MOLLI Surgical Inc. Privacy Statement

PRIVACY POLICY
MOLLI Surgical Inc. (“MOLLI”), now part of Stryker’s group of affiliated companies, recognizes that the personal information it receives is held in a position of trust. MOLLI seeks to fulfill that trust by adhering to general principles regarding the protection of personal information. This Privacy Statement explains how we collect, use, share and protect information in the course of operating our business. MOLLI operates the Site from Canada. As such, by using the Site, you are consenting to the transfer to, storage and processing of your Collected Data in Canada.

Scope
This Privacy Statement (“Statement”) applies to the personal information of consumers that is collected or used by MOLLI, as an affiliate or subsidiary of Stryker (collectively, “Stryker,” “we,” “our,” “us”). This Statement applies to all the personal information that MOLLI collects when consumers interact with us, such as when visiting our websites, using, or purchasing our products or services, contacting customer service and when interacting with us as a business customer, supplier, or business partner (collectively, the “Services”).

This includes, without limitation, all online and offline collections of all types of personal information. However, some MOLLI collections involve types of data with special requirements (for example, health information) which require a different privacy notice. Whenever that is the case, MOLLI will make it clear that the privacy notice concerned is different from this Statement.

Collection and Use of Information
MOLLI may ask you to provide personal information for purposes including, but not limited to, the following:

Buying products and services;
Activating or registering certain products and services or enhancing functionality;
Receiving information about products and services;
Participating in online communities
Storing your preferences for future interactions and communications from MOLLI;
Helping us to develop products and services and create campaigns that are designed around you, optimize customer services and continuously improve our websites;
Helping us to improve products and services, and allowing MOLLI to keep you informed of, or involve you in the testing of, new products and services;
Resolving consumer and/or product and services issues;
Registering visitors of facilities or organized events and conferences;
Contract or tender management; and
Receiving personalized messages, special offers and advertisements that are relevant to your personal interests, based on the information you have shared with us and on the information we have collected through cookies or similar techniques regarding your use of the MOLLI websites/social media/blogs.

MOLLI maintains physical, technical, and administrative safeguards to protect your personal information and only allows disclosures as permitted by law to assist in providing products or services. We may also collect product and service information and provide these statistics to others in an aggregate form where the information has been de-identified.

Personal information collected may include:

Contact information, such as name, address, email, telephone number, fax number, organization name, and/or job title;
Unique identifiers and preference information such as username, password, marketing preferences, internet protocol (IP) address, browser type, operating system, computer or mobile device, or navigation and clickstream behavior for online interactions;
Resume or CV, including work history, professional qualifications, publications, awards, references, completed trainings, and signature;
Pictures, video, and audio recordings where you have provided your permission;
Sensitive personal information, such as health information or reports of an individual end-customer (e.g., concerning product claims and investigations, patient pre- and post-operative outcomes for research & statistical purposes, or criminal records for due diligence procedures in accordance with applicable law).

MOLLI will retain and use the personal information collected for above mentioned processes and processing purposes in accordance with legal obligations.

Legal Basis
The legal basis MOLLI uses to process personal information will be dependent on the processing purposes and the jurisdictional legal requirements. in general, we use the following basis:

Consent to use the personal information, e.g., where this involves (digital) direct marketing activities and where we would like to use a photo, video, or audio recording with identifiable individuals for external publishing;
Establishment or performance of a contract, e.g., where we enter into a contract with a party and we collect contact information and signatures, as well as potential bank account details that may be linked to a representative of a company we do business with;
Compliance with a legal obligation, e.g., where we need to disclose consumer details for compliance with (local or industry) laws such as the Medical Device Regulation;
Legitimate interest of MOLLI
Public interest or for the exercise of public authority in strictly limited cases, e.g., where we would be required to cooperate with the police or other government bodies in case of illegal conduct;
For the establishment, exercise or defense of legal claims, e.g., for court cases;
For scientific or research purposes, e.g., for clinical research studies with sufficient safeguards safeguarding confidentiality;
For preventative and occupational medicine, medical diagnosis pursuant to contract with healthcare professionals;
For public interest in the public health to ensure high standards of quality and safety of healthcare and products; and
Where the individual chooses to disclose the personal information publicly by its own initiative.

If you choose not to provide the personal information we reasonably require, it may hinder MOLLI’s ability to provide the information or services you have requested.

Cross-Border Transfers
To the extent personal information is transferred out of the country where the owner of that personal information lives, such as to MOLLI affiliates or business partners in other countries, including in the United States, different standards may apply to how your data is used and protected in those countries. MOLLI has appropriate safeguards in place in accordance with applicable legal requirements to ensure that data is adequately protected irrespective of the country. This includes obtaining written assurances from any third party given access to your data so as to require them to adopt standards that ensure an equivalent level of protection for data as that adopted by MOLLI and standardized corporate safeguards and contractual measures for internal data transfers to MOLLI affiliates in third countries which are deemed to provide an inadequate level of data protection.

Use of Cookies and Tracking Technology
MOLLI collects information indirectly through various types of cookies. Cookies are small text files stored on your device to remember your preferences. MOLLI uses cookies for various purposes, such as monitoring website traffic, maintaining browsing integrity, improving user experience, and other legitimate business purposes, including marketing.

MOLLI uses session cookies and persistent cookies. Session cookies last only for your visit and are deleted when you close your browser, ensuring security and preventing fraudulent use. Persistent cookies remain after closing your browser, allowing us to remember your actions and preferences, and to analyze site visits to improve the online experience.

While you can disable cookies, certain site features require them to function correctly and securely. Your browser may allow you to refuse or delete cookies, but doing so may restrict access to some site features. Information collected by cookies may include personal information, such as IP addresses linked to you.

Use of Google Analytics
The Site uses Google Analytics, a web analysis service provided by Google, to carry out analytics on the Site. Google Analytics may collect and process your Personal Information for its use in the course of providing its services to us. Google also uses the data it collects from your web browser, which may include demographic information, to prepare reports that it shares with other Google services. Google may use the data collected to contextualize and personalize ads of its own advertising network. Google collects cookie and usage data and processes such information in the United States. For more information on Google’s use of information collected through Google Analytics, including how to opt out of Google Analytics data collection, please see “How Google uses information from sites or apps that use our services” (www.google.com/policies/privacy/partners/), Google’s privacy policy (http://www.google.com/intl/en/policies/privacy/), and Google’s instructions on installing the “Google Analytics Opt-out Browser Add-on” (https://tools.google.com/dlpage/gaoptout).

Disclosure of Information
MOLLI may share personal information we have collected with companies or agents doing technological maintenance or working on our behalf to help fulfil business needs, including providing customer services and distributing marketing communications. MOLLI may also share personal information with our subsidiaries and affiliates.

Other service providers that may be used to perform certain functions on our behalf and to whom personal information may be disclosed in order to perform their intended function include call-center support, sending or processing postal or electronic mail or analyzing or hosting information on cloud-based servers.

MOLLI does not share your personal information with unaffiliated third parties for their own direct marketing purposes.

If you do not want us to share your data, you can opt out by following the instructions below.

Rights
You may request details of personal information which we hold about you. If you believe that any personal information we are holding about you is incorrect or incomplete, please contact us as soon as possible, at the address below. We will promptly correct any personal information found to be incorrect.

You may always choose to object to the collection or use of your personal information or to have your information erased. If you would like a copy of the information held about you for your own use or to transfer to another party, or if you wish to exercise any other right, please contact us using the contact information listed below.

Newsletter
You have the option to opt in to receive our electronic newsletter by completing a form on our Site. MOLLI will only send the electronic newsletter to you once we have received your completed form and your consent. If you change your mind, you can unsubscribe through a link in the email delivering the newsletter.

California Residents
This privacy section for California Residents details the privacy practices of MOLLI and its affiliates regarding the personal information of California residents. It covers information collected through interactions with MOLLI, such as visiting websites, purchasing products or services, and contacting customer service. This section supplements the general Privacy Statement, outlining what personal information is collected, how it is used, and the limited circumstances under which it may be sold or shared. It also explains the retention period for personal information and how consumers can manage cookies and opt-out preferences. Cookies, which are small text files stored on your device, help remember preferences and support site functionality, and opting out of targeting cookies can limit the sale or sharing of personal information for advertising purposes.

MOLLI collects various categories of personal information, including identifiers, customer records, and internet activity. Information is obtained from multiple sources, such as direct interactions, device data, and third-party services. Personal information is used for purposes like delivering services, improving products, and complying with legal obligations. Disclosure of personal information is limited to circumstances like obtaining consent, sharing with affiliated companies, and complying with legal requirements. California residents have rights to know, correct, delete, and opt-out of the sale or sharing of their personal information. To exercise these rights, verified requests must be submitted by providing details such as name and email address for identity confirmation.

Please see the contact section below for more information on how to submit a request and exercise your rights. Updates to the Notice will be posted on the website.

Safeguards
MOLLI has physical, technical, and administrative controls in place to protect your personal information from unauthorized access, use and disclosure. MOLLI evaluates these safeguards on an ongoing basis to help minimize risks from new security threats as they become known.

Updates to Privacy Statement
This Statement may be amended at any time. If material changes are made in how personal information is collected, used, disclosed, or otherwise processed, this Statement will be updated, and notices will be provided when/where appropriate. Any material changes to this Statement will be effective at the time of our posting of the notice of the update. Where required to do so by law, MOLLI may seek your prior consent to any material changes we make to this Privacy Statement.

Contact Information
If you have any questions or complaints, desire additional information, or need to notify MOLLI of anything regarding any Collected Data or otherwise relating to this policy, please promptly contact MOLLI as follows:

MOLLI Surgical Inc.
22 St. Clair Avenue, Suite 1500
Toronto, Ontario M4T 253
Canada

-or-

info@mollisurgical.com

Please note that MOLLI is likely to require not less than 30 days to investigate and respond to your complaint. Upon MOLLI’s completing such investigation, we will contact you to see if together we can find a path to resolving your complaint. If any aspect of your complaint remains unresolved after 30 days, you have options which include making a complaint to the applicable privacy authority (in most cases, the Office of the Privacy Commissioner of Canada). You hereby agree that any litigation against MOLLI in connection with its management of Collected Data will be brought exclusively in a court located in Toronto, Ontario, Canada, with jurisdiction over your complaint. You consent to any such court’s being, and waive any objection (including, but not limited to, any such objection based on inconvenience) to such court’s not being, a proper venue for your complaint.

© 2022 MOLLI Surgical Inc. All rights reserved. For illustrative purposes only and subject to change without notice. Please contact MOLLI Surgical Inc. for information on regulatory clearance status in your jurisdiction. MOLLI and MOLLI Precision Surgery Made Simpler are trademarks of MOLLI Surgical Inc., registered in the United States Patent and Trademark Office and the European Union Intellectual Property Office.