Medical Device Quality Assurance and Compliance Professionals

Privacy

GENERAL PRIVACY STATEMENT

July 11, 2019

Lovett Consulting is committed to protecting your personal information. This Privacy Notice outlines the types of personal information Lovett Consulting may collect; the means by which Lovett Consulting may collect, use, or share your personal information; steps Lovett Consulting takes to protect your personal information; and choices you are provided with respect to the use of your personal information.

This Notice only applies to Lovett Consulting websites that link to this Statement.

For purposes of this Statement, “Personal Data” is any information by which you can be individually identified both directly and indirectly, including, but not limited to, your name, address, e-mail address, and telephone number. This website is not designed or intended for use by children under the age of 16. We do not knowingly collect any Personal Data from anyone under the age of 16 without the prior, verifiable consent of a parent or guardian. Such parent or guardian may have the right, upon request, to view the information provided by the child and require that it be deleted. Moreover, all minors should seek their parent’s or guardian’s permission prior to using or disclosing any Personal Data on this website or online resource.

Identity and Contact Details of the Data Controller

The data controller is Lovett Consulting, LLC, 440 Bridle Ct., San Ramon, CA 94582

You may contact the data controller by email at linda@lovettconsulting.net

How and Why We Process Your Personal Data

On this website, Lovett Consulting may request Personal Data about you. Examples of Personal Data that Lovett Consulting may collect that directly identifies you includes your name, contact information, email address, and other information in combination with these identifiers. Lovett Consulting may also may collect certain Personal Data information that does not directly identify you by name, but could be used to identify that a specific computer or device has accessed this website.

Lovett Consulting processes your Personal Data on our websites for many reasons, including:

  • To respond to your requests or inquiries;

  • To complete a transaction;

  • To personalize your experience;

  • To perform website analytics and measure website performance; and

  • To maintain the website, including for security purposes.

Several places on Lovett Consulting’s website require Personal Data if you choose to use them, including surveys, registration, and content sharing features (i.e., “E-mail to a Friend” links). Lovett Consulting may collect this information about you only if you voluntarily provide it to us. Please be aware that certain features of this site may not be available to you if you elect not to provide certain Personal Data. Any Personal Data you provide to Lovett Consulting will be used in accordance with this Privacy Statement.

More Information on our Processing Activities

This section outlines each processing activity in greater detail and provides information on the categories of information collected for each activity as well as the legal basis of processing for each of these activities.

Responding to Requests or Inquiries. Certain parts of the Lovett Consulting website and online resources allow you to submit your Personal Data to us to for various purposes. For example, you may submit a Medical Information request, inquire about a product, or subscribe to Lovett Consulting mailing lists. In these instances, Lovett Consulting may use the information that you provide to take the steps necessary to respond to your request. Depending on your request, Lovett Consulting may collect your contact information (such as your name, mailing address, telephone number, job title), your interests and preferences (such as products or areas of interest), and any other information you provide to Lovett Consulting. Lovett Consulting collects and processes your Personal Data for these purposes based on your consent. If reporting is required, Lovett Consulting may process your data to comply with our legal obligations.

Completing Transactions. Some parts of the Lovett Consulting website may collect your Personal Data to fulfill services that you have requested and to understand your interests and preferences. In these instances, Lovett Consulting may collect your contact information as well as a history of your previous transactions with Lovett Consulting (such as order history, customer account information). If you are purchasing or ordering a product or service from Lovett Consulting, Lovett Consulting uses this information to perform Lovett Consulting’s agreement with you.

Personalizing Your Experience. Lovett Consulting may collect certain information about you, your preferences, and how you have interacted with Lovett Consulting in the past in order to understand your interest in our products and services so that Lovett Consulting can best serve you. This may include information about your contact and product preferences, languages, marketing preferences, and demographic data. In cases where Lovett Consulting collects this information automatically, Lovett Consulting collects and processes this information for Lovett Consulting’s legitimate business interests. In other cases, Lovett Consulting will collect and process this information pursuant to your consent.

Website Analytics and Tracking. Where permitted by law, Lovett Consulting may combine Personal Data you provide with other information you have provided to Lovett Consulting through Lovett Consulting’s websites. Where permitted by law, Lovett Consulting may also combine Personal Data collected through our websites and online resources with Lovett Consulting‘s offline records and information provided to Lovett Consulting by third parties.

To Run and Maintain our Website. Lovett Consulting uses this information to secure Lovett Consulting’s websites, network systems, and other assets. This may include information concerning your IP Address, geographic location, resources you have accessed, and similar information. Lovett Consulting collects this information automatically, for Lovett Consulting’s legitimate business interests.

Cookies and Other Web Trackers

Lovett Consulting’s websites and online resources also collect other basic information about you which does not directly identify you but which may correspond with you or a particular device. Lovett Consulting uses this information to learn more about how Lovett Consulting’s websites and online resources are used and to otherwise improve and administer the site. Lovett Consulting also uses this information to enable it to deliver information tailored to your interests and preferences, based on your use of the site. For example, Lovett Consulting may collect the Internet Protocol Address assigned to your computer by your internet service provider. This address may change each time you connect to the internet (a “dynamic” IP address), or it may remain the same (a “static” IP address). In most cases, this information is collected automatically, for Lovett Consulting’s legitimate business interests. In some jurisdictions, Lovett Consulting is required to ask for your consent before collecting this information, in which case you will be presented with a choice as to whether you wish to allow the collection and use of this type of information. Please see Lovett Consulting’s Cookie Policy for more information.

Cookies. Lovett Consulting’s websites may use a tracking technology called a “cookie.” A cookie is a small data file that a website can place on your computer’s hard drive, where your internet browser files are kept. Cookies enable Lovett Consulting to recognize when a computer being used to browse Lovett Consulting’s websites has previously visited a Lovett Consulting website or online resource. Cookies can also be used to enable a site to “remember” the information a visitor has previously inputted. Cookies may be placed on your computer both by Lovett Consulting and by third parties with whom we have a relationship, such as web analytic services and advertising network services.

Web Beacons. On certain web pages or in emails Lovett Consulting may send to you, Lovett Consulting may utilize a technology called a “web beacon” (also known as an “action tag” or “clear GIF technology”). Lovett Consulting may use web beacons to help determine which email messages sent by Lovett Consulting were opened and whether a message was acted upon. Web beacons also help analyze the effectiveness of websites by measuring the number of visitors to a site or how many visitors clicked on key elements of a site.

Social Plugins. Lovett Consulting’s website may use social plugins (e.g., the Facebook “Like” button) to enable you to easily share information with others. When you visit the Lovett Consulting site, the operator of the social plugin may be able to place a cookie on your computer, enabling that operator to recognize individuals who have previously visited the Lovett Consulting website. If you have previously logged into the associated social media website (e.g., Facebook) before browsing on Lovett Consulting’s website, the social plugin allows that social media website to receive information about your visit to particular pages on the Lovett Consulting website. The social plugin may collect this information for any such visitors who have logged into social networks, whether or not they specifically interact with the plugin on the Lovett Consulting websites (e.g., by clicking “Like” or “Share”). The social plugin may also allow the social media website to share information about your activities on Lovett Consulting websites with other users of their social media website. For further details about the information shared via a particular social media plugin, you should refer to that social media site’s privacy statement.

Certain web browsers and other programs may be used to signal your preferences to Lovett Consulting about how or whether Lovett Consulting or third parties may collect information about your online activities. Currently, Lovett Consulting does not respond to such signals.

Use of Data for Marketing

Lovett Consulting will not sell or transfer your Personal Data to any non-affiliated entity for their own direct marketing use unless Lovett Consulting provides clear notice to you and obtains your explicit consent. Lovett Consulting may use third party advertising companies to place ads on other websites. These companies may use data about your visits to the Lovett Consulting and other websites in order to measure advertising effectiveness and to provide advertisements about Lovett Consulting’s goods and services that may be of interest to you. If you would like more information about this practice and your choices to opt out of having this information used by these companies, see Lovett Consulting’s Cookies Policy.

Information Sharing / Recipients of Personal Data

Recipients of your Personal Data

Lovett Consulting may share your Personal Data with Lovett Consulting affiliates around the world. Lovett Consulting affiliates will use your Personal Data for the same purposes as Lovett Consulting.

Lovett Consulting may also share your Personal Data with outside third parties, including Lovett Consulting’s data processors, for the following purposes:

To help fulfill Lovett Consulting business transactions;

To conduct technical maintenance of Lovett Consulting’s websites and other web platforms;

To facilitate a merger, consolidation, transfer of control or other corporate reorganization in which Lovett Consulting participates, or pursuant to a financial arrangement undertaken by Lovett Consulting;

To respond to appropriate requests of legitimate government authorities, or where required by applicable laws, court orders, or government regulations; and

Where needed for corporate audits or to investigate or respond to a complaint or security threat.

International Transfers of Your Personal Data

Any Personal Data you provide to Lovett Consulting through your use of the Lovett Consulting website may be transferred to or stored in a geographic region which imposes different privacy obligations than your country of origin. This may mean that your Personal Data may be sent to a country with less restrictive data protection laws than your own. Any such transfer will be conducted in compliance with applicable law.

If your Personal Data is covered by the GDPR: For transfers of data, contracts containing the EU Standard Contractual Clauses according to the EU Commission decisions of 27 December 2004 (2004/915/EC) and 05 February 2010 (C(2010)593) constitute appropriate and suitable safeguards to ensure compliance with GDPR. In addition to Standard Contractual Clauses, Lovett Consulting may also use data processors that are certified under the EU-U.S. Privacy Shield, which establishes appropriate and suitable safeguards to ensure compliance with the GDPR according to the EU Commission decision of 12 July 2016 (C(2016) 4176).

Retention / Storage Period of Your Personal Data

The length of time in which Lovett Consulting will store your Personal Data will differ depending on the purpose for which Lovett Consulting has collected and is processing your data. In most cases, Lovett Consulting will keep the data for three (3) years following Lovett Consulting’s last interaction with you. Lovett Consulting may, however, maintain your data for a longer period of time if Lovett Consulting is required by law to maintain your data.

Information About Your Rights Regarding Your Personal Data

Your Rights If Your Data is Covered by the GDPR

If your Personal Data are covered by the GDPR (that is, if you are an individual within the European Economic Area), you may have certain additional rights with regards to Lovett Consulting’s use and processing of your Personal Data.

You have the following rights with respect to your Personal Data:

The right to request access to the Personal Data that Lovett Consulting has about you;

The right to rectify or correct any Personal Data that is inaccurate or incomplete;

The right to request a copy of your Personal Data in electronic format so that you can transmit the data to third parties, or to request that Lovett Consulting directly transfer your Personal Data to one more third parties;

The right to object to the processing of your Personal Data for marketing and other purposes;

The right to erasure of your Personal Data when it is no longer needed for the purposes for which you provided it, as well as the right to restriction of processing of your Personal Data to certain limited purposes where erasure is not possible.

To exercise any of these rights, please contact Lovett Consulting using the information provided above.

Please note that erasure or restriction of processing is only possible if and to the extent that the processing of Personal Data is based on consent or legitimate interest. If data processing is based on consent, note that you have the right to withdraw your consent at any time, but that the withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal. In the event of an erasure request, Lovett Consulting may retain a copy of your Personal Data for its record-keeping purposes and to avoid entering your personal data in Lovett Consulting’s systems after your request.

In the event that you believe or have the impression that our data processing does not comply with the GDPR, you are entitled to lodge a complaint with the responsible supervisory authority.

Your Rights If Your Data is Covered by California Law

California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please use the contact information provided above.

Be sure to include your name and address; you can include your email address if you want to receive a response by email. Otherwise, Lovett Consulting will respond by postal mail within the time required by law.

Data Security

Lovett Consulting and its business partners take reasonable steps to protect Personal Data Lovett Consulting accesses or receives through the Lovett Consulting website from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Nevertheless, Lovett Consulting makes no guarantee as to the security of your Personal Data and disclaims, to the fullest extent permitted by law, all liability and damages caused by loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Lovett Consulting recommends that you take any available precautions to protect Personal Data you submit on Lovett Consulting’s website.

Updates to This Privacy Notice

From time to time, Lovett Consulting may revise this Privacy Notice. Any such changes to this Privacy Notice will be reflected on this page. Lovett Consulting recommends that you review this Privacy Notice regularly for any changes. The date on which this notice was last revised is located at the top of this notice.