Notice at Collection and Privacy Notice for California Residents
Last updated: May 30, 2024
NOTICE AT COLLECTION FOR CALIFORNIA RESIDENTS
This Notice at Collection is provided pursuant to the California Consumer Privacy Act, as amended
by the California Privacy Rights Act (collectively, the “CCPA"). It applies to California residents andprovides details regarding the types of personal information that Aspen Surgical Products, Inc.
(“Aspen Surgical,” “we,” or “us”) collects, and how we use that information, when an individual whenaccesses, uses, or interacts with our website.
Categories of personal
information about consumers tobe collected. * ***No sensitive personal
information about consumers
will be collected.
**None of the information
described in this Notice atCollection is “sold” or “shared”(as those terms are defined bythe CCPA).
The business purposes for which
the above categories ofpersonal information arecollected and used.

••

•
•

•
•
•

•

Identifiers and personal information, such as:
unique personal identifier, online identifier, IPaddress; if you fill out a “Contact Us” or similar
form, a real name, alias, postal address, emailaddress, phone number; if you use the website
to log into our application, your username andpassword.
Internet activity, such as unique personalidentifier, browsing history, search history,
information on a consumer’s interaction with a
website, application, or advertisement,
including page views and clicking tendencies.
Providing and optimizing your experience on
our website and ensuring that our content ispresented to you in the most effective manner.
Communicating with you and responding to
your inquiries about our solutions, including toprovide you with promotional andinformational communications regarding oursolutions, informing you about new solutions,
updating you about changes to our solutions,and investigating any concerns you haveabout our solutions or your interactions with us.
Fulfilling transactions with your company.
Engaging in analytics regarding use of oursolutions by users for the purposes of marketing
to current or potential customers.
Developing, updating, and improving oursolutions, customer service, customer
experience, and marketing efforts, andotherwise improving our knowledge andinsights regarding customers.
To help maintain the safety, security, andintegrity of our website.

Preventing and detecting fraud, hacking
activities, security breaches, and otherunlawful activities in connection with oursolutions.
• Enforcing our agreements and complying with
our legal or regulatory obligations.
Aspen Surgical will retain the personal information
it collects and uses so long as it has a legitimate
business need to do so, or as required by law(e.g., for tax, legal, accounting, or otherpurposes), whichever is the longer.
•The criteria used by Aspen
Surgical to determine the periodof time such personal
information will be retained

To learn more about our online and offline practices in connection with the collection, processing,and disclosure of personal information relating to California residents, continue to read our Privacy
Notice below.
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Aspen Surgical understands the importance of your privacy and we take our responsibility to protect
your information seriously. This Privacy Notice for California Residents (“Notice”) supplements theinformation in our website privacy policy and applies solely to “consumers” as defined by the CCPA.
This Notice explains our online and offline practices with respect to the collection, processing, anddisclosure of “personal information” relating to California consumers. Any terms defined in the CCPA
have the same meaning when used in this Notice. Please read this Notice carefully before sharing
information with us so you understand our practices regarding your information. This Notice is limited
to our activities when we are acting as a “business,” as defined by the CCPA.
Personal Information We Collect and Disclose
As defined by the CCPA, “personal information” includes any information that identifies, relates to,describes, references, is reasonably capable of being associated with, or could reasonably be linked,directly or indirectly, with a particular California consumer, household, or device. Personal
Information does not include:••••

Publicly available information from government records or that Aspen Surgical has areasonable basis to believe a consumer lawfully makes available to the general public;
Deidentified or aggregated consumer information;
Medical or protected health information covered by the HIPAA or the California
Confidentiality of Medical Information Act; orInformation collected as part of a clinical trial.

In the past 12 months, we have collected the following categories of personal information from
California residents and disclosed such information to the following categories of third parties forbusiness or commercial purposes.

Category

ExamplesPersonal
information
categories in
California’sConsumer
Records
statuteName, address, telephone
number, facility name,signature

IdentifiersName, postal address, IPaddress, other online
identifier, email address,
account number

Internet or
similarnetwork
activity
Commercial
information

Information relating to yourinteraction with our website
or applications, browsing
history, search history
Purchasing or consuming
histories, records of personal
property, products andservices purchased

Sensory
information

Audio, voicemail

Categories of Third Parties to Whom
Disclosed• IT and cloud/hosting service
providers, such as our email
provider, business application
providers, hosting providers,managed services providers, andIT consultants• Event hosting and registration
service providers• Financial institutions and payment
processors• Governmental entities or otherparties where in response tolegally binding requests, such as
to comply with a subpoena• Delivery or courier providers• IT and cloud/hosting service
providers, such as our email
provider, business application
providers, hosting providers,managed services providers, andIT consultants• Event hosting and registration
service providers• Financial institutions and payment
processors• Governmental entities or otherparties where in response tolegally binding requests, such as
to comply with a subpoena• Delivery or courier providers• IT and cloud/hosting service
providers.
• Online analytics and advertising
service providers• With service providers that assist us
with managing our customer
relationships (including our hosted
customer relationshipmanagement software provider),communications with customers
and those who inquire about ourbusiness, contract fulfilment, andproduct support• IT and cloud/hosting service
providers, such as our email

provider, business application
providers, hosting providers, andtelephone communication
providers
From time to time, Aspen Surgical may be required to disclose your information to governmental
authorities for the purpose of complying with applicable laws and regulations or in response to legal
process. We may also disclose your personal information to third parties in connection with the sale ofour business or assets, or any merger or similar corporate matter, when your personal information ispart of the assets involved in such transaction. Finally, we may “aggregate” or “deidentify”
information from you pursuant to the CCPA, in which event the information is no longer “personalinformation.”
Category of Sources of Personal Information
Aspen Surgical collects these categories of personal information from the following sources:•Direct collection: We collect information directly from you when you choose to provide it to us
by filling out forms on our website, registering to use any of our services, creating an accountor completing the details of any profile using the services, reporting a problem with theservices, signing up to receive emails or information from us, communicating with us,purchasing our services or products or otherwise engaging in transactions with us, attending
an event or presentation, visiting our offices, or otherwise directly providing the information tous.

•Indirect and technology-based collection: We also collect certain information from you
indirectly when you visit, use, or navigate our website. Aspen Surgical collects certain
identifiers (such as IP addresses) and internet and similar network activity (such as website
usage data) from you indirectly using cookie, pixels, and passive tracking technologies, as
described in our website privacy policy.

•Third-party collection: From time-to-time, we may obtain invitee lists for events that we are cohosting with other companies or in which we participate.

Business or Commercial Purposes for Collecting and Disclosing Your Personal Information
We use the personal information that you provide us, or that we collect about you, for the following
business and commercial purposes.
•••••

To present our website and its contents to you.
To provide you with information, products or services that you request from us or that we arecontracted to provide to you.
To carry out our obligations and enforce our rights arising from any contracts entered into
between you and us, including for billing and collection.
To notify you about changes to our website or any products or services we offer or provide
through it.
To fulfill any other purpose for which you provide it, such as subscribing you to an e-mailnewsletter.

•••
•
•••
••

To communicate with you regarding products you may have purchased from us.
To allow you to participate in interactive features on our website, if any.
To comply with applicable laws, regulations, and legal process.
To keep a record of our transactions and communications.
As otherwise necessary or useful for us to conduct our business, provided the use is permitted
by law. For example, analyzing audience and use patterns from the websites; storing
information about your preferences and allowing us to direct or customize specific content toyou; recognizing you when you return to our websites.
To protect our rights, privacy, safety, operations, or property.
For any other purposes with your consent.
In any other way we may describe when you provide the information.
As otherwise described in our website privacy policy.

Sale or Sharing of Personal Information
Aspen Surgical has not sold or shared for cross-contextual behavior advertising (as defined by theCCPA) any categories of personal information to third parties in the past 12 months. Likewise, we docollect personal information regarding minors under 16 years of age and, accordingly, do not haveactual knowledge of any sales of such information.
Please note, however, that we may also use, disclose, or transfer your information in connection withthe sale, merger, dissolution, restructuring, divestiture, or acquisition of our company or its assets.
Sensitive Personal Information
Aspen Surgical does not collect “sensitive personal information” about consumers (including job
applicants or independent contractors) for the purpose of inferring characteristics about them.
Accordingly, Aspen Surgical treats any such information as “personal information” pursuant to theCCPA.
Applicable Retention Periods
Aspen Surgical retains personal Information relating to consumers for as long as necessary to fulfill thepurpose for which it was collected or as required to comply with legal obligations. At the end of that
period, or as dictated by its document retention policy, Aspen Surgical will securely delete thepersonal information. If there is any data that we are unable, for technical reasons, to delete entirely
from our systems, we will put in place appropriate measures to prevent any further use of such data.
Your Rights Under the CCPA
Subject to exceptions, the CCPA provides California residents with the rights discussed below. For
convenience, and as required by the CCPA, we explain how you can exercise those rights, to theextent they are applicable.
1. Right to Request Access Information. You have the right to request that we disclose certain
information about our collection and use of your personal information during the past 12months. Specifically, you may request that we disclose:

•
•
•
•
•
•

The categories of personal information we collected about you;
The categories of sources for the personal information we collected about you;
The business and commercial purposes for collecting your personal information;
The categories of third parties to whom we disclose your personal information;
The specific pieces of personal information we collected about you; andIf we disclosed your personal information for a business purpose, the categories of personal
information received by each category of third party.

2. Right to Data Portability. You have the right to request that we provide copies of the specificpieces of personal information we collected about you. If a verifiable consumer request ismade, and subject to any exceptions or limitations under the CCPA, we will take steps todeliver the personal information to you either by mail or electronically. If we provide theinformation to you electronically, it will be in a portable and readily useable format, to theextent technically feasible. Note: consistent with the CCPA, we will not provide copies of yoursocial security number, driver’s license number, other government-issued identification
number, financial account number, health or medical identification number, accountpassword, or security questions or answers in response to a CCPA request.
3. Right to Request Deletion. You have the right to request that we delete personal information
we collected from you, subject to any exceptions or limitations under the CCPA.
4. Right to Correct Inaccurate Information. If we maintain inaccurate personal information about
you, you have the right to request that we correct that inaccurate personal information,taking into account the nature of the personal information and the purposes of the processingof the personal information.
Consumers in California also have the right to opt-out of (a) the sale of personal information, or (b)the sharing of their personal information for the purposes of cross-context behavioral advertising (asdefined in the CCPA). California consumers also have the right to limit the use or disclosure ofsensitive personal information by the business if such information is used or disclosed for certain
purposes, as required by the CCPA. Because Aspen Surgical does not engage in any of theforegoing activities, these rights are not available.
Exercising Your Rights
To exercise the rights described above, you—or someone authorized to act on your behalf—must
submit a verifiable consumer request to us by calling us at 888-364-7004 or sending an email to
CAPrivacy@aspensurgical.com. Your request must allow us to reasonably verify that you are theindividual regarding whom we collected the personal information and must describe the request
with enough detail that we can understand and respond to it. Specifically, so we may verify yourrequest, you must provide your name, address, phone number, email address, and the name of theorganization, business, or facility at which you work (if applicable), as well as a description regarding
the methods you believe you used to submit personal information to Aspen Surgical. To confirm thatyou are a resident of California, we may require you to provide proof of your residency. For requests
made by an authorized representative, the representative will be required to provide the foregoing
information together with proof of authorization, which may include an authorization form signed by
the consumer. Depending on the nature of your request, we may ask for additional information to
verify your identity. If you do not provide the requested information, we will not be able to respondto your request or provide you with the personal information requested. Please do not provide social
security numbers, government identification numbers, payment card information, bank accountinformation, or any similar information as part of your request.
You may only submit requests for access or data portability twice within any 12-month period. We will
only use the personal information provided in a consumer request to verify a requestor’s identity orauthority to make the request. As indicated above, please be aware that the CCPA provides
certain limitations and exception to the foregoing rights, which may result in us denying or limiting our
response to your request.
Response Timing and Format
The CCPA requires us to respond to a verifiable consumer request within 45 days but permits us toextend that period by an additional 45 days, provided we notify you of the reason for the extension
in writing. We will notify you that we have received your request within 10 days of its receipt. Ingeneral, we will not charge a fee to respond to a verifiable request, unless it is excessive, repetitive, orunfounded. We will deliver our written responses to your request via email. Any disclosures weprovide will only cover the 12-month period preceding the date of your request, provided that you
may request disclosure beyond the 12-month period. The response will also explain the reasons wecannot comply with a request, if applicable. For data portability requests, we will select the format ofour response; the format will be readily usable and should allow you to transmit the information fromone entity to another.
Our Commitment Not to Discriminate
If a California consumer exercises the rights discussed above, consistent with the CCPA, we will notdiscriminate against that individual by denying goods or services, charging different prices or rates forgoods or services, providing different levels or quality of goods or services, or suggesting that theresident will receive a different price, rate, or quality of goods or services.
Changes to this Notice
Please note that we may change this Notice from time to time. We will post change here andupdate the “Last Updated” date at the top of this document. Continued use of this website after any
changes is deemed to be acceptance of those changes. Please check this Notice periodically forupdates.
Our Contact Information
To contact us regarding this Notice, your rights under the CCPA, or to exercise those rights, pleasecontact us using the information below.
Aspen Surgical Products, Inc.
Attn: Customer Service
Address: 6945 Southbelt Dr SE, Caledonia, MI 49316
Phone: 888-364-7004
Email: CAPrivacy@aspensurgical.com