Effective Date: June 2024
Global Privacy Policy
CytoSorbents, Inc. and its affiliates and subsidiaries (collectively “CytoSorbents, Inc.,” “us,” “we,” or “our”) are committed to protecting your privacy. This Global Privacy Policy (“Global Privacy Policy”) describes how we may use and collect information about you (“you,” “user”).
Scope of This Global Privacy Policy
This Global Privacy Policy applies to the following (collectively referred to as the “Services”):
- CytoSorbents, Inc. websites, mobile or web applications, and other digital or online services or offerings that link, post, or reference this Global Privacy Policy;
- When you interact with us in the ordinary course of business (e.g., communications by phone, e-mail, or in person as part of a business relationship; or when we interact with companies or organizations you work for).
This Global Privacy Policy does not apply to the following:
- Services that link, post, or reference a different privacy policy;
- Certain components of the CytoSorbents, Inc. website that hyperlink to a different privacy policy;
- If our Services hyperlink to a third party site or service that has its own privacy policy.
CytoSorbents, Inc. has other Privacy Policies and/or Notices which may supplement or supersede this Privacy Notice, including but not limited to:
- US Privacy Policy, for United States residents;
Personal Information
For purposes of this Privacy Policy, “Personal Information” means information that may identify you that we collect or generate when you use or interact with our Services. Examples of Personal Information may include your name, your address, or an online identifier that could identify you (such as an IP address). Depending on where you live, Personal Information may have a different definition according to the local privacy laws in your area. This Global Privacy Policy applies to all types of Personal Information as defined by the local privacy laws that apply to you.
Types of Personal Information We Collect
We collect and generate different types of Personal Information depending on how you use or interact with our Services. The following describe various categories and sources of Personal Information we may collect and generate.
Demographic and Contact Information
Demographic and contact information that you provide to us. For example, we may collect information such as your name, mailing address, e-mail address, and telephone and fax number.
Online or Other Account Information
Username or email address and corresponding passwords, security questions, and other information needed to permit access to certain components of our Services which require registration and/or credentials.
Webforms and Requests
Information you submit to us through online or interactive forms available within our Services. For example, you may “contact us,” submit feedback, request additional information about a product or Service, sign up for a mailing or other type of newsletter, or reach out to us regarding a question or concern.
Websites
Information such as your username and password to enter certain sections of our websites or Services, unique identifiers, preference information (such as marketing preferences), browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site, operating system, date/time stamp, and clickstream data and other pieces of information further described in Tracking Technologies.
Mobile Apps
Some of our Services are available either as mobile applications or mobile sites that you can use on your mobile device. If you use a mobile device to access and use our Services, we may additionally collect mobile-specific information including your device ID, device type, hardware type, media access control (“MAC”) address, the version of your mobile operating system, the platform used to access or download the Services, location information and usage information about your device and your use of the Services. Please note that not all of our mobile services link to this Global Privacy Policy, so be sure to read the applicable privacy notice before using mobile services.
Device Information
Device-specific information including Internet Protocol (IP) address, hardware model, operating system, unique device identifiers, and mobile network information. We may also associate the information we collect from your different devices, which helps us provide consistent Services across your devices.
Log Information
Usage details of our Services, including the address (or URL) where you came from before visiting us, which pages or features you visit or utilize, which browser you use, search terms you enter, and items you click on. We may also create usage statistics and monitor the traffic from your use or interaction with our Services.
Internet Protocol (IP) Addresses
Internet protocol (IP) addresses are unique identifiers automatically assigned to each computer when logging onto the Internet. We generally collect IP address information from visitors using or interacting with the Services and we log them for system administration purposes. In some cases, as described below, we may also use IP addresses to serve you ads on third party websites regarding our Services that may be of interest to you based upon your use or interaction with the Services if you have opted-in to certain types of cookies. You can always adjust your Cookie Settings or your individual browser’s settings.
Location Information
Your location information may be collected in a variety of ways depending on how you use or interact with our Services. For example, location information can be derived from your IP address, location information associated with your use of a device, your country or location selection, or other location-based components and content of our Services.
Health Information
If you use certain types of our Services, we may collect information about your health or medical condition, and your treatment (including the specific device or product that you are prescribed). Additional privacy laws may apply to this type of sensitive information, so other privacy policies may apply.
Business Interactions
Information derived from your business-related requests, communications, and dealings we have with you, or the company/organization you work(ed) for or are associated with. This may include your job title, business contact information (phone, email, fax, and address), information about products or services you expressed an interest in or purchased from us, or that we have purchased from you or your company/organization, and other information needed to verify your ability to conduct business with us.
Financial Information
If you use a credit card to purchase a product or service from us, we may also collect information necessary to process the credit card transaction, such as the credit card type, number and expiration date.
Social Media
Our Services may link to our pages or accounts on Third Party Social Media Networks/Platforms (“Social Media”) but our Services do not use social media plug-ins. If you choose to interact with us on social media, we may collect the information you publish or submit. Note that this information is also governed by the privacy policies of the respective companies offering the social media service. Please refer to the respective Privacy Policies of these Social Media Networks/Platforms:
- LinkedIn Privacy Policy: LinkedIn Privacy Policy
- Facebook/Meta Policies: Facebook Terms and Policies / Meta Privacy Policy – How Meta collects and uses user data | Privacy Center | Manage your privacy on Facebook, Instagram and Messenger | Facebook Privacy
- Google Privacy Policies: Privacy Policy, Terms of Service, and AI – Transparency Center
- Twitter (X) Privacy Policy: X Privacy Policy (twitter.com)
- YouTube Privacy Policy: Privacy Policy – Privacy & Terms – Google
Forums and Blogs
Some Services may link to blogs or forums (“forums”) that may or may not be owned or operated by CytoSorbents, Inc. If you choose to participate in forums, we may collect the information you submit to the forums. Note that such information may also be governed by the privacy policies of the respective companies offering the forums.
Tracking Technologies
Our Services may incorporate tracking technologies to provide you with certain functionalities available within our Services. These tracking technologies, including those described below, may collect or generate Personal Information about you when you interact with us, but only if you decide to allow them in your Cookie Settings, or in your individual browser’s settings.
You may adjust these preferences at any time, and you may be prompted to make your selections again if you navigate to a new part of our Services where different tracking technologies are used. Please review the Cookie Policy that is displayed at the time you use our Services to learn more, and feel free to contact us with any questions.
Our Services may incorporate the following tracking technologies:
- Cookies: Small files that are transferred to your device’s hard drive for a period of time to store user preferences and other types of information to help us provide you with certain features. Read more about cookies in our Cookie Policy.
- Web Beacons: Electronic images placed in the code of a webpage, application, or email that allow us to monitor things such as user activity and site traffic.
- Tags: Pieces of code, or tags, which gather information about users. For example, tags are used on our websites to better understand online usage patterns and trends. We may also use tags in our emails or newsletters to count how many of those messages are read.
- Widgets: Small components embedded within our Services which enable you to use certain functionalities.
- Google Analytics: Google Analytics uses cookies to collect data such as time of visit, website pages visited, time spent on each CytoSorbents, Inc. website page, IP address, URL, and type of operating system. To learn more about how Google Analytics collects and processes Personal Information, please visit www.google.com/policies/privacy/partners.
How We Use Your Personal Information
Depending on what Services you use and how you interact with us, we may use your Personal Information in the following ways. If you live in certain jurisdictions (including but not limited to the European Union), we may not process your information for some of the below purposes unless you first provide us with your consent to do so.
To Administer and Provide You with the Services
For example, if you access a section of our Services requiring a username and password, we will use your Personal Information to create and/or administer your account, authenticate your credentials, remember your preferences, and allow you to access and use the Services.
To Manage Business Transactions
During certain business interactions, we may use your Personal Information to manage business transactions with you or the company or organization you work(ed) for. This may include making or responding to requests related to the Services, or obtaining or making payments for such Services.
To Respond to Your Inquiries and Provide Information about the Services
If you send us questions, make an inquiry or request, or ask for certain information, we may use your Personal Information to respond to you.
To Send You Marketing Information
We may use your Personal Information to provide you with information about our Services, to send you marketing communications, or to enable you to participate in surveys or questionnaires.
To Serve Advertisements You May Be Interested In
We may use your Personal Information to tailor and deliver relevant advertisements to you when you are using our Services, or when you are accessing a third party service. For example, you may receive online advertisements, emails, texts or social media notifications from us for promotional purposes.
To Improve the Services and User Experience
We may use your Personal Information to gather and create statistics regarding your usage of our Services. For example, we may monitor how many users visit our Services in a given time, which components or pages are most popular, which domains you come from, which browsers you use, and how you navigate our Services. We use this information to better understand our users, personalize users’ experiences and interactions with us, and improve the content and performance of our Services.
To Comply With Applicable Laws and Our Legal Obligations
We may use your Personal Information to comply with applicable laws, regulations, industry codes of conduct, and CytoSorbents, Inc.’s internal policies and procedures, including:
- For compliance with applicable retention obligations;
- For purposes of adverse event reporting, pharmacovigilance, product safety, and other reporting obligations;
- To respond to lawful requests by public authorities (e.g., to investigate fraud or respond to a government request);
- To investigate potential breaches; and
- To protect our rights, property, safety, and those of our users.
For Treatment and/or Quality Control
We may use your Personal Information to carry out your treatment, including treatment prescribed by a physician, and to provide you with general information about your treatment. We may also use your Personal Information to ensure high standards of quality and safety for our Services related to health care, medical products, and medical devices.
Merger or Sale
If we are involved in a merger, acquisition, or sale of our assets (or a portion thereof), it may impact how we process your Personal Information. In such an instance, we will comply with all applicable laws and treat your Personal Information accordingly.
Other Uses
Where permitted by law, we may also enhance or combine information about you, including your Personal Information, with information about you that we obtain from third parties for the same purposes described in this Global Privacy Policy.
Legal Basis for Processing Your Personal Information
CytoSorbents, Inc. will only use or process your Personal Information if the use or processing is permitted by applicable privacy laws in your jurisdiction. This is sometimes referred to as having a “legal basis” to use or process your Personal Information. The legal basis CytoSorbents, Inc. may rely on to process your Personal Information may include:
Performance of a Contract
For example, to carry out our contractual obligations with you or your institution pursuant to a consulting, professional services, or other type of contract to supply goods or services.
Legal Obligations
For example, some countries have transparency requirements regarding interactions with healthcare professionals, or requirements to provide information to authorities in case of adverse events or medical incidents related to the use of our Services.
Vital Interests
For example, when processing your Personal Information is in your vital interest or required to protect your life.
Consent
For example, if you opt-in to receive marketing communications from us or expressly provide your consent for us to process your Personal Information. In the event you provide your consent, you may also withdraw your consent when permitted by applicable law, if you contact us.
Legitimate Interests
This may include, for example, managing, operating, maintaining, and securing our websites, network systems, and other assets; providing you with features and functionalities in the Services; and communicating with you to manage our business interactions.
How We Interact with Third Parties
Links to Third-Party Websites
As a resource to our users, we may provide links to other unaffiliated websites or services within our Services. If you choose to visit such third-party websites or services, please note that any information you submit to them is not subject to this Global Privacy Policy.
CytoSorbents, Inc. Affiliates and Subsidiaries
CytoSorbents, Inc. is a global company and it shares Personal Information with its affiliates and subsidiaries for the purposes described in this Global Privacy Policy. For more information about CytoSorbents, Inc.’s affiliates and subsidiaries, please contact us.
Service Providers
We may share your Personal Information with third party service providers that we hire to help us administer and provide the Services to you. These third parties are required to treat your Personal Information in accordance with appropriate contractual and legal privacy and security requirements.
Advertising
We may engage third party service providers who utilize tracking technologies to serve you advertisements that you may be interested in. Some of these advertisements may be personalized to you, meaning that the advertisements are intended to be relevant to you based on what we, or the third party service providers, know about you. Depending on where you live, we may be required to obtain your consent before we serve you with these types of advertisements. If you are unsure whether or not you provided your consent, you can always review and adjust your Cookie Settings or your individual browser’s settings.
Embedded Videos
We may provide embedded videos on our Services that are hosted by third party video providers, such as YouTube (Google). If you click “play” on a video embedded within the Services, the third-party video provider may place tracking technologies on our Service, for example to remember where you left off in the video. Depending on where you live, we may be required to obtain your consent before this type of tracking technology is used. If you are unsure whether or not you provided your consent to such tracking technology, you can always review and adjust your Cookie Settings or your individual browser’s settings.
Joint Services
We may partner with other companies to provide you with Services that are jointly offered or “co-branded” or “co-promoted.” As such, you may see the logos of both CytoSorbents, Inc. and one or more of our partners. You should review the privacy policies of such partners before providing them with your Personal Information, as their privacy practices may differ from ours.
International Transfers of Personal Information
CytoSorbents, Inc. is a global company with global affiliates, and therefore we use global vendors, subcontractors, systems, and applications. As a result, the Personal Information that we collect and generate about you may be transferred, stored, or accessed in a destination outside of your country which may have less strict, or no, data protection laws, when compared to the laws in your country. Any transfers of Personal Information to CytoSorbents, Inc. affiliates or third parties outside your local country will be conducted in compliance with the international data transfer restrictions that apply under applicable data protection laws.
We take legally required steps under applicable data protection law to ensure that adequate safeguards are in place (e.g., standard contractual clauses, data transfer agreements) to protect your Personal Information in accordance with this Global Privacy Policy. You may contact us for more information about the safeguards that we have put in place to protect your Personal Information and your privacy rights when we make cross-border transfers of your Personal Information.
Your Personal Information Rights
In certain circumstances, local privacy laws may give you rights with respect to your Personal Information, as described in more detail below. You may exercise your rights by accessing your user account or profile when using certain of our Services. You can also exercise your rights by contacting us.
We will handle any request to exercise your rights in accordance with applicable law, but please note that these rights may not be absolute. CytoSorbents, Inc. may refuse or deny a request in accordance with applicable privacy laws. Additionally, depending on the circumstances and where you are located, not all of the below rights may be available to you.
Your rights with respect to your Personal Information may include the following:
Withdraw Consent
If we use or share your Personal Information based on your consent, you may withdraw your consent at any time. Note that withdrawal of your consent will not affect the lawfulness of our uses or sharing of your Personal Information before you withdraw your consent.
Access
You may request access to or copies of your Personal Information. You may also request what types of Personal Information we have, the purposes for which we process it, and who has received access to your Personal Information.
Correction and Deletion
You may request that we correct your Personal Information if you think it is inaccurate or incomplete. You can also request that we erase or delete your Personal Information in certain circumstances.
Restrict Processing
You may request that we restrict the processing of certain Personal Information.
Data Portability
You may request that we provide you with your Personal Information that we obtained from you, and you can ask us to provide it to another entity.
Object
You may have the right to object to our processing of your Personal Information for certain purposes.
Lodge a Complaint
If you believe we are using, disclosing, or otherwise processing your Personal Information in a way that is not in accordance with applicable law, you can lodge a complaint with the relevant data protection authority in your country.
Minors
Online components of our Services are not directed to children under the age of 13, and we do not knowingly collect Personal Information via online Services from children under the age of 13. If you think that we have collected Personal Information via an online Service from a child under the age of 13, please contact us.
Security
We have reasonable and appropriate security measures in place to protect against the loss, misuse, and alteration of any Personal Information we receive about you. We maintain reasonable security standards to protect the Personal Information that we maintain. If you have any questions about the security of your Personal Information, please contact us.
Do Not Track
Certain laws require us to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. As of the effective date of this Global Privacy Policy, an industry standard has not yet been established on how to respond to these signals, and therefore CytoSorbents, Inc. does not currently respond to such signals. Instead, we adhere to the standards set out in this Global Privacy Policy. If you have any questions, please contact us.
Data Retention
We will retain your Personal Information only for as long as we reasonably consider it necessary for achieving the purposes set out in this Global Privacy Policy, or for as long as we are legally required to retain it. If you have questions about applicable retention periods, please contact us.
How to Submit a Complaint
CytoSorbents, Inc. respects your privacy and is committed to ensuring that complaints and disputes concerning CytoSorbents, Inc.’s privacy practices are investigated and resolved. CytoSorbents, Inc.’s process for receiving and resolving complaints is as follows: If an individual submits a privacy-related concern to CytoSorbents, Inc., it will be investigated by CytoSorbents, Inc., which will take steps to resolve the concern.
Privacy questions or complaints may be submitted to CytoSorbents, Inc. by contacting us by e-mail, telephone, or mail.
Europe:
CytoSorbents Europe GmbH
Müggelseedamm 131
12587 Berlin
Tel.: +49 30 654 99 145
[email protected]
Data protection officer EU:
Prof. Norman Uhlmann
h3ko Vertriebsgesellschaft mbH
Pappelallee 64, 16359 Biesenthal
Germany
E-Mail: [email protected]
Tel.: +49(0) 30-549887013
US:
CytoSorbents Corporation and CytoSorbents Medical Inc.
305 College Road East
Princeton, New Jersey 08540; United States of America
T: +1 732-329-8885
[email protected]
Data protection US:
Daniel Churco
Director of Information Technology
305 College Road E
Princeton, NJ 08540
United States of America
E-Mail: [email protected]
Tel.: (D) 732.392.6002
Changes to this Global Privacy Policy
We may periodically update this Global Privacy Policy to describe new Services and how such Services may affect our collection and use of Personal Information. If we make material changes to this Global Privacy Policy, we will post a notice of the material changes on our website. In the event that we use your Personal Information for other purposes not specified in this Global Privacy Policy, we will notify you. We encourage you to periodically review this Global Privacy Policy for the latest information on our privacy practices.
Contact Us
If you have questions or concerns about this Global Privacy Policy, our information practices, or any other aspect of the privacy and security of your Personal Information, please contact us using the information below.
Data protection officer:
Prof. Norman Uhlmann
h3ko Vertriebsgesellschaft mbH
Pappelallee 64, 16359 Biesenthal
Germany
E-Mail: [email protected]
Tel.: +49(0) 30-549887013
Data protection US:
Daniel Churco
Director of Information Technology
305 College Road E
Princeton, NJ 08540
United States of America
E-Mail: [email protected]
Tel.: (D) 732.392.6002