LAST MODIFIED FEBRUARY 2019
1. THE DATA WE COLLECT ABOUT YOU
Personal Information, means any information about an individual from which that person can be identified. It does not include data where the identity of the individual has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:
- Identity Data includes name or similar identifier.
- Contact Data includes email address and any other information you choose to provide to us in the “Contact Us” form.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Information but is not considered Personal Information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated 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 notice.
If you voluntarily provide us with your personal information for any purpose (such as future employment, potential business relationships, prospective patients or subjects), we will process your information in accordance with your request and may retain that information for future opportunities consistent with your request. Processing of this information is necessary for the purposes of carrying out the obligations and exercising our rights when deciding whether to recruit you.
2. HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Information you provide when you:
- fill out a “Contact Us” form; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies, tracking technologies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third-Party Links. The Site may contain content that is supplied by a third party, and those third parties may collect Usage Information and your device identifier when pages from the Site are served to you. In addition, when you are on the Site you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Site onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies. Third-party applications may also be available via the Site. The owners of these applications may collect Personal Information and other data from you and may have their own policies and practices. We are not responsible for how third-party or their applications collect or use your information and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. These third-party owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us. You may provide updates and changes by contacting us using the Contact us section. European residents should also read our EU Legal Rights section below.
3. HOW WE USE YOUR PERSONAL INFORMATION
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL INFORMATION
We will only use your Personal Information when the law permits such use. Most commonly, we will use your Personal Information in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests include:
- To provide you with information that you requested;
- To improve our services, to customize your experience, or to serve you specific content that is most relevant to you;
- To contact you with regard to your requests or use of any use of our services and, in our discretion, changes to any of our services and/or any of our policies;
- For internal business purposes such as complying with our internal policies;
- To protect our interests, including establishing, exercising and defending legal rights and claims.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your Personal Information other than in certain instances.
We may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your data.
We do not share your Personal Information with third parties for third party marketing purposes. If we do so in the future, we will first give you the choice to consent. If you’re a EU resident, we will get your express opt-in consent before we share your Personal Information with any company outside the Intact Vascular Group of companies for marketing purposes.
CHANGE OF PURPOSE
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
We will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent or explaining our legal basis for doing so.
Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4. DISCLOSURES OF YOUR PERSONAL INFORMATION
We may have to share your Personal Information for the purposes set out below. We require third parties to respect the security of your Personal Information and to treat it in accordance with the law.
- External Third Parties:
- We may use third-party vendors to perform certain services on behalf of us, such as recruitment services, hosting our website, designing and/or operating website features, tracking website activities and analytics, or perform other administrative services. We may provide these vendors with access to user information, including device identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own tracking technologies on your device and they may otherwise collect or have access to information, potentially including Personal Information, about you.
- When we are required to do so by law.
- Internal Third Parties. We may share your information within the Intact Vascular.
- Legal Process. Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.
The above does not affect your legal rights under the relevant data protection legislation of your country.
We do not transfer your Personal Information out of the United States.
5. DATA SECURITY
We put in place reasonable security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that you use our Service and provide us with your information at your own risk.
We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL INFORMATION?
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
7. YOUR LEGAL RIGHTS
YOUR CALIFORNIA PRIVACY RIGHTS
We do not share information about you collected by us on the Service with third parties for those third parties’ direct marketing purposes.
We do not track our users and visitors over time and across third party websites to provide targeted advertising. Consequently, we do not respond to Do Not Track (DNT) signals. Other third-party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.
YOUR EUROPEAN PRIVACY RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your Personal Information. You have the right to:
You have the right to request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
You also have the right to request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing
You may object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing
This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of Personal Information to you or a third party
We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you wish to exercise any of the rights set out above, please Contact us.
No fee usually required
You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
This Site is not directed to children and does not provide services to children, or knowingly collect or solicit personal information from children under 13 years of age.
9. CHANGES TO THE PRIVACY NOTICE
10. CONTACT DETAILS
We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any EEA member requests to exercise your applicable legal rights, please contact us using the details set out below.
Our full details are:
Full name of legal entity: Intact Vascular, Inc.
Email address: firstname.lastname@example.org
Intact Vascular, Inc.
Attention: Data Manager
1285 Drummers Lane, Suite 200
Wayne, PA 19087
If you are based in the EU, you have the right to make a complaint at any time to the relevant supervisory authority for your member state. The supervisory authority in the UK for data protection issues is the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us in the first instance.