Introduction

Stereotaxis, Inc. values your privacy and acknowledges the responsibility that comes with ensuring your personal information is collected properly and protected. This Privacy Statement (“Statement”) explains how we collect, use, share and protect information in our business operations, including within the SynX app and through the following websites: www.stereotaxis.com, www.roboticarrhythmiacare.com, www.roboticheartcare.com, www.synxconnect.com and www.roboticep.com.

These sites are protected by reCAPTCHA, and the Google Privacy Policy and Terms of Services apply to any information collected through these sites.

Scope

This Statement applies to the personal information of potential or actual consumers, consultants, employees, agents, vendors, and business affiliates (“Users”) collected or used by Stereotaxis, Inc., its affiliates or subsidiaries (collectively, “Stereotaxis”, “we”, “our”, “us”). This Statement applies to all the personal information Stereotaxis collects when Users interact with us, such as when visiting our websites, using or purchasing our products or services, contacting customer support (including our virtual support center), and when interacting with us as a business customer, supplier or business partner (collectively, the “Services”).

This includes, without limitation, online and offline collections of personal information. However, at times Stereotaxis collects data with special requirements (for example, health information) which may require a different privacy notice. Whenever that is the case, Stereotaxis will make it clear that the privacy notice concerned is different from this Statement.

By using any of the above-mentioned websites, you agree to the terms of the most recent version of this Statement.

For those who reside in California, please see our Privacy Notice for California Residents for additional information regarding our practices.

Personal Information

Stereotaxis may collect different kinds of personal information that can be used to specifically identify you. This information may include:

• Contact information, such as name, address, email, telephone number, fax number, organization name and/or job title or position;
• Unique identifiers and preference information such as username, password, marketing preferences, internet protocol (IP) address, browser type, operating system, computer or mobile device;
• Resume or CV, including work history, professional qualifications, publications, awards, references, completed training and signature;
• Passport information for travel bookings or identification purposes, social security number (where required by law), bank account details, (emergency) contact persons, and family information (where applicable and in accordance with local law);
• Creditworthiness, VAT number, product, purchase information history, and request documentation;
• Pictures, video and audio recordings where you have provided your permission or as permitted by law consistent with Stereotaxis’ purchased services;
• Sensitive personal information, such as health information or reports of an individual end-customer (e.g., concerning product support during case procedures, claims and investigations, patient pre- and post-operative outcomes for research and statistical purposes or criminal records for due diligence procedures in accordance with applicable law).

Information Collection

Stereotaxis may collect or obtain personal data from the following sources:

• From you directly;
• From the products or services we provide to you or your purchasing entity as a customer;
• Interactions with our websites;
• Service and business providers that assist us with the operation, maintenance, and improvement of our sites, products, and services;
• Health care providers;
• Research partners;
• Social media; and
• Third-party sites and applications.

We may ask you to provide personal information for purposes including, but not limited to, the following:

• Buying or using Stereotaxis products and services;
• Activating or registering products and services or enhancing functionality;
• Receiving information about Stereotaxis products and services, including to the extent permitted by law, information about clinical trials and educational and marketing communications about products and services;
• Participating in Stereotaxis online communities, including our social media channels/pages;
• Participating in video conferencing sessions;
• Storing your preferences for future interactions and communications from Stereotaxis;
• Developing products and services, creating campaigns that are designed around you, and optimizing customer services and continuously improve our websites;
• Improving products and services, and allowing Stereotaxis to keep you informed of, or involve you in the testing of, new products and services;
• Resolving consumer and/or product and services issues;
• For U.S. healthcare providers, to link your name, National Provider Identifier (NPI), state license number, and/or your IP address to web pages you visit, for compliance, marketing, and sales activities;
• Registering visitors of Stereotaxis facilities or Stereotaxis organized events and conferences;
• Contract or tender management;
• Receiving personalized messages, special offers and advertisements that are relevant to your personal interests, based on the information you have shared with us and on the information we have collected through cookies or similar techniques regarding your use of the Stereotaxis websites/social media/blogs;
• Administering any future or current employment or consulting relationship with you and Stereotaxis;
• Enforcing this Privacy Statement and other rules regarding website and service use;
• Protecting our rights or property; or
• Complying with a law, regulation, court order, or other legal process.

In some places on this website, you have the opportunity to send personal information, to elect to receive particular information, or to participate in an activity (e.g. completion of registration forms, surveys, or e-mails).

Stereotaxis maintains physical, technical, and administrative safeguards to protect your personal information and only allows disclosures as permitted by law to assist in providing products or services. We may also collect product and service information and provide these statistics to others in an aggregate form where the information has been de-identified.

FOR ADDITIONAL INFORMATION ABOUT OUR USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES, PLEASE SEE OUR COOKIE POLICY.

Stereotaxis will retain and use the personal information collected for the above-mentioned processes and processing purposes in accordance with legal obligations.

Legal Basis

Stereotaxis’ legal basis for collecting and retaining personal data depends on the processing purposes and the jurisdictional legal requirements. Where the personal information collected involved is of EU citizens, in general, we use the following basis:

• Consent to use the personal information, e.g. where this involves (digital) direct marketing activities and where we would like to use a photo, video or audio recording with identifiable individuals for external publishing;
• Establishment or performance of a contract, e.g., where we enter into a contract with a party and we collect contact information and signatures;
• Compliance with a legal obligation, e.g., where we need to disclose consumer details for compliance with (local or industry) laws such as the Physician Payments Sunshine Act or for compliance with the Medical Device Regulation;
• Legitimate interests of Stereotaxis, e.g., where Stereotaxis collects contact information and preferences to create an optimal user experience for its customers;
• Public interest or for the exercise of public authority in strictly limited cases, e.g., where we would be required to cooperate with the police or other government bodies in case of illegal conduct;
• For the establishment, exercise or defense of legal claims, e.g., for court cases;
• For scientific or research purposes, e.g., for clinical research studies with sufficient safeguards safeguarding confidentiality;
• For preventative and occupational medicine and medical diagnosis pursuant to a contract with healthcare professionals under a legal obligation of confidentiality;
• For public interest in the public health to ensure high standards of quality and safety of healthcare and products; and
• Where the individual chooses to disclose the personal information publicly by its own initiative.

If you choose not to provide the personal information we reasonably require, it may hinder Stereotaxis’ ability to provide the information or services you have requested.

Cross-Boarder Transfers

To the extent personal information is transferred out of the country where the owner of that personal information lives, such as to affiliates or business partners in other countries, including Stereotaxis’ headquarters in the United States, different standards may apply to how your data is used and protected in those countries. Stereotaxis has appropriate safeguards in place in accordance with applicable legal requirements to ensure that data is adequately protected irrespective of the country. This includes obtaining written assurances from any third party given access to your data, so as to require them to adopt standards that ensure an equivalent level of protection for data as that adopted by Stereotaxis and standardized contractual measures (based on the European Commission Model Clauses) for internal data transfers to Stereotaxis affiliates in third countries that are deemed to provide an inadequate level of data protection.

Privacy Statement for Children

The privacy of children is of the utmost importance to us. Stereotaxis will not intentionally collect personal information from anyone we know to be under the age of 16 without the prior, verifiable consent from his or her legal representative. If you are under the age of 16, please refrain from using Stereotaxis’ sites or applications. To the extent Stereotaxis becomes aware that data has been collected of a minor under this Statement, such information shall be expunged from Stereotaxis’ systems. If you think we have collected personal information from a child under the age of 16, please contact us.

Retention of Information

Stereotaxis will retain your personal information for as long as reasonably necessary to comply with legal obligations or for no longer as required for legitimate business purposes consistent with its document retention schedules if applicable. As such, we may retain your information as necessary to comply with its legal, regulatory and/or ethical obligations, to resolve disputes, exercise our rights, conduct internal research, maintain records, or enforce and comply with our agreements.

Disclosure of Information

Stereotaxis will not share your personal information collected with unrelated third-parties without your permission, except as otherwise provided in this Privacy Statement. Stereotaxis does not sell your information to third-parties.

In the usual course of business, Stereotaxis may share some personal information with companies that we hire to perform services or functions on our behalf. For example, we use third-parties for hosting of our websites, which are responsible for processing your information. We may also use vendors or suppliers to ship products that you order. In these situations, vendors and third-parties may have limited access to your information; however, we will not authorize them to keep, disclose, or use your information with others except for the purpose of providing our contracted or requested services. Such companies are also legally bound by contracts and other mechanisms to only use your information as directed by Stereotaxis and to keep your information private in accordance with the law.

Stereotaxis may also disclose your information to the extent required or provided by law in a designated jurisdiction, or to protect its legal rights or property.

Security

Stereotaxis maintains physical, technical and administrative controls to protect your personal information from unauthorized access, use and disclosure. Stereotaxis evaluates these safeguards on an ongoing basis to help minimize risks from new security threats as they become known.

Rights

You may request details on the personal information that we hold about you. If you believe that any personal information we are holding about you is incorrect or incomplete, please contact us as soon as possible, at the address below. We will promptly correct any personal information found to be incorrect.

You may always choose to object to the collection or use of your personal information or to have your information erased. If you would like a copy of the information held about you for your own use or to transfer to another party or if you wish to exercise any other right, please contact us at privacyofficer@stereotaxis.com.

IF YOU ARE A CALIFORNIA RESIDENT, PLEASE SEE OUR PRIVACY NOTICE FOR CALIFORNIA RESIDENTS FOR ADDITIONAL INFORMATION REGARDING YOUR RIGHTS AND CHOICES.

Updates to Privacy Statement

This Statement may be amended at any time. If material changes are made in how personal information is collected, used, disclosed or otherwise processed, this Statement will be updated and notices will be provided as a banner at the top of our website. Any material changes to this Statement will be effective at the time of our posting of the notice of the update.

Contact

If you have any questions, concerns or comments about this Statement, please contact us. Stereotaxis will use reasonable efforts to respond to you as soon as possible.

Send mail to:

Stereotaxis, Inc.
Attn.: Privacy Officer
710 North Tucker Boulevard, Suite 110
St. Louis, MO 63101

Send email to:

privacyofficer@stereotaxis.com
EU Data Protection Officer: privacyofficer@stereotaxis.com

If you are a resident of a European Union member and are unhappy with the way that we have handled your information or any inquiry regarding your information, you have the right to complain to the EU Data Protection Authority (“DPA”) in your jurisdiction.