CTM Privacy Policy
Update effective date: November 9, 2023
 

CTM Biomedical, LLC and its affiliates (“CTM“, “Us” or “We“) develops and creates Connective Tissue and ExtraCellular Matrix (ECM) structural implants designed to cover or protect tissues intra-operatively and to augment or replace damaged or inadequate tissue at the surgical site.

This privacy policy (the “Privacy Policy”) describes CTM’s collection, use, and disclosure of the information collected from visitors to www.ctmbiomedical.com website ("Site") and in the ordinary course of business, including the sale of our products.. By accessing and using the site and/or services, you expressly consent to our collection, storage, use and disclosure of your information as described in this Privacy Policy.

CTM is engaged primarily in business-to-business (“B2B”) sales. As a result, we treat all Personal Information (as defined herein) covered by this Privacy Policy, including information about visitors to our website, as pertaining to individuals acting in their capacity as business representatives rather than in their personal capacity. However, if during the course of providing services we receive: (1) consumer Personal Information; or (2) B2B data treated as Personal Information under the California Laws, this Privacy Policy describes how we process such information.

This Privacy Policy does not apply to the practices of third parties that CTM does not own or control, or to individuals that CTM does not employ or manage. By voluntarily providing us with Personal Information, you are consenting to our use of it in accordance with this Privacy Policy.

What types of information does CTM collect about its users?

Personal Information. “Personal Information” is information that identifies or can be used in conjunction with other readily accessible information to identify such individual, including name, title, company name, job function, expertise, postal address, telephone number, or email address. If you submit any Personal Information relating to other people to us or to our service providers in connection with the Sites, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Other Information. “Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. This might include, for instance, browser and device information; App usage data; information collected through cookies, pixel tags, and other technologies; pages visited; content downloaded; demographic information and other information provided by you; or aggregated information. We use this information to facilitate our operation of the Sites and for other purposes described below.

“California Information” means all Personal Information that relates to residents of California and that is covered by the California Consumer Privacy Act (as amended by the California Privacy Rights Act or otherwise), the California Online Privacy Protection Act, or any other applicable California privacy or data protection law, including any amendments thereto (collectively, the “California Laws”).

How does CTM collect information?

Personal Information. We and our service providers may collect Personal Information in a variety of ways, including without limitation:

  • Through the Sites: We may collect Personal Information through the Sites, e.g., when you register for a webinar, contact us, subscribe to our email newsletter, submit an order, download content (e.g., whitepapers), or register to use our Sites.
  • Offline: We may collect Personal Information from you offline, such as when you attend one of our events, during phone calls with sales representatives, or when you contact customer service.
  • Through You: CTM may collect information such as your name, job title and preferred means of communication when you voluntarily provide it. Note that there is no legal obligation for you to provide us with Personal Information, and any information collected by us will be provided by you at your own will and with your consent.
  • Information From Other Sources: In order to enhance our ability to provide relevant marketing, offers, and services to you, we may obtain information about you from other sources, such as public databases, joint marketing partners, and social media platforms, as well as from other third parties.

Other Information. We and our service providers may collect Other Information in a variety of ways, including:

Through Your Browser or Device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Sites (such as the Apps) you are using.

Through Cookies and Other Similar Technologies: We may use a technology called “cookies” in operating and managing the Site. A cookie is a piece of information that the computer that hosts the Site gives to your browser when you access the Site. Our cookies help provide additional functionality to the Site and help us analyze usage of the Site accurately. On most web browsers, you will find a help section on the toolbar. Please refer to this section for information on how to receive notifications when you are receiving a new cookie and how to turn cookies off.

CTM also uses web analytics services, which use cookies and similar technologies to analyze how users use the Domains. The information generated about Domain usage (including your shortened IP address) is transmitted to the service and is used to evaluate visitors’ use of the Domain, compile statistical reports on Domain activity, and provide other services related to the Site and Internet use. Such services may also collect information about Domain visitors’ use of other websites.

How does CTM use and disclose Personal Information?

How does CTM use and/or disclose Personal Information?

  • To respond to your inquiries and fulfill your requests, such as to send you sales enablement content, price lists, sales intelligence, etc.
  • To send administrative information to you, for example, information regarding the Sites and changes to our terms, conditions, and policies.
  • To communicate with you and provide you with related customer service.
  • To send you marketing communications that we believe may be of interest to you and the business with which you are associated. For example, we may send materials related to webinar events, CTM attendance at conventions, product information, etc.
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Sites and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
  • As we believe to be necessary or appropriate: (a) under applicable law, that may include laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including without limitation public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect CTM rights, privacy, safety or property, and/or those of our employees, our agents, our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Information about our users is an integral part of our business. We only share your Personal Information as described in this Privacy Policy.

AGENTS AND SERVICE PROVIDERS:

We contract with other companies and people to perform tasks on our behalf and may share your Personal Information with them to provide products or services to you, or to otherwise communicate with you, such as to provide marketing or offers on our behalf. Examples may include removing repetitive information from customer lists, analyzing data, providing marketing assistance, and performing analysis related to our products or services. We may also provide your Personal Information to agents and service providers to verify or compile aggregate usage data that we provide to our partners. When we share this information in this way, we seek to require the agent or service provider to maintain the privacy, confidentiality and security of the Personal Information.

CTM BLOG AND SOCIAL MEDIA PAGES:

Personal Information may also be disclosed by you through the Sites, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including, without limitation, our CTM Blog, and the Social Media Pages). This information may appear in public ways, such as through search engines or other publicly available platforms and may be “crawled” or searched by third parties. Please do not post any information that you do not want to reveal to the public at large.

How does CTM use and disclose other information?

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.

In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we do, we will treat the combined information as Personal Information for as long as it is combined.

How does CTM secure Personal Information about me?

CTM does not manage or maintain on-premise servers to store data related to Its business, including Personal Information Accordingly, Personal Information collected by CTM may be transferred to third parties designated by CTM (including, but not limited to, any affiliates, distributors, sub-contractors or vendors engaged by CTM to perform administrative and technological functions) for any purposes for which CTM could use such Personal Information. However, CTM requires third parties to (a) limit the use of Personal Information to the purposes for which It was collected, and (b) take commercially reasonable steps to ensure that Personal Information is processed in a manner consistent the standards set forth in this Privacy Policy and the relevant privacy and security laws.

Nonetheless, to the limited extent that Personal Information is stored locally by CTM, we have implemented organizational, technical, and administrative measures to protect Personal Information within our organization, including security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Information from loss, misuse, interference and unauthorized access, modification and disclosure, you should be aware no security procedures or protocols are ever guaranteed to be 100 percent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Information online.

How can I correct or remove information about me?

If you feel that any Personal Information about you that has been collected and stored by CTM (or its service providers) is incorrect, or if you would like Personal Information about you to be removed from our systems, (or our service providers' systems) please notify us at privacy@ctmbiomedical.com so that we may consider and respond to your request in accordance with applicable law. You may also request access to your Personal Information held by CTM, by sending a written request to privacy@ctmbiomedical.com.

For your protection, we may only respond to requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before reviewing your request. We will try to satisfy your request as soon as reasonably practicable, subject to applicable law.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

For how long will CTM retain my Personal Information?

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

What choices do I have?

Text message communications: We use text messaging to communicate with you about your business. Normal messaging rates apply, and the frequency of messages may vary. Mobile Carriers are not liable for delayed or undelivered messages.

Opt-out of text message communications: You may opt out of text messaging at any time by replying to any message with STOP. This will end the communications from that phone number. You may continue to receive service-related and other non-marketing text messages from other phone numbers managed by CTM, and you may opt out of those in a similar fashion.

You may opt out of receiving marketing messages from CTM by emailing privacy@ctmbiomedical.com or by unsubscribing through the unsubscribe or opt-out link in an email sent by us. You may continue to receive service-related and other non-marketing emails.

Cookies: Most browser settings let you delete and reject cookies placed by websites. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, you may not be able to use all functionality of the Service and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit https://www.allaboutcookies.org.

Choosing not to share your Personal Information. Where we are required by law to collect your Personal Information, or where we need your Personal Information to provide the service or product to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services or products. We will tell you what information you must provide to receive the service or product by designating it as required at the time of collection or through other appropriate means.

Third-party sites

The Sites may permit you to link to other websites on the Internet through direct links or through applications such as “share” or “Like” buttons, and other websites likewise may contain links to the Sites. The information practices or content of such other websites is governed by the privacy statements of those websites and not by this Privacy Policy. We encourage you to review the privacy policies found on such other websites, services, and applications to understand how your information may be collected and used by such websites.

Similarly, please note that we are not responsible for the collection, use and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, Blackberry, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or the Social Media Pages.

Children

This Site is not Intended for children under 13 years of age. However, If a parent or guardian of a child who Is under 13 years of age discovers that Personal Information of such child has been submitted to CTM through the Site without the parent's or guardian's consent, CTM will use commercially reasonable efforts to remove such Information from the Site and the relevant servers at the parent's or guardian's request. To request removal of such Personal Information, the parent or guardian must contact CTM at privacy@ctmbiomedical.com.

California Residents

CTM does not sell or share any California Information. A comprehensive description of CTM's online practices pertaining to California Information, and an explanation of the rights afforded to California residents pursuant to the California Laws, can be found at the following link: California Privacy Disclosures. CTM does not discriminate against California residents for exercising any right of such resident under the California Laws, except as permitted under the California Laws.

Changes to this Privacy Policy

CTM may amend this Privacy Policy from time to time. The “Effective Date” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Sites. Your use of the Sites following these changes means that you accept the revised Privacy Policy.

Contact Information

Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and handle your information, please contact us by email at privacy@ctmbiomedical.com or by mail at CTM HQ, 2 Bloor St W, Suite 2005, Toronto, ON M4W 3E2.

ATTN: Privacy Group. Because email communications are not always secure, please do not include credit card information or other sensitive information in your emails to us.

CTM will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.