LAST MODIFIED: JMay 30 10, 2021

Privacy is very important to Lumendi Ltd., its subsidiaries and affiliates (collectively, “Keep Your Colon,” “Lumendi,” “we,” “us,” or “our”). We also understand that privacy is very important to you. This Privacy Statement tells you how we protect and use information that we gather through our web sites, including any content (which includes text, graphics, images and other information), functionality and services offered on or through our web sites (all of which are collectively called our “Website”).

We may change this Privacy Statement at any time and for any reason. Significant changes to the Privacy Statement are discussed below. If we make changes to this statement, we will update the “Last Modified” date at the top of this page, however we encourage you to review this Privacy Statement each time you visit the Website.

Our Website is not intended for use by persons under 18 years of age. No one under age 18 may provide any personal information to or on our Website. We do not knowingly collect personal information from persons under 18. If you are under 18, do not use or provide any information on our Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a person under 18, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us at info@lumendi.com.

Please read this Privacy Statement 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 to refrain from using our Website. By using this Website, you agree to the terms of the most recent version of this Privacy Statement. Please read our Terms of Use, found at http://lumendi.com/terms-of-use/, and incorporated herein by reference, to understand the general rules about your use of this Website. Except as written in any other disclaimers, policies, terms of use, or other notices on this Website, this Privacy Statement and the Terms of Use are the complete agreement between you and Lumendi with respect to your use of this Website. You may be subject to additional terms that may apply when you access particular services or materials on certain areas in this Website, or by following a link from this Website.

Introduction

The information we receive, and how we use it, depends on what you do when visiting our Website. We collect and use your non-personal information (information that is not identifiable to you personally) differently than your personal information.

What is non-personal information?

Non-personal information is information we collect through this Website that does not identify you as an individual person. It may include information such as the following:

• the type of web browser software you use (for example, Internet Explorer)
• the name of the domain from which you access the Internet
• the Internet address of the web site from which you linked directly to our Website
• the date and time you access our Website
• which pages you have visited on our Website (note: U.S. healthcare providers, please see the “uses of personal information” described below)
• the search terms you use
• the links on which you click
• personal information that has been made non-personal or anonymized (i.e., information that no longer reflects or references an individually identifiable user)

If you visit our Website to read or download information, such as information about a health condition or about one of our products, we may collect certain non-personal information about you from your computer. This information is collected from your computer’s web browser. If you only read or download information on our Website, we do not collect or learn your name, e-mail address, home address, or other personal information about you.

We may place a text file called a cookie in the browser files of your computer when you visit our Website. The cookie may be stored on your computer’s hard drive. The information that we collect using cookies is non-personal information. You are always free to decline our cookies if your browser permits, but some parts of our Website may not work properly for you if you do so. We will not allow third parties other than those companies that we hire to perform services or functions on our behalf to place cookies on your browser. Please refer to your browser help instructions to learn more about cookies, and see below for an explanation of our use of cookies as well as how to opt-out of our use of cookies.

What does Lumendi do with non-personal information?

Because non-personal information cannot identify you or be tied to you in any way, there are no restrictions on the ways that we can use or share non-personal information. We are always looking for ways to better serve you and improve this Website. We will use your non-personal information to help us make this Website more useful to its users. We also will use non-personal information for other business purposes. For example, we may use individual non-personal information or aggregate non-personal information to:

• create reports for internal use to develop programs, products, services or content
• customize the information or services that are of interest to you
• share with or sell to third parties
• provide aggregated information on how visitors use our Website, such as “traffic statistics” and “response rates,” to third parties

We may use third-party tracking and advertising providers to act on our behalf to track and analyze your usage of our Website through the use of cookies, pixel tags/web beacons, and similar technologies. These third parties may collect, and share with us, as we may request, web site usage information about visits to our Website, measure and research the effectiveness of our advertisements, and track page usage and paths followed during visits to our Website. Also, these third-party providers may place our Internet banner advertisements on other web sites that you visit, and track use of our Internet banner advertisements and other links from our marketing partners’ web sites to our Website.

The information collected on Lumendi’s behalf by these third parties does not contain your name, address, e-mail address, or any other personally identifiable information.

California “Do Not Track” disclosures

California Online Privacy Protection Act (CalOPPA) requires Lumendi to let you know how we respond to web browser “Do Not Track (DNT) signals”. When a user turns on the DNT signal, the user’s browser sends a message to web sites requesting them not to track the user. [Because there currently is not an industry or legal standard for recognizing or honoring DNT signals,] we do not honor Do Not Track requests at this time.

Choices about online tracking and opt-out options

For more information on third-party advertising-related cookies and how to opt out of some cookies as you choose, see the descriptions and links below.

Click here  to visit the Network Advertising Initiative site to set preferences and opt out of third-party targeting cookies.

Click here to opt out of the Google Network (Doubleclick, AdSense, Analytics).

EU visitors can find general information and opt-out resources at youronlinechoices.eu and U.S. visitors can visit aboutads.info.

As noted above, you may also configure your own browser settings to block or manage cookies. Please refer to your browser’s “help” function.

What is personal information?

Personal information is information we collect through this Website that we can use to specifically identify you, such as your:

• name
• telephone number
• e-mail address
• medical device serial number
• personal health information
• date of birth
• for U.S. healthcare providers, a National Provider Identifier (NPI) and/or a state license number
• IP (Internet Protocol) address when such address is associated with a specific user

In some places on this Website you have the opportunity to send us personal information about yourself, to elect to receive particular information, or to participate in an activity. For example, you may fill out a registration form, a survey, or an e-mail form and you may elect to receive educational material about our products and therapies.

You also may choose to allow us to personalize your visits to the Website, in which case we will ask you for certain personal information to make your visits to our Website more helpful to you. When this information is combined with the non-personal information that we collect through cookies (described above), we will be able to tell that you have visited our Website before and can personalize your access to our Website, for example, by telling you about new features that may be of interest to you.

How does Lumendi keep and use personal information?

We may keep and use personal information we collect from you through this Website to provide you with access to this Website. In addition, we may keep and use your personal information:

• to respond to your requests
• to personalize your access to our Website, for example, by telling you about new features that may be of interest to you
• to develop records, including records of your personal information
• to contact you with information that might be of interest to you, including information about clinical trials and about products and services of ours and of others
• for analytical purposes and to research, develop and improve programs, products, services and content
• for U.S. healthcare providers, to link your name, NPI, state license number, and/or your IP address to web pages you visit, for compliance, marketing, and sales activities
• to remove your personal identifiers (your name, e-mail address, social security number, etc.); in this case, you would no longer be identified as a single unique individual; once we have de-identified information, it becomes non-personal information and we may treat it like other non-personal information
• to enforce this Privacy Statement and other rules about your use of this Website
• to protect our rights or property
• to protect someone’s health, safety or welfare
• to comply with a law or regulation, court order or other legal process

Does Lumendi ever share personal information with third parties?

Lumendi will not share your personal information collected from this Website with an unrelated third-party without your permission, except as otherwise provided in this Privacy Statement.

In the ordinary course of business, we will share some personal information with companies that we hire to perform services or functions on our behalf. For example, we may use different vendors or suppliers to ship you products that you order on our Website. In these cases, we provide the vendor with information to process your order such as your name and mailing address. In all cases in which we share your personal information with a third-party, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the requested services. We will not sell, exchange or publish your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition.

We may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting visitors to our Website who violate our rules or engage in behavior which is harmful to other visitors (or illegal).

We may disclose your personal information to third parties if we feel that the disclosure is necessary to:

• enforce this Privacy Statement and the other rules about your use of this Website
• protect our rights or property
• protect someone’s health, safety or welfare
• comply with a law or regulation, court order or other legal process

Please note: in addition to the ways that we may keep, disclose, and use information described in this Privacy Statement, we also may keep, disclose, and use personally identifiable information that you provide to us through this Website in ways that we believe are consistent with the U.S. Food and Drug Administration and other governmental guidance, directions, regulations, and laws.

What happens if the privacy statement changes?

If we make changes to this statement, we will update the “Last Modified” date at the top of this page; however, we encourage you to review this Privacy Statement each time you visit the Website. If we make a significant change to our Privacy Statement, [we will post a notice on the homepage of our Website] after the change is made. Significant changes to this Privacy Statement are also described below.

What about privacy on other web sites?

This Website may contain links to other web sites operated by third parties. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of web sites operated by others. This Privacy Statement does not apply to any other web site. We are not responsible for the performance of web sites operated by third parties or for your business dealings with them. Therefore, whenever you click-through to other web sites from this Website we recommend that you review each web site’s privacy practices and make your own conclusions regarding the adequacy of these practices.

Does Lumendi ever communicate directly with visitors to this Website?

We may contact you periodically by e-mail, mail or telephone if you agree to that contact to provide information regarding programs, products, services and content that may be of interest to you. In addition, some of the features on this Website allow you to communicate with us using an online form. If your communication requests a response from us, we will send you a response via e-mail. The e-mail response or confirmation may include your personal information, including personal information about your health, your name, address, etc. We cannot guarantee that our e-mails to you will be secure from unauthorized interception.

Are there special rules about children’s privacy?

We care about protecting the online privacy of children. We will not intentionally collect any personal information (such as a child’s name or e-mail address) from children under the age of 18. If you think that we have collected personal information from a child under the age of 18, please contact us.

What about web site security?

Security is very important to us. We also understand that security is important to you. We take reasonable steps to protect your personal 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, e-mail sent to or from this Website may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail

How to contact Lumendi

If you have questions or comments about this Privacy Statement, please use the Contact Us form on our Website.