Privacy Policy

Privacy Policy – Last Updated: January 10, 2024

This Privacy Policy is applicable to this website and the communications defined and described below. The responsible entity for this website is GoldenGait Ltd. The services are partially provided by GaitBetter Inc., and data transfer between GoldenGait Ltd. and GaitBetter Inc. occurs. Appropriate agreements and safeguards are in place to secure your data in all jurisdictions, in accordance with the requirements of Chapter 5 General Data Protection Regulation (GDPR).

The controller of your personal data is GoldenGait Ltd., which collects personal data from and about you or to which you provide personal data. If you have any questions regarding the controller of your specific personal data, please contact the Data Protection Officer of GoldenGait Ltd. at info@gaitbetter.com.

GoldenGait Ltd. (or “We“) respects your privacy and is committed to protecting it through our compliance with the practices described in this Privacy Policy. If the GDPR applies to your data or our processing, we will only process your personal data in accordance with Article 6 GDPR based on consent, performance of a contract, compliance with a legal obligation, vital interests, or our legitimate interests.

This Privacy Policy outlines our practices for processing, including collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit GoldenGait Ltd. website or other digital properties, communications, or forms (“Website”), or when you submit requests or forms or any other type of communication, be it physical, electronic, via telephone, or in-person (“Communication”) that links or refers to this Privacy Policy. This Privacy Policy applies to the personal data collected through the Website, emails, or website-related electronic communication, as well as offline activities and communications, regardless of the country you are located in. This Privacy Policy does not apply to device usage and maintenance. Please refer to the applicable privacy policy of the device buyers (e.g., clinic’s/hospital’s).

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

Please carefully read this Privacy Policy to understand our policies and practices for processing and storing your personal data. This Privacy Policy may change from time to time. Your continued engagement with the Website after any revisions indicates that you have taken notice of them, so please check the Privacy Policy periodically for updates.

Data We May Collect About You

We collect and use different types of data from and about you:

1. Personal Data: Information relating to an identified or identifiable natural person (“personal data”). This may include your and/or your facility’s/company’s name, postal address, email address, telephone number, title, position, market, or other similar identifiers which we may use to contact you online or offline; if you make a purchase, we may ask for your credit card number and/or billing information.

2. Technical Information: Information related to your person, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, or operating system and platform.

3. Non-Personal Data: Information that does not directly or indirectly reveal your identity or does not relate to an identified individual. If we combine non-personal data with personal data to directly or indirectly identify an individual, we treat the combined information as personal data.

 How We Collect Data About You

We use different methods to collect data from and about you, including:

1. Direct Interactions: Information you provide when you fill in forms, correspond with us by phone, email, or otherwise. This includes information you provide when you create an account, subscribe to our services, search for a product, place an order, provide us with your contact details, or other information at trade shows, and when you report a problem with our Website.

2. Automated Technologies or Interactions: Technical data about your equipment, browsing actions, and patterns collected automatically as you interact with our Website. We collect this information using cookies, server logs, and other similar technologies.

3. Third Parties or Publicly Available Sources: Information about you received from third parties, such as business partners, sub-contractors in technical, payment, and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, data brokers, or aggregators.

Cookies and Automatic Data Collection Technologies

Our Website uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other Website users. For further information about cookies and related technologies, please refer to our Cookie Notice.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Websites are provided by third parties. These third parties may use cookies or other tracking technologies to collect information about you. We do not control how these third-party tracking technologies operate or how they may use the collected data. A list of such third parties is included in the Cookie Notice.

How We Use Your Personal Data

We use your personal data to provide you with products, offer you services, communicate with you, deliver advertising and marketing, or to conduct other business operations. Examples of how we may use the personal data we collect include to:

• Present our Website and provide you with the information, products, services, and support that you request.
• Send information and respond to your inquiries and/or other requests or questions.
• Process your orders and send information and updates pertaining to such orders as well as the ordered products or services.
• Process and/or collect payments as well as performance of credit checks.
• Provide you with customized advertisements, content, and information.
• Assign you to the appropriate sales representative (based on your country information) for personal contact.
• Meet our obligations and enforce our rights arising from any contracts with you, including billing or collections or complying with legal requirements.
• Fulfill the purposes for which you provided the data or that were described when it was collected.
• Notify you about changes to our Website, products, or services.
• Ensure that we present our Website content in the most effective manner for you and for your computer.
• Administer our Website and conduct internal operations, including troubleshooting, data analysis, testing, research, and statistical and survey purposes.
• Improve our Website, products or services, marketing, or customer relationships and experiences.
• Administer contests, promotions, or other site features.
• Protect our Website, employees, or operations.
• Measure or understand the effectiveness of the advertising we serve you and others, and to deliver relevant advertising to you.
• Build and establish individual profiles of our customers.

We may combine the information we collect online from or about you with the information we collect offline from or about you. We may also combine your information that we’ve collected from you with information we may receive from other sources, such as address update services or co-promotion partners.

We may also use personal data to contact you about our own goods and services as well as third parties that may be of interest to you. If you do not want us to use your data in this way, please let us know by not checking the relevant box located on the form where we collect your data (the order form/registration form) or by

 sending a request to info@gaitbetter.com.

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. For further information regarding the retention of specific categories of personal data from you, please contact the Data Protection Officer of GoldenGait Ltd. at info@gaitbetter.com.

Disclosure of Your Personal Data

We may share your personal data with:

• GaitBetter Inc.: GaitBetter Inc. may use the data as a controller or processor for the purposes set forth in this Privacy Policy, for example, to contact you about their products or services which could be of interest to you.
• Business Partners, Suppliers, Service Providers, Sub-contractors, and Other Third Parties: We may share personal data with entities that support our business operations, subject to confidentiality agreements.
• Third Parties for Marketing: If you consent, we may share your personal data with third parties for marketing purposes.
• Advertisers and Advertising Networks: Data may be shared for the purpose of selecting and serving relevant advertisements.
• Credit Reference Agencies: Personal data may be disclosed to assess credit scores before entering into a contract with you.

We may also disclose your personal data to third parties:

• In the event that we sell or buy any businesses or assets, in which case we may disclose your personal data to the prospective seller or buyer.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.
• To comply with any court order, law, or legal process, including responding to any government or regulatory request.
• To enforce agreements.
• To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.
• To fulfill the purpose for which you provide the data.
• For any other purposes that we disclose when you provide the data.

We may share non-personal data without restriction.

Personal Data Transfer

We may process, store, and transfer the personal data we collect to a country outside your own, with different privacy laws. In such cases, we ensure that the recipients of your personal data maintain an adequate level of data protection in accordance with the requirements of Chapter 5 GDPR.

Your Personal Data Use Choices

We provide choices regarding certain personal data uses, particularly around marketing and advertising:

1. Promotional Offers from GoldenGait Ltd.: You can opt-in to receive promotional emails by checking the relevant box on the form where we collect your data or by adjusting your account profile’s user preferences. You may opt-out at any time by following the opt-out links in the message.

2. Third-Party Advertising: If you consent, you can opt-in to share personal data with third parties for promotional purposes by checking the relevant box on the form where we collect your data or by contacting us at info@gaitbetter.com. You may opt-out at any time by contacting us at info@gaitbetter.com.

3. Tracking Technologies and Advertising: You can opt-in to or adjust your advertising preferences by sending an email with your request to info@gaitbetter.com.

Our Website may contain links to and from the websites of our partner networks, advertisers, and affiliates or plug-ins enabling third-party features. These third parties have their own privacy policies, and we do not accept any responsibility or liability for these policies. Please check these policies before submitting any personal data to these third parties.

Your Rights: Accessing, Correcting, Deleting, and Objecting to Processing of Your Personal Data

You can access, review, and change your personal data by sending an email to info@gaitbetter.com to request access to, reception, correction, or deletion of any personal data that you have provided us with or to restrict or object to the processing of your personal data. Depending on the applicable law, you may also ask for data portability and have a right to lodge a complaint with a supervisory authority.

When you request your data, please include your name, email, postal address, and specific request, along with any information we may need to process your request. Please note that GoldenGait Ltd. might have to disclose your personal data in the request to GaitBetter Inc. to attend to your request.

You have the right to withdraw your consent any time, but this will not affect the lawfulness of processing based on your consent before withdrawal. Please note that we can only delete your personal data by also deleting your user account. We may refuse a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.

Data Security

The security of your personal data is crucial to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. Please do not share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Websites.

Changes to Our Privacy Policy

We will post any changes to our Privacy Policy on this page and indicate on the Website home page that we updated this Privacy Policy. If changes fundamentally alter how we use or treat your personal data, we will notify you through a notice on the Website home page or by email. Please check back frequently to see any updates or changes to our Privacy Policy.

Contact Information

Questions, comments, and requests regarding this Privacy Policy and our privacy practices are welcome and should be addressed to GoldenGait Ltd. by email at info@gaitbetter.com.