PLEASE READ THIS PRIVACY STATEMENT CAREFULLY

Your privacy is very important to Implantica MediSwiss. We also understand that privacy is very important to you. This Privacy Statement (hereinafter “Privacy Statement“) is designed to tell you about our practices regarding collection, use and disclosure of any personal data we gather through this website located at www.ImplanticaMediSwiss.com (hereinafter “Implantica website”). The Implantica website is owned and operated by Implantica Management AG, Baarerstrasse 57, CH-6300 Zug, Switzerland (hereinafter together: “Implantica”, “we”, “us”, “our” etc.). This Privacy Statement describes the types of personal data collected and processed through the Implantica website, through the services delivered via the Implantica website and how Implantica treats such information.

Please read the entire Privacy Statement and Cookie Policy before using or submitting information to the Implantica website. Controller Details

Please contact Implantica with any problems, questions or suggestions that you may have. The constant development of the internet requires occasional adjustments to our privacy statement. We retain the right to make changes when necessary.

The Controller of your Personal Data is: Implantica Management AG Baarerstrasse 57 CH-6300 Zug Switzerland Phone: +41 41 539 19 08 E-Mail: DataProtection@Implantica.com

WHAT IS PERSONAL DATA?

By using the term “Personal Data” in our Privacy Statement, we refer to information that you individually provide to Implantica either directly or indirectly that on its own or in combination with other information, can be used to identify you or make you identifiable. Personal Data includes for example your name, your mailing address, your telephone number, your e-mail-address or other information that identifies you or makes you identifiable.

Information without any connection to you as an individual does not qualify as Personal Data.

HOW DOES IMPLANTICA PROCESS YOUR PERSONAL DATA?

The Implantica website gathers Personal Data in two ways: (a) passively (for example, through our website’s technology), and (b) directly (for example, when you, the website user, voluntarily provide Personal Data by communicating with us).

Implantica shall only process your Personal Data for the purposes described in this Privacy Policy or as otherwise permitted under applicable law, including Regulation (EU) 2016/679 of 27 April 2016 (“General Data Protection Regulation” or “GDPR”).

In light of the importance of protecting children’s privacy, we do not collect, process or use on our website any information relating to an individual whom we know to be under 16 years old without the prior, verifiable consent of his or her legal representative.

WEB SERVER PROTOCOLS (INCLUDING IP ADDRESS)

Each time you visit the Implantica website to read or download information we may automatically collect, due to technical reasons, certain information about you from your computer. This information is collected from your computer’s web browser and may include information such as the following:

• The type of web browser software you use (for example: Firefox, Internet Explorer, etc.)
• The name of the domain from which you access the internet
• The internet address of the website from which you linked directly to our site
• The date and time you accessed our site
• The pages you visited on our site
• Information that has been de-identified

We will process the web server information for statistical purposes as well as for the optimisation of our marketing endeavours, our content and the layout of the Implantica website. The legal basis for such processing is our legitimate interests (Art. 6 para. 1 lit. f) GDPR), in particular, to ensure the proper functioning of the Implantica website and to improve our website services.

Further, we may process your web server information in cooperation with your internet access provider and/or local authorities in cases of system misuse in order to investigate and identify the originator of such system misuse. The legal basis for such processing is our legitimate interests (Art. 6 para. 1 lit. f) GDPR), in particular, the protection of the integrity of the Implantica website, our system, as well as our users.

IMPLANTICA SERVICES ON THE IMPLANTICA WEBSITE

Further, Implantica collects and processes Personal Data that you have provided to us on a voluntary basis; for example, when you complete a form, register for a newsletter, or correspond with us over the Implantica website. You may also use the Implantica website without actively providing Personal Data to us. However, please be aware that in this case you may not be able to use all of our services offered.

USER ACCOUNT

Most of our services do not require any form of registration, allowing you to visit our website without telling us who you are. However, some services may require registration. When you register with us, you may need to complete certain fields (some are required, and some are optional). We only process your Personal Data for the respective purpose. In these situations, if you choose to withhold any Personal Data requested by us, it may not be possible for you to gain access to certain parts of the Implantica website and for us to respond to you. The legal basis for such processing is the provisioning of our Implantica website services to you (Art. 6 para. 1 lit. b) GDPR) or, as the case may be, your consent (Art. 6 para. 1 lit. a) GDPR).

The Personal Data that we collect if you register for our services or when you ask us to personalize your visits to the Implantica website may include:

• Your name
• Address
• Email address

NEWSLETTER

Provided you have given us your consent, we will process your name and email address in order to send to you our newsletter on Implantica product and services and events. We only process your Personal Data to send you our newsletters. We will not sell or share your information with any third parties. The legal basis for such processing is your consent (Art. 6 para. 1 lit. a) GDPR).

The Personal Data that we collect if you register for our newsletter may include:

• Your name
• Address
• Email address

You may withdraw your consent to receive our newsletter at any time with future effect (e.g., by clicking the opt-out link provided in each newsletter or by contacting us directly under the contact details designated under item 11 below).

CONTACT REQUEST

In some places on the Implantica website you may have the chance to send us information about yourself. For example, the Implantica website may include contact or email forms. We only process your Personal Data in order to correspond with you. The legal basis for such processing is the provisioning of our Implantica website services to you (Art. 6 para. 1 lit. b) GDPR) or, as the case may be, your consent (Art. 6 para. 1 lit. a) GDPR).

The Personal Data that we collect if you fill out such contact forms may include for example:

• Your name
• Address
• Email address
• Other Personal Data included in the communication

SURVEYS AND ASSESSMENT

The Implantica website may offer users the opportunity to participate in surveys or assessments via the internet. Implantica will provide information about the purpose and process for each survey or assessment as part of the applicable survey or assessment. Please refer to the respective privacy statement provided in connection with the survey or assessment. The legal basis for such processing is your consent (Art. 6 para. 1 lit. a) GDPR).

You may withdraw your consent to participate in the survey or assessment at any time with future effect (e.g., by contacting us directly under the contact details designated under item 11 below).

COOKIES AND OTHER TECHNOLOGIES

Certain Personal Data may be passively collected (that is gathered without you actively providing the information) using various technologies, such as cookies, internet tags or web beacons, and navigational data collection (e.g., log files, server logs, clickstream, etc.) (hereinafter: “Cookies”). When you use the Implantica website, we may place a text file called a “Cookie” in the browser files of your computer when you visit. The Cookie may be stored on your computer’s hard drive. The information that we collect using Cookies is Personal Data that does not directly identify you. You are always free to decline our Cookies if your browser permits but some parts of the Implantica website may not work properly for you if you do so.

HOW DOES IMPLANTICA USE PERSONAL DATA?

Implantica may only process and store your Personal Data for the business purposes that are consistent with this Privacy Statement.

Implantica will obtain your consent i) before sharing your Personal Data with any third party that is not an affiliate or acting as an agent or vendor to perform tasks on our behalf or ii) to use the information for a purpose materially different from the purpose for which it was initially collected or subsequently authorized by you.

An exception to this will be (among others) where Implantica’s processing of Personal Data is necessary for compliance with a legal obligation under the applicable law (legal basis: Art. 6 para. 1 lit. c) GDPR) or for the purposes of the legitimate interests pursued by Implantica or by a third party (legal basis: Art. 6 para. 1 lit. f) GDPR).

SHARING PERSONAL DATA WITH OTHERS

Implantica may share Personal Data with affiliates as well as with vendors or agents, which are acting as data processors (cf. Art. 4 no. 8 GDPR) on behalf of Implantica for the purposes described in this Privacy Statement. For example, we may hire companies to assist with the provisioning of Implantica‘s services or protecting and securing our systems (e.g., the hosting of the Implantica website). Any vendor or agent that we retain must comply with our data privacy and security requirements and are not allowed to use Personal Data they receive from us for any other purpose. Like Implantica, they will never barter, trade or sell access to your Personal Data.

In all other cases, we do not share personal data with any third party, unless this is necessary to fulfil our services, permitted by applicable law or has been agreed by you.

DATA TRANSFERS TO THIRD COUNTRIES OUTSIDE THE EU/EEA

The processing of Personal Data contemplated in this Privacy Statement may involve the data transfer to third countries located outside the EU/EEA which have not been found by decision of the EU Commission to ensure an adequate level of data protection within the meaning of Art. 45 para. 1 GDPR.

In this case, Implantica ensures the protection of Personal Data by appropriate safeguards, which provide for an adequate level of data protection: for example, by (a) the execution of standard data protection clauses adopted by the Commission under applicable data protection laws; (b) the recipient’s certification under the EU-U.S. Privacy Shield framework (only applicable for transfers to the U.S.) or (c) the existence of any other specifically approved safeguard for data transfers (as recognised under applicable data protection laws, cf. Art. 46 GDPR).

STORAGE TIME

Implantica will only store your Personal Data as long as necessary to fulfil the purposes for which they were collected or – where the applicable law provides for longer retention periods – for the duration of the retention period required by law. After that, your Personal Data will be deleted.

PATIENT INFORMATION AND OTHER SENSITIVE INFORMATION

For processing of your sensitive information (e.g., medical information, Personal Data revealing ethnic or racial origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or a natural’s person sex life or sexual orientation), we will obtain your explicit consent.

Implantica is among others not required to obtain explicit consent with respect to sensitive information where the processing is (a) necessary to protect the vital interests of the data subject or another natural person where the data subject is physically or legally incapable of giving consent; (b) necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity; (c) necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or Implantica’s obligation to ensure high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of Union or Member State law, which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject, in particular professional secrecy; or (e) related to information that is manifestly made public by the individual.

If you provide us with Personal Data about other individuals, such as personal health information or other Personal Data information, you are obligated to ensure that the individual or the individual’s personal representative is aware of the disclosure and that he or she consents to the disclosure as well as to our Privacy Statement.

YOUR RIGHTS UNDER DATA PROTECTION LEGISLATION

In particular but without limitation, the following rights are vested in you by applicable data protection law:

• Right of access, rectification, erasure and restriction of processing: You have the right to obtain at any time access to your Personal Data stored by us. If we process your Personal Data, we shall endeavour to ensure by implementing suitable measures that your Personal Data is accurate and up-to-date for the purposes for which they were collected. If your Personal Data is inaccurate or incomplete, you have the right to obtain the rectification of such data. Furthermore, you may have the right to obtain the erasure or restriction of processing of your Personal Data, for example if no legitimate business purpose exists anymore for the data processing under this Privacy Statement or applicable law and the further storage is not required by statutory storage obligations.

• Right to data portability: You may have the right to receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another controller.

• Right to withdraw your consent: If you have given your consent to the collection or processing of your Personal Data, you have the right to withdraw your consent at any time on a prospective basis without affecting the lawfulness of processing based on the consent before its withdrawal. Supervisory authority competent for complaints: You may have the right to lodge a complaint with the competent data protection supervisory authority or, as the case may be, file a civil claim with the Kantonsgericht, Zug, Switzerland.

• Right to object: As far as we process your Personal Data on the basis of our legitimate interests pursuant to Art. 6 (1) lit. f) GDPR, you may object to processing at any time. You may find the detailed description of our processing activities and the legal basis in the sections before. If you object, we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing or the data is necessary for the establishment, exercise or defence of legal claims. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your Personal Data and decide whether to adjust the processing accordingly. Please note that the processing of your Personal Data may involve direct marketing activities as described above. If you do not want that we process your Personal Data for direct marketing activities, you can object free of charge at any time via email at DataProtection@Implantica.com.

To exercise your data subject rights, you may at any time contact us as provided in item 11 b