Privacy Policy

Last modified: August, 2021.

Introduction

Purpose. The purpose of this Privacy Policy is to describe how Peli BioThermal, Ltd. ("Peli BioThermal"), acting as data controller, collects, uses and shares information about you through our U.S. online interfaces (e.g., websites and mobile applications) owned and controlled by us, including www.pelibiothermal.com (collectively referred to herein as the "Site"). Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us or as described at the end of this Policy.

By submitting your Personal Data through the Site and accepting this Privacy Policy, you specifically consent to the processing of your data as described herein.

Our Privacy Policy explains:

• Information We Collect and Why We Collect It
• How We Use and Share Your Information
• Access to Your Information and Choices
• Security of Your Information
• Consent to Processing Personal Data in Other Countries
• Changes to Our Privacy Policy
• Questions and How Contact Us

Scope; Third Party Sites. This Privacy Policy applies only to information we collect at and through the Site, and certain Peli BioThermal affiliated sites accessible through or that may redirect you to our Site. Some of our affiliated sites owned or controlled by Peli BioThermal are governed by their own separate privacy policies. Our Site may also contains links to third party sites that are not owned or controlled by Peli BioThermal. For example, consumers in certain countries and jurisdictions may be directed to sites owned and operated by independent Peli BioThermal dealers, and such websites are not owned or operated by Peli BioThermal. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects personal information.

Terms of Use. Please note that your use of our Site is also subject to our Terms of Use.

Information We Collect and Why We Collect It

Information You Provide To Us

We collect several types of information from and about users of our Site (“Personal Data”). This includes information:

• by which you may be personally identified, such as name, postal address, e-mail address, telephone number, any other identifier by which you may be contacted online or offline;
• Usage Details. Details of your visits to our Site, such as traffic data, location, logs, referring/exit pages, date and time of your visit to or use of our Site, error information, clickstream data, and other communication data and the resources that you access and use on or in the Site;
• Device Information. Information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, browser type, and App version information; and
• Location Data. Information about your location collected through Geolocation technology.

You can provide information to us on our Site through various means, such as when you fill out forms on our website or digital forms, your responses to surveys that we might ask you to complete, or when create an account for dealer support. This Personal Data will be included in data files owned by Peli BioThermal.

The Personal Data we collect from you is required to enter into a contract with Peli BioThermal, for Peli BioThermal to perform under the contract, and to provide you with our products and services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data (when appropriate), then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it. You must notify Peli BioThermal of any modification to the Personal Data provided and you will be solely liable for the veracity and accuracy of the data provided to us.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Site or transmitted to other users of the Site or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

We generally do not request you provide and do not process any special categories of Personal Data as defined by the EU GDPR.

Information We Collect through Automatic Data Collection Technologies

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns.

The information we collect automatically may include Personal Data, or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service by enabling us to:

• estimate our audience size and usage patterns;
• store information about your preferences, allowing us to customize our Site according to your individual interests;
• develop and improve our Site, our products, and our services; and
• recognize you when you return to our Site.

Details about the automated data collection technologies and the specific cookies that we use can be found in our Cookie Policy.

Information Collected Through Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. ("Google") to collect certain information relating to your use of the Site. Google Analytics uses "cookies", which are text files placed on your computer, to help the Site analyze how users use the site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on Site activity for Site operators and providing other services relating to Site activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this Site. By using this Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as www.google.com/analytics/terms/us.html.

Information Collected Through Cookies and Similar Technologies

We and our service providers use cookies, web beacons, session replay and recoding technology (recording your movements, clicks, etc.), pixel tags, and other technologies to receive and store certain types of information whenever you interact with our Site through your computer or mobile device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the Site again, the cookie allows that site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Site features or services may not function properly without cookies.

Web beacons and pixel tags are small electronic files (also referred to as clear gifs and single-pixel gifs). Web beacons permit us to do things such as count users who have visited certain webpages, opened an email, or provide insight on other Site statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).

No Information From Children Under Age 13

If you are under the age of 13, please do not attempt to register with us at this Site or provide any Personal Data about yourself to us. By registering at this Site or providing any Personal Data you represent and warrant that you are 13 or older being solely responsible for this declaration. If we learn that we have collected Personal Data from a child under the age of 13, we will promptly delete that information. If you believe we have collected any Personal Data from a child under the age of 13, please Contact Us or call us at (877) 537-9800.

How We Use and Share Your Information

Lawful Basis for Processing your Personal Data

If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):

• Consent. By using our Site, you consent to our collection, use, and sharing of your Personal Data as described in this Privacy Policy. If you do not consent to this Privacy Policy, please do not use the Site;
• Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your interests and rights and freedoms and we do not process your Personal Data if your interests or rights and freedoms outweigh our legitimate interests. Our legitimate interests include to: facilitate communication between Peli BioThermal and you; detect and correct bugs and to improve our Site; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; develop our product and services;
• To Fulfill Our Obligations to You under our Contract. We process your Personal Data in order to fulfill our obligations to you pursuant to our contract with you to deliver our goods and services to you; and
• As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.

To Provide Products, Services, and Information

As described above, we collect information from you so that we can provide you with information and support that you request from us. We use your Personal Data to contact you about your requests.

If you have previously authorized us to do so, we may send you information about our products and services, and new offerings. You can opt-out of receiving marketing and promotional e-mails from Peli BioThermal by sending us an email at info@pelibiothermal.com saying "Please remove," or using the opt-out or unsubscribe feature contained in the e-mails.

We may use third parties to help host our Site and provide other technology support, send out email updates about the Site, provide marketing and advertising services for us, remove repetitive information from our user lists, and process payments. All these service providers will have access to your Personal Data in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service. We use demographic information to better understand our customers, and improve our products and services.

If it appears you may be interested in our products, we may also share your personal information with distributors in our distributors network so that our distributors may contact you with information about our products.

We will store your data as long as is necessary to provide you the information that you have requested, for as long as we have a lawful basis to do so, or for as long as we are required by law.

After you close your account, we may retain your Personal Data:

• for as long as necessary to comply with any legal requirement;
• on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
• for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
• for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.

Advertising

With your consent, we may use how you browse and shop in order to show you ads for Peli BioThermal or our advertising partners that are more relevant to your interests. Peli BioThermal does not use your Personal Data with any automated decision making process, including profiling, which may produce a legal effect concerning you or similarly significantly affect you. However, we use cookies and other information to provide relevant interest-based advertising to you, including the use of automatic identifiers in respect to emails that direct you to information, products, and services that may be interest of you. Interest-based ads are ads presented to you based on your browsing behavior in order to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing our site or third-party sites not owned by Peli BioThermal. We belong to ad networks or use marketing companies that may use your browsing history across participating websites to show you interest-based advertisements on those websites. You can learn more about your choices and how we use Personal Data in Cookies, Flash Cookies, and Web Beacons by visiting our Cookie Policy.

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Site may then be inaccessible or not function properly. Please note that if you choose to opt out, you will continue to see ads on our Site, but they will not be based on how you browse and shop.

Our Site does not respond to “do not track” signals or similar mechanisms to indicate you do not wish us to collect information about your online activity or receive interest-based ads. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org).

Your Consent

In addition to sharing for reasons as described elsewhere in this Policy, we will share Personal Data with companies, organizations or individuals outside of Peli BioThermal when we have your specific and prior consent to do so; in any other way we may describe when you provide the information; and to fulfill any other purpose for which you provide it.

Legal Requests or Requirements and to Prevent Harm

We will share Personal Data with third party companies, organizations or individuals outside of Peli BioThermal if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Meet any applicable law, regulation, subpoena, legal process or enforceable governmental request.
• Enforce applicable Terms of Use, including investigation of potential violations.
• Detect, prevent, or otherwise address fraud, security or technical issues.
• Protect against harm to the rights, property or safety of Peli BioThermal, our users, customers or the public as required or permitted by law.

By submitting your Personal Data and accepting this Privacy Policy you consent to these disclosures to the extent that your consent is necessary under the applicable regulation.

Transfer in the Event of Sale or Change of Control

If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Site to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your Personal Data to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently. By submitting your Personal Data and accepting this Privacy Policy you agree to this transfer. Following such transfer, you may contact the entity to which we transferred your Personal Data with any enquiries concerning the processing of that data.

Access to Your Information and Choices

We do not control the collection and use of your information collected by third parties described above in (How We Use and Share your Information). When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.

• Access and Update. You can review and change your Personal Data by contacting with Peli BioThermal using the information provided below. You may also notify us through the information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
• Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
• Portability. To the extent the Personal Data you provide Peli BioThermal is processed based on your consent and that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
• Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by contacting us using the information below. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
• Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies. If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Site users.
• Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.

You may exercise your rights set forth above by contacting with Peli BioThermal using the information provided below. Any such request must include the following data: full name of the User, address for correspondence and photocopy of National ID document or Passport. In the case of representation by a third party, this must be proved by means of an authenticated document. If you believe that Peli BioThermal has infringed its obligations under the applicable data protection regulation, you have the right to file a claim against us before the competent supervisory authority.

Security of Your Information

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.

In order to help secure your Personal Data, access to your data on our Site is password-protected, and sensitive data (such as a social security number) is protected by encryption when it is exchanged between your web browser and our Site. To protect any data you store on our servers, we also regularly audit our system for possible vulnerabilities and attacks, and we use a tier-one secured-access data center. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. The safety and security of your information also depends on you. It is your responsibility to protect the security of your login information. Please note that e-mails, User Contributions, and other communications you send to us through our Site are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

Consent to Processing Personal Data in Other Countries

Peli BioThermal is the data controller of your Personal Data. At this time, Peli BioThermal has not appointed a Data Protection Officer, and we will update this policy if we do. Peli BioThermal's Site are operated and managed on servers located and operated within the European Economic Area (EEA) in countries that provide adequate level of data protection. If you are a resident of the European Economic Area (“EEA”), in order to provide our Site, products, and services to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data.

Your Personal Data is transferred by Peli BioThermal to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. By using our Site, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside the country where you reside or are located. To ensure your Personal Data is treated in accordance with this Privacy Policy when we transfer it to a third party, Peli BioThermal uses Data Protection Agreements between Peli BioThermal and all other recipients of your data that include, where applicable, the Standard Contractual Clauses adopted by the European Commission (the “Standard Contractual Clauses”). The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Data. Under these Standard Contractual Clauses, you have the same rights as if your data was not transferred to such third country. You may request a copy of the Data Protection Agreement by contacting us through the contact information below.

Changes to Our Privacy Policy

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

Questions and How to Contact Us

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please Contact Us, email us at info@pelibiothermal.com, call us at +44(0) 1525 243770, or contact us by postal mail at the following address:

Peli BioThermal, Ltd.
Celsius House
The Stanbridge Building
Stanbridge Road
Leighton Buzzard
Bedfordshire LU7 4QQ
United Kingdom