Privacy Policy
Effective Date: December 10, 2020
Scope
Pulse Biosciences, Inc. (“Pulse Biosciences”, “we”, “our”, or “us”) is committed to protecting and maintaining your privacy. This Privacy Policy describes how we use, disclose, transfer, and retain information about you that we collect when you visit our websites (collectively, the “Sites”) or when it is shared with us by our business partners and customers. This Privacy Policy does not apply to the practices of companies that Pulse Biosciences does not own or control, or to individuals that we do not employ or manage, including operators of websites that link to or from our Sites.
What information do we collect?
We collect personal information, which is information that can be used to identify or contact an individual person. Personal information under this Privacy Policy can be categorized and is described below.
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Contact information may include your name, personal or business address, email, telephone number, fax number, or business contact information such as an organization name, or job title. Contact information about you may be collected when you visit our Sites or engage us about our products.
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Site interactions information may include information that you have provided or created for identify or preference purposes, such as a username, password, identifiers unique to yourself for our Sites, business or medical practice name, or marketing preferences.
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Site usage information may include information that is collected from you or your device when you engage our Sites, such as an internet protocol (“IP”) address, computer or mobile device name, browser type, operating system, or your navigation and clickstream behavior from actions that you take on our website. Site usage information may not always include personal information but may be combined with personal information that has been collected separately.
Some information, in isolation, may not identify an individual and may not be personal information. However, when that information is combined with personal information about an individual, it may then become part of a data set of personal information related to that individual. When combined in this manner, we will treat the data set as personal information.
How do we collect your personal information?
We collect personal information about you when you visit and use our Sites as well as when you inquire or engage us regarding our services or products. The personal information that we collect about you is that which you choose to share with us in registration, when using our products and services, when responding to offers from Pulse Biosciences, or when responding to offers from our business partners or customers.
How do we use personal information?
Pulse Biosciences will use the personal information we collect about you as permitted by the terms of collection at the time you share your personal information. These terms of collection will be available at that time and we recommend that you review them in advance. The uses of personal information by Pulse Biosciences may include the following:
- Provide information and services requested, and market products that may be of interest to you.
- Determine eligibility for certain products, programs and services.
- Conduct processing necessary to fulfill contractual obligations for customers or individuals.
- Understand and assess the ongoing needs of our customers.
- Deliver customer and other business communications.
- Administration of services, billing, and operations.
- Conduct analysis to understand how the Sites are used.
- Perform market research.
- Operate, administer, analyze performance, and serve the functioning of the Sites.
- Comply with applicable laws.
- Enforce our Terms of Use and contractual agreements.
From time to time, to the extent permitted by the terms of collection, we may request to collect additional personal information.
Do we share your personal information with third parties?
Pulse Biosciences shares your personal information with third parties only to the extent that you have been informed of the sharing when we collect the personal information. In those instances, you may “opt-out” and direct us not to share your personal information with third parties or you may “opt-in” to allowing us to share your personal information with third parties. Examples of third party sharing of personal information for which we engage include:
- You consent, or “opt in”, to the collection of your personal information by Pulse Biosciences and you also agree that your information may be shared with third parties.
- You have responded to an offer by a third party on the Pulse Biosciences Sites and consent.
- You direct us to enter you in a contest.
- You direct us to sign you up for a service which is sponsored by one of our partners.
- You direct us to provide your information to a company we profiled when you “opt in” for their investor kit.
- You otherwise “opt in” to have your information shared with third parties.
- We respond to subpoenas, court orders or legal process.
- We find your actions on our website violate our Terms of Use or any of our usage guidelines for specific products or services (and then only to pursue appropriate action).
- We transfer your information in connection with a sale, merger, transfer, exchange, or other disposition (whether assets, stock or otherwise), of all or a portion of a business of Pulse Biosciences. If, however, as a result of the business transfer your personal information will be used in a new and different manner, then you will have a choice as to whether to allow this new use.
In each of the above situations and similar situations not described above, Pulse Biosciences can no longer update your personal information that has been transferred to such third parties nor opt you out of receiving promotional and/or marketing information from such third parties. Instead, you must contact that third party to update your personal information or to let them know that you no longer want to receive promotional and/or marketing information about their products, services, or offerings.
Does Pulse Biosciences use or share aggregated data?
Pulse Biosciences may collect information regarding customer activities on our Sites, or from our products and services, that is aggregated. Aggregated data may include reports on unique visits, repeat visits, page views, referring URL’s, website usage, and other similar statistics. Aggregated data is not personal information for the purposes of this Privacy Policy and is not associated with your personal information. Aggregated data provides valuable information to Pulse Biosciences about our Sites and users, without identifying individuals. Pulse Biosciences also shares aggregated data with our partners and advertisers.
How do we use tracking technologies?
Our Sites use tracking technologies that provide our Sites certain functionalities, our organization certain insights, and our visitors a more valuable interaction. These tracking technologies may include cookies, web beacons, Javascript, etags, or related technologies, some of which are described below.
- Cookies. When you visit our Sites, we may place pieces of code, commonly referred to as "cookies," or similar technology on your device. A cookie is a piece of programming information contained in a very small text file that is placed in your Internet browser or elsewhere on your hard drive. You can control acceptance of cookies by modifying your Internet browser preferences. You have the ability to accept all cookies, to be notified when a cookie is set, or to reject all cookies. Please note that, if you choose not to consent to all cookies (including essential cookies) you may not be able to access all or part of our site and may be unable to use those services or engage in activities that require the placement of cookies. We use cookies to distinguish you from other users of our website and to help us compile aggregate statistics about usage of our websites.
- Web beacons. Pulse may also use tracking technologies such as web beacons, to collect information about your visits to our Sites. These are small electronic images embedded in web content or e-mail messages and are ordinarily not visible to users. Like cookies, this tracking technology enables us to track pages and content accessed and viewed by users on the Sites. The use of these technologies also helps us to provide you with a positive experience when you browse our Sites, and it also helps refine our content and personalize your experience.
- Google Analytics. Google Analytics uses cookies to collect and store data such as time of visit, pages visited, time spent on each page of our Sites, the IP address, and the type of operating system used in your device. By downloading and using a browser plugin provided by Google you can choose to opt out of Google Analytics. This plug-in is available at: https://tools.google.com/dlpage/gaoptout.
You can control cookies and tracking tools in a manner that is browser and device specific. How you do so will depend on the type of tracking tool. Your browser may give you the ability to control cookies or other tracking tools, such as browsers that can be set to reject browser cookies. However, flash cookies, which we may use on our Sites from time to time, cannot be controlled through your browser settings.
- Do not track. Some web browsers may transmit “do not track” signals to websites with which the browser communicates. These features are not uniform, and we may not respond to those “do not track” signals.
For more detailed information about cookies in general you may wish to visit www.allaboutcookies.org.
If you reside in the European Economic Area (“EEA”), we will obtain your consent before storing cookies on your browser. For more specific information about the development of user profiles and the use of targeting/advertising cookies, please see www.youronlinechoices.eu.
Do we transfer personal information across borders or jurisdictions?
Information that you provide to us may be transferred to or stored upon servers in the United States, Canada, countries within the European Economic Area, and other countries in which we do business. Some jurisdictions may require an approved transfer basis, mechanism, or agreement, such as the European Commission approved standard contractual clauses. Where such a requirement exists, Pulse Biosciences executes such mechanisms or agreements in advance of a data transfer or transfers. In addition, Pulse Biosciences confirms that required safeguards are followed prior to the initiation of a data transfer or transfers.
To request more about the transfer mechanisms, means, and safeguards that we use to transfer personal information across jurisdictions, please contact us with your request at privacy@pulsebiosciences.com.
Security
The security of your personal information is important to us and we employ physical, technical, and administrative measures to reduce the risk, loss, misuse, alteration, or destruction of your personal information. Access to your personal information is managed and restricted. Our service providers and agents are contractually bound to maintain the confidentiality of personal information and may not use the information for any unauthorized purpose. In addition, we train our employees about the importance of privacy and how to handle personal information appropriately and securely.
Children
Our Sites are not directed at children and children are prohibited from using our Sites. By using our Sites, you affirm that you are at least 18 years old. We do not knowingly collect personal information from children, and we are not liable for damages that may result from a user’s misrepresentation of age.
California Residents
California law provides California residents with certain privacy rights. California residents should review Notice to California Residents, found via the link below:
Notice to Individuals Located in the European Economic Area
Pulse Biosciences processes personal information for the purposes and in the manner described in this Privacy Policy. Personal information should be understood to be inclusive of Personal Data, as that term is defined under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).
Information about privacy & data protection for users outside the U.S. and GDPR countries
Legal Basis for Processing Information: We process personal information only when we have a legal basis to do so. The legal basis we will rely upon will be one of the following:
- You have consented to the processing of your personal information. At any time, you can withdraw your consent by contacting us;
- The processing is necessary to perform a contract with you or directly or indirectly on your behalf;
- The processing is necessary to comply with a legal obligation that applies to Pulse Biosciences; or
- The processing is necessary for purposes that are in Pulse Biosciences legitimate interests, such as protecting the security of our Sites, conducting market research to improve our products and services, improving the functioning of our Sites, and providing you with promotional material about our products and services; provided always that such processing is fair, and balanced and that our processing does not unduly impact your rights.
Choice: You can choose not to provide personal information to us. However, if you do not provide personal information when requested, we may not be able to provide you with information about our us, our products, or our services.
Data Subject Rights: You may have certain rights regarding the personal information that we maintain about you, which in certain circumstances, you will be able to exercise. These rights are as follows:
- You may request a copy of the personal information that we maintain about you.
- If your personal information is incorrect, you may request that we correct, amend or delete personal information that is inaccurate or incomplete.
- You may request that we erase or restrict the processing of your personal information if there is disagreement about its accuracy or legitimate usage.
- When our legal basis for processing your information is your consent, you may withdraw your consent at any time.
- You may object to the processing of your personal information in certain circumstances when we (i) process your information for the purposes of our legitimate interests, (ii) use your personal information for direct marketing; or (iii) use your personal information for statistical purposes.
Individuals who desire to make an individual rights request in accordance with the GDPR are directed to make such a request to a Data Protection Officer via an email to privacy@pulsebiociences.com.
Pulse Biosciences does not use personal information for automated individual decision-making, including profiling, in the sense of Art. 22 GDPR.
Pulse Biosciences will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In addition, we may retain personal information for as long as the retention of data can be justified by a legitimate interest in the sense of Art. 6 GDPR.
Changes to this Privacy Policy
We may amend this Privacy Policy from time to time and we encourage you to periodically review this page for updated information on our privacy practices. If we make a material change to the Privacy Policy, we will notify you by posting a notice on our Sites.
Contacting Us
If you have concerns or complaints about the way in which we have handled your personal information, please contact us. We also welcome any questions, suggestions, or requests for further information about this Privacy Policy and our handling of your data. All inquiries should be directed to:
or
Pulse Biosciences, Inc.
Attn: Privacy / Legal
3957 Point Eden Way
Hayward, California 94545