Privacy Policy Supplement for California Residents

Last Updated: April 10, 2025
 

I. Introduction; Scope; Definitions

Minitüb GmbH, its subsidiaries, divisions, and brands (collectively, "Minitüb," "we," "us," or "our," as the context may require) is a pioneering reproductive technology company. This Privacy Policy Supplement for California Residents (this "CA Supplement") supplements the information contained in our Data Protection Declaration & Privacy Policy (which is incorporated herein by reference) and applies exclusively to visitors and users of the Services who are residents of the state of California (as defined in Cal. Civ. Code § 1798.140(g)) ("Consumers," "you," or "your" as the context may require). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this CA Supplement. Capitalized terms not otherwise defined herein have the meaning assigned to them under our Data Protection Declaration & Privacy Policy. 

As used in this CA Supplement, "Personal information" means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. "Personal information" does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
  • Aggregated or deidentified data

II. Personal Information We Collect

We may collect, and in the last twelve (12) months have collected, the following categories of personal information from Consumers: 
 

Category	Examples	Collected
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes
C. Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	No
G. Geolocation data	Physical location or movements.	No
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information	Current or past job history or performance evaluations.	No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

III. Sources of Personal Information 

We may collect your personal information from the categories of sources of personal information identified in our Data Protection Declaration & Privacy Policy.

IV. Use of Personal Information

We may use, disclose, or otherwise process your personal information that we collect for the business and/or commercial purposes identified in our Data Protection Declaration & Privacy Policy.

V. Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Minitüb has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information. In the preceding twelve (12) months, Minitüb has not sold the personal information. For more on your personal information sale rights, see Section VI.E.
 

Personal Information Category	Category of Third-Party Recipients
	Business Purpose Disclosures	Sales
A: Identifiers	None	None
B: California Customer Records personal information categories	None	None
C: Protected classification characteristics under California or federal law	None	None
D: Commercial information	None	None
E: Biometric information	None	None
F: Internet or other similar network activity	None	None
G: Geolocation data	None	None
H: Sensory data	None	None
I: Professional or employment-related information	None	None
J: Non-public education information	None	None
K: Inferences drawn from other personal information	None	None

VI. Your Rights and Choices

The CCPA provides Consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

A. Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months (your "Right to Know"). Once we receive your request and confirm your identity (see Section VI.C), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and 
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 
• The specific pieces of personal information we collected about you.

To the extent permitted by the CCPA, we may elect not to provide the foregoing disclosures for B2B Personal Information.

B. Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (your "Right to Delete"). Once we receive your request and confirm your identity (see Section VI.C), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Enable internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
7. Comply with a legal obligation.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

At your request, we will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action. 

C. Exercise Your Rights to Know or Delete
To exercise your Right to Know or your Right to Delete described above, please submit a request by either: 

• Calling us at 1-800-646-4882
• Emailing us at info@minitube.com

You may authorize another person (an "Authorized Agent") to exercise any of your rights under the CCPA and this Section. To designate an Authorized Agent to make a request with us, (i) provide the authorized agent signed permission to submit a request under this Section with us, and (ii) confirm with us that you provided the Authorized Agent permission to submit the request by submitting such signed permission to us by email at info@minitube.com. Please note that you may be required to verify your identity before your confirmation of permission for the Authorized Agent is effective.

Only you or your Authorized Agent may make a verifiable consumer request related to your personal information. You may only make a Request to Know, Data Access Request, or Data Portability Request twice within a twelve (12) month period. Your Request to Know, Data Access Request, or Data Portability Request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such person, which may include:
  • Information which we already maintain; or
  • If we cannot verify your identity based on information already maintained by us, such information that we or our representatives request from you.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

D. Response Timing and Format
We will timely respond to your request. 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. If we cannot verify your request within forty-five (45) days from the date that we receive your request, we may deny your request.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 

We do not charge a fee to process or respond to your verifiable consumer request unless the request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Any disclosures we provide will only cover the twelve (12)-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. 

E. Personal Information Sales Opt-out and Opt-in
As indicated in our Data Protection and Privacy Policy, the Site is not directed at individuals under the age of 16 and we do not knowingly collect personal information of individuals under 16. If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (your "Right to Opt-Out"). We do not collect, and therefore do not sell, the personal information of Consumers we actually know are less than sixteen (16) years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time.

We do not presently sell personal information and therefore do not currently offer a mechanism for exercising your Right to Opt-Out.

F. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

VII. Other California Privacy Rights

California's "Shine the Light" law (Cal. Civ. Code § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not currently disclose personal information to third parties for their direct marketing purposes.

VIII. Changes to this CA Supplement

We reserve the right to amend this CA Supplement at our discretion and at any time. When we make changes to this CA Supplement, we will post the updated notice on the Site and update the notice's effective date. Your continued use of the Services following the posting of changes constitutes your acceptance of such changes.

IX. Contact Information

If you have any questions or comments about this notice, the ways in which Minitüb collects and uses your information described here and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-800-646-4882
Website: https://www.minitube.com/
Email: info@minitube.com
Postal Address:
Minitube USA
Attn: Office Administration
419 Venture Ct
Verona, WI 53593