Last updated: October 23, 2026

The California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (collectively, the “CCPA”), gives California residents certain rights and requires businesses to make certain disclosures regarding their collection, use, and disclosure of personal information. This Business Contacts Privacy Notice (“Notice”) describes how Recor Medical, Inc. (“Recor,” “we,” “us,” or “our”) collects, uses, discloses, and retains personal information about our vendors, contractors, service providers, their employees, and other individuals with whom we interact in a business-related capacity who are residents of California (collectively, “Business Contacts”).

Please note that this Notice does not apply to information we collect from non-Business Contacts or to Business Contacts that are not California residents. For further details about our privacy practices pertaining to non-Business Contact personal information, please visit https://www.recormedical.com/privacy-policy/

I. Definitions

• “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Business Contact or household. Personal information also includes “sensitive personal information” that we specifically describe in this Notice. Personal information does not include publicly available information or deidentified or aggregated consumer information.
• “Sell,” “Sale,” or “Sold” means renting, releasing, or transferring an individual’s personal information to a third party for money or other valuable consideration.
• “Share,” “Shared,” or “Sharing” means transferring an individual’s personal information to a third party for cross-context behavioral advertising purposes, whether or not for money or other valuable consideration.
• “Third Party” means any non-affiliated person that is not a Service Provider.
• “Service Provider” means a service provider, contractor, or processor which collects, stores, or otherwise handles personal information for us and is bound by contractual obligations to use your personal information only as directed by us.

Other terms used herein that are defined terms under the CCPA shall have the meanings afforded to them by the CCPA, whether or not capitalized, unless the context indicates otherwise.

II. Categories of Business Contacts Personal Information We Collect

We collect, and in the past 12 months have collected, the following categories of personal information from Business Contacts:

III. Purpose for Collecting, Processing, and Disclosing Business Contacts Personal Information

We collect, process, and disclose, and in the past 12 months have collected, processed, and disclosed, the categories of personal information listed in Section II of this Notice for the following purposes:

• To authorize, grant, administer, monitor, and terminate access to or use of Recor systems, facilities, records, property, and infrastructure;
• To respond to your inquiries about our engagement with you and to provide you with information when you request it;
• To identify and evaluate potential Business Contacts;
• For budget planning and administration;
• To provide training and certification and conduct background checks and performance evaluations;
• For problem resolution, internal investigations, auditing, compliance, risk management and security purposes;
• To conduct conflict of interest reporting;
• For project management, planning and managing business activities, including management of Business Contact relationships and Recor personnel that interact with Business Contacts;
• To perform on-site injury and illness evaluation and reporting, for those who access our facilities;
• To monitor and conduct surveillance for industrial hygiene, public health and safety;
• To audit our programs and resources for compliance and security purposes;
• To provide access to our resources and keep track of our interactions with you both offline and online;
• To develop our sales and marketing programs;
• To determine the appropriateness, given the requirements of laws applicable to our business, of engaging Business Contacts for certain of the business purposes described above;
• To comply with a law or regulation, court order or other legal process, including to comply with requests from competent authorities;
• To reimburse you for expenses or pay you under a contract we have entered into with you;
• To manage and protect our network and IT systems;
• To protect someone’s health, safety or welfare;
• For the establishment, exercise or defense of legal claims or proceedings, to protect our rights or property, and to comply with and enforce our policies; and
• For fraud prevention and detection.

Further, we collect, process, and disclose the categories of sensitive personal information described in this Notice only for purposes that are permitted by the CCPA regulations, including to perform the services or provide the goods reasonably expected by an average Business Contact who requests those goods or services and to perform services on behalf of the business.

We may also aggregate and/or deidentify Business Contact personal information and analyze those data for analytical, research, statistical, or any other purposes permitted by law. When we do so, we take reasonable measures to ensure that the information cannot be associated with a Business Contact or household, and we maintain and use the information in deidentified form. We will not attempt to reidentify the information, except that we may attempt to reidentify the information solely for the purpose of determining whether our deidentification processes satisfy applicable legal requirements. After it has been deidentified, the information is no longer personal information and is not subject to this Notice.

Please note that we may also process Business Contacts personal information via use of automated technologies, including artificial intelligence, for the purposes listed above. To the extent permitted by applicable law, we may also use personal information we collect to train automated technologies we use for the above purposes.  However, we do not process Business Contact personal information using automated decision making technologies to make significant decisions concerning Business Contacts. 

IV. Business Contacts Personal Information Retention

We may retain your personal information for as long as your account is active or as needed for the specific business purpose for which it was collected. In some cases, we may be required to retain information for longer to comply with laws or regulations or other legal obligations, resolve disputes and enforce our agreements.

V. Sale & Sharing of Business Contact Personal Information

We generally do not Sell or Share personal information that we collect about Business Contacts. However, we do Sell and Share, and we have Sold and Shared in the past 12 months, personal information we collect from consumers in other contexts. This includes personal information collected via cookies and other tracking technologies, including identifiers, such as IP addresses and other device identifiers, commercial information, internet or other electronic network activities information, and inferences via cookies and other tracking technologies used on our Services to third party marketing and analytics providers. We Sell and Share these categories of personal information for marketing, advertising, and analytics purposes, including to analyze or predict consumer preferences to identify aggregated trends to develop, improve or modify our products, services and business activities, and to deliver marketing communications, promotional materials, or advertisements, including interest-based advertisements, and improve our advertising efforts. We do not otherwise “Sell” or “Share” other types of personal information we may collect about Business Contacts outside the cookie and online tracking technology context.

California Business Contacts have the right to opt-out of the Sale and Sharing of their personal information. To do so, click the “Your Privacy Choices” link in the footer of our websites and click “Reject All.”

We do not Sell or Share personal information of Business Contacts we know, or reasonably should know, are under 16 years of age.

VI. Disclosure of Business Contacts Personal Information

We disclose, and in the past 12 months have disclosed, the categories of Business Contacts personal information listed in Section II of this Notice in the following contexts:

• Affiliates. We may disclose the personal information we collect about you to our parent company, affiliates, subsidiaries, and related entities for the purposes set out in Section III of this Notice.
• Service Providers. We may disclose the personal information we collect about you to Service Providers who perform functions and business operations on our behalf. For example, we engage Service Providers to help audit our interactions and transactions with you, address security, fix errors, help with our internal research, verify service quality and safety, and provide other services such as information technology and hosting services, and legal and other professional services. We impose contractual limitations on our vendors’ use of personal information they collect in conjunction with providing services to us

We may also disclose Business Contacts personal information in the following contexts:

• Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company. As part of the business transfer process, we may disclose certain of your information to lenders, auditors, and third party advisors, including attorneys and consultants. If such a transfer occurs, we will seek assurances that the recipients, including any successor organization, will treat the personal information we disclose to it in accordance with this Notice.
• In Response to Legal Process. We may disclose your personal information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
• To Protect Us and Others. We disclose your personal information where we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions or this Notice, or as evidence in litigation in which we are involved.
• Aggregated and Deidentified Information. We may disclose aggregated, anonymized, or deidentified information about you for any purpose permitted under applicable law.
• Consent. We may disclose personal information as described in any privacy notice we provide to you via our Services, or with your consent if we obtain it from you in a particular context, to the extent permitted by applicable law.

VII. Sources of Business Contacts Personal Information

We collect personal information directly from Business Contacts, as well as from joint marketing partners; public databases; providers of demographic data; publications; professional organizations; educational institutions; social media platforms; and service providers and third parties when they disclose information to us.

VIII. Your Rights

As a California resident, you have the following rights regarding our collection and use of your personal information, subject to certain exceptions

Rights that Require Verification.

• Right to Know: You may request that we provide you with the following information about how we have handled your personal information:
  • The categories of personal information we have collected about you.
  • The categories of sources of the personal information we have collected about you.
  • Our business or commercial purposes for collecting, Selling, and Sharing the personal information.
  • The categories of Third Parties to whom we have disclosed personal information.
  • The categories of personal information we have Sold or Shared about you and the categories of Third Parties to whom we have Sold or Shared the personal information.
  • The categories of personal information we have disclosed for a business purpose and the categories of Service Providers to whom we have disclosed the personal information.
• Right to Deletion: You may request that we delete any personal information about you that we collected from you.
• Right to Correction: You may request that we correct any inaccurate personal information we maintain about you.
• Right to Access Specific Pieces of Personal Information: You may ask to obtain the specific pieces of personal information we have collected about you. You may not exercise this right more than two times in a calendar year.

Exercising the Rights to Know, Deletion, Correction, and Access Specific Pieces of PI: You can make such a request by calling us at 1-888-914-9661 (PIN 347535) or submit a request through our Webform. To verify your identity, we will match the information provided in the request to the information we have in our records. If necessary, we may ask the requestor to provide additional information to verify your identity and confirm that the request is valid. You may be able to authorize an agent to submit a request on your behalf. Authorized agents may submit a request in the same manner as a Business Contact, as listed above. When you use an authorized agent, we may ask the authorized agent to provide a copy of the Business Contact’s signed permission authorizing the agent to act on the Business Contact’s behalf, and in certain circumstances, we may ask you to verify your own identity directly with us. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.

Rights that Do Not Require Verification

• Right to Opt-Out of Sale and Sharing: You have the right to opt out of the Sale and Sharing of your personal information. To do so, click the “Your Privacy Choices” link in the footer of each page of our website and click “Reject All”.
• Limit the Use of Your Sensitive Personal Information: We do not use sensitive personal information that we collect about Business Contact for purposes other than those that are permitted by the CCPA regulations. But if we did, you would have the right to limit the use of your sensitive personal information to the purposes permitted by the CCPA.
• Right to Opt-Out of ADMT: We do not process Business Contact personal information using automated decision making technologies to make significant decisions concerning Business Contacts. But if we did, you would have the right to opt out of our use of automated decision making technologies to make significant decisions about you, subject to certain exceptions.

Opt-Out Preference Signals: We recognize opt-out preference signals that we are required to recognize for compliance with applicable law. Where required by the CCPA, we treat such opt-out preference signals as a valid request to opt-out of Sale and Sharing, as applicable, for the browser or device through which the signal is sent and any consumer profile we have associated with that browser or device, including pseudonymous profiles. Further, if we know the identity of the consumer from the opt-out preference signal, we will also treat the opt-out preference signal as a valid request to opt out of Sale and Sharing for such consumer. Consumers may use opt-out preference signals by downloading or otherwise activating them for use on supported browsers and setting them to send opt-out preference signals to websites they visit. However, our sites do not respond to the “Do Not Track” signal, which is different from the opt-out preference signals described above.

Non-Retaliation: You have the right not to receive discriminatory treatment for the exercise of these rights. For example, we will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.

IX. Other Disclosures

Financial Incentives: We do not provide financial incentives to California Business Contacts. We will describe such programs to you if and when we offer them to you.

X. Changes to this California Business Contact Notice

We may update this Notice from time to time and will provide notice of such changes by updating the “Last Updated” date listed on this Notice. If we make any changes to this Notice that materially affect our practices with regard to the information we have previously collected about you, we will, if required by applicable law, provide you with additional notice of such change by, for example, highlighting the change on our websites or sending you an email.

XI. Contact Us

If you have any questions or concerns regarding our Notice or any questions about the security of our Services, please contact us by email at DPO@RecorMedical.com or by phone at (888) 914-9661.