Privacy Policy

PION INC. and its affiliated company, Pion Inc. (UK) Ltd, (collectively, “PION,” “Company,” “we,” “us” and “our”) are committed to the protection of your personal information that is about you and which identifies you. This Privacy Policy (“Privacy Policy”) explains how PION collects and uses personal information about you as part of our business activities, including information provided to us offline, on websites, mobile sites, mobile applications, and other digital services and products controlled by PION that link to this Privacy Policy (collectively, “PION Sites”). This Privacy Policy describes what personal information we collect, how we will use such personal information, who we may disclose it to and your rights and choices in relation to your personal information. For purposes of data protection law, PION is the data controller in respect of the personal information that we collect and use as part of our business activities.

This Privacy Policy does not apply to third-party websites linked from PION Sites.

This Privacy Policy contains the following information:
Information We Collect
Website Use and Information We Collect Online
How We Use Your Information
How Long We Keep Your Information
Information We Disclose
Your Privacy Choices and Rights
Data Security
Accessing Our Sites Globally; Transferring Your Information to the US
Changes to Our Privacy Policy
How to Contact Us With Privacy Concerns

Information We Collect

For purposes of this Privacy Policy, “Personal Data” or “personal information” means information that identifies you or that could reasonably be used to identify you. While some of the information PION collects is required for business engagement purposes, other information is voluntarily given by the individual. The type of personal information that PION may collect, including through the PION Sites, may include, but is not limited to, the following:

Contact information such as your name, address, phone number, or email address
Registration information such as your username and password
Information about your employment such as employer name, title, address and contact information
Education and other background information when you inquire about employment with Pion
Payment information (such as banking information, payment card number, expiration date, delivery address, and billing address)
Content you may provide (for example, when you complete our Online Contact Form or submit other information)
Details of products and services you have purchased from us or inquiries you have made
Preference information, such as communications you receive from us
Any other information relating to you (or other individuals) which you provide to us directly or indirectly through access and use of our Sites, by email or by phone, surveys or questionnaires, completing forms or contacting customer service

We may also collect personal information from third parties including your organization and representatives, public sources, our related companies, and other parties.

Website Use and Information We Collect Online

The types of Personal Data that we may collect while you use the PION Sites are described in this section and include both information that you provide to us and information that we collect automatically when you use the PION Sites.

Information You Provide

You do not have to register for a service or program to receive much of the information available through PION Sites. However, some of our content is available only to registered or identified users and will require you to set up a profile or provide specific information about yourself in order to provide you the service.

Personal Data You Provide When Visiting PION Sites

PION collects Personal Data that you provide on PION Sites, for example, when purchasing a product, to receive marketing products and information, contact PION customer service, or respond to PION questionnaires or surveys.

Personal Data You Disclose During Other Interactions with PION

You may contact PION to ask questions, discuss your concerns, or report issues regarding our products. If you communicate with or request information from PION, you may be prompted to provide your contact information as well as any Personal Data that is relevant to your request.

Aggregated and De-Identified Data

We may also collect, use and disclose aggregated and de-identified data such as statistical or demographic data for any purpose. Aggregated and de-Identified data could be derived from your personal information but is not considered personal information under applicable law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated or de-identified data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.

Free-Text Boxes

The information that you provide in each case will vary. In some cases, you may be able to provide personal information via email or free text boxes, such as contacting the Company to request further information. When providing your personal information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.

Information That May Be Collected Automatically

When you use the PION Sites, we also may collect certain usage and device information automatically as described below.

IP Address

We may record the Internet Protocol (“IP”) address of your computer or other electronic device when you visit the PION Sites. An IP address identifies the electronic device you use to access the Sites, which allows us to maintain communication with your computer as you move about PION Sites and to customize content.

Cookies and Other Tracking Technologies

We also collect information about your use of PION Sites through tracking technologies such as cookies and web beacons. A “cookie” is a unique numeric code that is transferred to your computer to track your interests and preferences and to recognize you as a return visitor. A “Web beacon” is a transparent graphic image placed on a Web site, e-mail or advertisement that enables the monitoring of things such as user activity and site traffic. These technologies help remember your preferences and allow us to bring you the content and features that are likely to be of greatest interest to you on the basis of “clickstream” data that shows your previous activities on PION Sites.

We use Google Analytics to better understand our audience. In connection with that we, and Google, may use third-party cookies (such as the DoubleClick cookie) – and in some cases first-party cookies (such as the Google Analytics cookie) – to inform, optimize and serve information provided on our website as well as potentially displaying ads across the Internet, based on a user’s past visits to PION Sites.

We also may utilize Display Advertising (such as Retargeting with Google Analytics, Google Display Network Impression Reporting, DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting) to (1) show our ads based on your prior visits to PION Sites, and (2) better understand our ad impressions and use of ad services. In connection with the Google Analytics Demographics and Interest Reporting service, we may use data from interest-based advertising or third-party audience data (such as age, gender and interests) with Google Analytics to understand and improve our marketing campaigns and Site content.

You can opt out of Google Ads by visiting https://www.google.com/ads/preferences. If you do not want your data used by Google Analytics, you can install the Google Analytics opt-out browser add-on at the Google Analytics opt-out page.

Similarly, we may have LinkedIn tracking script running which serves advertisements based on activity on the PION Sites.

We may work with new technologies in the future that require cookies or web beacons to provide their services. As we work with new technologies, their descriptions will be updated in the Privacy Policy. This PION Site is not designed to respond to “do not track” signals received from browsers.

To learn more about cookies and other tracking technologies, including how to disable them, please visit https://www.allaboutcookies.org/. Please note that some cookies are essential to the functioning of our Sites and deleting or disabling them will reduce the site’s functionality.

Mobile Tracking

PION Sites are available either as mobile applications or mobile sites that you can use on your mobile device. If you use a mobile device to access and use the PION Sites, we may collect the following mobile-specific information in addition to the other information described above: device or advertising ID, device type, hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the version of your mobile operating system, the platform used to access or download the PION Site (e.g., Apple, Google, Amazon, Windows), location information and usage information about your device and your use of the PION Sites.

Information Collected From Other Sources

We may combine information about you from a visit to one PION Site with information about you from visits to other PION Sites. We may also combine information about you that is collected through the PION Sites with information that we have collected offline, as well as with information provided to us by third parties, such as third-party list providers.

As noted above, PION collects information from you in the course of your use of the PION Sites, products and services. We collect information from you when you request products or services. We collect information from you when you contact or communicate with us (including through the PION Sites, by email, phone or otherwise). We also collect your personal information while monitoring the PION Sites, products and services. We gather information about you when you provide it to us, or interact with us directly, for instance engaging with our staff. We may also in certain cases collect or receive information about you from other sources.

Other Websites

PION Sites may contain links to other third-party websites that are outside our control and are not covered by this Privacy Policy. These sites are not controlled by PION and PION is not responsible for any content on those sites or their privacy policies, which may differ from ours.

How We Use Your Information

PION uses the information we collect for the following principal purposes:

To provide you with the PION product and services you request and to respond to inquiries and communicate with you.
To offer and provide information about similar and/or related products and services.
To customize and improve your experience on PION Sites.
To generally improve our products and PION Sites and other internal business purposes.
Legal obligations to notify and report to authorities.
To manage our business relationship with you, including for billing and collection purposes.

Providing Products and Services You Request

If you choose to purchase a product or receive our services, we use the Personal Data that you provide through PION Sites to manage your orders and invoices, to process payments, to respond to your questions, provide you the services you request and offer an optimal customer experience.

Marketing

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information.

You may also receive marketing information from PION and related third parties, such as offers regarding PION related products or services, invitations to participate in surveys about our products, or notifications about special promotions. In such cases, we will use your contact and other Personal Data to send you marketing information. You may opt-out of receiving marketing communications from PION at any time by using the opt-out options specified in our marketing communications or by contacting us as described in the “How to Contact Us” section below. Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

Customized User Experiences

The Personal Data that you provide may be used to create customized offers, information, or services tailored to your interests and preferences. Also, we may use your IP address and the data that we obtain automatically through the use of cookies or similar tracking technologies to make our PION Sites easier to use and navigate as well as to personalize the content provided on PION Sites by anticipating the information and services that may be of interest to you.

Business and Product Improvement

In order to discover new facts that could help PION better understand customer needs and help improve, develop, and evaluate product, services, materials, and programs. PION analyzes the information that you have provided. For these purposes PION does not use information that can directly identify you.

Site Analytics and Improvement

We may use the information that you provide and the information we collect automatically about your use of the PION Sites to monitor user traffic patterns and preferences for site improvement, analytics and optimization. This may include things like buttons you click, mouse movements and other behavior on the Website, date and time of access, pages visited, web beacons, and cookie or pixel tag information. Please see our Cookies and Other Tracking Technology section above to learn more about cookies, pixels tags, and analytic technologies.

Legal Basis For Processing

For purposes of European data protection laws, PION has set out below the legal basis that we rely on to use your personal information. The legal basis that applies in a particular instance will depend on for which of the specific purposes described above PION is processing your personal information:

Consent – In certain cases, PION may ask for your consent to collect and use your personal information. Should you choose to provide your consent, you may later withdraw your consent by contacting us as described in the “How to Contact Us” section below. If you have consented to a particular purpose for our use of your personal information, then we may rely on your consent until you withdraw it. Please note that the withdrawal of consent will not affect processing that has already occurred, and may affect our ability to provide products, services or communications to you that are subject to the relevant consent.
To Comply With Legal Obligations or for Performance of a Contract – In other instances, the use of your personal information may be necessary in order to comply with an applicable law or regulation or for the performance of a contract to which you are subject. You may not be able to opt-out of this use, or your choice to opt-out may impact our ability to perform a contractual obligation otherwise owed to you.
Legitimate Business Interests – In still other instances, PION may use your personal information based on legitimate business interests of PION in communicating with you about our products and services, and about scientific research and educational opportunities. You have the right to opt-out of all such use of your personal information. You may do so by contacting us as described in the “How to Contact Us” section below.

How Long Do We Keep Your Information

The Personal Data we collect about you may be stored as long as it is required for the purposes identified when you provided the information for such specific purposes or for any new purposes identified by us and consented to by you, and for five years thereafter, after which point it will be archived only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.

Information We Disclose

We only disclose your Personal Data with third parties as described below. We do not sell or rent Personal Data to third parties for their own marketing purposes.

Advertising Service Providers

You may be provided with online advertisements of PION products and services on third-party websites and mobile services that are tailored to you, for example, on the basis of information that you provide to PION or a third-party website you are visiting, or of your browsing activity, purchases, or interests. These types of tailored online advertisements may come through several sources, such as the following:

We may disclose with our advertising service providers your non-identifying information that we have obtained from cookies and other tracking technologies on our PION Sites.
Some Web browsers may transmit “do-not-track” signals to Web sites with which the browser communicates. As of the Effective Date of this Privacy Policy, an industry standard has not yet been established on how to respond to these signals. Therefore, PION does not currently respond to these signals.

Affiliates and Third Party Vendors

We have relationships with suppliers and affiliated companies, who help us operate our business and for whom it may be necessary to have access to your Personal Data in the course of providing services to PION. We may combine, disclose and exchange your Personal Data with our related affiliated companies in an effort to assist in managing and providing products and services to you. We will not authorize these parties to use your Personal Data for any purpose that is not related to PION and its related third parties business operations. We may also disclose your Personal Data with third parties to offer and provide information about affiliate products and services. We do not disclose Personal Data from countries that require consent, unless consent has been obtained in advance to sharing with related third parties. We require these third parties to handle your Personal Data collected in accordance with this Privacy Policy, and we will only disclose your Personal Data to the extent reasonably necessary to perform their functions.

Co-Branded Sites

We may partner with other companies to provide you with content or services on a joint or “co-branded” basis. At a co-branded site, you will see both the PION logo and the logo of the co-branding partner displayed on your screen. You should read the individual privacy policies of our co-branding partners, as they may differ in some respects from ours. Reading these policies will help you to make an informed decision about whether to provide your information to a given site.

Product Reports

If you contact PION regarding your experience in using one of our products, we may use the information that you provide in submitting reports to the designated government regulatory authority, as required of us by law.

Legal Rights and Obligations

In certain limited circumstances, PION may need to disclose your Personal Data in order to comply with a legal obligation or demand, such as to comply with reporting obligations to our governing regulatory authorities regarding the safety of our products, including the U.S. Food and Drug Administration. In such instances, we will take measures to protect your Personal Data to the extent possible. We also reserve the right to use Personal Data to investigate and prosecute users who violate our rules or who engage in behavior that is illegal or harmful to others or to others’ property.

Change in Organization

In the event PION decides to reorganize or divest our business through sale, merger, or acquisition, or in connection with the sale or transfer of one of our product lines or divisions, which includes the services provided through one or more of the PION Sites, PION may disclose Personal Data about you with actual or prospective purchasers. We will require any actual or prospective purchasers to treat this Personal Data in a manner consistent with this Privacy Policy.

Children's Privacy

PION does not knowingly collect or use any Personal Data directly from children on PION Sites (PION defines “children” as minors younger than 18). We do not knowingly allow children to order our products, to communicate with us, or to use any of our online services. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below, and we will work with you to address this issue.

For Individuals Located in the EU and European Economic Area - Your Privacy Choices and Rights

Under the (i) General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), (ii) Data Protection Act 2018, (iii) the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland (i.e., “UK GDPR”) as provided in the Data Protection Act 2018, and (iv) any other applicable data protection legislation of any country or other jurisdiction (collectively “International Data Protection Laws”) individuals have specific rights with respect to their Personal Information, or “personal data” as defined under the International Data Protection Laws. For the purposes of this Privacy Policy, the Company operates as a data controller. Any personal data we collect from you is processed in the United States and under the terms of this Privacy Policy.

Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing. You may always withdraw your consent to our use of your personal data as described below. We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.

The data controller is:

PION INC.
Attn: Deren Dohoda
Privacy Office
10 Cook Street
Billerica, MA 01821
USA

You can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:

Access. You may request a copy of the personal data our Website databases currently contain.
Automated Processing and Decision-Making. You may request that we stop using your personal data for automated processing, such as profiling. When contacting Company, please explain how you wish us to restrict automated processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Policy, to include withdrawing your consent to the processing of your personal data.
Correction or Rectification. You can correct what personal data our Website database currently contains by accessing your account directly, or by emailing us (as provided below) to request that we correct or rectify any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.
Restrict Processing. When applicable, you may restrict the processing of your personal data by submitting a request via email (to the email provided below). In your email, please explain how you wish us to restrict processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
Object to Processing. When applicable, you have the right to object to the processing of your personal data by submitting a request via email to (to the email provided below). When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
Portability. Upon request and when possible, we can provide you with copies of your personal data. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Policy, to include withdrawing your consent. Where applicable, we will ensure such changes are shared with any trusted third parties.
Withdraw Consent. At any time, you may withdraw your consent to our processing of your personal data through this Website by notifying us via email (to the email provided below). Using the same email address associated with your Website account, simply type the words “WITHDRAW CONSENT” in the subject line of your email. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
Erasure. If you should wish to cease use of our Website and have your personal data deleted from our Website, then you may submit a request by emailing us at the email provided below. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.

Exercising your rights. If you are a data subject that has rights under the International Data Protection Laws, who chooses to exercise the rights listed above, you can submit a request via email at privacy@pion-inc.com.

Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below. If you reside in a European Union member state or the United Kingdom, you may also lodge a complaint with the supervisory authority in your country.

Data Security

PION maintains reasonable technical, administrative and physical controls to secure any Personal Data collected through the PION Sites. However, there is always some risk that an unauthorized third party could intercept an Internet transmission, or that someone will find a way to thwart our security systems. We urge you to exercise caution when transmitting Personal Data over the Internet, especially your financial-related information. PION cannot guarantee that unauthorized third parties will not gain access to your Personal Data; therefore, when submitting Personal Data to PION Sites, you must weigh both the benefits and the risks.

Third Party Sites and Social Media Plug-Ins

This Privacy Policy does not apply to PION Sites that do not link to this Privacy Policy, or to third-party Web sites to which PION Sites may link. PION Sites may use social media plug-ins (e.g., the Facebook “Like” button, “Share to Twitter” button) to enable you to easily disclose information with others. When you visit PION Sites, the operator of the social plug-in can place a cookie on your computer or other electronic device that enables that operator to recognize individuals who have previously visited our Site. If you are logged into the social media Web site (e.g., Facebook, Twitter) while browsing on our PION Site, the social media plug-in allows that social media Web site to receive information that you have visited our PION Site. The social media plug-in also allows the social media Web site to sharedisclose information about your activities on our PION Site with other users of their social media Web site. These sharing settings are managed by the social media Web site and governed by its privacy policy.

Accessing Our Sites Globally; Transferring Your Information To The US

This site is owned and operated by PION in the United States, but the information you provide will be accessible to our third parties, vendors, and suppliers in other countries in accordance with this Privacy Policy. Furthermore, if you are visiting this site from a country other than the United States, your communication with us will necessarily result in the transfer of information across international borders. We do not warrant or represent that this Privacy Policy or the Website’s use of your personal information complies with the laws of every jurisdiction. Where we transfer information outside the EEA, we will implement appropriate measures to ensure your Personal Data remains protected in accordance with applicable data protection laws. The level of legal protection for Personal Data is not the same in all countries and overseas entities may not be subject to laws that provide the same level of protection as your country; however, we will take the security measures described in this Privacy Policy in an effort to keep your information secure. By using this site, you understand that your Personal Data will be stored and processed in the United States and in any country to which we may transfer your information in the course of our business operations. Please see the Section “Information We Disclose” for more detail on how the information may be shared disclosed with PION related entities and third parties.

Unfortunately, the transmission of information via the internet is not completely secure. Although we use reasonable efforts to protect your Personal Data, we cannot guarantee the security of information transmitted to our Sites and any transmission is at your own risk. Once we have received your Personal Data, we will use reasonable and appropriate security measures to try to protect unauthorized access.

Notice To California Residents

Subject to certain limits under California Civil Code § 1798.83, California residents may ask us to provide them with (i) a list of certain categories of Personal Data that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. To make this request, California residents may contact us at privacy@pion-inc.com.

If you are a California consumer, as defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, you may have additional rights to your personal information. For more information regarding these rights, please review our California Privacy Disclosure.

Changes To Our Privacy Policy

We reserve the right to change the terms of this Privacy Policy at any time. Any changes to this Privacy Policy will be reflected on this page with a new effective date. PION encourages you to review this Privacy Policy regularly for any changes. Your continued use of the PION Sites after we post changes is deemed to be acceptance to those changes.

How To Contact Us With Privacy Concerns

To seek access to Personal Data about you, to file a concern, complaint, or request for correction, or to opt-out of particular programs, please contact our Privacy Office by emailing us at info@pion-inc.com. You may also send a letter to the following address: