FAQ Page – Privacy Policy

Last Updated: April 30, 2025

1. Introduction

Welcome to the Rigicon Patient FAQ system. Rigicon (“we,” “us,” or “our”) is committed to protecting the privacy of individuals who interact with our website and services, including the FAQ submission feature. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you use the FAQ system available on our website (the “Service”).

This policy applies specifically to the information collected through the FAQ submission form and related functionalities. It does not necessarily cover information collected through other parts of the Rigicon website or offline interactions, which may be governed by separate Rigicon privacy policies.

By using the Service, you agree to the collection and use of information in accordance with this policy. If you do not agree with the terms of this policy, please do not use the Service.

2. Who is Responsible for Your Information? (Data Controller)

Rigicon comprises several companies around the world. The specific Rigicon entity responsible for handling your information (the data controller) may differ depending on your country/region and your interaction with us.

For the purposes of the FAQ system and general data processing activities related to it, the local Rigicon entity you interact with in your country and Rigicon Inc., located in the United States, act as joint controllers for your information. These parties have entered into an arrangement pursuant to Article 26 of the EU General Data Protection Regulation (“GDPR”) outlining their respective responsibilities. The local Rigicon entity is primarily responsible for obtaining valid consent where required, while both the local entity and Rigicon, Inc. HQ share responsibility for ensuring data accuracy and keeping it updated. Rigicon, Inc. is ultimately responsible for the deletion or anonymization of data according to retention policies.

For further information about data controllership or data protection matters, please contact Rigicon’s data protection officer at [email protected] or visit the Data Privacy and Security section on our website (rigicon.com).

3. Information We Collect

We collect several types of information to provide and improve our Service to you through the FAQ system:

• Personal Data: When you use the question submission form, we ask you to provide certain personally identifiable information (“Personal Data”). This includes:

  • Your Name

  • Your Email Address

  • The content of the question you submit (which may include health-related information if you choose to provide it)

  • The category you select for your question

  • Any other information you voluntarily share within your question.

• Usage Data and Technical Information: We automatically collect certain information when you interact with the submission form. This may include:

  • Your Internet Protocol (IP) address

  • Browser type and version

  • The time and date of your submission

  • Other diagnostic data related to the submission process.

• reCAPTCHA Information: To protect our Service from spam and abuse, we use Google reCAPTCHA v2. This service collects hardware and software information (such as device and application data) and sends it to Google for analysis. This information is used by Google for improving reCAPTCHA and for general security purposes, not for personalized advertising.

Please note that if your interaction extends beyond the FAQ system (e.g., requesting support services, processing orders), we may collect additional personal information, including specific health information, based on your explicit consent and our contractual relationship, as detailed in our broader privacy notices.

4. How We Collect Information

We collect information in the following ways:

• Directly from You: When you voluntarily complete and submit the FAQ question form.

• Automatically: When you access and use the Service, our servers may automatically log Usage Data and Technical Information.

• Through Third-Party Services: When you interact with the reCAPTCHA v2 widget on the submission form, Google collects information according to its privacy policy.

5. How We Use Your Information

Rigicon uses the data collected through the FAQ system for the following purposes:

• To Process Your Submission: We use the question content, category, name, and email address to review and understand your submitted question.

• To Respond (If Necessary): While direct responses are not standard practice for FAQ submissions, we might use your email address if clarification is needed regarding your question or to potentially notify you if your question is selected for publication as a general FAQ. Your email address will not be published on the website.

• To Improve Our Services: Submitted questions help us understand patient inquiries and concerns, enabling us to improve our FAQ content and overall services.

• To Maintain Security: We use IP addresses and reCAPTCHA data to monitor for and prevent spam, abuse, and unauthorized access to the Service.

• To Comply with Legal Obligations: We may process or disclose information if required by law, subpoena, or other valid legal process.

6. How We Share Your Information

We value your privacy and limit the sharing of your personal information collected via the FAQ system. We may share it only in these specific circumstances:

• With Service Providers: We share information with third-party vendors performing services on our behalf, such as:

  • Google reCAPTCHA: Information is shared with Google solely to provide the anti-spam service, subject to Google’s Privacy Policy and Terms of Use.

• Within Rigicon: Information may be shared internally with relevant Rigicon-affiliated companies or personnel strictly as needed for processing, analysis, or improvement related to the FAQ system.

• With Healthcare Professionals (Limited Circumstances): If your question relates directly to support services you have separately consented to receive, and requires input from healthcare professionals involved in that service provision, relevant details from your question might be shared strictly on a need-to-know basis and with appropriate safeguards. This is not standard practice for general FAQ submissions.

• For Legal Reasons: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court order or government agency).

• To Protect Rights: We may disclose information if we believe in good faith that it is necessary to investigate potential policy violations, suspected fraud, situations involving potential threats to the safety of any person, or as evidence in litigation.

Rigicon does not sell your personal information or share it with third parties for their independent marketing purposes.

7. Legal Basis for Processing

We process your personal data submitted through the FAQ system based on the following legal grounds under GDPR and other applicable laws:

• Legitimate Interests (Article 6(1)(f) GDPR): Processing your submission to manage the FAQ system, improve our FAQ content and services based on user inquiries, and maintain the security and integrity of the system.

• Consent (Article 6(1)(a) and Article 9(2)(a) GDPR): If you voluntarily include sensitive personal information (such as specific health details) within your question, your act of submitting the question containing this information constitutes your explicit consent for us to process that specific data solely for the purpose of reviewing and understanding your question in the context of the FAQ system. For any broader processing of health information (e.g., related to support services or product orders), we rely on separate, explicit consent mechanisms as outlined in our general privacy notice.

• Contractual Obligation (Article 6(1)(b) GDPR): In many cases, general interactions with Rigicon (outside the scope of a simple FAQ submission) may be based on fulfilling a contractual relationship.

• Legal Obligation (Article 6(1)(c) GDPR): Processing necessary to comply with applicable laws and regulations.

We comply with relevant data protection regulations, including GDPR and, where applicable, HIPAA.

8. Data Security

We implement reasonable administrative, technical, and physical security measures designed to protect the security of the personal information we process via the FAQ system. Submissions are stored within the WordPress database on servers with security controls. However, please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

9. Data Retention

We retain your submitted information (name, email, question, IP address, submission status) only for as long as necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Submitted questions are retained for internal review, analysis, and potential development of new FAQ content.

• If a submission informs a published FAQ, the original submission data may be retained for archival purposes or deleted according to our internal data management policies. The published FAQ itself does not contain personal data from the submission.

• Data may be retained longer if necessary to comply with legal obligations (e.g., regulatory requirements), resolve disputes, or enforce our agreements.

• Generally, personal data associated with FAQ submissions may be deleted or anonymized if no interaction has occurred between you and Rigicon related to this data within the preceding three years, or if you successfully exercise your right to erasure (subject to legal retention requirements).

10. Your Privacy Rights

Depending on your location (particularly if you are in the European Economic Area or California), you may have certain rights regarding your personal information under applicable law (like GDPR or CCPA/CPRA). These rights may include:

• The right to access: Request copies of your personal data that we hold.

• The right to rectification: Request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

• The right to erasure (‘right to be forgotten’): Request that we erase your personal data, under certain conditions.

• The right to restrict processing: Request that we restrict the processing of your personal data, under certain conditions.

• The right to object to processing: Object to our processing of your personal data based on legitimate interests, under certain conditions.

• The right to data portability: Request that we transfer the data that we have collected (that you provided or was generated through your use, processed based on consent or contract) to another organization, or directly to you, in a structured, commonly used, machine-readable format, under certain conditions.

• The right to withdraw consent: Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

To exercise these rights or for further information, please contact Rigicon’s data protection officer at [email protected]. We will respond to your request in accordance with applicable data protection laws. You may also have the right to lodge a complaint with a supervisory authority.

11. Compliance (HIPAA & CalOPPA)

• HIPAA: Rigicon is committed to ensuring the privacy and security of protected health information (PHI) as defined under the Health Insurance Portability and Accountability Act (HIPAA), and complies with its applicable Privacy and Security Rules in contexts where HIPAA applies (e.g., specific patient support programs, interactions with US healthcare providers). The general FAQ submission process itself may not always fall under HIPAA regulations unless PHI is processed in that context.

• CalOPPA: In compliance with the California Online Privacy Protection Act, Rigicon, Inc. ensures:

  • Users can visit our site anonymously.

  • A link to this Privacy Policy (containing the word ‘Privacy’) is conspicuously posted and easily accessible, typically via our homepage or the first significant page upon entering our website.

  • We will notify users of material changes to this Privacy Policy by updating this page and its “Last Updated” date.

12. Children’s Privacy

Our Service is not directed at or intended for use by children under the age of 16 (or a higher age threshold if required by applicable local law). We do not knowingly collect personally identifiable information from children under this age without verified parental consent. If you are a parent or guardian and you are aware that your child has provided us with Personal Data without your consent, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our servers.

13. Third-Party Links and Services (reCAPTCHA)

Our Service uses Google reCAPTCHA. Your interaction with reCAPTCHA is governed by Google’s own Privacy Policy and Terms of Use. We are not responsible for the privacy practices or content of third-party services.

14. International Data Transfers

Your personal data submitted through this Service may be transferred to, stored, and processed in countries outside your jurisdiction, including the United States where Rigicon, Inc. is located and where our servers may be hosted. Data protection laws in these countries may differ from those in your jurisdiction. We take appropriate measures to ensure that your data is protected during such transfers in accordance with applicable laws, such as using Standard Contractual Clauses approved by the European Commission where required.

15. Dispute Resolution and Limitation of Liability

To the extent permitted by applicable law, you agree that Rigicon, Inc. shall not be liable for issues arising from your use of the Service. In the event of any dispute related to the Service, you understand and agree that Rigicon, Inc. is under no obligation to become involved beyond its legal requirements. You hereby release and indemnify Rigicon, Inc. from any and all claims and demands arising out of or in any way related to such disputes or the Service, except where prohibited by law. This limitation does not affect your statutory rights as a consumer or data subject rights under applicable privacy laws.

16. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of material changes by posting the updated policy on this page and revising the “Last Updated” date. We encourage you to review this policy periodically for any changes. Changes are effective when they are posted on this page.

17. Contact Us

For questions or concerns about this Privacy Policy or our privacy practices:

• Email (Data Protection Officer): [email protected]

• Email (General Operations): [email protected]

• Telephone: +1 (888) 202-9790

• Postal Address: Rigicon, Inc. 2805 Veterans Memorial Hwy STE 5 Ronkonkoma, NY 11779, USA

• Local Representative: Find your local Rigicon office via the Contact Us section on our corporate website (https://www.rigicon.com).