Privacy Policy

Last modified: 5/25/18

Introduction

Tower Surgical Partners (“Company,” Us or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you and/or that you may provide when you visit the website towersurgicalpartners.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On this Website.
  • In email, text, and other electronic messages between you and this Website.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Company or any third party including our affiliates and subsidiaries; or
  • any third-party including our affiliates and subsidiaries, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates, including the “last modified” date above.

Children Under the Age of 18

Content on this website is directed at individuals over the age of 18 and is not directed at or intended for children under the age of 18. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact Us at INFO@TOWERSURGICALPARTNERS.COM.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • by which you may be personally identified, such as name, postal address, email address, telephone number  (“personal information”);
  • that is about you but individually does not identify you, such as your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us.  The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided when requesting further services or through the Contact section. We may also ask you for information when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and does not include personal information but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps Us to improve our Website and to deliver a better and more personalized service, including by enabling Us to:

  • Estimate our audience size and usage patterns.
  • Learn and study Website trends (without identifying individual users).
  • Learn how users arrived at our Website.
  • Store information about your preferences, allowing Us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, seeChoices About How We Use and Disclose Your Information” below.
  • Web Beacons. Pages of the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Google Analytics. Google Analytics is a web analytics tool that helps website owners understand how visitors engage with their website. Like many services, Google Analytics uses first-party cookies to track visitor interactions as in our case, where they are used to collect information about how visitors use our site.  Google Analytics collects information anonymously. It reports website trends without identifying individual visitors. You can review Google Analytics Terms of Use here   You can learn about Google’s Privacy Policy and how it uses data collected through Google Analytics at this Google Analytics Help page  You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page.
  • Pardot. We have selected Pardot, LLC, a Salesforce company, as a marketing automation agent for the Website. Pardot uses cookies or similar technologies to help the Website analyze how users use the site. Please review Pardot’s Privacy Policy for information about Pardot’s data use policy and security measures. Please also review “How Does Pardot Track Activities” for information about how Pardot uses cookies and how you may refuse the use of cookies.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or that you provide to us.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with information or NEWS updates when you sign up for NEWS updates including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on our Website.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about our own goods and services that may be of interest to you. If you do not want Us to use your information in this way, please do not submit your information to Us on the Contact page or via any forms on the site. For more information, see “Choices About How We Use and Disclose Your Information” below.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • As permitted or required by law.
  • To contractors, service providers, and other third parties we use to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by Us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including responding to any government or regulatory request.
  • To enforce or apply our Terms of Use at and other agreements.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Tower Surgical Partners, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Promotional Information from the Company. Upon your request by email, the Company may send you information to promote our services or provide News and updates. You can opt-out by sending Us an email stating your request to INFO@TOWERSURGICALPARTNERS.COM or by mail at 3206 Tower Oaks Blvd, Suite 220, Rockville, MD 20852. If we have sent you a promotional email, you may send Us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a partnership agreement, product purchase, warranty registration, product service experience or other transactions.

In order to provide our Services, we may need to transfer your Personal Information to locations outside the jurisdiction in which you provide it. If you are based within the European Economic Area (EEA), please note that where necessary to deliver the services, we will transfer personal information to countries outside the EEA.  To the extent necessary, we will enter into data sharing agreements which will be based on the European Union standard contractual clauses to ensure that we comply with our legal and regulatory obligations in relation to your Personal Information, including having a lawful basis for transferring Personal Information. (Updated May 25, 2018)

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Accessing and Correcting Your Information

You may send Us an email at INFO@TOWERSURGICALPARTNERS.COM to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your California Privacy Rights

California 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. To make such a request, please send an email to INFO@TOWERSURGICALPARTNERS.COM or write us at: 3206 Tower Oaks Blvd, Suite 220, Rockville, MD 20852.

International User Notice

For international users, please note that it may be necessary to transfer your information internationally and, in particular, your information may be transferred to and processed in the United States. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Please be assured that we take steps to ensure that your privacy is protected as described in this Privacy Policy. By using the Website(s), you agree to have your information used and transferred to the United States as set forth in this policy.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to Us is stored on our secure servers behind firewalls.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Retention of Your Information

When you visit the Website(s) and use our Services, we retain your personal data for no longer than is necessary for the purposes for which the information is collected and in compliance with our obligations under the EU General Data Protection Regulation. When determining the relevant retention periods, we will take into account factors including:

  • legal obligation(s) under the applicable law to retain data for a certain period of time, for example, accounting obligations;
  • statute of limitations under applicable law,
  • (potential) disputes; and
  • Guidelines issued by relevant national data protection regulators.

Otherwise, we securely erase your information once this is no longer needed for the purposes for which the information is collected.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the following rights:

  • Right to access: If you ask us, we will confirm whether we are processing your Personal Information and, if necessary, provide you with a copy of such Personal Information.
  • Right to rectification: If the Personal Information we process is inaccurate or incomplete, you are entitled to request to have it rectified.
  • Right to deletion: You may, under certain circumstances, ask us to delete or remove your Personal Data. Such circumstances may arise where we no longer need it or if you withdraw your consent (where applicable).
  • Right to restrict processing: You can, under certain circumstances, ask us to ‘block’ the processing of Personal Information. Such circumstances may arise where you contest the accuracy of that Personal Information or you object to us.
  • Right to data portability: You have the right, under certain circumstances, to obtain the Personal Data you have provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
  • Right to object: You may, under certain circumstances, ask us to stop processing your Personal Information.
  • Right to withdraw your consent: If we rely on your consent as our legal basis for processing your Personal Information, You have the right to withdraw that consent at any time.
  • Right to complain: If you have a concern about any aspect of our practices regarding the processing of Personal Information, You can report it to the relevant supervisory authority.

If you wish to exercise your rights, you may send an email to INFO@TOWERSURGICALPARTNERS.COM or write us at: 3206 Tower Oaks Blvd, Suite 220, Rockville, MD 20852.

Changes to Our Privacy Policy

Any changes we make to our privacy policy will be posted on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact Us at:

3206 Tower Oaks Blvd
Suite 220
Rockville, MD 20852

or INFO@TOWERSURGICALPARTNERS.COM