Privacy Policy

Who is responsible for your data

The controller under the EU General Data Protection Regulation (GDPR) is:

Custom Surgical is a German medical technology company. We built this landing page to present MicroREC to visitors who arrive from our online advertising, and we designed the page to collect as little personal data as possible: there is no account, no checkout and no newsletter signup here.

What this policy covers

This policy covers only this landing page and its subpages (the FAQ, compatibility and legal pages on this domain). If you continue a conversation with us on WhatsApp, that conversation runs on Meta's platform and is also governed by WhatsApp's own terms and privacy policy.

What we collect, and why

a. Advertising and analytics measurement

Because visitors reach this page through paid campaigns, we run three measurement tags. Their shared purpose is to tell us which ads bring genuinely interested clinicians, so we can stop paying for the ones that do not.

• Google Ads conversion tracking (tag AW-10946397643). Records when a visitor who clicked one of our Google ads completes a meaningful action on this page, such as submitting the quote form or clicking a WhatsApp button. Google links this event to the ad click using cookies and click identifiers.
• Google Analytics 4 (property G-7MFLSHXLFZ). Gives us aggregated usage statistics: which sections are viewed, scroll depth, device type, browser and approximate region derived from your IP address. We use it to understand how the page performs, not to identify you.
• Meta Pixel (ID 277187357504671). Reports page views and CTA clicks back to Meta so we can measure Facebook and Instagram campaigns and reach people with similar professional interests. Meta may connect this data to your Meta account if you have one.

b. Ad origin parameters stored in your browser

When you arrive from an ad, the link may carry parameters describing where you came from: the campaign, the ad group, the search keyword and click identifiers such as gclid or fbclid. This page keeps those parameters in your browser's sessionStorage. They stay on your device, are not sent to any server by us, and are deleted automatically when you close the tab. Their only job is context: if you decide to contact us, we can see which topic brought you here and answer with less back and forth.

c. Contact through WhatsApp

Every call-to-action button on this page opens WhatsApp, a service operated by Meta, addressed to our business number +49 152 34689005. Nothing is transmitted to us until you press send inside WhatsApp. Once you do, we process the content of your message, your name as shown in WhatsApp and your phone number for one purpose: answering your inquiry about MicroREC.

d. Hosting and server logs

This page is delivered by Vercel Inc. Like every web host, Vercel keeps short-lived technical logs (IP address, timestamp, requested URL, browser signature) needed to serve the page reliably and to detect abuse.

Legal bases under the GDPR

• Consent, Art. 6(1)(a) GDPR: for the advertising and analytics tags described in section 3a, which rely on cookies and similar identifiers.
• Legitimate interest, Art. 6(1)(f) GDPR: for hosting logs and for the strictly local sessionStorage of ad parameters. Our interest is operating a secure page and understanding, at campaign level, where visitors come from.
• Steps prior to a contract, Art. 6(1)(b) GDPR: when you request a quote or a demo, we process your details because you asked us to prepare an offer.

Who receives your data

Depending on the sections above, the following providers process data on this page: Google Ireland Ltd. and Google LLC (conversion tracking and analytics), Meta Platforms Ireland Ltd. and Meta Platforms Inc. (pixel and WhatsApp) and Vercel Inc. (hosting). Where data is transferred to the United States, the transfer is based on the EU-US Data Privacy Framework or on the EU Standard Contractual Clauses. We do not sell personal data, and we do not share it with anyone beyond these processors.

How long we keep data

• sessionStorage parameters: deleted when you close the browser tab.
• Analytics data (GA4): retained for up to 14 months, then aggregated or deleted.
• Conversion data at Google and Meta: retained according to those platforms' standard advertising retention periods.
• Your inquiries: kept for as long as needed to answer you and to meet German commercial and tax retention duties where they apply, then deleted.

Your rights

Under the GDPR you can, at any time and free of charge:

• request access to the personal data we hold about you,
• have inaccurate data corrected and, under the legal conditions, deleted,
• request restriction of processing or portability of data you provided,
• object to processing based on legitimate interest,
• withdraw consent with effect for the future, for example for advertising measurement,
• lodge a complaint with a supervisory authority. For us, that is the Bavarian State Office for Data Protection Supervision (BayLDA) in Ansbach, Germany, but you may also contact the authority of your own country of residence.

To exercise any of these rights, write to info@customsurgical.de. We answer within the deadlines set by the GDPR.

Questions

If anything in this policy is unclear, ask us directly. A real person at Custom Surgical reads and answers every message sent to info@customsurgical.de or to +49 152 34689005.