Privacy Policy

Acutus Medical Privacy Policy

Last Modified: November 16, 2020

This privacy policy (“Policy”) informs you of our practices when handling Information we collect from or about you through and in connection with your use of the Website (both as defined below). In this Policy, “Acutus”, “we”, “our” or “us” refers to Acutus Medical, Inc., a company in California, United States with its registered address located at 2210 Faraday Avenue, Suite 100, Carlsbad, CA 92008, U.S., and Acutus Medical NV, a company registered in Belgium, with its registered address located at Ikaroslaan 25, 1930 Zaventum, Belgium. We are the data controller under the applicable privacy laws. This Policy describes how we collect and further process Information we collect from or about you in connection with your use of the Acutus websites at https://www.acutusmedical.com/us and https://www.acutusmedical.com/int (the “Website”).

When you use the Website, you accept and understand we collect, process, use and store your Information as described in this Policy. If you do not agree with this Policy, you must not use any of the Website. If you change your mind in the future, you must stop using the Website and you may exercise your rights in relation to your Information as set out in this Policy.

1. INFORMATION WE COLLECT

For the purpose of this Policy, “Information” means any information relating to an identified or identifiable individual and does not include data whereby personally identifiable information has been removed (such as anonymized data).

We will collect and use the following Information about you:

• Information you provide us when you choose to communicate with us. When you communicate with us via the Website or other means, you may provide us with Information such as your name, email address, phone number and the contents and nature of your correspondence with us.
• Information you provide should you choose to apply for a job with us. If you apply for a job with us, we will collect Information in connection with your application, including your name, contact details, CV, experience, educational history, and any other Information generated through the application and interview process, including references from third parties.
• Identifiers and usage. When you use the Website, we and third parties will automatically collect identifiers such as your IP address, information on your usage such as interactions with the Website and our team, and device information.
• Cookie information. We and third parties automatically collect information about your visit to and use of the Website via cookies (see below in section 3: “How We Use Cookies and Similar Technologies” for more information). Please note that you can turn off cookies and still access our Website. The information cookies collect may include Information, such as your IP address and related information as well as information about your interactions with our Website, such the time of your visit and where you have clicked. Note that websites you visit before or after our Website may track your visit to our Website and other information. Please check those respective policies and practices.
• Information we receive from third parties. We may receive Information about you from third parties such as data or marketing partners and combine it with other Information we have about you.

We also collect, use, and share aggregated or deidentified data (“Aggregated Data”) such as statistical or demographic data for our business purposes. Aggregated Data may be generated or derived from your Information, but it is not Information as this data will not directly or indirectly reveal your identity. For example, we may aggregate or deidentify data about your use of our Website to calculate the percentage of users accessing a specific feature. However, if we combine or connect Aggregated Data with your Information so that it can directly or indirectly identify you, we will treat the combined data as Information which will be used in accordance with this Policy.

2. HOW WE USE YOUR PERSONAL INFORMATION

We use your Information to:

• Provide you with support and to respond to your requests and general queries. If you reach out to us, or a third party acting on our behalf, for support or with a question or query, we will use your Information to respond and resolve your queries and facilitate support as we deem reasonable. The Information we process when doing so includes your correspondence, your name, contact details, and any other Information you choose to disclose during communications. It is in our legitimate interests to use your contact details or any other information you provide to contact you for administrative or business purposes to resolve your inquiry as we deem appropriate.
• To improve, monitor or analyze usage and usage trends of our Website. It is in our legitimate interests to improve our Website for our users, which includes conducting troubleshooting, testing, and research and to keep the Website secure. When doing so, we may use Information that we automatically collect about you, such as identifiers and information on use. It is also in our legitimate interests, either directly or via third parties, to analyze the use of our Website and our users’ preferences, in order to understand usage, develop new products, services and functionality. When doing so, we will process Information that we automatically collect about you or that is generated about you when you use the Website.
• Send you messages about promotions, events, and other news, products, or services we think will be of interest to you. We will send you emails with product news and other promotional materials about Acutus services and products. When doing so, we process your contact information and your interests. Where it is required, we will only do so where we have your consent. Your consent can be withdrawn at any time by following the unsubscribe mechanism at the bottom of each communication.
• Process your job application. When you submit a job application, it is in our legitimate interests to process your Information to assess your suitability for the role for which you are applying and to communicate with you about your job application. We will also process your Information where we have a legal obligation to do so, including evaluating your right to work.
• Provide you with advertising. We may present you with suggestions about our products and services on our Website and elsewhere, including LinkedIn. Your consent will be sought where necessary. Depending on your consent, or device or browser settings, these suggestions may be tailored. Otherwise it is in our legitimate interests to show you contextual advertising. To tailor suggestions, we use Information including that we automatically generate about you when you use the Services and Information received from third parties.
• Prevent fraud, defend Acutus against legal claims or disputes, enforce our terms and to comply with our legal obligations. It is in our legitimate interests to protect our interests by: (1) monitoring the use of the Website to detect fraud or any other user behaviour which prejudices the integrity of our Website; (2) taking steps to remedy aforementioned fraud and behaviour; (3) defending ourselves against legal claims or disputes; and (4) enforcing our terms and policies. When doing so, we will process the Information relevant in such a case, including Information you provide to us, Information we automatically collect about you, and Information which is provided to us by third parties.

3. HOW WE USE COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain information that is transferred to your computer’s hard drive.

Our Website uses cookies, beacons, invisible tags, and similar technologies (collectively “cookies”) to collect information about your browsing activities and to distinguish you from other users of our Website. This aids your experience when you browse our Website and allows us to improve the functionality of our Website.

We use the following cookies:

• Strictly necessary cookies. Some cookies are strictly necessary to make our Website available to you; for example, for security. We cannot provide you with the Website without this type of cookie.
• Functional cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences.
• Analytical or performance cookies. We use cookies for analytics purposes in order to operate, maintain, and improve our Website. We use third-party analytics providers, including Google Analytics, to help us understand how users engage with the Website. Google Analytics uses first-party cookies to track user interactions which helps show how users use our Website. This information is used to compile reports and to help us improve our Website. The reports disclose Website trends without identifying individual visitors. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

You can block cookies by setting your internet browser to block some or all or cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.

We use session cookies, which expire at the end of your web session, and persistent cookies. All persistent cookies will expire after six (6) months.

4. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We share your Information with selected third parties, including:

• Vendors and service providers we rely on for the provision of the Website, such as:
  • Cloud service providers who we rely on for data storage and disaster recovery, including Amazon Web Services which is based in the U.S.;
  • Customer support solution providers, who help us manage and respond to your queries. This includes Cloudflare which is based in the U.S.; and
  • Analytics providers. We work with several analytics service providers who help us understand our visitors. This includes Google LLC, which is based in the U.S. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• Third parties in connection with your job application. When you apply for a job with us, we will share your Information with third parties including recruiters, and for verification purposes.
• Advertising partners. We provide certain Information to advertisers who will use them for their own purposes, for example to measure who sees and clicks on ads.
• Companies who belong to the same group as Acutus. We share your Information with entities in the group we belong to, to operate the Website and our services.
• Law enforcement agencies, public authorities, or other judicial bodies and organisations. We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection).
• Change of corporate ownership. We may transfer your Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

5. SECURITY

We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of Information that we collect and maintain. However, the transfer of Information through the internet will carry its own inherent risks and we do not guarantee the security of your data transmitted through the internet. You make any such transfer at your own risk.

Our Website may contain features or links to websites and services provided by third parties. Any information you provide on third-party websites or services is provided directly to the operators of such websites or services and is subject to those operators’ policies governing terms of use, privacy, and security, even if accessed via our Website. We are not responsible for the content or privacy and security practices and policies of third parties to which links or access are provided through our Website. We encourage you to learn about third parties’ terms or use, privacy, and security policies before accessing them and/or providing them with your Personal Information.

6. WHERE WE STORE YOUR INFORMATION

We may transfer your Information to countries other than the country where you are located, including to the U.S. or any other country in which we or our service providers maintain facilities. If you are located in European Economic Area, the United Kingdom or Switzerland, or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer your Information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. We apply appropriate safeguards to the Information processed and transferred on our behalf. Please contact us for more information on the safeguards used.

7. HOW LONG WE STORE YOUR INFORMATION

Your Information is kept for as long as necessary to achieve the purpose set in this Policy, or for as long as we are required by law or in order to comply with a regulatory obligation.

When deleting Information, we will take measures to make the Information irrecoverable or irreproducible, and electronic files which contain Information will be deleted permanently.

8. YOUR RIGHTS

If you are based in Europe, in some circumstances you have certain rights in relation to your Information. You will find more information below on when which rights can apply. To exercise your rights, please contact us at [email protected] Please note that we may ask you to verify your identity before responding to such requests.

• Access. You have the right to access the Information we hold about you and to receive an explanation of how we use it and who we share it with.
• Correction. You have the right to correct any Information we hold about you that is inaccurate or incomplete.
• Erasure. You have the right to request for your Information to be erased or deleted.
• Object to processing. You have the right to object to our processing of your Information where we are relying on a legitimate interest or if we are processing your Information for direct marketing purposes.
• Restrict processing. You have a right in certain circumstances to stop us processing your Information other than for storage purposes.
• Portability. You have the right to receive, in a structured, commonly used and machine-readable format, Information that you have provided to us if we process it on the basis of our contract with you, or with your consent, or to request that we transfer such Information to a third party.
• Withdrawal of consent. Where we are relying on consent to process your Information, you have the right to withdraw your consent at any time.

9. CHILDREN

The Website is not intended for use by anyone under the age of 18. We do not knowingly collect Information from children under the age of 18, and no part of our Website is directed towards anyone under the age of 18. If you learn that a child has provided us with Information in violation of this Policy, please contact us as indicated below.

10. CONTACT & COMPLAINTS

We welcome questions, comments, and requests regarding this Policy.

If you wish to make a complaint about how we process your Information, please contact us at [email protected]. We will endeavour to deal with your complaint as soon as possible. This is without prejudice to your right to launch a claim with a data protection authority. In some circumstances you may lodge a claim with the Information Commissioner’s Office in the UK (at +44 0303 123 1113) or the data protection supervisory authority in the EU country in which you live or work (for example the Irish Data Protection Commissioner at +353 578 684 800), where you believe we have infringed data protection laws.

You can also send a letter to us at 2210 Faraday Avenue, Suite 100, Carlsbad, CA 92008 or Acutus Medical NV, Ikaroslaan 25, 1930 Zaventum, Belgium.

11. CHANGES

We review our Policy on a periodic basis, and we may modify our policies as appropriate. If we make material changes to the Policy, we will attempt to notify you via the Website or by sending you an email or other communication. We encourage you to review our Policy on a regular basis. The “Last Modified” date at the top of this page indicates when this Policy was last revised. Your continued use of the Website following these changes means that you accept the revised Policy.