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Privacy Policy

Privacy Policy

Surgo Group is committed to protecting your privacy. This Statement of Privacy applies to the Surgo Group website and services platform.  This statement governs the data collection, processing and usage practices of Surgo Group. By using the Surgo Group’s website or services platform, you consent to the data practices described in this statement.

Surgo Group complies with the U.S. – E.U. Safe Harbor framework and the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union and Switzerland respectively. Surgo Group has certified that it adheres to the U.S – EU and Swiss – EU Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.   Information regarding the both the E.U. and Swiss Safe Harbor Frameworks can be found at: http://export.gov/safeharbor

Information Related to Data Collected and Processed for our Clients on our Services Platform

Service Provider Collection/Use

Surgo Group collects information under the direction of its Clients, Surgo Group has no direct relationship with the individuals whose personal data it processes. Surgo Group works with its Clients to help them provide notice to their customers concerning, the purpose for which personal information is collected.

Choice

We collect information for our clients, if you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the client that you interact with directly.  If you are a Client and would like to update your account please contact us here.

Service Provider, Sub-Processors/Onward Transfer

Surgo Group may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients

Access to Data Controlled by our Clients

Surgo Group has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Client (the data controller). If the client requests Surgo Group to remove the data, Surgo Group will respond to their Client’s request within 30 business days.

Data Retention

Surgo Group will retain personal data we process on behalf of our Clients for as long as needed provide services to our Client. Surgo Group will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Website Collection and Use Practices

Surgo Group collects personally identifiable information, such as your e-mail address, name, company name, home and/or work address and/or telephone number

In the event that you contact us for customer support through the website, we may also request that you provide additional User Information relevant to the support requested by you. Users are under no obligation to provide such information. However, we cannot guarantee that we can provide customer support in the event that relevant information related to the use of our products or services is withheld. We may retain communications relating to customer support, and/or information drawn from such communications, for statistical and/or reference purposes.

Social Media (Features) and Widgets:

Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the “Share This” button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Links to Other Websites

Our Site includes links to other Web sites whose privacy practices may differ from those of Surgo Group.  If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.

Testimonials

With your consent we may post your testimonial along with your name.

Public Forums:

Our Web site offers publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Surgo Group’s public message boards, blogs, or forums, this information may be collected and used by others. Note: Surgo Group does not read your private online communications with others.

Use of your Personal Information

Surgo Group collects and uses your personal information to operate the Surgo Group website and deliver the services you have requested. Surgo Group may also use your personally identifiable information to inform you of other products or services available from Surgo Group and its affiliates. Surgo Group may also contact you via voluntary surveys to conduct research about your opinion of current services or of potential new services. Surgo Group does not sell, rent or lease its customer lists to third parties in which we do not have a formal agreement to provide services to Surgo Group and our customers or prospects. Surgo Group does not share personally identifiable information except as described in this policy. Surgo Group may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, Surgo Group may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries or contact you based on your interest to receive such communications. Such third parties are prohibited from using your personal information except to provide these services to Surgo Group, and they are required to maintain the confidentiality of your information.  Surgo Group does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

General Privacy Practices

Tracking Technologies

Log Files

Surgo Group also collects anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites using log files

There is also information about your computer hardware and software that is automatically collected by Surgo Group. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by Surgo Group for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Surgo Group website. For these purposes, we do link this automatically-collected data to personally identifiable information such as name, email address, address, and phone number.

Cookies

The Surgo Group website uses “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Surgo Group pages, or register with Surgo Group site or services, a cookie helps Surgo Group to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Surgo Group website, the information you previously provided can be retrieved, so you can easily use the Surgo Group features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Surgo Group services or websites you visit. Surgo Group keeps track of the websites and pages you visit within Surgo Group, in order to determine what Surgo Group services are the most popular. This data is used to deliver customized content and advertising within Surgo Group to customers whose behavior indicates that they are interested in a particular subject area.

Flash Cookies and Other Third Party Tracking Technologies

The Adobe Flash Player (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies but these are managed through a different interface than the one provided by your web browser. This technology creates locally stored objects that are often referred to as “Flash cookies.”

Surgo Group does not use Flash cookies.  However, our Clients of our software platform may create pages on the Surgo Group platform that employ Adobe Flash cookies.  Our Terms of Service requires our Clients to inform you about their use of Flash cookies.  Surgo Group does not have access or control over our Clients’ Flash cookies, but you may access your Flash management tools from Adobe’s web site directly.

Similarly, our Clients may create pages on the Surgo Group platform that use technology from tracking utility companies, such as cookies and web beacons   The use of these technologies by our Clients is not covered by our privacy statement.  We do not have access or control over these third party tracking technologies.

Advertising

We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites.  Our ad network partner uses cookies and Web beacons to collect non-personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based upon your interests.  If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here http://preferences.truste.com/. Please note this does not opt you out of being served advertising.  You will continue to receive generic ads.

Clear Gifs (Web Beacons/Web Bugs)

We employ [or our third party advertising partner employs] a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective.  Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users.  In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We tie [do not tie] the information gathered by clear gifs to our customers’ personally identifiable information.

We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients.  This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.  If you would like to opt-out of these emails, please see “Choice and Opt-out.”

Third Party Tracking Technologies

The use of cookies and web beacons by any tracking utility company is not covered by our privacy statement.  We do not have access or control over these third party tracking technologies.

Legal Disclaimer

Surgo Group websites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Surgo Group or the site; (b) protect and defend the rights or property of Surgo Group (including enforcing this agreement); and, (c) act under exigent circumstances to protect the personal safety of users of Surgo Group, or the public.

Access to Personally Identifiable Information

If your personally identifiable information changes, or if you no longer desire our service, you may correct, update, request deletion on our site by emailing us at info@surgogroup.com to our Privacy team.  We will respond to all access requests within 30 days. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

If you request that your user information be deleted from our records, there may be a brief delay in our processing that request, while verify that the request is valid and originates from you as opposed to an unauthorized third party. If you request that your information be deleted, we reserve the right to terminate and/or limit your access to the Surgo Group website.

If you provide Surgo Group with user information, you have the following rights with respect to that information:

To exercise any of these rights, please contact us at info@surgogroup.com

Security of your Personal Information

No method of safeguarding information is 100% secure. Surgo Group uses a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. Surgo Group secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When sensitive personal information (such as a credit card number) is collected on our site and/or transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

Data Retention

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at info@surgogroup.com.  We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Changes to this Statement

Surgo Group will occasionally update this Statement of Privacy to reflect company and customer feedback. Surgo Group encourages you to periodically review this Statement to be informed of how Surgo Group is protecting your information. When such a change is made, we will update the “Last Updated” date above. If we make any material changes we will notify you or our Client by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

Surgo Group welcomes your comments regarding this Statement of Privacy. If you believe that Surgo Group has not adhered to this Statement, please contact Surgo Group at info@surgogroup.com. We will use commercially reasonable efforts to promptly determine and remedy the problem. Surgo Group is located at 40 Worth Street, 7th Floor, New York, NY 10013.  We can be reached by phone at +1 (212) 389 6293.

 

We are in compliance with the Digital Millennium Copyright Act (DMCA) as a registered ISP under copyright.gov. If our site is infringing on the copyright of another site please email us stating your name, website and matter of infringement and we will remove.