Effective Date: September 09, 2020

ZEPHYRx LLC ("ZEPHYRx", “we”, “our”, “us”) is committed to protecting the privacy and security of your personal information. We want to share with you how we treat personal information about you that we receive in connection with our website, www.zephyrx.com (collectively, the “Website”).

Also, use of this Website is governed by the Terms of Use posted on the Website. As noted in those Terms of Use, ZEPHYRx LLC. is a Delaware Corporation. The servers that host this Website are located in the United States, and any personal details you provide to us will be processed by ZEPHYRx in the United States. 

1. What Personal Information We Collect About You

Information you provide

We obtain information that you provide directly to us when you use our website, for example, when you fill out a form to contact us or register for our support forum.  We also obtain information through cookies when you navigate the website (see Cookie Information below for more details). This information may include personal information, which is information that can be used to identify you.

Information you may choose to submit to us includes:

• email address
• name
• address
• phone number(s)
• health information
• company
• information about your interests in and use of various products, programs, and services
• any other information that you decide to provide us with

Personal Information Collected Automatically

As you interact with the Website, we may collect certain information using automated tools, such as cookies and other technologies. For more information on how we use cookies, please read our Cookie Information below.

The types of information we collect automatically when you visit the Website may include IP addresses, device identifiers, browser characteristics, operating system details, language preferences, referring URLs, length of visits, anonymous traffic data, and pages viewed.

2. How We May Use Your Personal Information

We may use personal information we collect through the Website:

• To respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our products and services.
• To send administrative information to you, for example, information regarding the site and changes to our terms, conditions, and policies.
• To send you marketing communications, including via email and SMS in compliance with applicable laws and in accordance with your preferences, that we believe may be of interest to you.
• To personalize your experience on the site by presenting products and offers tailored to you.
• To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. 
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving or modifying our Websites and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

Data Retention

We will retain your personal information for no longer than is necessary for the performance of our obligations, to achieve the purposes for which the information was collected, or as may be permitted under applicable law.

3. How We May Share Your Personal Information

• With our affiliates, subsidiaries, and any company owned or controlled by ZEPHYRx.
• With service providers assisting us in carrying out the transactions or services offered through this Website. These service providers are limited to use the personal information we share with them only for the purpose(s) stated within our contracts.
• In the event of a business transaction, such as if we sell or transfer all or a portion of our business or assets (e.g., further to a merger, reorganization, liquidation, or any other business transaction, including negotiations of such transactions), we reserve the right to disclose any information we obtain through the Service. You acknowledge that such transfers may occur and are permitted by and subject to this Privacy Policy.
• When required by subpoena, search warrant, or other legal processes, or in response to activities that are unlawful or a violation of ZEPHYRx’s rules for use of the Service, or to protect and defend our rights or property.
• With others only with your explicit consent.

Your Choices

• You have the choice to participate in our surveys, contests or sweepstakes.
• You may consent or withdraw your consent to our use of your personal information for marketing at any time by following the instructions to unsubscribe included in each marketing-related email sent to you or by sending an unsubscribe request to email@zephyrx.com.
• Please note that if you opt-out of receiving marketing-related emails from us, we may still send you administrative messages relevant to any specific services you may have signed up for.

Third-Party Links

For your convenience, the Service may from time to time include links to websites or services that are owned and/or operated by third parties. This Privacy Policy does not apply to those websites or services, which may have their own privacy policies or notices that you should review to understand how they may use or disclose your personal information. ZEPHYRx is not responsible for the content or privacy practices of any linked websites or services that are operated by third parties.

Security

We take industry-standard measures to protect your personal information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, we cannot guarantee the complete security of your information collected through the Website as data through the Internet and online digital storage can never be completely secure.

4. California Privacy Rights

Privacy Notice for California Residents

This Privacy Notice for California Residents supplements ZEPHYRx LLC. (“ZEPHYRx” or “Company’s) privacy notice and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), the Regulations proposed by the California Attorney General in 2019, and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

ZEPHYRx collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, ZEPHYRx has collected (or not collected, if indicated below) the following categories of personal information from its consumers within the prior twelve (12) months:

ZEPHYRx obtains the categories of personal information listed above from the following sources:

• Direct interactions. You may give us your information by filling in forms or by corresponding with us by mail, phone, or email. This includes, but may not be limited to, personal data you provide when you:
• Create an online user account;
• Customer Service engagement;
• Automated technologies. As you interact with our website, we may automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Information below for further details. ZEPHYRx does not sell your personal information as defined under the CCPA. Unless this Privacy Notice is updated to change this commitment, ZEPHYRx will treat personal information collected by this site as subject to a “do not sell” request under the CCPA and similar laws.

Use of Personal Information

We may use and/or disclose the personal information we collect for one or more of the following business purposes:

• To respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our products and services;
• To send administrative information to you, for example, information regarding the Sites and changes to our terms, conditions, and policies.
• To send you marketing communications, including via email and SMS in compliance with applicable laws and in accordance with your preferences, that we believe may be of interest to you.
• To personalize your experience on the Sites by presenting products and offers tailored to you.
• To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. 
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving or modifying our Websites and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

ZEPHYRx will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

ZEPHYRx may disclose your personal information for a business purpose. When we disclose personal information, we require that the recipient both keep that personal information confidential and not use it for any purpose except for the business purpose. We share your personal information with the following:

• With our affiliates, subsidiaries, and any company owned or controlled by ZEPHYRx.
• With service providers assisting us in carrying out the transactions or services offered through this Website. These service providers are limited to use the personal information we share with them only for the purpose(s) stated within our contracts.
• In the event of a business transaction, such as if we sell or transfer all or a portion of our business or assets (e.g., further to a merger, reorganization, liquidation, or any other business transaction, including negotiations of such transactions), we reserve the right to disclose any information we obtain through the Service. You acknowledge that such transfers may occur and are permitted by and subject to this Privacy Notice.
• When required by subpoena, search warrant, or other legal processes, or in response to activities that are unlawful or a violation of ZEPHYRx’s rules for use of the Service, or to protect and defend our rights or property.
• With others only with your explicit consent.

Sale of Personal Information

In the preceding twelve (12) months, we had not sold any categories of personal information.  ZEPHYRx does not sell and will not sell personal information to third parties.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Disclosure Rights

You have the right to request that we disclose the categories of personal information we collect in the preceding 12-month period prior to the request date. Consumer requests of this nature may be made no more than twice in a 12-month period.

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category C: Protected classification characteristics under California or federal law.
• Category D: Commercial information.
• Category E: Biometric information.
• Category F: Internet or other similar network activity.
• Category G: Geolocation data.
• Category H: Sensory data.
• Category I: Professional or employment-related information.
• Category J: Non-public education information.
• Category K: Inferences drawn from other personal information.

Data Access Request

You have the right to request that ZEPHYRx disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your consumer request (see section on Exercising Your Data Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The specific pieces of personal information we collected about you.
• If we shared personal information with third parties, the categories of these third parties.
• If we sold or disclosed your personal information for a business purpose, we will provide two separate lists disclosing:

• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

 ZEPHRYx Does Not Sell Personal Information to Third Parties. 

Deletion Request Rights

You have the right to request that ZEPHYRx delete any of your personal information that we collected from you and retained, subject to certain exceptions, required by applicable law. Once we receive and confirm your consumer request (see section on Exercising Your Data Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Data Rights

To exercise your disclosure, access, data portability, and deletion rights described above, please submit a consumer request to us by either:

• Calling us at 1-888-452-6269
• Emailing us at email@zephyrx.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a consumer request related to your personal information.

You may only make a consumer request for access or data portability twice within a 12-month period. The consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a consumer request to authenticate the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a consumer request within forty-five (45) days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically at your option.

Any disclosures we provide will only cover the 12-month period preceding the consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data access requests, we will deliver the data in a readily usable format.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.

5. Children’s Privacy

The Service is not intended for, nor targeted to, children under 13, and we do not knowingly request or collect personal information from any person under 13 years of age through the Service. If we learn that we have received information directly from a child who is under the age of 13, we will delete the information in accordance with applicable law.

6. Cookie Information 

ZEPHYRx uses cookies and other technologies to enhance user experience on our websites and in our mobile apps. This Policy explains how we use these technologies and the choices you have. 

1. A cookie is a small data file created by websites you visit used to store information on your device. Other tracking technologies are used for similar purposes. We use cookies on our websites (whether or not you have registered or signed in to any of the services we provide). Cookies may collect certain information about you, your device and your use of our websites to identify your device when you revisit our websites. For example, we may use cookies to remember your website preferences, deliver ads to you on or off ZEPHYRx websites, prepopulate forms, recall your authentication information so we can keep you signed in to our websites, or track statistical information related to navigation throughout our websites. We may use both "session" and "persistent" cookies to better operate our website applications and enhance your experience. A persistent cookie helps us recognize you as an existing user, so you can return to our password protected websites without signing in again. After you sign in, a persistent cookie stays in your browser and will be read by ZEPHYRx when you return to one of our websites. A session cookie enables certain features of our websites and is deleted from your device when you disconnect from or leave the website. Please note that third-party websites you navigate to from our websites may also use cookies to display ZEPHYRx content. We cannot control how or when those cookies are applied. For example, when you link from our websites to a third-party website, that website may have the ability to recognize that you have come from our websites by using cookies. If you have any questions about how third-party websites use cookies, you should contact those third parties directly.
   
   
2. Web beacons or GIFs We also may use web beacons or graphics interchange formats (GIFs) to allow us to adjust our website content to better respond to your needs. Web beacons are small graphics embedded in a web page, which unobtrusively track the online movements of visitors. The web beacons we use do not currently track, collect or link to your personal data.
   
   
3. We may update our Cookie Information from time to time. If you disagree with the changes you can edit your browser preferences to refuse to accept cookies, remove cookies or notify you when a cookie is set (select the "Help" menu on your browser to learn how to change your cookie preferences). You do not have to accept all cookies sent to you by our websites. Depending on the particular cookie you reject, you may not be able to use some features on the website you are visiting or signing in to. No change to the Cookie Information will change any data processing permissions you may have granted separately. If you have any questions regarding our Cookie Information, please send us an email to legal@ZEPHYRx.com.

7. Data Protection for European Union Residents

DATA PROTECTION under the EU General Data Protection Regulation (GDPR)

This data protection declaration describes how we use the data that we collect about you via this zephyrx.com website, which is operated by ZEPHYRx LLC based in the United States, as well as all mobile websites, applications ("apps"), widgets, conferences, events, electronic newsletters, communications or other services (collectively the "Services") that refer to this Privacy Policy. This privacy policy does not apply to any event in which we have advised you that a different privacy policy applies. This data protection declaration is intended for residents of the European Union.

This privacy policy also does not apply to data processing activities that specifically relate to current or former employees or applicants of ZEPHYRx. 

WHAT DATA DO WE COLLECT ABOUT YOU?

The data we receive and the way we use this data depend on what you do while visiting our website or using our services. We collect and use non-personal information (information that does not personally identify you) differently from your personal information.

YOUR PERSONAL DATA

Personal data is data that can personally identify you, such as:

1. First and Last Name
2. Address, telephone number, email address or other contact details
3. Serial number of a medical device
4. Personal information about your state of health
5. Date of birth or age
6. Username or profile in social media
7. Interests and qualifications
8. IP (Internet Protocol) address, if this address is linked to a specific user.
   

We collect personal information about our users in two ways:

If you enter or provide personal data directly on certain pages of the website; For example, when you fill out a registration form for a specific service, take part in a survey or fill out a contact form.

With automated means, in particular with cookies. Cookies are small text files that are stored on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, and to convey information to the owners of the website.

HOW DOES ZEPHYRx USE PERSONAL DATA?

We can use the data that you have transmitted to us via our website for the following purposes (with the exception of sensitive data, for which other provisions apply, more on this below):

• to respond to your inquiries
• to provide the services or data that you request
• to enable you to register for certain products or services or to improve their functionality
• to solve user concerns or problems with a product or service and to record the solution process
• to regulate our business relationship with you and, if necessary, to keep track of the necessary service processes (by storing the relevant data and settings for a reasonable period of time)
• to enter into or perform a contract with you (if you would like to purchase products or services from us)
• to enable you to participate in our online communities, including social media and blogs
• to provide you with information that may be of interest to you - more about this below in the Marketing and Education section
• for other purposes to which you consent
  

ZEPHYRx can also use your personal data to the extent necessary to pursue the following legitimate interests, insofar as it is compatible with your rights and expectations of data protection:

• for analytical purposes to research, develop and improve programs, products, services and content
• To anonymize your data by removing any personal identifiers (name, email address, social security number, etc.) so that they can be used for other purposes. In this case, the anonymized data would no longer identify you personally and can be treated as non-personal data. See the relevant section below for more details.
• to enforce this privacy policy and other rules regarding your use of this website
• to protect our rights or property
  

ZEPHYRx also has legitimate reasons for using your personal information:

• as part of the need to protect the health, safety or welfare of individuals
• to comply with a law or regulation, court order or other legal process
• Insofar as we are legally obliged to do so, we will ask you to consent or consent to the processing of your personal data for a specific purpose. For example, if required by law, we will only send you newsletters if you have subscribed to them. 

WHAT IS SENSITIVE DATA?

Some types of personal information belong to the special categories of personal information (so-called "sensitive information"). Sensitive information is information relating to your health (such as the serial number of a medical device or test results), genetic or biometric information, yours ethnic origin, your religious or philosophical beliefs, your sex life or orientation, your political opinions or your membership in a trade union.

DOES ZEPHYRx TREAT SENSITIVE DATA DIFFERENTLY TO OTHER PERSONAL DATA?

ZEPHYRx only collects and processes sensitive data from you:

• in such ways that you have expressly consented to
• to the extent necessary to protect the vital interests of yourself or of another person, in those cases in which your express consent cannot be given or can reasonably be requested
• in accordance with applicable laws, which include appropriate and special measures to protect your fundamental rights and interests
• insofar as the processing is necessary for medical purposes and we are subject to a duty of confidentiality under the given circumstances, which corresponds to that of a member of the health profession
• to the extent necessary to assert, exercise or defend a legal claim
  

Examples:

1. We may receive sensitive information directly from you if you voluntarily provide it to us for a specific purpose (i.e. when you come to us with a question or suggestion about our products and services);
2. We may also receive sensitive patient information from healthcare professionals with whom we work to provide you with therapy or technical support about our products or services;
3. We may collect sensitive information to ensure the safe and effective use of our products and services, as required by the US Federal Food and Drug Administration (FDA), European and other government agencies.
4. We can collect sensitive data from patients who have explicitly consented to participate in clinical trials, studies, and other research initiatives.

NON-PERSONAL DATA

Non-personal data are data that cannot personally identify you or which cannot be linked to you in any way. Therefore, the non-personal information that we collect about you through this website does not identify you personally as an individual and is not associated with you. This can include the following data:

• the type of browser you are using (e.g. Internet Explorer)
• the name of the domain from which you are accessing the Internet
• the Internet address of the website from which you accessed our website directly via a link
• Date and time of your access to our website
• which pages you have visited on our website 
• what search terms you use
• the links you click
• If you visit our website to read or download information, for example information about a state of health or about one of our products, we may collect non-personal data from your computer. This data is recorded by your web browser. If you only read information on our website or simply click on the corresponding download link, we will not collect or discover your name, your e-mail address, your home address or any other personal data about you. 
  

WHAT DOES ZEPHYRx DO WITH NON-PERSONAL DATA?

We are always looking for ways we can better serve you and improve our products and services as well as your experience on our website. We use non-personal information about you to increase the usefulness of this website for visitors. We can also use non-personal data for other business purposes. For example, we may use or collect non-personal information in order to

• Generate reports for internal use in order to further develop programs, products, services or content
• Adapt or improve the data or services we offer
• Share or sell data to third parties
• Transferring data on how our website is used, such as "traffic statistics" and "response times", to third-party providers
• Create materials for direct marketing and educational purposes
• ZEPHYRx may wish to provide you with educational materials or other information about our products and services, or information about clinical studies or the products and services of others that may be of interest to you; based on information about your use of ZEPHYRx websites, social media and blogs that you have shared with us and that we have collected using cookies or similar technical means.
  

In accordance with applicable law, we will ask you to "register" or consent to the processing of your personal data for such advertising purposes.

If at any time you no longer wish to receive educational materials, sales or promotional communications about our products or services or those of our affiliated companies or service providers, please send us an e-mail to the contact address below and write “UNSUBSCRIBE” in the subject line Your email. Alternatively, you can also use the unsubscribe function in an email that you receive from us.

Please note that even if you decide not to receive any more marketing communications from us, we may still send you relevant information for other legally permissible purposes - for example to manage a user account that you have with us to answer your inquiries to respond, to fulfill your agreements with us or to provide you with information that ZEPHYRx is required by law to provide, such as product recalls. 

DOES ZEPHYRx EVER SHARE PERSONAL DATA TO THIRD PARTIES?

ZEPHYRx will not disclose any personal information to a third party other than as described in this Privacy Policy.

In the normal course of business, we may share some personal information with ZEPHYRx affiliates or third-party vendors whom we engage to provide services or features on our behalf.

For example we can

• use various intermediaries or delivery services to deliver products to you that you order on our website. In these cases, we will provide the intermediary with the data he needs to process your order, for example your name and email address.
• use a service provider to manage certain newsletters or promotional emails for which you have registered and to enable this service provider access to your email address for this purpose.
• use a third application or platform to regulate and track your communication with us.
• use our affiliates to provide services related to your personal data - for example, we may store your data on a secure server at the headquarters of an affiliate in Europe or the USA. For more information on the circumstances in which we may transfer your data to other countries, please see the relevant section below.
  

In any case, we do not disclose more data than is necessary and we only authorize third-party providers to keep your data, to provide information about it or to use it to provide the requested services in accordance with the purposes listed above.

Please note that we can provide information about your personal data within the framework of the applicable laws if we are obliged to do so by a law, a regulation, a court order, a legal or an official request. In the unlikely event that our entire business or parts of it are taken over by a third party, your data, insofar as it is relevant for the company in question and taking appropriate security measures, can be transmitted to the new company owner.

In addition, if necessary, we can use your personal data and provide information to third parties in order to

• enforce this privacy policy and other rules regarding your use of this website
• protect our rights or property
• protect the health, safety, or welfare of individuals
• comply with a law or regulation, court order or other legal process
• conduct an investigation or take appropriate action if fraud or other illegal activities are suspected

Please also keep in mind that certain areas of our website may be interactive and allow you to post information that other users can see. If you do not want your information to be publicly visible, please do not use those areas of the website.

DO WE TRANSFER PERSONAL DATA TO OTHER COUNTRIES?

In certain cases, ZEPHYRx may transfer personal data that we have collected through this website to our affiliated companies or third-party service providers in other countries for the purposes set out in this privacy policy. In cases where personal data is transferred from Europe to other countries, we ensure that security measures are taken that correspond to those of European data protection laws. 

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We only keep your personal data for as long as is necessary to fulfill the purposes for which we are allowed to use it as set out in this privacy policy. For example, if you tell us that you no longer want to receive a newsletter from us, we will immediately delete your email address from our mailing list. If you participate in a program through our website, we will delete the personal data collected as part of that program within a reasonable period of time after completion of that program (for example, a period of six months after completion is normally considered appropriate - es unless we have legally permissible reasons

WHAT HAPPENS IF THE PRIVACY POLICY CHANGES?

This data protection declaration was last updated on September 09, 2020. We can change this data protection declaration at any time and for any reason. If we decide to change our privacy policy, we will identify a change by updating the Effective Date at the top of this Privacy Policy. We encourage you to read this privacy policy every time you visit our website. 

WHAT ABOUT THE DATA PROTECTION ON OTHER WEBSITES?

This website may contain links to other websites. Some of these websites are operated by ZEPHYRx affiliates and some are operated by third parties. This privacy policy does not apply to any other website, including any other ZEPHYRx website. We therefore recommend that every time you leave this website you read the data protection regulations that apply to the data that is collected from you on other websites. We provide the links for you, but we do not review, control, or monitor the privacy practices of websites operated by others. We are also not responsible for the websites operated by third parties, nor for your business interactions with them. 

ARE THERE SPECIAL RULES FOR CHILDREN'S DATA PROTECTION?

It is important to us to ensure the online privacy of children. We do not intentionally collect personal information (such as the child's name or email address) from children under the age of 13 without the consent of a legal guardian. If you think that we have nevertheless collected personal data from a person under the age of 13, please contact us.

WHAT ABOUT THE SECURITY OF THIS WEBSITE?

Security is very important to us. We also understand that security is important to you. We use industry-standard measures to protect your personal data from loss, misuse and unauthorized access, disclosure and modification as well as destruction. However, no website or e-mail transmission is 100% secure and we therefore advise you to exercise particular caution with what data you send or request via e-mail and to take appropriate precautions, such as the confidentiality of any user names and passwords.

YOUR RIGHTS

You can exercise your right to access your personal data at any time, have them corrected and, if necessary, deleted, or to restrict the processing of your personal data in accordance with applicable law.

You also have the right, based on your personal situation, to object to any use or processing of your personal data that is based on our legitimate interests.

If we process your personal data automatically as part of a service or on the basis of your consent, you also have the right to request a copy of your data in a structured, commonly used and machine-readable format (known as the right to "data portability").

You can  send inquiries of this kind to the e-mail address legal@ZEPHYRx.com or in writing to ZEPHYRx LLC, 43 New Scotland Ave, MC25, Albany New York 12208, USA.

Please note that we may ask you to provide proof of identity (such as a copy of your ID card or passport) before we can respond to your request.

If we are collecting or using your personal data on the basis of your consent, you also have the right to withdraw that consent at any time in the same way in which you gave it or by contacting us as described above.

You can also refuse any direct marketing measures at any time free of charge and without any reason and, as described above, request that you no longer receive advertising.

If you are not satisfied with the way we have processed your request, you can contact us / our data protection officer. Our data protection officer can be reached at the email address security@ZEPHYRx.com or via the following contact details:

Security Officer
ZEPHYRX LLC
43 New Scotland Avenue, MC25
Albany, New York, 12208, USA
Phone: +1 888 452 6269
Email: security@zephyrx.com

You can also contact the responsible data protection authority at: 
https://edpb.europa.eu/about-edpb/board/members_en

CONTACT ZEPHYRx

If you  have any questions or comments about this data protection declaration, please contact us via our website or using the contact details listed above in the "Your rights" section. 

8. Revisions

This Privacy Policy is subject to change at our discretion. We will identify changes, including material changes, to the Privacy Policy by updating the “Effective Date”. Your use of the Service after any update to this Privacy Notice will constitute your acceptance of the changes.

Contacting Us

If you have any questions or concerns relating to this Privacy Policy, please contact our Privacy Office as follows:

Privacy Office

ZEPHYRx LLC

43 New Scotland Avenue, MC25, Albany NY 12208

Tel: 1-888-452-6269

Email: legal@ZEPHYRx.com