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Curadel, LLC FCOI Policy Statement

Additional conflicts of interest policies apply when investigators are responsible for the design, conduct or reporting of PHS funded research. Please refer to the conflicts of interest policy under the Administration of Federal Awards section of this policy manual.

In order to maintain compliance with federal laws and regulations governing financial conflicts of interest for publicly funded research, CURADEL, LLC has established the following policy. Any investigator responsible for the design, conduct or reporting of research on behalf of CURADEL, LLC shall not participate in any PHS-funded research if he or she has a significant financial interest that could influence the design, conduct or reporting of such research activity. CURADEL, LLC will take immediate action under this policy to manage, reduce or eliminate any such FCOI that is brought to its attention.

The Department of Health and Human Services (“HHS”) published new FCOI Regulations that took effect on August 24, 2012. All PHS-funded research undertaken at CURADEL, LLC shall be conducted in full compliance with this policy and under all applicable federal and state laws to promote transparency as to any FCOI in research, including, without limitation, TITLE 42 CODE OF FEDERAL REGULATIONS (CFR) PART 50 SUBPART F pertaining to grants and cooperative agreements and TITLE 45 CFR PART 94 pertaining to research contracts (collectively, “FCOI Regulations”). The required information will be collected pursuant to the FCOI Regulations and recorded on the CURADEL, LLC FCOI Disclosure form. Investigators failing to comply with all FCOI Regulations shall be subject to corrective counseling and possible corrective action.

CURADEL, LLC employees and scientists may collaborate with companies, universities, research groups or government institutions to develop scientific and medical breakthroughs or to provide expertise. To assure professional and commercial integrity in such matters, CURADEL, LLC reviews these collaborations and, when appropriate, puts measures in place to eliminate, minimize, and manage any FCOI that may arise.

Definition of Terms of FCOI Policy:

Designated Official(s): means a person designated by CURADEL, LLC to determine whether an Investigator’s Significant Financial Interest is related to PHS-funded research, and if related, whether the Significant Financial Interest is a Financial Conflict of Interest.

Financial Conflict of Interest (FCOI): means a Significant Financial Interest that could directly and significantly affect the design, conduct, or reporting of PHS-funded research.

Financial Interest: means any interest of economic value in or relationship with an entity, whether private or public, including, but not limited to, ownership of stocks, bonds, stock options, partnership or other equity interests, rights to patent or royalty payments, receipt of consulting fees, speaking fees, salary, loans, gifts, lectureship fees, compensation for serving on boards of directors, scientific and other advisory boards, reimbursed or sponsored travel expenses related to Investigator’s Company Responsibilities, or other remuneration.

Immediate Family or Dependents: means a (i) spouse; (ii) child; or (iii) any other person residing in the same household as the Investigator who is a dependent of the Investigator or of whom the Investigator is a dependent.

Investigator: means the Project Director or Principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research under PHS grants, cooperative agreements, or contracts, including Investigators working for sub-awardees.

Manage: means taking action to address a financial conflict of interest, which can include reducing or eliminating the financial conflict of interest, to ensure, to the extent possible, that the design, conduct, and reporting of research will be free from bias.

Management Plan: means a written plan for the management, reduction or elimination of a FCOI relating to PHS-funded Research.

CURADEL, LLC’s Responsibilities: means an Investigator’s professional responsibilities on behalf of CURADEL, LLC, including, but not limited to, activities such as research, research consultation.

PHS: means the Public Health Service of the U.S. Department of Health and Human Services, and any components of the PHS to which the authority involved may be delegated, including the National Institutes of Health.

PHS Awarding Component: means the organizational unit of the Public Health Service (PHS) that funds the research that is subject to the FCOI Regulations.

Research: means a systematic investigation, study or experiment designed to develop or contribute to generalizable knowledge relating broadly to public health. The term encompasses basic and applied research and product development. This term includes any such activity for which research funding is available from a PHS Awarding Component through a contract, grant, or cooperative agreement.

Senior or Key Personnel: means the Project Director or Principal Investigator and any other person identified as Senior or Key Personnel in a CURADEL, LLC grant application, grant proposal, progress report, contract proposal, contract, or other report submitted to the PHS.

Significant Financial Interest: means an Investigator’s Financial Interest consisting of one or more of the following interests of the Investigator (and those of his or her Immediate Family or Dependents) that reasonably appears to be related to CURADEL, LLC Responsibilities including:

  • Remuneration received from a publicly traded entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of the disclosure that, when aggregated, exceeds $5,000. For the purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of a fair market value.
  • Remuneration received from a non-publicly traded entity in the twelve months preceding the disclosure that, when aggregated, exceeds $5,000 or any equity interest in such entity. Intellectual property rights and interests (e.g., patents, copyrights, trademarks) upon receipt of income related to such rights and interests.
  • Any reimbursed or sponsored travel expenses.

A Significant Financial Interest does not include any of the following:

  • Salary or other remuneration from CURADEL, LLC.
  • Any ownership interests in CURADEL, LLC.
  • Income from investment vehicles, such as mutual funds and retirement accounts, as long as Investigator does not directly control the investment decisions made in such vehicles.
  • Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.
  • Reimbursed or sponsored travel expenses by a federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

Subrecipient: means an individual or entity receiving federal funds that have come from or through CURADEL, LLC to conduct a substantive portion of the PHS-funded research and is accountable to CURADEL, LLC for programmatic outcomes and compliance matters.

Training on CURADEL, LLC’s FCOI Policy

Each Investigator who is a CURADEL, LLC employee, or consultant engaged by CURADEL, LLC who will be responsible for the design, conduct or reporting of PHS funded research will be trained prior to engaging in any PHS-funded Research and then periodically, but no less than once every four years. Each such Investigator is required to provide documentation that they have completed the NIH FCOI tutorial available at http://grants.nih.gov/grants/policy/coi/tutorial2011/fcoi.htm.

  • CURADEL, LLC’s Financial Conflict of Interest policy changes in a manner that affects Investigator requirements.
  • An Investigator is found to be non-compliant with CURADEL, LLC’s FCOI policy or Management Plan.

Disclosure of Investigator’s Financial Interests

It is each Investigator’s responsibility to disclose all of his or her (including Immediate Family and Dependents) Financial Interests as set forth herein. All such Significant Financial Interests can be submitted on Curadel, LLC FCOI Disclosure form.

Reporting Prior to Making a Research Submission

Prior to the submission of an application or proposal for PHS-funded Research, each Investigator must submit any Significant Financial Interest over the previous twelve-month period as well as Immediate Family and Dependents, that reasonably appear to be related to the Investigator’s institutional responsibilities. Such Significant Financial Interest may include remuneration from any publicly traded or non-publicly traded company, and any reimbursed or sponsored travel in the preceding twelve (12) months. CURADEL, LLC will not expend any funds under a PHS-funded research project in the event an Investigator reports a Significant Financial Interest, without first providing a FCOI report to the PHS Awarding Component outlining CURADEL, LLC’s implementation of a Management Plan for the Investigator with a Significant Financial Interest. However, if CURADEL, LLC eliminates the conflict of interest prior to the expenditure of PHS-awarded funds, a FCOI report will not be submitted.

Reporting an After-Acquired Financial Interest

CURADEL, LLC shall submit a CURADEL, LLC Disclosure Form identifying any new or increased Significant Financial Interest within sixty (60) days of acquiring such Financial Interest. These reports shall be submitted to CURADEL, LLC’s Designated Official in accordance with the reporting instructions set forth below.

Reporting Annually on Financial Interests

CURADEL, LLC shall submit annually a CURADEL, LLC Disclosure Form during the period of the applicable PHS-funded Research program. Annual reporting shall include submission of any new significant financial interests. These reports shall be submitted to CURADEL, LLC’s Designated Official via email as instructed on the form.

Designated Official(s) Review of Disclosure Forms

If any Financial Interests are disclosed on the CURADEL, LLC FCOI Disclosure form, CURADEL, LLC’s Designated Official will work with appropriate support to design a COI management plan and make appropriate disclosures to the Federal Government as required by TITLE 42 CODE OF FEDERAL REGULATIONS (CFR) PART 50 SUBPART F pertaining to grants and cooperative agreements and TITLE 45 CFR PART 94.

Standards for Approval for Financial Disclosures

Proposed Research will only be approved if the Designated Official(s) determines that 1) no FCOI exists or that 2) an adequate Management Plan can be implemented to manage or eliminate a Financial Conflict of Interest.

Management Plan for Financial Conflicts of Interest

The Designated Official shall determine the terms, conditions and restrictions, if any, that are required as part of a Management Plan. The Designated Official will convey the Management Plan in writing to the persons deemed appropriate.

The Management Plan will address, at a minimum:

  • The role and principal duties of the conflicted Investigator in the research project
  • Conditions of the Management Plan
  • How the Management Plan is designed to safeguard objectivity in the research project.
  • Confirmation of the Investigator’s agreement to the Management Plan.
  • Monitoring compliance with the Management Plan

The Management Plan may require that one or more of the following actions are taken in order to manage, reduce, or eliminate a potential FCOI that was not managed or prior disclosed by CURADEL, LLC:

  • Disclosure of the Financial Conflict of Interest, in each public presentation of the results of the Research and to request an addendum to previously published presentations;
  • Monitoring of PHS-funded Research by independent researchers and/or reviewers, disinterested individuals or committees;
  • Disqualification from participation in all or a portion of the PHS-funded Research; Requiring that Significant Financial Interests be divested, restructured, or placed in blind trust;
  • Modification or severance of relationships that create a potential FCOI;
  • Changing terms of agreement relating to the PHS-funded Research;
  • Requiring that Investigator participation in the recruitment or consent of subjects in human subjects PHS-funded Research be prohibited or restricted;
  • Requiring additional disclosures or actions; or
  • Requiring non-participation in any business transactions between CURADEL, LLC and parties to agreements involving sponsored PHS-funded Research.

Retrospective Review

When CURADEL, LLC identifies a Significant Financial Interest that was not timely disclosed by an Investigator or otherwise was not previously reviewed during a PHS-funded Research project, the Designated Official will review the Financial Interest and determine whether it is related to the PHS funded Research, and whether it is a Significant Financial Interest within sixty (60) days. The Designated Official will implement a Management Plan specifying actions that have been or will be taken to manage the Significant Financial Interest.

In addition, the Designated Official will conduct and document a retrospective review in the case of noncompliance with this policy. This review will be conducted within one hundred and twenty (120) days of the Designated Official’s determination of such non-compliance. If bias is identified as a result of the retrospective review, CURADEL, LLC will promptly notify the PHS Awarding Component and submit a mitigation report documenting the retrospective review, describing the impact of the bias on the Research project, and CURADEL, LLC’s plan of action to eliminate or mitigate the effect of the bias.

Summary Disposition Procedures

The Designated Official may implement procedures for the disposition of matters involving compliance with this policy that it deems reasonable and appropriate. These procedures may include written approvals for annual reports, renewals, and no-cost extensions where the Designated reasonably determines that the facts and circumstances pertaining to the matter being approved have not materially changed since the date of the original review and approval. All such summary approvals shall be in writing.

Public Disclosure for FCOIs Managed by CURADEL, LLC, related to PHS-Funded Research

Investigator FCOIs managed by CURADEL, LLC will be made available within this section of CURADEL, LLC’s publicly accessible Web site to ensure public accessibility of information concerning any Significant Financial Interest disclosed to CURADEL, LLC that meets the following three criteria: 1) the Significant Financial Interest was disclosed and is still held by the Senior or Key Personnel; 2) CURADEL, LLC determines that the Significant Financial Interest is related to the PHS-funded research; and 3) CURADEL, LLC determines that the Significant Financial Interest is a FCOI. Such Significant Interest will remain disclosed on CURADEL, LLC’s website for the period during which the research is ongoing, in situations where a conflict exists, but not less than three (3) years from the date that the information was most recently updated.

Sanctions and Remedies for Violation of CURADEL, LLC’s FCOI Policy

Whenever an Investigator has violated this policy, including failure to make a required disclosure of Significant Financial Interests or failure to comply with the requirements of any Management Plan, the Designated Official shall be responsible for enforcing this policy, and shall take reasonable steps to respond appropriately to violations, including, but not limited to: 1) suspending expenditures on applicable Research account; 2) administratively suspending approval; and 3) instituting disciplinary measures to include suspension or termination of such Investigator.

Subrecipient Requirements

Each Subrecipient Investigator is subject to conflict of interest rules, and must provide assurances to CURADEL, LLC that Subrecipient has policies and procedures no less stringent than this FCOI policy. CURADEL, LLC takes reasonable steps to confirm that all Investigators who are Sub-awardees participating in PHS-funded Research are in compliance with the FCOI regulation. Such reasonable steps include: 1) incorporating into a written agreement that dictates that Subrecipient will adhere to CURADEL, LLC’s FCOI policy if it is determined that the FCOI policy applies to Subrecipient’s Investigators; 2) if the Subrecipient Investigator is to comply with Subrecipient’s FCOI policy, the Subrecipient shall certify that such policy complies with CURADEL, LLC’s FCOI policy, or if certification cannot be obtained, the written agreement must state the subrecipient Investigators are subject to disclosing significant financial interests that are directly related to the subrecipient’s work for CURADEL, LLC; 3) subrecipient’s Investigators must comply with the subrecipient’s FCOI policy and the agreement shall specify time period(s) for the subrecipient to report all identified financial conflicts of interest to CURADEL, LLC so that CURADEL, LLC can provide timely FCOI reports, as necessary, to the PHS, or alternatively, subrecipient’s Investigators must comply with Curadel’s FCOI policy and the agreement shall specify time period(s) for the subrecipient to submit all Investigator disclosures of significant financial interests to CURADEL, LLC so that CURADEL, LLC can comply timely with its review, management, and reporting obligations; and 4) CURADEL, LLC providing FCOI reports to the PHS Awarding component regarding all financial conflicts of interest of all subrecipient Investigators prior to the expenditure of funds and within sixty (60) days of any subsequently identified FCOI.

Reporting to PHS Awarding Component

CURADEL, LLC shall be responsible for reporting to the applicable PHS Awarding Component all Significant Financial Interests in accordance with federal requirements. CURADEL, LLC will promptly notify the applicable PHS Awarding Component in accordance with federal regulations if bias is found with the design, conduct, or reporting of any Research. This report will address the impact of the bias of the Research and the actions CURADEL, LLC has taken, or will take, to eliminate or mitigate the bias.

Record Retention of Financial Conflict of Interest Disclosure Forms

Records of and related to Significant Financial Interest disclosures shall be retained by CURADEL, LLC for no less than six (6) years after the termination or completion of the PHS-funded Research to which they relate or from the date the final expenditure report is submitted to the PHS Awarding Component, whichever is later.

Acceptance Governing Provisions — These General Terms of Use (“Terms of Use”) shall govern all use of the websites (“Websites”) owned and controlled by Curadel, LLC and its subsidiaries Curadel ResVet Imaging, LLC and Curadel Surgical Innovations, Inc (henceforth “Curadel”). In these Terms of Use, “we,” “us,” and “our” means Curadel, and “you,” “user”, and “your” means the person, company or other legal entity that visits, browses, downloads, or views any services on our Websites.

Ownership
Our Websites are owned exclusively by Curadel. All rights, title, and interest to the content displayed on the Websites (excluding Content, as defined below), including, but not limited to, the Websites’ look and feel, data, information, text, graphics, images, sound or video materials, designs, trademarks, service marks, trade names, and URL, are the property of Curadel.

Copyright
All Content on the Websites is and remains owned by Curadel. Content includes, but is not limited to, all text, images, documents, models, audio, or video published or provided on the Websites. Unless otherwise indicated on specific pages within the Websites, users are authorized to view, play, print, and download Content provided on the Websites for personal, informational, and non-commercial purposes only. Users may not modify the Websites or Content provided on the Websites, and users may not copy, distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, transfer or sell any Content on the Websites. Except as authorized under the law relating to copyright, you may not reuse any Content without first obtaining the written consent of Curadel. Removal of any copyright, trademark or other proprietary notices found on the Websites is prohibited.

Intellectual Property
Unless otherwise indicated, intellectual property rights in the Websites and Content remain the property of Curadel and are protected by global copyright laws and treaties. All such rights are reserved by Curadel and its licensors.

Linking to this Website
You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. The Websites may not be framed on any other site, nor may you create a link to any part of the Websites other than the home page. We reserve the right to withdraw linking permission without notice.

Disclaimer as to ownership of trademarks, images of personalities and third party copyright except where expressly stated to the contrary
All persons (including their names and images), third party trademarks and content, services and/or locations featured on the Websites are in no way associated, linked or affiliated with Curadel and you should not rely on the existence of such a connection or affiliation. Any trademarks or brand names featured on the Websites are owned by the respective trademark owners. Where a trademark or brand name is referred to it is used solely to describe or identify the products and services and is in no way an assertion that such products or services are endorsed by or connected to Curadel.

Trademarks
All trademarks, service marks, and trade names of Curadel used on the Websites (including, without limitation. FLARE®, Seeing is Curing®, Until Cancer is Powerless™, and Powering Innovation and Animal Care™) are unregistered or registered trademarks of Curadel. Users may not use, copy, reproduce, republish, upload, post, transmit, distribute, or modify Curadel trademarks in any way, including in advertising or publicity pertaining to distribution of Materials on the Websites, without Curadel’s prior written consent. The use of Curadel trademarks on any other website or network computer environment, for example the storage or reproduction of (a part of) the Websites in any external internet site or the creation of links, hypertext, links or deep links between the Websites and any other internet site, is prohibited without the express written consent of Curadel.

Website Intended Audience
Our Websites are intended for researchers, veterinarians, clinicians, pet owners, and clinicians. Our Websites are not intended for any individuals under the age of 18.

Compliance with Laws
You agree to comply with all applicable local laws regarding your use of the Websites, including, without limitation, laws regarding import/export of technical data by virtue of your online transmission.

Prohibitions
Users must not misuse the Websites and will not: commit or encourage a criminal offense; transmit or distribute a virus, Trojan, worm, logic bomb or any other material which is malicious, technologically harmful, in breach of confidence or in any way offensive or obscene; hack into any aspect of the Service; corrupt data; cause annoyance to other users; infringe upon the rights of any other person’s proprietary rights; send any unsolicited advertising or promotional material, commonly referred to as “spam”; or attempt to affect the performance or functionality of any computer facilities of or accessed through the Websites. Any breach of this provision constitutes a criminal offense and Curadel will report any such breach to the appropriate law enforcement authorities along with all identifying demographic information available.

Accuracy of Information
Curadel uses judicious efforts to ensure that all information included on the Websites is accurate and current. However, Curadel makes no representation or warranty of any kind, either expressed or implied, regarding the accuracy or completeness of the Content of the Websites. In no event shall Curadel, its affiliates, officers, directors, employees, agents or representatives be liable for any direct, indirect, incidental, consequential, special, exemplary, and punitive or other damages, even if informed of the possibility of such damages. Curadel shall not be liable for any damages or injury resulting from your access to, or inability to access, the Websites or from your reliance on any information at this site. The information contained in the Websites is subject to change without notice.

Limitation of Liability
IN NO EVENT WILL CURADEL BE LIABLE FOR DIRECT, INDIRECT, INCIDENTAL, PUNITIVE OR CONSEQUENTIAL DAMAGES (INCLUDING WITHOUT LIMITATION THOSE RESULTING FROM LOST PROFITS, LOST DATA OR BUSINESS INTERRUPTION) ARISING OUT OF THE USE OF THE WEBSITES, WHETHER BY YOU OR US OR SOME THIRD PARTY, OR INABILITY TO USE THE WEBSITES, WHETHER SUCH DAMAGES ARE BASED ON WARRANTY, CONTRACT, TORT OR ANY OTHER LEGAL THEORY, AND WHETHER OR NOT CURADEL HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. In some locations applicable law may not allow certain of the limitations described above, in which case such limitations will be applied to the fullest extent permitted by applicable law.

If any provision of these Terms of Use or any provision of any document incorporated by reference herein shall be held invalid, such invalidity shall not affect the other provisions of the Terms of Use, which can be given effect without the invalid provision, and to this end the provisions of the Terms of Use are declared to be severable.

Dispute Resolution
It is hereby agreed that any dispute between the user and Curadel arising out of or relating to these Terms of Use (“Disputes”) will be governed by the arbitration procedure outlined below. These procedures DO NOT apply to any products purchased by the user from Curadel and only apply to disputes specific to these TERMS OF USE of the Websites.

Governing Law: The Terms of Use and the resolution of any Disputes shall be governed by and construed in accordance with the laws of the State of Massachusetts, U.S.A. without regard to its conflict of laws principles.

Informal Dispute Resolution: We want to address your concerns without needing a formal legal case. Before filing a claim against Curadel, you agree to attempt to resolve your dispute informally by contacting legal@curadel.com. Curadel will try to resolve your dispute informally by contacting you through email. If your dispute is not resolved within 15 days after submission, you or Curadel may bring a formal proceeding.

Agree to Arbitrate: If Informal Dispute Resolution is unsuccessful, you and Curadel agree to resolve any Disputes through final and binding arbitration, except as set forth under “Exceptions to Agreement to Arbitrate” below.

Opt-out of Agreement to Arbitrate: You can decline this agreement to arbitrate by contacting legal@curadel.com within 30 days of first accepting these Terms of Use and stating that you decline this arbitration agreement.

Arbitration Procedures: The American Arbitration Association (AAA) will administer the arbitration under its Commercial Arbitration Rules and the Supplementary Procedures for Consumer Related Disputes. The arbitration will be held in Boston, Massachusetts, U.S.A, or any other such location as is required by the applicable arbitration rules or as is mutually agreed upon by the Parties.

Arbitration Fees: The AAA rules will govern payment of all arbitration fees.

Exceptions to Agreement to Arbitrate: Either you or Curadel may assert claims, if they qualify, in small claims court in Worcester (MA) or any United States county where you live or work. Either party may bring a lawsuit solely for injunctive relief to stop unauthorized use or abuse of the Curadel Products or Curadel Services, or infringement of intellectual property rights (for example, trademark, trade secret, copyright or patent rights) without first engaging in arbitration or the informal dispute-resolution process described above.

No Class Actions: You may only resolve Disputes with Curadel on an individual basis, and may not bring a claim as a plaintiff or a class member in a class, consolidated, or representative action. Class arbitrations, class actions, private attorney general actions, and consolidation with other arbitrations are not allowed under our agreement.

Judicial Forum for Disputes: In the event that the agreement to arbitrate is found not to apply to you or your claim, you and Curadel agree that any judicial proceeding (other than small claims actions) will be brought in the federal or state courts of Worcester County, Massachusetts. Both you and Curadel consent to venue and personal jurisdiction in Worcester County, Massachusetts. You and Curadel both agree to waive our respective right to a jury trial.

Limitation on Claims: Regardless of any statute or law to the contrary, any claim or cause of action arising out of or related to your use of the Curadel Products or Curadel Services must be filed within one (1) year after such claim or cause of action arose, or else that claim or cause of action will be barred forever.

Privacy
Curadel takes your privacy seriously. All information that Curadel obtains through your use of the Websites (including but not limited to: demographic information entered during the registration process, information obtained through analytics, emails, etc.) is subject to our Privacy Policy. The Curadel Privacy Policy addresses the collection and use of the data provided to us, and details your rights relative to that information. Before using the Websites, we recommend that you review the Privacy Policy. If you are unwilling to accept the terms and conditions of the Privacy Policy, we ask that you not use the Websites or post or submit any materials on them.

Restricted access
Certain areas of the Websites are restricted. Curadel reserves the right to restrict access to any or all areas of the Websites at our discretion. Registering for the Websites will enable you to access some restricted content. Please ensure that your login credentials are kept confidential. The user accepts responsibility for all activities that occur under your user ID or password. Curadel reserves the right to disable any user ID and password at our sole discretion. Engaging in any activity prohibited by the Terms of Use outlined herein will result in immediate termination of your login credentials.

Electronic Communications
All information disseminated on the Websites constitutes an electronic communication. When you utilize the Websites to communicate with us by using any forms provided herein or via email, the communications are considered electronic. You agree that all electronic communications including notices, disclosures, and agreements are equivalent to communications in writing and shall have the same force and effect as if they were in writing and signed by the party sending the communication.

International and Export issues
Curadel administers the Websites from its offices in Worcester, MA. Curadel makes no representation that the Curadel Websites is appropriate or available for use outside the United States and access to the Curadel Websites from territories where its contents are illegal or restricted is prohibited. If you access the Websites from outside the United States you do so on your own initiative and are responsible for compliance with all applicable laws. You agree to comply with all export, deemed export and re-export restrictions and regulations of the Department of Commerce and any other United States or foreign agencies and authorities in connection with your use of the CURADEL Websites and to not, in violation of any Laws, transfer, or authorize the transfer, of any Materials to a prohibited country or otherwise in violation of any Laws. In particular, but without limitation, the Materials may not, in violation of any Laws, be exported or re-exported (a) into any U.S. embargoed countries or (b) to anyone on the U.S. Treasury Department’s list of Specially Designated Nationals or the U.S. Commerce Department’s Table of Deny Orders or U.S. Department of Commerce Entity List of proliferation concern, or the US State Department Debarred Parties List. By using any Materials subject to any such restrictions and regulations, you represent and warrant that you are not located in, under the control of, or a national or resident of any such country or on any such list.

Our Products and Your Feedback
Providing Curadel with feedback by any means, including: phone, e-mail, fax, direct mail, or submitting a form through the Websites regarding any of Curadel’s products does not grant you any rights in any of our manufactured devices, software, or reagents. Though we appreciate your feedback, please be aware that we may use, modify, incorporate into our products and services, license and sublicense, any feedback, comments, or suggestions you send us without any obligation to you.

Sales
Curadel’s subsidiaries, Curadel ResVet Imaging, LLC and Curadel Surgical Innovations, Inc provide manufactured devices and drugs for sale to researchers, veterinarians, and clinicians. All sales are governed by Curadel’s Terms and Conditions of Sales [Link to Policy]

Research Reagent Requests
Only academic investigators appointed at academic institutions may request free samples of research reagents. All reagents are for laboratory research use only. Veterinary and human use is prohibited. Research utilizing reagents received from Curadel must be conducted in accordance with any applicable Federal, State or local laws and regulations. All users are required to accept the Terms of Use of the Websites before a request can be submitted. By accepting the Terms of Use, as stated herein, users agree that there will be no attempt to reverse engineer, disassemble, or attempt to derive the source of, any reagents received. Curadel will consider any attempt to reverse engineer any reagent a breach of this restriction and may result in criminal and/or civil prosecution. NO WARRANTIES whatsoever are applicable to research reagents provided for free.

Publication Reprint Requests
Requesting a reprint of any publication on the Websites permits you to obtain one copy for your sole personal use. All publications contain material protected under International and Federal Copyright Laws and Treaties. Any unauthorized reprint or use of this material is prohibited. No part of any publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopying, recording, or by any information storage and retrieval system without express written permission from the author or publisher.

Indemnification
You agree to indemnify, defend, and hold harmless Curadel from and against any and all claims, liabilities, damages, losses, costs, expenses, or fees (including reasonable attorneys’ fees) that such parties may incur as a result of or arising from your (or anyone using your account’s) violation of these Terms of Use. Curadel reserves the right to assume the exclusive defense and control of any matter otherwise subject to indemnification by you and, in such case, you agree to cooperate with Curadel’s defense of such claim.

Changes
Curadel may at any time revise these Terms and Conditions by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the then current Terms and Conditions to which you are bound.

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Privacy & Cookies Policy

Privacy Overview

This website uses cookies to improve your experience while you navigate through the website. Out of these cookies, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may have an effect on your browsing experience.
Necessary
Always Enabled

Necessary cookies are absolutely essential for the website to function properly. This category only includes cookies that ensures basic functionalities and security features of the website. These cookies do not store any personal information.

Non-necessary

Any cookies that may not be particularly necessary for the website to function and is used specifically to collect user personal data via analytics, ads, other embedded contents are termed as non-necessary cookies. It is mandatory to procure user consent prior to running these cookies on your website.