Privacy Policy

YOUR PRIVACY IS IMPORTANT TO US. PLEASE READ THIS PRIVACY POLICY TO LEARN ABOUT THE INFORMATION THAT SEASPINE COLLECTS FROM YOU AND HOW CASSIOPEA USES THAT INFORMATION.

BY USING THE SITE YOU CONSENT TO THE COLLECTION, USE, AND TRANSFER OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, THEN PLEASE DO NOT USE THE SITE.

PLEASE BE AWARE THAT THE SITE’S ASSOCIATED SERVICES AND SYSTEMS ARE HOUSED ON SERVERS IN THE UNITED STATES. IF YOU ARE LOCATED IN THE EUROPEAN ECONOMIC AREA YOUR DATA WILL BE PROCESSED IN COMPLIANCE WITH THE REGULATION 2016/679, AS FULLY EXPLAINED IN THE PRIVACY POLICY YOU CAN FIND AT THIS LINK.

Scope

This Privacy Policy describes the information that Cassiopea collects (directly or indirectly) and why we collect it, what we do with the information we collect and how you can manage your Personal Information (defined below).

This Privacy Policy does not apply to any website or service that does not display or link to this Privacy Policy.

This Privacy Policy is incorporated into and made a part of Cassiopea’s Terms of Use. If you have not done so already, please also review the Terms of Use.

About Children

This Site is not intended for children under the age of 18. We will not knowingly collect information from Site visitors in this age group. We encourage parents to talk to their children about their use of the Internet and the information they disclose to websites.

Active Information Collection

Like many websites, this Site actively collects information from its visitors both by asking you specific questions and by permitting you to communicate directly with us via email and feedback forms. Some of the information that you submit may constitute Personal Information (that is, information that can be uniquely identified with you, such as your full name, address, email address, phone number, and so on). Some areas of this Site may require you to submit information in order for you to benefit from the specified features (e.g., newsletters, press releases) or to participate in a particular activity. You will be informed at each information collection point what information is required and what information is optional.

Passive Information Collection

Cookies

As you navigate through a website, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, Internet tags, and navigational data collection.

We use Internet Protocol (IP) addresses on this Site. An IP address is a number assigned to your computer by your Internet Service Provider so you can access the Internet and is generally considered to be non-personally identifiable information, because in most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user’s computer). We use your IP address to diagnose problems with our server, report aggregate information, determine the fastest route for your computer to use in connecting to our Site, and administer and improve the Site.

A “cookie” is a bit of information that a website sends to your Web browser that helps the site remember information about you and your preferences.

Session cookies are temporary bits of information that are erased once you exit your Web browser window or otherwise turn your computer off. Session cookies are used to improve navigation on websites and to collect aggregate statistical information. This Site uses session cookies.

Persistent cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (e.g., passwords), helping to determine what areas of the website visitors find most valuable, and customizing the website based on your preferences. This Site uses persistent cookies.

“Internet tags” (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the website server information such as the IP address and browser type related to the visitor’s computer. We do not use Internet tags at this Site.

“Navigational data” (“log files,” “server logs,” and “clickstream” data) are used for system management, to improve the content of the site, market research purposes, and to communicate information to visitors. This Site uses navigational data.

Do Not Track: Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Cassiopea, do not respond to DNT signals.

Use and Disclosure of Information

Cassiopea uses your Personal Information for the purposes for which you gave it to us. For example, if you have expressed an interest in a particular product or receiving investor updates, we will use your data to provide you with the requested information. We may also ask for your permission to send you information about Cassiopea or its products that we believe may be of interest to you.

We also may use your Personal Information and data concerning your use of this Site for analytics purposes. For example, we may use this data to determine which parts of our Site are of most interest to users, which parts are of least interest, and to modify the Site accordingly. Except as otherwise stated, we may use your information to improve the content of our Site, to customize the Site to your preferences, to communicate information to you (if you have requested it) for our marketing and research purposes, to consider you for employment, and for the purposes specified in this Privacy Policy.

We may disclose your Personal Information with other Cassiopea affiliates, or partners with whom we are jointly marketing a product or service, and service providers whom we have engaged to assist us in our business functions. These entities will be required to abide by this Privacy Policy. In addition, we may disclose your Personal Information to third parties, located in the United States and/or any other country, but only:

i. to contractors we use to support our business (e.g., fulfillment services, technical support, delivery services, and financial institutions), in which case we will require such third parties to agree to treat it in accordance with this Privacy Policy; ii. in connection with the sale, assignment, or other transfer of the business of this Site to which the information relates, in which case we will require any such buyer to agree to treat it in accordance with this Privacy Policy; or iii. where required by applicable laws, court orders, or government regulations. In addition, we will make full use of all information acquired through this Site that is not in personally identifiable form.

If you subscribe to receive one or more promotional communications from Cassiopea, you can later unsubscribe by following the instructions in such communications.

We will also disclose your personally identifiable information if we reasonably believe we are required to do so by law, regulation, legal process, or other government authority (such as reporting safety information to the Food and Drug Administration); to investigate fraud; to protect your safety or the safety of others; or when we have reason to believe that disclosing this information is necessary to protect our rights or the rights of a third party who may be harmed by your activities.

Applicable law may also require Cassiopea to disclose your Personal Information if: (i) reasonably necessary to comply with legal process (such as a court order, subpoena, or search warrant) or other legal requirements; (ii) disclosure would mitigate Cassiopea’s liability in an actual or threatened lawsuit; (iii) necessary to protect legal rights of Cassiopea, users, customers, business partners, or other interested parties; or (iv) necessary for the prevention or detection of crime (subject in each case to applicable law). For residents of the European Economic Area, Cassiopea will process data in accordance to the provisions of the EU Regulation 2016/679 on the protection of personal data (General Data Protection Regulation – GDPR) and therefore will disclose Personal Information only when and to the extent that is permitted by the GDPR as fully explained in the Privacy Policy you can find at this link. We will not sell your Personal Information to any other company or organization except we may transfer your Personal Information to a successor entity upon a merger, consolidation, or other corporate reorganization in which Cassiopea participates or to a purchaser of all or a portion of Cassiopea’s assets. Such successor entity shall be bound by the terms and conditions of this Privacy Policy.

Access and Correction

Cassiopea is committed to respecting your right to access and correct your Personal Information. To keep your Personal Information accurate, current, and complete, please contact us at info@cassiopea.com. We will take reasonable steps to update or correct Personal Information in our possession that you have previously submitted via this Site.

Security

We take reasonable steps to protect the information that you provide through our Site and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, email sent to or from this Site may not be secure, and you should therefore take special care in deciding what information you send to us via email. Moreover, where you use passwords, ID numbers, or other special access features on this Site, it is your responsibility to safeguard them. You are responsible for maintaining the confidentiality of your account password and for any access to or use of the Site using your password, whether or not authorized by you. Please notify us immediately of any unauthorized use of your password or account or any other breach of security.

As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information. If we believe that the security of your information may have been compromised, we will endeavor to give you appropriate notice as quickly as possible, including by email, and in accordance with applicable laws.

If we become aware of a breach that affects the security of your Personal Information, we will provide you with notice as required by applicable law. To the extent permitted by applicable law, Cassiopea will provide any such notice to you at your email address. By using the Site, you agree to accept notice electronically.

We retain Personal Information in identifiable form only for as long as necessary to fulfill the purposes for which the Personal Information was provided to Cassiopea or, if longer to comply with legal obligations, to resolve disputes, to enforce agreements, and similar essential purposes.

Links to Other Websites

This Site may contain links or references to other websites. Please be aware that we do not control other websites and that, in any case, this Privacy Policy does not apply to those websites. We encourage you to read the privacy policy of every website you visit.

Notice to International Visitors

The Site is operated in the United States but the information that you provide is accessible to affiliates, vendors, and suppliers in other countries. If you are visiting the Site from a country other than the United States, your communication with Cassiopea will necessarily result in the transfer of information across international boundaries. The level of legal protection for Personal Information is not the same in all countries. If you are using the Site from outside of the United States, by providing your Personal Information to us, you consent to the transfer of your Personal Information to the United States for processing consistent with this Privacy Policy in the United States and in any country to which we may transfer your information in the course of our business operations.

Other Terms

Your use of this Site is subject to the Terms of Use https://www.cassiopea.com/terms-of-use/

How to Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or the information practices of this site, please contact us as follows:
Email: info@cassiopea.com
Mail:
Cassiopea, Inc.
6265 Greenwich Drive, Suite 210
San Diego, California 92122
Attention: Data Protection Officer

This policy was updated in October 2019.

___________________________

INFORMATION NOTICE ACCORDING TO GENERAL EUROPEAN DATA PROTECTION REGULATION N. 679/2016 (GDPR)

THIS PAGE DESCRIBES THE WAYS IN WHICH CASSIOPEA S.P.A. AND CASSIOPEA INC., AS JOINT DATA CONTROLLERS (ALSO DEFINED AS FOLLOW “US” OR “WE” OR “CASSIOPEA”), COLLECT AND PROCESS YOUR PERSONAL DATA THROUGH THE WEBSITE WWW.CASSIOPEA.COM

ATTENTION TO CONFIDENTIALITY, PROTECTION OF USERS’ PERSONAL DATA REPRESENT OUR PRECISE BUSINESS COMMITMENT. IN FACT, WE PROCESS YOUR PERSONAL DATA WITH THE UTMOST CARE AND IN COMPLIANCE WITH THE APPLICABLE PRIVACY AND DATA PROTECTION REGULATIONS (IN PARTICULAR GENERAL DATA PROTECTION REGULATION 679/2016) AND THEREFORE, AS PROVIDED FOR BY ART. 13 OF THE GDPR, WE PROVIDE THE USERS WITH THIS INFORMATION, DESCRIBING THE FOLLOWING ELEMENTS OF THE DATA PROCESSING.

What Data Do We Collect And Process?

The personal data we process is the information that you voluntarily decide to provide us with a contact request or to ask a question.

When you send a request using the appropriate form, or by e-mail or when you register to newsletter, we process your identification data and your contact data (such as name, surname, email address, company and role).

In addition to the common data provided directly and intentionally by the user, the computer systems and software procedures used to operate this website acquire, during their normal operation, some personal navigation data whose transmission is implicit in the use of the protocols of communication of the Internet network. This is information that is not collected for the purpose of association with the identity of the interested party, but which by their very nature would allow, through processing procedures and associations with data held by third parties, to identify users. This category of data includes IP addresses or domain names of the computers used by users who connect to the site and other parameters relating to the operating system and the user’s IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site.

For more information on this, please refer to the dedicated Cookie Policy under the Passive Information Collection section in this Privacy Policy.

For What Purposes Do We Use Your Data?

The main purpose is to provide you with the opportunity to get in touch with us and satisfy your specific request, send you informative contents about it and/or allow you to access the chosen services.

Through the appropriate section of the site you can voluntarily decide to subscribe to our newsletter in order to receive press releases about topics specifically selected by you (news, financial reports, presentations, events, etc.). You can change your preferences or unsubscribe at any time.

The underwriting of data is optional, however, the refusal to release your data for this purpose makes it impossible for us to handle your request and satisfy your needs.

How Do We Protect Your Data?

Data is processed using mainly automated tools and for the time strictly necessary to achieve the purposes for which they were collected. The appropriate security measures, as required by General Data Protection Regulation (EU) 2016/679, are applied to prevent data breaches.

Data Retention

Personal data will be kept for the time necessary to complete your request and to ensure you to continue to receive newsletters as long as you consider it appropriate.

To Whom Do We Communicate Your Data?

Data that you send via this site will be processed by Cassiopea. Data could be processed by the company that manages the website and the related systems connected to it.

We inform you that the processing of personal data is carried out by Cassiopea S.p.A. under a joint data controller agreement with Cosmo Group, to whom some services have been outsourced. The parties have determined in a transparent manner the respective responsibilities regarding the observance of the obligations deriving from the Regulation, by means of an internal agreement stipulated in accordance with Art. 26 of the EU Regulation.

We also inform you that the processing of personal data is carried out by Cassiopea S.p.A. under a joint data controller agreement with Cassiopea Inc. The parties have determined in a transparent manner the respective responsibilities regarding the observance of the obligations deriving from the Regulation, by means of an internal agreement stipulated in accordance with Art. 26 of the EU Regulation. In particular, the parties agree that the respective areas of joint controlling concern the processing of your data in the management of this website.

Extra UE Data Transfer

Cassiopea is composed of companies with offices located throughout Europe and outside Europe.

It should be noted that the transfer of personal data to non-EU countries is permitted only in cases where the State or the recipient company of the data, could guarantee an adequate level of data protection compared to the provisions of General Data Protection Regulation.

Data are transferred to companies and to providers based in the United States which guarantee an adequate level of data protection by signing standard contractual clauses.

Data will be stored at server Amazon.com Inc. which adheres to the privacy shield.

Passive Information Collection:

Cookies
As you navigate through a website, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, Internet tags, and navigational data collection.

A “cookie” is a bit of information that a website sends to your Web browser that helps the site remember information about you and your preferences.

In detail, the cookies present on the Site are as follows:

Cookie	Purpose	Duration	Privacy Information
Google Analytics	Anonymous website analytics	Until cookies are cleared by the user	No identifiable information collected

What Are Your Rights?

Pursuant to EU Regulation 679/2016, the following rights are recognized: the right to ask to Data Controller for access to personal data (Article 15), rectification (Article 16), Right to be erased (Article 17), limitation of processing of personal data ( Article 18), the right to data portability (Article 20) or to object to their processing (Article 21), in addition to the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects that concern you or which significantly affect your person (Article 22).

Requests can be made to:

Cassiopea S.p.A.
Address: Via Cristoforo Colombo 1, Lainate, Italy
E-mail: info@cassiopea.com
Phone: +39 0286891124

The right to lodge a complaint with the supervisory authority (Article 77 of GDPR) is also recognized if you believe that the processing carried out by Data Controller is not compliant.

Changes To The Rules On Privacy

The website, its content and these Privacy rules may be periodically updated or changed without notice. Any changes to the following information notice will affect the processing of data collected as a result of the change. We therefore ask you to periodically review any changes to the Privacy.