This RPM Surgical Solutions Privacy Policy was updated January 11, 2017
Quality patient care is dependent upon accurate and high quality surgical instrument sets deployed on time in an efficient manner. In an effort to create and maintain such sets, we need to collect and share information relating to a Facility’s inventory. This Privacy Policy outlines the intended uses and restrictions of Facility information.
NOTICE REGARDING
SPD Track is a subscription service platform and integrated suite of technology and services operated by RPM Surgical Solutions, LLC (hereinafter and collectively, “RPM Surgical Solutions”), that allows an entity or facility (each, a “Client,” and collectively, the “Clients”), to interact, collect and share information. Within the service, Clients can access Client data and information and monitor activities that occur at a Client’s premises. The service includes, but is not limited to, the website at http://www.spdtrack.com, any application or program that interacts with third-party websites, and mobile applications, equipment, or devices used to interact with the website (collectively, the “ Platform”). Clients shall utilize their own unique usernames and passwords to access the Platform, and each Client will be granted access to the Platform and information maintained within the Platform in accordance with each such Client’s permissions and credentials. RPM Surgical Solutions values online privacy and strives to maintain appropriate privacy and security of Clients’ information. If you have any questions concerning this Privacy Policy, please contact RPM Surgical Solutions by email.
COLLECTION AND USE OF INFORMATION
Through use and operation of the Platform, RPM Surgical Solutions collects and shares User information with Clients who have a relationship with such User (collectively, a User’s relationship with one or more Clients shall be referred to herein as a “User’s Client List”). This information includes items submitted by Clients and Users, such as name, email address, and employer identity, all of which are used to authenticate the identity of Clients and Users and to send notifications to Clients and Users relating to RPM Surgical Solutions’ services. RPM Surgical Solutions, through the Platform, also collects other profile data of Clients and Users, including, without limitation, job titles, work address, and work URL’s. Use of this information allows interactive communications between Clients and Users.
RPM Surgical Solutions also logs non-personally-identifiable information through the Platform, including, without limitation, IP address, profile information, aggregate user data, and browser type, from Clients, Users, and other visitors to the Platform. This data allows RPM Surgical Solutions to effectively manage the Platform, track usage, and improve Platform services and capabilities. Such non-personally-identifiable information may be shared by RPM Surgical Solutions with third-parties to provide more relevant services and advertisements to Clients and Users. Platform visitor IP addresses, whether for Clients, Users, or others, are recorded for security and monitoring purposes. RPM Surgical Solutions takes extra precautions with respect to the Client and User information it collects and has implemented this Privacy Policy and related security safeguards to protect such information from inappropriate access or use.
In addition to this Privacy Policy and the Terms of Use for the Platform, a Client may also collect and use information provided by Users, and such information may be subject to the terms and conditions or certain other policies and rules that are established and amended, from time to time, by a Client. RPM Surgical Solutions encourages all Users to contact a Client directly to obtain information regarding such Client’s policies governing the collection and use of User information.
Protection of Personal Information
RPM Surgical Solutions takes the security of personal information of a Client and User very seriously. RPM Surgical Solutions utilizes international industry standards for the encryption and security of Client and User information. The availability of information is controlled by and subject to each Client’s and User’s role, permissions and associations within the Platform. User account information is shared only with authorized RPM Surgical Solutions’ administrators, a User’s Proxy (as defined in the Terms of Use), and those Clients included in a User’s Client List. A User’s account information cannot be viewed by any Client that is not included in User’s Client List.
USE OF COOKIES
The Platform uses cookies to store the preferences and record the session information of visitors to the Platform, to customize newsletter, advertising, and web page content offerings based on browser type and User profile information. RPM Surgical Solutions does not link the information stored in cookies to any personally-identifiable information submitted by Users to the Platform. Clients and Users may also be able to configure their browser to accept or reject all or some cookies, or notify them when a cookie is set. However, Clients and Users must enable cookies from the Platform in order to use most functions on the Platform.
LINKS: The Platform may contain links to other websites. RPM Surgical Solutions is not responsible for the privacy policies or practices on such other websites, and Clients or Users will access the content of any other website(s) through such links at their own risk. When linking to another website, a Platform user should read the privacy policies or practices as stated on that website. RPM Surgical Solutions’ Privacy Policy only governs information collected on the Platform. Please be aware that, whenever Clients or Users voluntarily post public information to their profiles or the profiles of other Clients or Users, that information can be accessed by other Clients and Users who contract for Platform access.
ACCESSING AND UPDATING INFORMATION
Other than information that is restricted for editing or removal only by RPM Surgical Solutions, Clients and Users may modify or update their personal information at any time by logging into their account with their unique username and password and accessing features to edit Client or User profile and account information.
SECURITY
Client and User accounts and profiles are secured by unique usernames and passwords established by or assigned to Clients and Users. RPM Surgical Solutions takes precautions to ensure that Client and User account information remains private. RPM Surgical Solutions also uses commercially reasonable measures to protect Client and User information that is stored within its database. A User’s identifiable and credentialing information, as applicable, is shared only with authorized RPM Surgical Solutions’ administrators, a User’s Proxy (as defined in the Terms of Use), and Clients that are included in the User’s Client List. While RPM Surgical Solutions utilizes commercially reasonable security measures and protocols to secure and protect Client and User information, it cannot guarantee the security of any Client or User account information at all times. Unauthorized entry or use of the Platform, hardware or software failure, and other factors may compromise the security of Client or User information at any time. For additional information about the security measures that
RPM Surgical Solutions uses, please contact RPM Surgical Solutions by email.
DISCLOSURE OF INFORMATION BY RPM SURGICAL SOLUTIONS
Except as otherwise described in this Privacy Policy or in the Terms of Use, RPM Surgical Solutions will not disclose personally-identifiable information of a Client or User to any third party without the consent of such Client or User, unless such disclosure is permitted by applicable law or if RPM Surgical Solutions believes that such disclosure is necessary: (1) to conform to legal requirements or to respond to a subpoena, search warrant, or other legal process received by RPM Surgical Solutions, whether or not a response is required by applicable law; (2) to comply with or enforce RPM Surgical Solutions’ Terms of Use for the Platform or to otherwise protect RPM Surgical Solutions’ rights, which may include communications with, or disclosures to, you or your employer to facilitate your continued compliance with the access rights applicable to Clients or Users; or (3) to protect the safety of Clients and Users of RPM Surgical Solutions’ services, or members of the public whose safety may reasonably be deemed to be in jeopardy based on information posted to the Platform. If disclosure of an individual’s personal information is not permitted by applicable law or if RPM Surgical Solutions believes it is necessary to disclose an individual’s personal information for a purpose other than those listed in the preceding sentence, RPM Surgical Solutions will notify such individual of RPM Surgical Solutions’ intent to disclose the information when commercially reasonable. Notification will be made using the contact information provided by the individual to RPM Surgical Solutions via the Platform. Non-personally-identifiable information of a Client or a User collected or generated by RPM Surgical Solutions through the Platform may be shared by RPM Surgical Solutions with third-parties without further notification to or consent from any Client or User.
RPM Surgical Solutions reserves the right to transfer personal information to a successor in interest that acquires rights to that information as a result of the sale of RPM Surgical Solutions or substantially all of its assets to such successor in interest. RPM Surgical Solutions will notify individuals who provided personal information to RPM Surgical Solutions of any acquisition. See the “Changes in Our Privacy Policy” section below for more information.
CHANGES IN OUR PRIVACY POLICY
From time to time, RPM Surgical Solutions may make changes to this Privacy Policy. If RPM Surgical Solutions makes changes, it will post them on the Platform to make Users aware of what the changes are so that Clients and Users will always be aware of what information RPM Surgical Solutions collects, how RPM Surgical Solutions uses and protects information, and the circumstances in which RPM Surgical Solutions may disclose information. Clients and Users are bound by any changes to this Privacy Policy when the Client or User accesses or uses the Platform for the first time after those changes have been posted by RPM Surgical Solutions. If, however, RPM Surgical Solutions plans to use a Client’s or User’s personally-identifiable information in a manner that is materially different from that which is stated at the time such information is collected, RPM Surgical Solutions will post notice of such change on the Platform for a period of no less than 15 days.
CONTACTING RPM SURGICAL SOLUTIONS
If you have any questions or concerns about this Privacy Policy, the Terms of Use, the policies or procedures used to operate and maintain the Platform, or any dealings with the Platform, please contact RPM Surgical Solutions via email. All such communications are examined and replies issued where appropriate as soon as possible.