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Adagio Medical

Adagio Medical Privacy Policy

Adagio Medical Website Privacy Policy

Adagio Medical, Inc. and its subsidiaries and affiliates (collectively, “Adagio Medical,” “we,” or “us”) recognize the importance of protecting the privacy needs of visitors to our websites (the "Websites") and through other interactions by email and telephone. This Privacy Policy describes the types of personal information we may collect from you or that you may provide when you visit the Websites and our practices for collecting, using, maintaining, protecting, disclosing, and processing such personal information. Please read this policy carefully to understand our policies and practices regarding your personal information and how we will treat it. As used in this Privacy Policy, “personal information” means information that identifies, relates to, or describes an identified or identifiable natural person.

The Websites do not collect “protected health information” as that term is defined by the U.S. Health Insurance Portability and Accountability Act (HIPAA), and the Websites do not comply with HIPAA.  Do not submit any health information through the Websites.

By accessing or using the Websites, you agree and consent to the collection, maintenance, use, and disclosure of your personal information by Adagio Medical. If you do not agree to the terms of this Privacy Policy or do not consent to the collection, maintenance, use, and disclosure of your personal information by Adagio Medical as described within this Privacy Policy, you should leave the Website and stop using and/or requesting our Websites immediately.

INFORMATION WE COLLECT AND USE

We collect personal information through our Websites, when delivering products, customer service and otherwise, and use it for typical business management, operational and commercial purposes (including to maintain or service accounts, provide customer service, verify consumer or customer information, perform analytics, store data, advertising and marketing, internal research, verifying and maintaining the quality or safety of Websites and our products and services, for auditing the use of the Websites or other products or services, to defend and protect us and others from harm or legal claims, and as required by applicable law) and as described more specifically below:

Through the Websites and by Email and Telephone. In addition to the above, we collect and store the following personal information and use it as described more specifically below.

  • Personal identifiers and Professional Information. We receive personal identifiers (such as your name, phone number, e-mail address, mailing address, county) and use them to respond to your requests, and to communicate with you for marketing, newsletters, and informational purposes. We may also collect and use this information to respond to feedback, complaints, and to provide information about our products and services. If you are a health care professional, you may also create an account to request and receive additional information from us.  To create an account, you may be required to submit your personal identifiers and professional information, including your name, email address, job title, job role and specialty, and employer name.

  • Message content. We receive messages you provide through email, by phone, or a “contact us” form on the Websites, including in connection with customer service requests, appointment requests, and complaints. We use this information to respond to your requests and to improve the Websites and our service. 

  • Location information. We may use some of the information we collect, such as IP addresses, to estimate an approximate location of the visitors of our Websites in order to enhance and personalize the features and functionality of the Websites and service offerings and for internal business purposes. To create a health care professional account, you may be required to submit your city, state, zip code, and country.

  • Inferences from the information listed above. Except as otherwise stated above, we will use the information listed above to draw inferences about your preferences to help us provide you with personalized content and offers and help us develop and provide better products and services.

From Job Applicants. Job application information may be collected by us directly online.  For California residents, the privacy notice required by California is available at https://us.adagiomedical.com/privacy-policy-for-apply.

Automatically Through the Websites. When you visit and use our Websites (including watch videos), we and our third-party partners, collect information by automated means. Such means include the use of cookies, pixels, web beacons, web server logs, and other similar technologies.

We and our service providers and third-party partners, such as advertising networks, social media widgets, and analytics providers, may automatically collect personal information using cookies and similar technology when you use a Website and our emails. We use this information to provide and improve our Websites and systems, for anti-fraud purposes, to tailor your experience on our Websites and our marketing efforts, and to create aggregate internal reports on website usage and activity, such as views of certain products. These additional categories of personal information may consist of:

  • Online identifiers. We and our service providers and third-party partners may collect your IP address, device advertising id, and other device and online identifiers when you use the Websites. 

  • Website and mobile application activity and technical information. We and our service providers and third-party partners may monitor and collect Website usage activity information and device characteristics, such as Website clicks, content and page views, feature usage, the website each visitor visited prior to our Website, the search engine and search terms that you used, and information about your previous visits to our Website, domain type, browser version, app or operating system version, the length of your visit or use, your Internet service provider, the language settings on your computer, and/or certain software (e.g., Java support).

  • Inferences from the information listed above. We and our service providers and third-party partners will use the information listed above to draw inferences about your preferences (such as your preferred brands) to help us provide you with personalized content and offers and help us develop and provide better products and services. 

An “HTML Cookie” is a small amount of data that is sent to your browser from a webserver and stored on your computer’s hard drive. HTML Cookies provide a means for websites that you visit to keep track of your online usage patterns and preferences. Among other things, HTML Cookies help us identify returning users and customize our services to a user’s needs. By understanding which areas of the Website a user has visited, HTML Cookies allow us to present information, products, and specials that may be of the user’s interest.

In some cases, our third-party partners may process information collected by cookies and related technologies that we permit them to use on the Websites. Like most websites, we use Google Analytics to collect and process certain website usage data. To learn more about Google Analytics and how to opt out, please visit https://tools.google.com/dlpage/gaoptout. In addition, you can click the following link in order to find out more information about your options with respect to Google Analytics and other Google services: https://policies.google.com/technologies/partner-sites.

You may be able to change a web browser’s settings to block and delete cookies when you access the Websites through that web browser. However, if you do that, the Websites may not work properly; also, we will still receive basic information (such as last URL visited) when you navigate to the Websites. The Websites do not respond to browser do-not-track signals.

De-identified or Aggregated Information. We de-identify and/or aggregate data we receive and may use and disclose it for any business or commercial purpose. Once de-identified, we will maintain the data in de-identified form and not attempt to re-identify it.

INFORMATION DISCLOSURES

We may provide third parties with the personal information we collect (as described above) for our business purposes to assist us in providing products and services to you, including to put you into contact with a partner or to help us market.

We do not sell your personal information for money or other consideration.  We do not perform targeted advertising across unaffiliated websites.

Service providers. We share any of your personal information with service providers that provide services to us, including to help us conduct maintain our databases and Websites, administer emails, facilitate product registration, and perform marketing and advertising.

Affiliates. We may share any of your personal identifiers (such as name, mailing address, and email address) and commercial transaction information with affiliated and subsidiary companies so we can more efficiently operate our business and they can provide services to you and us.

Government agencies, legal, and similar disclosures. We may disclose personal information about you with law enforcement, the courts, our advisors, attorneys, and others who participate in the legal process, if necessary to do so by law or based on our good faith belief that it is necessary to enforce or apply our Website Terms of Use, conform or comply with the law or is necessary to protect us, the users of the Websites, or others.

Sales, Mergers, and Acquisitions. In the event of a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another entity (whether by private sale, through operation of law, as part of a divestiture plan, or otherwise), we will provide personal information and transaction history associated with each such business unit to the persons and/or entities assuming control of such business unit or as otherwise necessary to complete the transaction as permitted by law or contract.

Other Sharing. We may share information as described under “Information We Collect and Use” above and for other business purposes as otherwise explained in this Privacy Policy.

RETENTION OF PERSONAL INFORMATION

As a general matter, we only keep information for as long as necessary to fulfill the purposes for which it was collected, as stated in our retention policies, and permitted or required by law, such as to comply with recordkeeping and other legal obligations. There may also be residual information that will remain within our backup files, databases, and other records, which will not be removed or changed, except in accordance with retention policies.

PROTECTION OF PERSONAL INFORMATION

We employ reasonable security measures to secure and protect the information we receive. No method of electronic transmission or storage is 100% secure. As a result, we do not ensure, warrant, or guarantee the security or integrity of such information.

LINKS TO THIRD-PARTY WEBSITES

The Websites may contain links to other websites, and other websites may link to the Websites. This Privacy Policy does not apply to personal information that you submit to the websites of our business partners, partner practices, or any other third-parties or that are collected by them from you, even if those third-party websites are linked to our Websites. We are not responsible for the privacy practices of such other websites. When you visit another website – via a link from the Websites or otherwise – you should review the privacy policy of that other website. This Privacy Policy applies solely to information provided or obtained on our Websites.

NO USE BY PEOPLE UNDER THE AGE OF 18

If you are under the age of 18, you may not use our Websites. The Websites are not intended for use by children under the age of 18. We do not knowingly collect, maintain, or use personal information from children under 13 years of age. If we believe that any information has been posted by a child under the age of 13, we will promptly delete that information. Parents may contact us using the methods set forth below to request that information concerning their child be removed from our Website.

PRIVACY RIGHTS

Certain states impose specific legal requirements and grant data subject rights with respect to personal information, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to know about our practices with respect to your personal information and to review, correct, receive, receive in a portable manner, and delete personal information we have about you, or to consent or withdraw consent to certain uses or sharing of personal information (e.g., a right to opt-out of the “sale” of personal information or “sharing” of personal information for targeted advertising, as described above). You may also have the right to not be discriminated against for exercising your privacy rights.

Making Requests. When you make a request, we may require that you provide information (such as your name, email address and/or zip code) and follow procedures so that we can verify a request you make and your jurisdiction before responding to it. The verification steps we take may differ depending on your jurisdiction and the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.

Certain privacy laws permit consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the consumer. An authorized agent must follow the process described below to make a request, and we will additionally require the authorized agent to verify his/her own identity and we will confirm the agent’s authority with the consumer about whom the request was made.

If you would like to request more information about personal information collected about you or that we update, correct, or delete any such information, you may email us at: web_request@adagiomedical.com.

Responding to Requests. We will respond to your request within the time period required by applicable law. However, we may not always be able to fully comply with your request, and we will notify you in that event. As permitted by applicable law, we may charge a reasonable fee to help cover the cost of responding to your request, and we will inform you of the fee before completing your request. Specific provisions for some jurisdictions are set forth below.


Appeals Process. Contact us at web_request@adagiomedical.com to appeal our decision to deny your request.  Please include in your appeal request all information about your original request and our denial response to you. We will review and respond to your appeal as required by applicable law.

California Residents. 

We have disclosed in the last 12 months the categories of personal information listed above in this Privacy Policy for our business and commercial purposes (including to maintain or service customers, provide customer service, process or fulfill orders and transactions, verify consumer or customer information, process payments, perform analytics, storing data, advertising and marketing, internal research, to verify and maintain the quality or safety of products and services, auditing the use of the Websites or other products or services, defend and protect us and others from harm or legal claims, and as required by applicable law). We do not use or disclose sensitive personal information for purposes other than those specified in section 7027, subsection (m).

California consumers have the following privacy rights: to request additional information about our data collection, use, and disclosure practices in connection with the consumer’s personal information; to request access to the specific personal information collected about the consumer; to request the deletion of personal information we have about the consumer; to request a restriction on certain processing of personal information; and to request correction of inaccurate information. Also, California consumers have the right not to receive discriminatory treatment if they exercise the rights listed above.

You may be able to use the Websites to access and update the information that you have provided to us through your use of the Website or otherwise. If you would like to request access to such information or that we update, correct, or delete any such information, in California you may email us at: web_request@adagiomedical.com. We will comply with requests you submit as required by applicable law.

We do not sell your personal information for money or other consideration, including as defined under the California Consumer Privacy Act, as amended by the California Privacy Rights Act. We do not perform targeted advertising across unaffiliated websites. We also do not rent, sell, or share “personal information” as defined by California Civil Code §1798.83 about you that we collect on the Website with other people or unaffiliated companies for their direct marketing purposes.

The Website does not request sensitive personal information and we do not offer the ability to limit the use or disclosure of such information. Please do not submit sensitive personal information, such as health information to the Website.

You may be able to use the Websites to access and update the information that you have provided to us through your use of the Websites or otherwise. If you would like to request access to such information or that we update, correct, or delete any such information, you may email us at: web_request@adagiomedical.com. We will comply with requests you submit as required by applicable law.

NOTIFICATION OF CHANGE TO THE PRIVACY POLICY

We reserve the right to modify this Privacy Policy. Whenever we decide to change this Privacy Policy in a material manner, notice of the change will be posted on the Websites for a reasonable period of time or provided to you using other means. Nevertheless, you should review the Privacy Policy from time to time to be sure you are aware of the most recent version. Please be assured that we will only use information in accordance with the Privacy Policy in effect at the time the information was collected, unless we receive your consent.

HOW TO CONTACT US WITH QUESTIONS

Customer questions, comments, and feedback are very important to us. If you have questions about this Privacy Policy please contact us at:

Adagio Medical, Inc.

26051 Merit Cir #102, 

Laguna Hills, CA 92653

or by e-mailing us at web_request@adagiomedical.com 

Effective: July 29, 2024.