disputes, to enforce our agreements (including this Privacy Policy and the Terms of Service) with you, or if in our reasonable discretion use is necessary to protect our legal rights or to protect third parties.

EMAIL COMMUNICATIONS

If you register and provide your email address, we will send you administrative and promotional emails, including newsletters. If you wish to opt out of newsletters and promotional emails, you may do so by following the "unsubscribe" instructions in the email. All users receive administrative emails, so you cannot opt out of them while you remain registered.

WHAT INFORMATION DO WE DISCLOSE TO THIRD PARTIES?

PERSONAL INFORMATION

We will not disclose your Personal Information to any third parties except as follows:

(i) to third party contractors engaged to provide services on our behalf ("Contractors"), such as analyzing data and usage of the Service, operating the Service or providing support and maintenance services for the Service, performing marketing support, or providing customer service. We enter into agreements with all Contractors that require Contractors to use the Personal Information they receive only to perform services for us; and

(ii) when we have your consent to share the information.

WEB TRACKING INFORMATION

We disclose Web Tracking Information to Contractors, in order to analyze the performance of the Service and the behavior of users, and to operate and improve the Service. Certain Web Tracking information that is not correlated to individual user Personal Information, such as the popularity ranking of certain pages of the Service, may be published on the Service and so disclosed to all users of the Service. Gunze may disclose to its institutional and corporate subscribers how the users of the Service affiliated with the subscriber use the Service.

AGGREGATED INFORMATION

We may disclose aggregated data that does not contain Personal Information to third parties, such as potential customers, business partners, advertisers, and funding sources, in order to describe our business, operations, products, and services.

NETWORK OPERATORS

Use of the Service may involve use of the services of third party search engine operators or telecommunications carriers. Such operators are not our contractors, and any information that such operators collect in connection with your use of the Service is not "Personal Information" and is not subject to this Privacy Policy. We are not responsible for the acts or omissions of such operators.

ADDITIONAL DISCLOSURES

We reserve the right to disclose any information we collect in connection with the Service, including Personal Information to any successor to our business as a result of any merger, acquisition, asset sale or similar transaction.

We will also share your information with law enforcement agencies, public authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary and in our legitimate interests to:

• comply with a legal obligation, process or request;
• enforce our Terms of Service and other agreements, including investigation of any potential violation thereof;
• detect, prevent or otherwise address security, fraud or technical issues; or
• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (i.e., exchanging information with other companies and organizations for the purposes of fraud protection).

WHAT RIGHTS DO YOU HAVE REGARDING YOUR INFORMATION?

PRIVACY SETTINGS/OPT OUT

If you would like your Personal Information or geographical location data permanently removed from our database, please contact us at medical@gunze-usa.com. We will delete your account and you will no longer receive marketing email from Gunze. Your removal from the mailing list or database will not remove records of past transactions or delete information stored in our data backups and archives. If you opt-out of allowing Gunze to collect geographical location data, the performance of the Service may be affected and you may not be able to access certain applications within the Service. If you are a User accessing the Service on behalf of an organization, the organization may require Personal Information or tracking of geographical location data in order to deliver the Service. Data on past transactions and data stored in backups and archives will be maintained and/or deleted in the ordinary course of Gunze' business. Gunze may still contact users who have deleted their information for administrative purposes. Please note that this opt-out process may take some time to complete, consistent with applicable law.

ACCESS AND UPDATING OF INFORMATION

Gunze is happy to allow you to review or amend your email address or contact details held in our database, at any time. Please contact us by sending an email to: medical@gunze-usa.com or by using your settings panel in your account online.

NOTICES FOR CALIFORNIA RESIDENTS

THE CALIFORNIA CONSUMER PRIVACY ACT

The California Consumer Privacy Act (“CCPA”) went into effect on January 1, 2020.  The law gives California residents certain rights to access and delete their “Personal Information,” and to opt out of the sale of their Personal Information.  The CCPA also requires businesses to disclose in their privacy policies information about how they collect, use, and share Personal Information.  This section of the privacy policy contains the disclosures Gunze is required to make and summarizes the rights that California residents have under the CCPA.

For purposes of this section, the term “Personal Information” means Personal Information under Cal. Civ. Code 1798.140(o).  To the extent that any other provision of this Privacy Policy conflicts a provision of this section, the provision in this section controls as to California residents. 

a. Categories of Information Collected, Disclosed, and Sold in the Past 12 Months

The below table discloses the categories of Personal Information that Gunze has collected in the past 12 months from the effective date of this privacy policy.  For each category of Personal Information, the table identifies: (i) whether Gunze has sold to a third party, or disclosed for a business purpose, the category of Personal Information; and (ii) the categories of third parties to whom the information was disclosed or sold.  The table does not include Personal Information provided to us by providers or other customers in a business-to-business context. 

b. Summary of California Residents’ CCPA Rights

California residents may:

• Request that we delete their Personal Information (a “Request to Delete”).
• Opt-out of the sale of their Personal Information (a “Request to Opt-Out”).
• Request information about our collection, use, and sharing of their information (a “Request to Know”), including:

1. the categories and specific pieces of Personal Information we have collected about them;
2. the categories of sources from which we have collected their Personal Information;
3. the business or commercial purpose for collecting or selling their Personal Information;
4. the categories of their Personal Information that we have sold; and
5. the categories of third parties with whom we have shared, disclosed for a business purpose, or sold their Personal Information, and which categories of Personal Information we have sold to which categories of third parties.

Consistent with the anti-discrimination protections provided by the CCPA, we will not discriminate against users for exercising these rights.  Consistent with Cal. Civ. Code 1798.125, we may charge users different prices, or provide different levels or quality of goods or services, if the difference is reasonably related to the value of their data.  We may also offer financial incentives for the collection, sale, or deletion of your Personal Information.

California residents, such as providers, who share their Personal Information with Gunze in their capacity as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government agency do not have the right to submit a Request to Know or Request to Delete.

c. Submitting “Requests to Know”

California residents may submit a Request to Know by emailing their request to [medical@gunze-usa.com].

California residents may submit two types of Requests to Know: (1) A request for the specific pieces of Personal Information that Gunze has collected about you in the past twelve months; or (2) a request for the categories of Personal Information that Gunze has collected about you in the past twelve months.  Depending on the type of request you submit, we will need to verify your identity to a reasonable degree of certainty or a reasonably high degree of certainty. 

• If you are not a Gunze account-holder, we will attempt to verify your identity by matching information that you provide to us with information that we have on file for you.  This may include your name, email address, phone number . . .  For Requests to Know the specific pieces of information that Gunze has collected about you, we may also require you to submit a signed declaration under the penalty of perjury stating that you are the consumer whose Personal Information is the subject of the request. 
• If you maintain a password-protected account with Gunze, we will ask you to verify your identity through your account.

If Gunze is able to verify your identity, we will respond to your Request to Know by: (a) providing the requested information; or (b) explaining why the CCPA does not require us to provide the requested information.  If Gunze is unable to verify your identity, Gunze will respond by explaining why it cannot verify your identity.

We will confirm receipt of your Request to Know within 10 business days and will respond to your request within 45 days. If a response requires additional time, we will notify you of the basis for the delay and may extend our response period up to an additional 45 days.  If the CCPA requires us to provide the information requested, we will provide the information free of charge and in a readily useable portable format.  We have no obligation to provide Personal Information to you more than twice in a 12-month period.  If a request or series of requests are manifestly unfounded or excessive, we may charge a reasonable fee for processing the request(s), or may refuse to process the request(s).

d. Submitting “Requests to Opt-Out”

California residents may opt out of the sale of some or all of their Personal by emailing Gunze at medical@gunze-usa.com. 

Within 15 business days of receiving a Request to Opt-Out, Gunze will:

• Not sell your Personal Information unless and until you subsequently provide express authorization for the sale of your Personal Information.
• Notify any third parties to whom we sold your Personal Information after we received your Request to Opt-Out but before we complied with the request, and instruct them not to sell your Personal Information.
• Not ask for permission to sell your Personal Information for 12 months after receiving the Request. 

California residents who have opted out of the sale of their Personal Information may opt back into the sale of their Personal Information by emailing us at medical@gunze-usa.com.

e. Submitting “Requests to Delete”

California residents may submit a Request to Delete by completing the Request to Delete Form by emailing Gunze at medical@gunze-usa.com.  You may request that we delete all or some of your Personal Information.

We will confirm submission of your Request to Delete within 10 business days.  When you submit a request, we will need to verify your identity to a reasonable degree of certainty or a reasonably high degree of certainty depending on the type of Personal Information we have collected about you.

• If you are not a Gunze account-holder, we will attempt to verify your identity by matching information that you provide to us with information that we have on file for you.  This may include your name, email address, phone number . . .    
• If you maintain a password protected account with Gunze, we will ask you to verify your identity through your account.

If Gunze is able to verify your identity, we will respond to your request by (a) deleting your Personal Information and, if applicable, directing any of our service providers to delete your Personal Information; or (b) explaining why the CCPA does not require us to delete your Personal Information.  Gunze may choose to delete Personal Information by de-identifying, aggregating, or completely erasing the information.  We will specify the manner in which we delete your Personal Information. 

If a request or series of requests are manifestly unfounded or excessive, we may charge a reasonable fee for processing the request(s), or may refuse to process the request(s).

f. Authorized Agents

California residents may submit Requests to Know, Requests to Opt-Out, and Requests to Delete through an authorized agent.  Unless the agent provides Gunze with a power of attorney executed by the California resident, Gunze may require the California resident to verify their identity with Gunze and/or to provide Gunze with written confirmation of the agent’s authority to make the request.

g. Minors

Gunze does not have actual knowledge that it sells the Personal Information of minors under 16 years of age.

CALIFORNIA ONLINE PRIVACY PROTECTION ACT NOTICE

On September 27, 2013, California enacted A.B. 370, amending the California Online Privacy Protection Act to require website operators like Gunze to disclose how they respond to "Do Not Track Signals"; and whether third parties collect personally identifiable information about users when they visit Gunze.

(1) Gunze does not respond to "do not track" signals.

(2) Gunze does not authorize the collection of personally identifiable information from Gunze users for third party use through advertising technologies without separate member consent.

ADDITIONAL POLICIES

SECURITY

We have put in place appropriate physical, electronic, and managerial procedures and security precautions to protect the security and integrity of your Personal Information in accordance with this policy and applicable law. However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties that breach our reasonable security procedures.

THIRD PARTY ACTIVITY (INCLUDING LINKS NAD COOKIES)

The Service may contain links to other websites, cookies or other materials from, or which may be operated by, parties other than Gunze, whose information practices may be different than ours. Gunze is not responsible for the privacy practices, the content or the actions of those third parties. This Privacy Policy applies solely to information collected by Gunze in connection with the Service.

RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information in accordance with the appropriate statutory limitation periods as provided by local law, or in other cases, for as long as such personal data is needed for the following reasons:

• as required by law or court order;
• as needed to defend or pursue legal claims;
• in line with industry codes of practice; and/or
• as required for legitimate business purposes.

AMENDMENTS

Gunze may modify or amend this policy from time to time. If we make any material changes, as determined by Gunze, in the way in which Personal Information or Web Tracking Information is collected, used or transferred, we will notify you of these changes by modification of this Privacy Policy, which will be available for review by you at the Service. Notwithstanding any modifications we may make, any Personal Information and Web Tracking Information collected by Gunze from you will be treated in accordance with the privacy policy in effect at the time information was collected, unless we obtain your consent otherwise.

COMPLAINTS

In the event that you wish to make a complaint about how we process your Personal Information, please contact us in the first instance at medical@gunze-usa.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to raise a complaint with a relevant supervisory authority in the country in which you live or work, where you think we have infringed information protection laws.

ACCESSIBILITY

Any person with a disability that prevents or restricts them from accessing this Privacy Policy through the Apps or through Gunze’s website may request a copy of the Privacy Policy in an alternative format by contacting Gunze at [email] or [phone]

CHILDREN

The Children’s Online Privacy Protection Act imposes certain requirements on website operators that have actual knowledge that they collect personally identifiable information from children under 13 years of age.  Gunze does not knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of the Service is directed at persons under 13. If you are under 13 years of age, then please do not use the Service. If Gunze learns that personally identifiable information of persons less than 13 years of age has been collected without verifiable parental consent, then Gunze will take the appropriate steps to delete this information. To make such a request, or if you have any questions or concerns about the Privacy Policy for the Service or its implementation, please contact us at medical@gunze-usa.com.

SERVICE VISITORS FOM OUTSIDE THE UNITED STATES

Gunze and its servers are located in the United States and are subject to the applicable state and federal laws of the United States. Those who choose to access the Service do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Service’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. We do not represent or warrant that the Service, or any part thereof, is appropriate or available for use in any other jurisdiction. If you choose to access or use the Service, you consent to the use and disclosure of information in accordance with this privacy policy and subject to such laws.