Privacy Policy

Rayner Group – External Privacy Policy

 

(A) This Policy

This Policy is issued by each of the Controller entities listed in Section (P) below (together, “Rayner”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, clinic staff who use our platforms, visitors to our Sites, users of our Apps, other users of our products or services, personnel of corporate customers and vendors, applicants for employment, and visitors to our premises (together, “you”). Defined terms used in this Policy are explained in Section (R) below.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

This Policy was last updated on 19 May 2025.

 

(B) Collection of Personal Data

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources: Data provided to us: We obtain Personal Data when those data are provided to us (e.g., when you sign up for our Newsletter; when you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application). In particular, when you create or use a RayPRO account, we may receive your account details.

• Data we obtain in person: We obtain Personal Data during meetings, at trade shows, during visits from sales or marketing representatives, or at events we attend.
• Collaborations: We obtain Personal Data when you collaborate with us in research or in an advisory/consultancy capacity.
• Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you, or to your employer).
• Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
• App data: We collect or obtain Personal Data when you download or use any of our Apps.
• Site data: We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
• Registration: We collect or obtain Personal Data when you use, or register to use, any of our platforms, Sites, Apps, products, or services, or when you use a RayPRO account.
• Content and advertising information: If you interact with any third party content or advertising on a Site or in an App (including third party plugins and cookies) we receive Personal Data from the relevant third party provider of that content or advertising.
• Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

 

(C) Creation of Personal Data

We also create Personal Data about you in certain circumstances, such as records of your interactions with us. We may also combine Personal Data from any of our platforms, Sites, Apps, products, or services, including where those data are collected from different devices or sources.

 

(D) Categories of Personal Data we Process

We Process the following categories of Personal Data about you: Personal details: given name(s); preferred name; last name; work name; and photograph.

• Contact details: correspondence address; shipping address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
• Correspondence: records and copies of your correspondence if you contact us.
• Professional details: your CV; records of your expertise; professional history; practising details and qualification details; information about your experience; participation in meetings, seminars, advisory boards and conferences; information about your professional relationship with other individuals or institutions; language abilities; and other professional skills.
• Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
• Visitor logs: records of visits to our premises.
• Consent records: records of any consents you have given, together with the date and time, means of consent, and any related information (e.g., the subject matter of the consent).
• Order details: records of orders; and consignee name, address, contact telephone number and email address.
• Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.
• Data relating to our platforms, Sites, and Apps: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; location data; country; region; post code; and other technical communications information (some of which may constitute Personal Data); registration details; clinic name; clinic address; username; password; security login details; usage data; aggregate statistical information; crash data (e.g., error reports, logs, operating system); and usage statistics (e.g., number of sessions, session duration, features accessed).
• Employer details: where you interact with us in your capacity as an employee of a third party; your job role, and the name, address, telephone number and email address of your employer, to the extent relevant.
• Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
• Cookie data: we collect information via cookies and similar technologies. Please see our Cookie Policy for more details.
• Security information: your password(s); login attempt details; security settings; and other security-related information.
• Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

 

(E) Sensitive Personal Data

We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

• Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
• Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);
• Establishment, exercise or defence of legal claims: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal claims; or
• Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

 

(F) Purposes of Processing and legal bases for Processing

The purposes for which we Process the categories of Personal Data identified in Section (D) above, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

 

 

 

(G) Disclosure of Personal Data to third parties

We disclose Personal Data to other entities within the Rayner group, for legitimate business purposes and the operation of our platforms, Sites, Apps, products, or services to you, in accordance with applicable law. In addition, we disclose Personal Data to:

• you and, where appropriate, your appointed representatives;
• accountants, auditors, consultants, lawyers and other outside professional advisors to Rayner, subject to binding contractual obligations of confidentiality;
• third party Processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);
• clinics and their staff, including surgeons, medical professionals and clerical staff, subject to duties of confidentiality;
• any relevant party, regulatory body, governmental authority, tax authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;
• any relevant party, regulatory body, governmental authority, tax authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
• any relevant third party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
• any relevant third party provider, where our Sites use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

 

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

 

(H) International transfer of Personal Data

Because of the international nature of our business, we transfer Personal Data within the Rayner group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Policy. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where no exemption or derogation applies, and we transfer your Personal Data from the UK or the EEA to recipients located outside the UK or the EEA (as applicable) who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses / UK addendum to the Standard Contractual Clauses). You are entitled to request a copy of our data transfer mechanisms using the contact details provided in Section (P) below.

Please note that when you transfer any Personal Data directly to any Rayner entity established outside the UK or the EEA (as applicable), we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Policy.

 

(I) Data security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

 

(J) Data accuracy 

We take every reasonable step to ensure that:

• your Personal Data that we Process are accurate and, where necessary, kept up-to-date; and
• any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

 

(K) Data minimisation

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.

 

(L) Data retention

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data are as follows:

 

(1)   we will retain Personal Data in a form that permits identification only for as long as:

(a)   we maintain an ongoing relationship with you (e.g., where you have subscribed to our Newsletter, or where you are an employee of a corporate customer); or

(b)   your Personal Data are necessary in connection with the lawful purposes set out in this Policy, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between us and your employer, and we have a legitimate interest in Processing those Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),

plus:

(2)   the duration of:

(a)   any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and

(b)   an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim)

and:

(3)   in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

 

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

 

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

• permanently delete or destroy the relevant Personal Data; or
• anonymize the relevant Personal Data.

 

 

(M) Your legal rights

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

• the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our platforms, Sites, Apps, products, or services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
• the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
• the right to request rectification of any inaccuracies in your Relevant Personal Data;
• the right to request, on legitimate grounds:
  • erasure of your Relevant Personal Data; or
  • restriction of Processing of your Relevant Personal Data;
• the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
• where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
• the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (i.e., in relation to the UK, the Information Commissioner’s Office (https://ico.org.uk/) or in relation to the EU, the Data Protection Authority for EU Member State in which you live, or in which you work, or in which the alleged infringement occurred (see the list here: https://edpb.europa.eu/about-edpb/about-edpb/members_en)).

 

 

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data: the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR / UK GDPR; and the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

 

This does not affect your statutory rights.

 

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (P) below. Please note that:

• in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and
• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

 

(N) Terms of Use

All use of our platforms, Sites, Apps, products, or services is subject to our Terms of Use. We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

 

(O) Direct marketing

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Platforms, Sites, Apps, products, or services that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Platforms, Sites, Apps, products, or services. If we provide Platforms, Sites, Apps, products, or services  to you, we may send or display information to you regarding our Platforms, Sites, Apps, products, or services , upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

 

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send. Please note that it may take up to 2 weeks to process your unsubscribe request during which time you may continue to receive communications from us. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Platforms, Sites, Apps, products, or services  you have requested.

 

(P) Details of Controllers

For the purposes of this Policy, the relevant Controllers are:

Alternatively, you may contact us using our online Contact Us form.

 

(Q) Representative

Each of the controllers established outside the EEA and listed in Section (P) above has appointed Rayner Surgical GmbH (reg: HRB 4881), Rudower Chaussee 9, 12489 Berlin to be its representative for the purposes of Article 27 of the GDPR.

Each of the controllers established outside the UK and listed in Section (P) above has appointed Risk & Compliance Manager, the Rayner Group, 10 Dominion Way, Worthing, West Sussex, BN14 8AQ, United Kingdom to be its representative for the purposes of Article 27 of the UK GDPR.

 

 

(R) Definitions

• “App” means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).
• “Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
• “CCPA” means the California Consumer Privacy Act, as amended by the California Privacy Rights Act.
• “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
• “Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
• “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
• “EEA” means the European Economic Area.
• “GDPR” means the General Data Protection Regulation (EU) 2016/679.
• “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
• “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
• “Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
• “Relevant Personal Data” means Personal Data in respect of which we are the Controller.
• “Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, biometric data, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.
• “Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
• “Site” means any website operated, or maintained, by us or on our behalf.
• “UK GDPR” means the GDPR as it forms part of the laws applicable in the UK by virtue of section 3 of the European Union (Withdrawal) Act 2018 and the Data Protection Act 2018, and as applied and modified by Schedule 2 of the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419) or as modified from time to time.
• “UK International Data Transfer Agreement” means the template transfer agreement adopted by the UK Information Commissioner’s Office on 21 March 2022.

 

 

Local Appendices

 

Australia   To the extent that the laws of Australia govern the Processing of Personal Data under this Policy, the following amendments to this Policy apply:   Applicable law: Where we collect, hold, use and disclose your Personal Data, we will comply with our obligations under the Privacy Act 1988 (Cth) (“Privacy Act”), (including the Australian Privacy Principles (“APPs”) to the extent they apply) and any applicable binding codes issued under the Privacy Act, irrespective of our role as controller or processor under other laws. Throughout this Policy, the terms “Controller” and “Processor” are reinterpreted accordingly.   Personal Data and Sensitive Personal Data: In this Policy, references to Personal Data includes opinions about an identified individual or an individual who is reasonably identifiable, whether or not those opinions are true.   Failure to provide Personal Data: If the Personal Data you provide to us is incomplete or inaccurate, or if you elect not to provide us with Personal Data, we may be unable to provide you with the service or information you are seeking.   Laws requiring or authorising collection: We collect Personal Data to assist us to fulfil our legal and regulatory obligations, including under the Corporations Act 2001 (Cth), the Competition and Consumer Act 2010 (Cth), the A New Tax System (Goods and Services Tax) Act 1999 (Cth).   International transfers of Personal Data: The transfer of Personal Data to other countries as contemplated by Section (H) includes the transfer of Personal Data outside of Australia. The recipients of such Personal Data may be located in any part of the world.   Your legal rights: In Section (M) (Your legal rights) the following additional rights shall apply:   The right to request access to, or correction of, your Personal Data held by us using the contact details provided in Section (P) (Details of Controllers). If we deny your request (in accordance with applicable law), we will provide reasons within a reasonable time. The right to contact us about any complaint in relation to a breach of the Australian Privacy Principles (“APP”) or a registered APP code. Please use the contact details provided in Section (P) (Details of Controllers).  We will take all reasonable steps to investigate and will respond to you within a reasonable time. The right to make a complaint to the Office of the Information Commissioner (“OAIC”) if you are dissatisfied with our response. To lodge a complaint, visit the Privacy ‘Complaints’ section of the OAIC website located at https://www.oaic.gov.au/privacy/privacy-complaints.

 

 

Brazil   To the extent that the laws of Brazil govern the Processing of Personal Data under this Policy, the following amendments to this Policy apply:   Purposes of Processing and legal bases for Processing: In Section (F) (Purposes of Processing and legal bases for Processing), the legal basis for Processing Personal Data for the purposes of Management of IT Systems, Security, and Fraud Prevention shall each be deemed include the following: Whenever the Processing is necessary to prevent fraud and to ensure your safety with respect to the identification and authentication procedures of electronic systems (to the extent that such Processing is not overridden by your data protection rights, fundamental rights, or freedoms)   Your legal rights: In Section (M) (Your legal rights) the following additional right shall apply: The right to be informed about the public or private entities with whom we have shared your Personal Data.

 

 

 

 

 

If you are a California resident, the CCPA grants you the following rights regarding your Personal Information:

 

• Right to Know: California residents have the right to request that we disclose the categories of Personal Information that we collect, use, disclose or sell about you. You may also request the specific pieces of Personal Information that we have collected about you.
• Right to Request Deletion of Personal Information: California residents have the right to request that we delete any Personal Information that we have collected from or about you. However, we may retain Personal Information as authorized under the CCPA or other applicable law, such as Personal Information required to provide our services, to protect our business and systems from fraudulent activity, to debug and identify errors that impair existing functionality, to comply with legal obligations, to comply with law enforcement requests pursuant to lawful process, for scientific or historical research, for us or others to exercise free speech or other rights, or for our own internal purposes reasonably related to your relationship with us.
• Right to Correct: California residents have the right to request that we correct inaccurate Personal Information that we maintain about you, taking into account the nature of Personal Information and the nature of processing. However, we are not required to comply with a request to correct where we have a good-faith, reasonable, and documented belief that a request is fraudulent or abusive, or if we have determined based on the totality of the circumstances, that the contested Personal Information held by us is more likely than not accurate and therefore does not require correction.
• Right to Opt-Out: California residents have the right to opt-out of the sale or sharing of their Personal Information for cross-context behavioral advertising. We do not sell or share for cross-context behavioral advertising any of the categories of Personal Information that we collect about California residents via our platforms, Sites, Apps, products, or services – so there is no need to exercise these opt-out rights.
• Right to Non-Discrimination. California residents have the right to not be discriminated against for exercising their CCPA rights. We will not “discriminate” against you for exercising your CCPA rights as we understand that term to be defined by the CCPA and its implementing regulations.
• Authorized Agent. Under the CCPA, you may appoint an authorized agent to submit requests to exercise your rights on your behalf. Should you choose to do so, for your and our protection, we will require your authorized agent to provide us with signed permission demonstrating they are authorized to submit a request on your behalf. We note, should your authorized agent fail to submit proof that they have been authorized to act on your behalf, we will deny their request.

 

To exercise your rights under the CCPA, please submit your request through email at: privacy@rayner,com. Generally, in order to verify your requests to exercise your rights, we will compare the personal information we have about you to pieces of personal information we will request in the course of processing your request. The personal information required for verification may include your name, email address, phone number, or postal address. We will deliver a response to you within 45 days of receiving your verifiable California resident request.

 

California’s “Shine the Light” Law:  Under California’s “Shine the Light” law, California residents are entitled to ask us for a notice describing what categories of Personal Information Rayner shares with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. However, we do not “share” your Personal Information as we understand that term to be defined by “Shine the Light” law, so there is no need to exercise these rights.

 

Metrics On Your Rights: The CCPA requires us to track and publish the below metrics for the previous calendar year. The below metrics are our calculations from 1 January to 31 December of the previous year, and include requests from all individuals in the U.S.

 

Right to Know

Received: 0

Complied with: Non applicable

Denied: Non applicable

Average response time: Non applicable

 

Right to Delete

Received: 0

Complied with: Non applicable

Denied: Non applicable

Average response time: Non applicable

 

Right to Opt-out of Sale We don’t sell or share your Personal Information as those terms are used in the CCPA.

 

 

 

Canada   To the extent that the laws of Canada govern the Processing of Personal Data under this Policy, the following amendments to this Policy apply:   Rayner Surgical Corp is the entity that is responsible for your personal information.   We rely on consent as the legal basis to Process your Personal Data for the purposes described in this Privacy Policy, including in Sections (E) and (F) above. Such consent may be express or implied depending on the context, and in some cases, where legally required or permitted, we may rely on an exception to consent to Process your Personal Data.   If you unsubscribe or otherwise ask to stop receiving our marketing communications, we will give effect to your request without delay and in any event within 10 business days.   Your Personal Data will be transferred (or otherwise made available) to third party Processors and entities within the Rayner group that may be located outside of Canada or your province (including, for individuals in Quebec, outside Quebec), including in the U.S. or other foreign jurisdictions.   We and our Canadian, US, and other foreign service providers may provide your Personal Data in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S., or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities.   Information about our Privacy Governance Policies and Practices   We are committed to protecting personal information and have implemented a comprehensive set of policies and practices that govern our treatment of personal information including. This includes, among other things:   Policies and procedures to protect personal information in our custody and control from unauthorized access, use or disclosure. Processes to respond to data subject requests and complaints in a timely and effective manner. A framework for the retention and destruction of personal information to ensure compliance with legal obligations, and to securely destroy personal information once no longer required. A framework that defines the roles and responsibilities for our employees with respect to the treatment of personal information throughout the lifecycle of the information.   Contact Us   If you have any questions about out this Privacy Policy or our privacy practices, including our use of service providers located outside of Canada, or wish to exercise your rights to access, correct, or rectify your Personal Data, or to withdraw your consent, please contact us by email at privacy@rayner.com.

 

 

India   To the extent that the laws of India govern the Processing of Personal Data under this Policy, the following amendments to this Policy apply:   Applicable law: Where we process your Personal Data and your Sensitive Personal Data, we will comply with our obligations under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”), the Digital Personal Data Protection Act, 2023 and the draft Digital Personal Data Protection Rules, 2025 (to the extent they apply).   Data collection: We will share with you, the name and the contact details of the agency that is collecting and / or retaining your sensitive personal data or information.   Grievance Officer: The Managing Director of Rayner Surgical India Private Limited has been designated as the Grievance Officer (as defined under the SPDI Rules) and the following are their contact details privacy@rayner.com.   Disclosure to a third party: Before your sensitive personal data or information is disclosed to a third party, we shall specifically take your permission or add it in your consent form, permitting us to share sensitive personal data or information with third parties.   Transfer of information: We shall only transfer your sensitive personal data or information to a third party either in India or outside if, the third party ensures the same level of data protection that we are providing according to the SPDI Rules.   Notice: Prior to asking for your consent, to share your personal data with us, we shall share a notice which will include (a) the manner in which you can exercise your rights and (b) the manner in which you may make a complaint to the Data Protection Board of India, in case of breach of your personal data.   Consent: We shall ensure that your consent shall be limited for a specific purpose, and shall not be conditional or ambiguous.   Your legal rights: In Section (M) (Your legal rights), the following additional rights shall apply:   (a)   The right to obtain details of all the other entities with whom your data has been shared, along with the description of the personal data that has been shared. (b)   The right to address grievances in respect of any act or omission by us, regarding the performance of our obligations to you, before approaching the Data Protection Board of India. (c)   You shall have the right to nominate another individual who shall in the event of your death or incapacity, exercise your rights.   Breach of Personal Data: Upon becoming aware of a breach of Personal Data, we shall immediately inform you of the breach, the consequences of the breach, the actions that we will take to mitigate the damage, the safety measures that you can take and the contact details of the person that you can contact to respond to your queries.   Data Protection Contact: The Managing Director of Rayner Surgical India Private Limited is the Data Protection Contact who can answer your queries. The following are their contact details, privacy@rayner.com.

 

 

Philippines   To the extent that the laws of the Philippines govern the Processing of Personal Data under this Policy, the following amendments to this Policy apply:   Sensitive Personal Data: In Section (E) (Sensitive Personal Data) the following wording is deemed to be deleted:   Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);   and replaced by the following wording:   Compliance with court order: We may Process your Sensitive Personal Data in compliance with a warrant or subpoena or other similar order issued by a court pursuant to the Cybercrime Prevention Act of 2012 or other laws;   In Section (R) (Definitions), the definition of “Sensitive Personal Data” is deemed to be deleted and replaced with the following wording:   “Sensitive Personal Data” refers to personal information: (1) About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations; (2) About an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings; (3) Issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and (4) Specifically established by an executive order or an act of Congress to be kept classified.