1. Scope.

This privacy policy covers Vita Imaging, Inc., its affiliates (collectively, “Vita Imaging, Inc.,” “we,” “us,” or “our”) and the website located at: www.vita-imaging.com as well as any other websites and subdomains owned or controlled by us (collectively, the “site”) and any and all tools, information, materials and other content offered through the site (“site content”).

Our site is provided as an information service for the startup community. While we implement reasonable security measures to protect personal information as described in Section 12 below, we cannot guarantee absolute security of data transmitted over the internet or stored electronically. Please consider this carefully before sending us any information that you deem confidential or proprietary. However, we remain committed to protecting your personal information in accordance with applicable data protection laws and this privacy policy.

 

By accessing or using our site, you acknowledge that you have read and understood this privacy policy. For processing activities that require consent under applicable law (including GDPR Article 6(1)(a) and Article 9(2)(a) for special categories of data), we will obtain your separate, explicit, and freely-given consent through clear affirmative action before collecting or processing such data. Your continued use of the site does not constitute consent for processing activities that legally require explicit consent. 

2.Your location.

You understand that our site is directed at users within the United States. You agree that all usage of our site and interactions by you with our site shall be deemed to have occurred in the United States, where we currently have all of our personnel and operations. Your information collected through the site will be stored and processed in the United States. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please be aware that we will process your personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR) where applicable. For EU residents, we rely on appropriate safeguards for international data transfers, including Standard Contractual Clauses (SCCs) approved by the European Commission under Commission Implementing Decision (EU) 2021/914, supplemented by additional technical, organizational, and contractual measures to ensure adequate protection as required by the Schrems II decision (Case C-311/18). You have specific rights under GDPR as detailed in Section 7 of this policy.

 

3. Information that We Collect and Legal Basis for Processing.

We collect personal information from our site visitors. The categories of information we collect can include:

Information that you provide to us. Information you provide through the site and on applications or other forms, or via email, telephone calls or written correspondence to us, or via other online platforms or digital media, such as your company name, your name and email address, social media handles, phone number, mailing address, payment information, medical device usage information, health-related information (if applicable), and other information you provide about you or your company. We may also collect sensitive personal information as defined under applicable law, including precise geolocation data and health information related to our medical devices.

Legal Basis for Processing (EU Residents): We process your personal data based on the following legal grounds under GDPR Article 6: (a) your consent; (b) performance of a contract with you; (c) compliance with legal obligations, including FDA and medical device regulations; (d) protection of vital interests; or (e) our legitimate interests in operating our business, provided such interests are not overridden by your data protection rights. For sensitive health data under Article 9, we rely on: (a) your explicit consent; (b) necessity for medical diagnosis or healthcare provision; or (c) public health purposes as required by law. For such sensitive data, we will obtain your explicit consent before collection, except where permitted by law (such as for medical device safety monitoring required by FDA regulations). You have the right to withdraw this consent at any time.

Information from other sources. We may obtain information from other sources, such as third-party information providers and combine this with information previously collected. In these cases, our privacy policy governs the handling of the combined information.

Information via cookies and tracking technology. We may obtain information about you as described below in “Cookies and Tracking Technology.”

We use information that we receive, collect or obtain from or about you for the following purposes: (a) to operate, maintain, and provide the site and our services; (b) to fulfill our contractual obligations to you; (c) to communicate directly with you regarding your account, transactions, or service-related matters; (d) to send you our newsletter and other marketing messages about our services (only with your prior opt-in consent where required by law); (e) to respond to your inquiries and requests; (f) to comply with legal obligations, including FDA medical device regulations and adverse event reporting; (g) to protect vital interests and ensure device safety; (h) for our legitimate business interests in improving our services and conducting analytics; and (i) for other purposes with your consent. For EU residents, each purpose corresponds to a legal basis under GDPR Article 6 as specified in Section 3. For more information about your communication preferences and rights, see Section 7 below.

 

4.Cookies and Tracking Technology.

We, and our third-party partners, automatically collect certain types of usage information when you visit our site, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, file information and similar technology (collectively, “tracking technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information. We also collect information about the way you use our site, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the site, whether you open emails or click the links contained in emails, and other actions you take on the site. When you access our site from a mobile device, we may collect unique identification numbers associated with your device, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the site and to understand more about the demographics of our users. We respond to Global Privacy Control (GPC) signals as required by California law. If you enable GPC, we will treat it as a request to opt-out of the sale or sharing of your personal information. Although we honor GPC signals, we do not currently respond to Do Not Track signals set by your browser.

We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) provide and monitor the effectiveness of our site; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance our site.

For EU residents: In compliance with the ePrivacy Directive and GDPR, we will only use cookies and similar tracking technologies after obtaining your explicit, freely-given consent through our cookie consent banner, except for strictly necessary cookies required for the site to function (such as session cookies, security cookies, and load-balancing cookies). You can withdraw your consent and manage your cookie preferences at any time through our cookie consent management tool accessible via the “Cookie Settings” link in our website footer. Withdrawing consent will not affect the lawfulness of processing based on consent before withdrawal.

If you prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the site. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. We and our third party partners may also use cookies and tracking technologies for advertising purposes.

 

5. Messaging Terms & Conditions

I. General

When you opt-in to the service, we will send you a message to confirm your signup.

By opting into messages, you expressly consent to receive recurring automated marketing and informational text messages from Vita Imaging. Automated messages may be sent using an automatic telephone dialing system or prerecorded voice to the mobile telephone number you provided when signing up or any other number that you designate. This consent is not required as a condition of purchasing any goods or services.

Message frequency varies, and additional mobile messages may be sent periodically based on your interaction with Vita Imaging. Vita Imaging reserves the right to alter the frequency of messages sent at any time to increase or decrease the total number of sent messages. Vita Imaging also reserves the right to change the short code or phone number where messages are sent.

Message and data rates may apply. If you have any questions about your text plan or data plan, it is best to contact your wireless provider. Your wireless provider is not liable for delayed or undelivered messages.

Your consent to receive marketing messages is not a condition of purchase.

II. Carriers

Carriers are not liable for delayed or undelivered messages.

 

III. Cancellation

You can cancel any time by texting “STOP”. After you send the SMS message “STOP”, we will send you a message to confirm that you have been unsubscribed and no more messages will be sent. If you would like to receive messages from Vita Imaging again, just sign up as you did the first time and Vita Imaging will start sending messages to you again.

 

IV. Info

Text “HELP” at any time and we will respond with instructions on how to unsubscribe. For support regarding our services, email us at Info@vita-imaging.com.

 

V. Transfer of Number

You agree that before changing your mobile number or transferring your mobile number to another individual, you will either reply “STOP” from the original number or notify us of your old number at Info@vita-imaging.com. The duty to inform us based on the above events is a condition of using this service to receive messages.

 

VI. Privacy

If you have any questions about your data or our privacy practices, please visit our [Link to SMS privacy policy].

 

VII. Messaging Terms Changes

We reserve the right to change or terminate our messaging program at any time. We also reserve the right to update these Messaging Terms at any time. Such changes will be effective immediately upon posting. Your continued enrollment following such changes shall constitute your acceptance of such changes.

 

VIII. Third Parties

Mobile opt-in data will not be shared with third parties.

 

6. How We Share Information and Categories of Third Parties.

We may share your personal information as described below:

For California residents: We may share your personal information with the following categories of third parties: service providers, business partners, advertising networks, analytics providers, affiliates and subsidiaries, and parties involved in corporate transactions. We do not sell your personal information as defined under CCPA. However, our use of certain advertising and analytics services may constitute “sharing” under California law, from which you have the right to opt-out.

For EU residents: We share your personal data only as necessary for the purposes described in this policy and in compliance with GDPR requirements. When we transfer personal data outside the European Economic Area to countries not deemed adequate by the European Commission (including the United States), we implement appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission pursuant to Article 46 GDPR, supplemented by additional technical and organizational measures as necessary. You may request a copy of these safeguards by contacting us at info@vita-imaging.com.

We may share your personal information with third-party service providers or business partners who help us maintain, update and operate the site or who perform services on our behalf, such as creating and operating email marketing campaigns, identifying and serving targeted advertisements, processing payments, sending mail, providing back-office services, or measuring traffic to the site and behavior on the site.

We may aggregate, or strip information of personally identifying characteristics, and then share that aggregated or anonymized information with third parties.

We may share or disclose your personal information if we determine, in our sole discretion, that we are required to do so under applicable law or regulatory requirements, or if we reasonably believe disclosure is necessary to prevent harm or financial loss, or in connection with preventing fraud or illegal activity, and/or to enforce our terms of use.

We may share with other companies and brands owned or controlled by Vita Imaging, Inc. or its affiliates and other companies owned by or under common ownership with Vita Imaging, Inc., which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies may use your personal information in the same way we can under this privacy policy.

We reserve the right to transfer any information we collect in the event we sell or transfer all or a portion of our business or assets or any portion or combination of our services, businesses and/or assets. Should such a transaction occur (whether a divestiture, merger, acquisition, bankruptcy, dissolution, reorganization, liquidation, or similar transaction or proceeding), we will use reasonable efforts to ensure that any transferred information is treated in a manner consistent with this privacy policy.

7. Your Privacy Rights and Choices.

From time to time, we may send you emails related to our site, public notices about our organization, or information about services we offer (or promotional offers from third parties) that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe” link provided at the bottom of the email communication. You have the right to opt-out of any marketing communications we send to you but not mandatory service-related communications (e.g., technical or legal notices).

Data Retention: We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. Specific retention periods include: (a) customer account information – for the duration of the business relationship plus 7 years for legal and tax purposes; (b) health-related data – as required by FDA regulations (typically 10 years from last device use); (c) marketing data – until you opt-out or 3 years of inactivity; and (d) website analytics – 26 months. After these periods, we will securely delete or anonymize your information.

Privacy Rights: Depending on your location, you may have the following rights regarding your personal information:

For California Residents (under CCPA/CPRA):
– Right to know what personal information we collect, use, disclose, and sell
– Right to delete personal information we hold about you
– Right to correct inaccurate personal information
– Right to opt-out of the sale or sharing of personal information
– Right to limit use of sensitive personal information
– Right to non-discrimination for exercising your rights

For EU Residents (under GDPR):
– Right of access to your personal data
– Right to rectification of inaccurate data
– Right to erasure (“right to be forgotten”) in certain circumstances
– Right to restrict processing
– Right to data portability
– Right to object to processing based on legitimate interests or for direct marketing
– Right to withdraw consent at any time (where processing is based on consent)
– Right to lodge a complaint with your local supervisory authority

For Virginia, Colorado, Connecticut, Utah, and other applicable state residents:
– Right to confirm whether we process your personal data
– Right to access your personal data
– Right to correct inaccuracies
– Right to delete personal data
– Right to data portability
– Right to opt-out of targeted advertising, sale of personal data, and profiling

To exercise any of these rights, please contact us at info@vita-imaging.com or write to us at Vita Imaging, Inc., 47633 Westinghouse Drive, Fremont, CA 94539. We will respond to your request within the timeframes required by applicable law (typically 30-45 days). We may need to verify your identity before processing your request.

 

8. Links to Third Party Sites.

We provide links to third party sites merely as a convenience and the inclusion of links does not imply any endorsement of or responsibility for the opinions, ideas, products, information, or services offered at such sites, or any representation regarding the content at such sites. When you click links to third party websites from our site, you understand that you will be leaving this site and that these third-party sites have their own privacy policies and terms of use. These links take you to publicly available sites which are not within our control. To the fullest extent permitted by law, Vita Imaging, Inc. and its affiliates disclaim all liability and are not responsible for the content of third-party sites, the privacy practices of such sites, or that those sites are free of viruses, contamination or contain accurate, complete or compliant information. We encourage you to review the privacy policies of any third-party sites you visit.

 

9. Children’s Privacy (COPPA Compliance).

Our site is intended for use strictly by adults. We do not knowingly solicit or collect personal information from children under the age of 13 (or 16 in the European Economic Area) without verifiable parental consent. If we learn that any personal information has been collected inadvertently from a child under the applicable age threshold, we will delete the information as soon as possible, and in any event within 30 days of discovery. If you are a parent or guardian and believe that we might have collected information from a child under the applicable age, please contact us immediately at: info@vita-imaging.com. Parents and guardians have the right to review, request deletion of, and refuse further collection of their child’s personal information.

 

10. Contact.

For further details about our privacy policy, to exercise your privacy rights, or to submit a privacy-related request or complaint, please contact: Vita Imaging, Inc., Privacy Officer, 47633 Westinghouse Drive, Fremont, CA 94539 or at info@vita-imaging.com. For users in the European Economic Area, you may also contact our EU representative at [EU representative contact information], and you have the right to lodge a complaint with your local data protection authority.

 

11. Changes to this Privacy Policy:

We may change the terms of this privacy policy from time to time. You may find a current version of this policy posted on our website at https://www.vita-imaging.com/privacy-policy/. If we make any material change(s) to this privacy policy, we will post a notice on our site before such change(s) take(s) effect.

 

Last updated: January 28, 2026