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Privacy Notice

Document No. ESWI005
Version: A
Revision Date: 04/22/2026

E Surgical Privacy Notice
For ESurgical.com within the United States

Introduction

This notice describes how E Surgical collects and uses information about you ("personal data'") in connection with the activities described below, including when you order E Surgical products and services, on your or your employer’s behalf, when you visit this website and E Surgical office locations, when you contact E Surgical, or when you participate in E Surgical events, surveys, or other activities in the United States.
Unless set out otherwise below, the company responsible for processing your personal data is E Surgical LLC , (together "E Surgical," "we," or "us").

In this Privacy Notice (“Privacy Notice”), we will tell you what personal data we obtain about you, how we use that information, with whom we share it, what rights you have regarding your information, and how to contact us to exercise these rights. E Surgical and some of its affiliates, including our international affiliates, also operate other websites.
This Privacy Notice does not apply when you have been notified that an alternative notice applies. This website is a commercial website for the sale and distribution of various medical and healthcare products and services of E Surgical to licensed or authorized healthcare professionals. It is not intended or authorized to sell medical products or medical device to consumers or for personal use. It is not intended to provide any medical advice or personal medical treatment and care to individual patients. Your medical institution, employer, and/or personal healthcare professional is solely responsible for the processing of your personal data for the provision of your own personal medical treatment and care.

Personal and Electronic Data We Collect and How We use it

This section describes how E Surgical uses your personal data (which includes your electronic data) to provide you with its products and related services. Unless we need your personal and/or professional data in order to comply with laws and regulations, you are not required to provide information to us, but if you choose not to do so, we may not be able to offer you certain products, services, and related features or to respond to requests that you may have. The following situations are discussed in more detail below.

Visiting our websites

When you visit our websites or apps, we may collect and/or process both your personal data and the electronic data from your electronic devices (from your interaction with our sites) to learn more about how you use our site/app and services.

What personal (electronic) data we obtain
  • Electronic device information, including identifiers associated with your electronic devices, operating system type and characteristics
  • Internet and network activity information, including internet protocol (IP) address, domain name, web browser characteristics, language preferences, navigation, and your interactions with our site or app (such as the pages you visit, links you click, features you use, dates and times of access to our site/app, browsing history, search history, the pages that led or referred you to our site), and other information about your use of our site or app
  • Geolocation data, including approximate location information from your use of our site/app
  • Certain information by automated means, including cookies and similar technologies, such as Flash cookies, local storage, web beacons and pixels, JavaScript, software development kits (SDKs) and device identifiers
How we use your electronic data
  • To ensure our sites or apps operate correctly and secure logins work properly
  • Improve visitor experience and learn how they use our sites/apps and their features
  • Provide you with enhanced functionality such as video content and show you targeted ads on other sites or social media channels

Depending on your location, some cookies may require your consent. See our cookie policy to learn more about our use of cookies and how to manage cookie setting and preferences.

Creating and Managing an E Surgical Account

When you create an account or register your electronic device with us, we may collect and process your personal data to create and manage the account or to respond to your request for information about our products or related services.

What personal data we obtain
  • Identification information, such as your name, user ID number, date of birth or age, phone number, email address, physical address, and mailing address
  • Location data, such as your country/region and language preference
  • Login credentials, such as your username/email address and password
  • Information about a medical device that we sell and distribute, such as its identification/serial number(s), model and type, and other status information related to it
  • Professional information of a healthcare professional account holder, such as your profession, your job title and your medical specialty, the name of the medical institution or employer you work for, and your professional email address
How we use your data
  • Create and manage your account, including to authenticate you and ensure account security
  • Together with the information collected through our products or services, we may communicate with you about and provide you with the products and services you requested, unless you have been notified that an alternative notice applies to such use
  • Engage in health vigilance activities, post-market surveillance, recall, complaint, and quality monitoring, and similar activities, described below
Contacting Our Customer and Support Services

You may make an inquiry, or require assistance or support, by contacting our customer service or support team by phone or email, or by using our "How to contact us" form, our chat tools, and automated communications assistants, or other customer support tools.

What personal data we obtain

If you contact our customer and support services to make an inquiry about a product or request support, the types of personal data we obtain or process about you from that interaction include the following.

  • Contact information you directly submit to us, including name, title, physical, postal, and email address, and telephone number
  • Medical device identifiers or information, including device serial number, if any
  • Demographic information, including country of residence, date of birth, and age
  • Preferences including preferred language
  • Session information and device and network identifiers including IP address
  • Other information about you necessary for dealing with your request, including data relating to your purchased medical device or our product offering
  • Recordings and notes if we record the conversation we have with you
  • Other content posted or submitted by you including your relationship to E Surgical that you indicate, the type of healthcare provider you are if applicable, stage of education or training, and areas of interest.
How we use your data
  • To respond to you, provide you with required support, and follow up on your request, including, where applicable, ensuring compliance with our regulatory obligations and establishing, exercising, or defending ourselves from legal claims.
  • We may use automated communications assistants including "chatbots" and other contact aides to route, analyze, and respond to your customer and support service interactions, as well as to improve our automated communications assistants, products, and services.
  • We may also keep a record of the communications we have with you for evidentiary purposes and to train our personnel and improve the quality of our services. If you call us, you will be notified at the beginning of the call whether our conversation will be recorded.
  • To perform analytics and research
  • To improve our products, content, and services
  • To perform quality assurance and complaint handling functions
  • To detect, investigate, and respond to malicious and fraudulent activities
  • To debug and repair our products and services
Health Vigilance/Post-market Surveillance/Recalls/Complaints

As a seller and distributor of medical devices, we are subject to regulatory obligations when we place (or make available or put into service) our products in the marketplace. Compliance with those obligations require us to process personal data.

What personal data we obtain

The types of personal data we obtain or process as a seller and distributor of medical devices, which may be obtained from your interactions with or submissions to our site, your account, your purchase orders, your medical device's registration or telemetry data, or from your medical institution or employer as well as from information you communicate to us or post on a public forum, include:

  • Data allowing the identification of the patient or person exposed to an adverse health event, such as age, year or date of birth, gender, weight, height, and identification number
  • Data relating to the identification of the product concerned, such as the type of product used, and any available serial number.
  • Other information necessary for the assessment of an undesirable health event, such as health data, therapy data, consumption of tobacco, alcohol, or drugs, and life habit and behavior
  • Contact details of the person who made a complaint or notified us of an adverse health event, or of any health professional likely to provide details.
How we use your data
  • Conduct health vigilance related activities, including managing adverse health events and handling product complaints. We'll do so to ensure compliance with our legal obligations and with high standards of quality and safety of healthcare and medical devices.
Direct Marketing Communications

When we communicate with you directly to promote our product and service offerings (e.g., by email, text, or phone), we will use your personal data to do so.

What personal data we obtain

The types of personal data we obtain or process about you to send you such communications include:


  • Information you have shared directly with us (e.g., when you complete a form to sign up for such communications), such as your name, email address and/or phone number, age, and status as a business customer, including your professional details
  • Information that we have obtained through our interactions with you, such as expressions of interest you have made through this website or other methods of communication.
  • Publicly available information about you (e.g., from the public website of the medical institution or employer where you work)
  • Metadata collected from cookies or similar technologies, including to understand how you have interacted with our website and whether you have opened or clicked on the content in the emails that we have sent you. For more information on how we use cookies, and your choices in that regard, see our cookie policy.
How we use your data
  • To tailor our communications to your specific interests and preferred methods of communication
  • To avoid sending you communications that are not of interest to you or for which you have not consented
  • To follow up with you on the subjects that appear to be most relevant and useful for you. To this end, we may organize the data we obtain into interest-based groups that we associate with you.

We will ask you to "opt-in" or consent to the use of your personal data for the purposes of such communications where required by applicable laws. You can decide at any time to stop such communications by using the opt-out procedure provided in the relevant message (e.g., clicking the unsubscribe link in our promotional emails), or alternatively by contacting us as specified in the "How to Contact Us" section below.
Please note that if you choose to no longer receive promotional messages from us, we may still continue to send you relevant information for other lawful purposes, such as to administer any business account or contract you may have with us for products you have ordered, send you communications of an operational nature (e.g., updates to products), respond to your requests and as required by law (e.g., in case of a product recall).

Cookies and Similar Technologies

When you visit our websites or apps, we may collect certain information by automated means, including cookies and similar technologies, such as Flash cookies, local storage, web beacons and pixels, JavaScript, software development kits (SDKs) and other device identifiers. While personal data collected through these technologies is not shared for money or other similar compensation, the use of these technologies may be considered personal data sharing under applicable law. The types of technologies, purposes of use, parties involved, and controls available to you, which may vary across our digital offerings, are detailed in our cookie policy.

When you Interact on Social Media with or about E Surgical

You may send us a private or direct message via social media, or you may communicate about us or E Surgical products on social media (e.g., if you participate in our online communities, share a comment about a E Surgical product, or tag E Surgical in your post).

What personal data we obtain:

If you interact on social media with or about us, the types of personal data we obtain or process about you from that interaction include:


  • Social media information, such as your social media username, profile picture, country
  • Information about you that is contained in your comments, posts, or other content about E Surgical that you share on social media services
How we use your data:
  • To review or respond to your message or comments, and where applicable, to provide you with the required support and take any necessary follow-up actions
  • Using your data to understand your feedback and improve our products and services if you communicate about us or our products
Visiting E Surgical Locations

You may visit our office locations in order to interact with our personnel, to provide services or perform certain tasks.

What personal data we obtain:

If you visit an E Surgical location, the types of personal data we obtain or process about you include:

  • Your contact information and visit details, such as your name, signature and arrival/departure time and date, to enable you to access our premises and provide you with a badge as applicable
  • Video recordings of you if we operate closed-circuit television (CCTV) systems in the location you visit
How we use your data:

We will use this information for security and safety reasons, including ensuring the security of E Surgical personnel, property and assets, and complying with our internal security policies.

Participating in Events or Interviews

You may wish to participate in one of our physical or virtual events (such as workshops, meetings, webinars or live broadcast events), sponsored by us, or we may ask you to share your story, provide a testimonial or take part in an interview about your use of an E Surgical product. In this case, we'll need to process some personal data about you, as described below.

What personal data we obtain

If you participate in one of our events, testimonials or interviews sponsored by us, the types of personal data we obtain or process about you from your participation include:

  • Identification/contact information, such as your name (or a fictitious name to protect your privacy), email address, nationality, country
  • Professional information, such as your job type and title, place, and location of work,
  • Product(s)/service(s) of interest to you, where applicable
  • Anonymous patient health data, such as the medical condition treated by the E Surgical product
  • Images, video and/or audio recordings of you, if our event/interview is filmed or recorded
How we use your data

We will use your data to organize and facilitate the event/interview, and conduct our educational, promotional, and advertising activities.

Participating in Surveys

From time to time, we may invite you to participate in an E Surgical survey to gather your feedback to help us determine our customers’ satisfaction levels, identify areas of potential product improvement or to carry out market research.

What personal data we obtain

To the extent possible, we will gather your feedback in an anonymous manner. In some cases, however, the survey may gather identifiable respondent information. In such instances, the types of the personal data we obtain or process about you includes:

  • Identification/contact information, such as your name, email address, phone number
  • Professional details of you as a business customer, such as your employer's details, specialty, professional experience, professional qualifications etc.
  • Opinions, views, or information you choose to provide us as part of your survey responses.
  • Where applicable, information collected by automated means (including cookies), such as your IP address, and survey metadata (e.g., the language you take the survey in, duration of your survey response, last date the survey was started)
How we use your data

We will use your personal data to conduct the survey, including to send it to you, allow you to submit your survey responses, prevent survey fraud, analyze the survey results, and improve or develop our products and services, accordingly.

Participating in Clinical Studies and other Research Activities

We may participate with others in clinical activities, including clinical studies, clinical investigations, clinical surveys and other studies or research activities with regard to supplying our products or potential products. In this context, we process personal data of healthcare personnel involved in such activities. For such activities, we typically have no access to directly identifiable information about patients as that information is kept confidential by the relevant healthcare professional.

If you're a healthcare professional involved in (clinical) research activities, the types of personal data we obtain or process about you include:
  • Identification data, such as name, gender, professional contact details, bank details
  • Training and qualifications
  • Other relevant details of professional life(e.g., professional curriculum)
  • If applicable, identification number in the directory of health professionals
  • Amount of compensation and remuneration received
  • Collaboration in research activities
  • History of access, and connection to the medical data of participants in the research activities, where relevant
How we use your data
  • To carry out research activities in the public interest. including to generate evidence to submit to health regulatory authorities in order to comply with our medical device manufacturer's obligations, to assess the safety, performance and quality of our medical products, and to develop and improve the safety and performance of these medical products aiming at enhancing and improving healthcare

We will do so based on your consent or as required by applicable law in conducting research activities, for scientific research, or to ensure high standards of quality and safety of our products and services.

General Business Purposes

In some circumstances, we process personal data to comply with applicable legal requirements and our policies, to perform auditing and other internal functions, or for litigation and dispute resolution purposes.

What personal data we obtain

When this is the case, the types of personal data we obtain or process about you include:

  • Your identification and contact information
  • Other information as is necessary and relevant to the particular case; e.g., in the event of an (internal) audit, information contained in documents and materials audited, or in the event of litigation, information gathered in the evidence necessary for the litigation
How we use your data

We will use your information - in an anonymized, de-identified or redacted form, where appropriate - in order to:

  • Fulfill our contract with you when it is our legal duty except where legally required to disclose in accordance with applicable law
  • Support and manage our products or related services by our service providers and/or business partners.
  • Manage our relationship with you and keep our records up to date
  • Manage websites for healthcare professionals, account access support, verify your personal identity as needed for us to provide our products and related services, and provide on line support, safely and lawfully
  • Properly administer our business, products, or related services
  • Enforce, establish, exercise, or defend our legal rights. including this Privacy Notice and other rules about use of our products or services
  • Protect and secure websites, networks, systems, data, and services E Surgical provides to our customers
  • Manage compliance with our policies, including conducting (internal) audits, investigations, or due diligence checks for the above reasons
  • Understand how to improve our products or related services
  • Comply with applicable legal requirements, regulations, court orders, or other legal processes.
Secondary Use of Data
  • With the authorization of you or your medical institution or employer the data obtained as part of the products and services provided to you, your medical institution or employer may be further used to support and improve those E Surgical’s products and services, to conduct benchmarking, business analytics or market research, to train and educate E Surgical personnel or healthcare professionals, or to support regulatory filings.
Telephonic Contact
  • By disclosing the phone number(s) you provide to E Surgical, we may contact those number(s), including via text, SMS, or voice call, for the transactional purposes defined in this Privacy Notice, as well as for responding to requests you make of E Surgical. If you provide an additional consent for marketing communications, E Surgical may then contact you by telephone for marketing, advertising, or offers of sale of E Surgical products or related services as well.
  • When making contact by telephone, we may use automated technologies (including recordings and auto-dialing), and telephone, airtime, message, and data rates may apply. By providing your phone number(s) and/or consent(s), you certify that (a) you are age 18 and older,(b) the contact information you provide is yours, and (c) you authorize and consent to use of the information provided for E Surgical to contact you. Consent is not a condition for purchase or services. You may opt out of telephonic contact from E Surgical using automated technologies and for marketing communications at any time by (i) texting "STOP" in reply to a text message or (ii) for marketing messages, signing into your E Surgical profile and updating your communication preferences.
Data Sharing

In the ordinary course of business in carrying out the purposes described in this notice, we may share your personal data with certain categories of third parties, including:

  • E Surgical-affiliated companies: Given the corporate structure of E Surgical, your personal data may be shared with other affiliates of E Surgical.
  • Service providers: We may share personal data with relevant third-party service providers, who act on our behalf to fulfill the activities noted in this Privacy Notice, including IT providers, providers of communication tools and customer relationship management systems, survey tool providers or platforms, event organization management tool providers, outsourced operations such as accounts payable providers, email automation tool providers, cloud hosting service providers, and contract management platform providers.
  • Government Regulators: E Surgical may also disclose any data you provide to us to health oversight agencies such as government regulators to support with audits, investigations, and inspections.
  • To business and other specialists: We may share the data you provide us with external organizations with which E Surgical has partnered (such as research partners and as part of co-branding initiatives), and with external specialists or professional advisors within a particular field (such as lawyers, consultants, tax advisors, auditors, specialist delivery providers, banks, payment service providers, and benchmarking agencies).
  • Parties to a corporate transaction: We may share your data as necessary with parties to a potential, pending, or in process corporate transaction, such as if we sell or transfer all or a portion of our business or assets, or if we undergo a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation.
  • For legal and other related interests: We may share your personal data where:
  • Required by law
  • Required to disclose and/or share your personal data with regulatory, public, or governmental authorities to comply with any law, regulation, court order, legal, or government request
  • Allowed or required by law for public health purposes, including reporting complaints and quality issues to medical device regulators
  • Needed to protect E Surgical’s own or others vital interests, including the safety of life and property, or for investigating illegal or malicious activities, where allowed by law
  • Needed to exercise or defend legal claims
  • Needed with its affiliates, who have the same privacy requirements
  • Others, per your request: With your consent, we may share your personal data with other parties you choose.
International Transfers

In some cases, E Surgical may transmit, or store personal data collected with affiliates, vendors, or sites in other countries. We will only transfer personal data as allowed by applicable law to further the purposes set out in this document. Where personal data is transferred to another country, we take administrative and technical measures to ensure adequate safeguards and protections are applied as provided for by applicable law. In cases where personal data is transmitted to other countries, we will ensure that safeguards equivalent to those required by applicable data protection laws are in place. For more information on the safeguards implemented by E Surgical, please contact us via email.

Data Retention

We will only keep your personal data for so long as necessary to fulfill the purposes for which we are allowed to use them, as set out in this Privacy Notice. Your personal data may be archived for longer in order to take into account applicable statute of limitation periods, or as otherwise required by law. For more information on the retention of your personal data, contact us as indicated in the "How to contact us" section below.

Your Privacy Rights

You may have some of the rights listed below relating to your personal data, depending on applicable laws.

  • Access your personal data and confirm how your personal data is being processed.
  • Transfer or obtain a copy in a structured, machine-readable, or portable format.
  • Correct or amend if it is incomplete, inaccurate, or outdated.
  • Request deletion of your personal data, which in some cases may be fulfilled by restricting, obfuscating, de-linking, or deidentifying that data.
  • Restrict or limit excessive or unlawful processing, where the accuracy of the data is contested.
  • Object to or opt-out of processing in circumstances where E Surgical claims a legitimate interest in its processing and where your rights outweigh those of E Surgical, such as where that data is used for direct marketing (including email or telephonic marketing).
  • Withdraw (or manage) consent where it is the basis for processing. Where consent is revoked, we will not further process that data unless required or otherwise permitted by applicable law.
Exercising Your Rights

How to exercise your rights. You or your authorized agent may exercise these rights at any time or contact us with any inquiries through the methods provided in the "How to contact us" section below.

Process. We will first confirm that we have received your request. For rights requests, we are required to verify your identity, your right to access the information requested, and, as applicable, your authorized agent's authority to act on your behalf. We may need to ask you for additional information that will help us do so, including government-issued IDs containing your name and address, or other documentation containing that same information, and/or unique identifiers like user names. We will only use that additional information in the verification process, and not for any other purpose.

After the validation of identity and authority (including if we do not receive that information), we will process your request and then contact you with our response to your request, including any data and reasons for rejection as applicable, within the time required by applicable law. If we need more time, we will notify you in accordance with applicable law.

Additional Options. Depending on your jurisdiction, you may have additional options if you are dissatisfied with our response:

You may internally appeal or contact our Chief Technical Officer (CTO) if you disagree with a decision we made about your rights. Please include a copy of or reference to the decision.

You may also complain to a data protection or regulatory authority if you have further concerns about our data practices or our response to a request. If you need information about which authority may apply to you depending on your location and circumstances, please contact us. You will not be discriminated against for your exercise of your rights.

Children and Personal Data Online

We do not intentionally collect personal data from children (as defined by applicable law). If you believe we have collected personal data from a child, contact us using the information found in the "How to contact us" section.

Special Provisions for Specific Jurisdictions

United States of America

  • Past practices. The statements in this notice are our data processing activities for the described scope of the notice both as current and within the past twelve months.
  • Protected health information under HIPAA. This notice does not apply to our data processing activities and practices for Protected Health Information (PHI), which is regulated under the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
  • Sales/sharing of personal data: E Surgical does not sell your personal data for money or other consideration, nor share it for direct or behavioral marketing purposes, with unrelated third parties, except as described in the above Cookies and Similar Technologies paragraph.
  • Right to opt-out or object. As noted above, you may have the right to opt-out of some processing, such as sharing data with third parties for their own or for cross-contextual marketing, sales of personal data, making certain decisions or profiles about you by automated or artificial means, or certain kinds of automated/prerecorded telephonic messages.
  • Right to restrict or limit. In some jurisdictions you may have the right to restrict some processing if the data is considered sensitive and is used for purposes additional to delivering requested products/services.
  • Exercising your privacy rights. United States residents can file a privacy rights request by sending an email to us. You do not have to create an account with us to submit a request.
Updates to this Privacy Notice

This Privacy Notice may be updated periodically to reflect changes in our personal data practices.

How to contact us

If you have any questions about this privacy notice you may contact us as follows: General inquiries (all geographies): By email: service@esurgical.com