Privacy Policy

(SI-BONE NON-US PRIVACY POLICY)

Last Modified: May 25, 2018

SI-BONE, Inc. and its affiliates and subsidiaries (collectively, “SI-BONE”) is committed to protecting and respecting your privacy.

This Privacy Policy (the “Privacy Policy”) describes how SI-BONE collects, handles and uses your Personal Information when you access, register and/or use this website (“Website”).

Please read the following carefully to understand our views and practices regarding your Personal Information and how we will treat it.  

This Privacy Policy explains:

  1. The Personal Information we may collect, how it is used and to whom it may be disclosed. 
  2. Where we store and transfer Personal Information, and how long it will be retained.
  3. Your ability to access and control your Personal Information.
  4. The security procedures in place to protect your Personal Information.
  5. How to contact us.
  6. Our practices in relation to revising, updating or changing this Privacy Policy.

Personal Information We May Collect

In this Privacy Policy, “Personal Information” means any information relating to any identified or identifiable individual that is sufficient to identify such person, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity. This website is not intended for children and we do not knowingly collect Personal Information relating to children.

The types of Personal Information we may collect are as follows:

Information You Provide Directly to Us

A user may submit limited Personal Information (such as name and email address) in order to take advantage of certain functionality on our WebsiteSimilarly, you may provide Personal Information if you use social media functions available on our Website or if you report a problem with our Website.

Information We Receive From Other Sources

We may receive Personal Information about you if you use any of the other websites we operate or other services we provide.  We may also work closely with third parties (including, for example, business partners and sub-contractors for technical services, analytics providers such as Google Analytics, or search information providers) and may receive Personal Information about you from them.

We may combine this Personal Information with Personal Information you give to us and Personal Information we otherwise collect about you.

Collection and Use of Other Information About You; Cookies

We collect other Personal Information to help us understand how you use our Website.  For example, each time you visit our Website, we may automatically collect your IP address, browser type, browser, browser language and computer type, access time and date, the web page from which you came, and the web page(s) you access during your visit as well as other web server log files.  This data is collected, in particular, to protect and enhance the operation of our Website and services.

In particular, if access is via a web browser, we may use “cookies” or other local storage -based web tracking technology to store and sometimes track information about users.

A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer's hard drive. Cookies can make use of the web easier by saving status and preferences about a website.  Some parts of our Website that are customizable may require that you accept cookies.  Most browsers are initially set to accept cookies but users of most browsers may change the setting to refuse cookies or to be alerted when cookies are being sent.

Use of Personal Information

We use Personal Information about you for business purposes shown in the chart below.  If you are in the European Economic Area (EEA), our “legal basis” for processing your Personal Information is shown in column 2.

Purpose/Activity

EEA lawful basis for processing, including basis of legitimate interest

To provide you with the information, products and services that you request from us; to allow you to participate in interactive features of our Website, when you choose to do so; to manage accounts; and to manage our relationship with you, including providing you with the information, products and services that you request from us, and notifying you about changes to our terms or privacy policy

(a) Performance of a contract with you
(b) Necessity to comply with a legal obligation
(c) Necessity for our legitimate interests (for instance, to keep our records updated)

To make suggestions and recommendations to you about things that are similar to those that you have enquired about or may otherwise be of interest to you

Necessity for our legitimate interests (to grow our business)

To improve our Website and to ensure that content is presented in the most relevant and effective manner for you and for your device; to administer our Website, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to keep our Website, business and users safe and secure; to comply with applicable laws and regulations; and to protect or exercise our legal rights or defend against legal claims.

(a) Necessity for our legitimate interests (for running and protecting our business; for provision of administration and IT services; for network security and to prevent cybercrime and fraud; in the context of a business reorganisation or group restructuring exercise; to study how people use our website, to develop it, to keep our website updated and relevant, to grow our business and to inform our communications strategy)
(b) Necessity to comply with a legal obligation

Unless you ask us not to, we may contact you (subject to applicable law) via email, SMS or by telephone in the future to follow up regarding the outcome of the service or information that we provided to you.

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your Personal Information for an unrelated purpose, we will endeavour to notify you and explain the legal basis which allows us to do so.

Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of Personal Information

We may share your Personal Information with any member of our corporate group and with selected third parties, including: business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; and analytics and search engine providers that assist us in the improvement and optimization of our Website.

We also may disclose your Personal Information to third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets;
  • if we, or substantially all of our assets, are acquired by a third party, in which case Personal Information held by us about you may be one of the transferred assets;
  • if we have reasonable cause to believe that we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements, or to protect the rights, property, or safety of SI-BONE, our customers, or others.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Personal Information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of other websites that you visit.

Where We Store and Transfer Your Personal Information

We may, for some of the purposes listed above, transfer, collect, store and process your Personal Information outside your country of residence, for instance in the United States and any Member State of the EEA, consistent with (and for the purposes set out in) this Privacy Policy. The data protection laws and other laws of countries to which your Personal Information may be transferred might not be as comprehensive as those in your country.  We will comply with applicable law, and will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Data Retention

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Access to and Control Over Personal Information

If you have granted consent to the use of your Personal Information, you can withdraw that consent free of charge, at any time, by contacting us via the details given below.  You may also opt out of contacts from us at any time by taking advantage of the “opt-out” functionality included in our emails to you or by contacting us at info@si-bone.com.  Please note that this will not affect all communications from us, for instance those we are legally required to provide.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes.

If information access and correction is not available where you registered and you would like to make a request to access, correct, restrict, delete or transfer your Personal Information, or otherwise object to our processing of such Personal Information, please contact us via the email address or phone number given on our Website.  We will respond to reasonable requests in accordance with applicable law and subject to legal and contractual restrictions.  There may be instances where we cannot comply with such requests.  For example, where required or permitted by applicable law, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality.  If that happens, we will give you written reasons for any refusal.  We may also need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to, or modified at the request of, any person who has no right to do so. We may also contact you to ask you for further information in relation to your request to speed up our response.

If provided for by applicable law, you have the right to make a complaint at any time to the supervisory authorities for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach them, so please contact us in the first instance.  If you are unsure who your relevant supervisory authority is, you should also contact us.

Security

We take precautions to protect your Personal Information from loss, misuse or unauthorized access or disclosure. However, no data transmission over the Internet is certain to be secure and we cannot guarantee its security.

We also take measures to protect your Personal Information offline. For example, only employees who need the Personal Information to perform a specific job are granted access to it.

Contact Us

If you have any questions about this Privacy Policy, or any other aspects of your privacy, or wish to exercise control over your Personal Information please contact us via telephone at 408-207-0700 or via email to privacy@si-bone.com, and we will endeavor to respond to your inquiry promptly.

For the purposes of EEA data protection law, we (SI-BONE, Inc.) are the “controllers” in respect of the handling of Personal Information as described in this Privacy Policy.  SI-BONE, Inc.’s headquarter offices are at 471 El Camino Real, Suite 101, Santa Clara, CA 95050, USA.

Revisions, Updates and Changes

SI-BONE reserves the right to modify, amend and update this Privacy Policy at any time and for any reason without notice. When changes are made to this Privacy Policy, the updated document will be posted to the Website and the “Last Modified” date at the top of the document will be revised. Your continued use of our Website means that you accept such updates. We suggest that you periodically review this Privacy Policy to see if any changes have been made to it that may affect you.