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Privacy

Privacy Statement

Introduction

Medicrea recognizes that the personal information it receives is held in a position of trust. Medicrea seeks to fulfill that trust by adhering to general principles regarding the protection of personal information. This Privacy Statement explains how we collect, use, share and protect information in the course of operating our business.

Scope

This Privacy Statement (“Statement”) applies to the personal information of customers that is collected or used by Medicrea, its affiliates or subsidiaries (collectively, “Medicrea”, “we”, “our”, “us”). This Statement applies to all the personal information that Medicrea collects when customers interact with us, such as when visiting our websites, using or purchasing our products or services, contacting customer service and when interacting with us as a business customer, supplier or business partner (collectively, the “Services”).

This includes, without limitation, all online and offline collections of all types of personal information. However, some Medicrea collections involve types of data with special requirements (for example, health information) which require a different privacy notice. Whenever that is the case, Medicrea will make it clear that the privacy notice concerned is different from this Statement.

For those who reside in California, please see our Privacy Notice for California Residents for additional information regarding our practices.

Information collection

Medicrea may ask you to provide personal information for purposes including, but not limited to, the following:

  • Buying Medicrea products and services;
  • Activating or registering certain products and services or enhancing functionality;
  • Receiving information about Medicrea products and services;
  • Participating in Medicrea online communities, including our social media channels/pages;
  • Storing your preferences for future interactions and communications from Medicrea;
  • Helping us to develop products and services and create campaigns that are designed around you, optimize customer services and continuously improve our websites;
  • Helping us to improve products and services, and allowing Medicrea to keep you informed of, or involve you in the testing of, new products and services;
  • Resolving consumer and/or product and services issues;
  • Registering visitors of Medicrea facilities or Medicrea organized events and conferences;
  • Contract or tender management; and
  • Receiving personalized messages, special offers and advertisements that are relevant to your personal interests, based on the information you have shared with us and on the information we have collected through cookies or similar techniques regarding your use of the Medicrea websites/social media/blogs.

Medicrea maintains physical, technical, and administrative safeguards to protect your personal information and only allows disclosures as permitted by law to assist in providing products or services. We may also collect product and service information and provide these statistics to others in an aggregate form where the information has been de-identified.

Personal information collected may include:

  • Contact information, such as name, address, email, telephone number, fax number, organization name, and/or job title;
  • Unique identifiers and preference information such as username, password, marketing preferences, internet protocol (IP) address, browser type, operating system and computer or mobile devices.
  • Resume or CV, including work history, professional qualifications, publications, awards, references, completed trainings, and signature;
  • Food restrictions, passport info for travel bookings or identification purposes, social security number (where required by law), bank account details, (emergency) contact persons, family information (where applicable and in accordance with local law);
  • Creditworthiness, VAT number, product, purchase information history, request documentation;
  • Pictures, video and audio recordings where you have provided your permission;
  • Sensitive personal information, such as health information or reports of an individual end-customer (e.g. Concerning product claims and investigations, patient pre- and post-operative outcomes for research & statistical purposes, or criminal records for due diligence procedures in accordance with applicable law).

Medicrea will retain and use the personal information collected for above mentioned processes and processing purposes in accordance with legal obligations.

Cookies

We also may collect this information through cookies, pixels, web beacons, and similar technologies (“cookies”), that work through placing a small file (like a text file or graphic) in the browser files of your computer when you visit. The cookie may be stored on your computer’s hard drive. Cookies are used to collect information for business purposes, such as enabling essential website functions and improving the user experience. You are free to decline our cookies if your browser permits, but some parts of our website may not work properly for you if you do so. Medicrea may use third-party tracking and advertising providers to act on our behalf to track and analyze your usage of our sites. These third parties may collect, and share with us, as we may request, website usage information about visits to our sites, measure and research the effectiveness of our advertisements, and track page usage and paths followed during visits through our sites. Also, these third-party providers may place our Internet banner advertisements on other sites that you visit, and track use of our Internet banner advertisements and other links from our marketing partners’ sites to our sites. To the extent the information collected on Medicrea’s behalf by these third parties contains any personally identifiable information, we will protect it in accordance with this privacy statement.

We will not allow third parties other than those companies that we hire to perform services or functions on our behalf to place cookies on our website. Please refer to your browser Help instructions to learn more about managing cookies.

Legal Bases

The legal basis Medicrea uses to process personal information will be dependent on the processing purposes and the jurisdictional legal requirements. Where personal information is collected, in general, we use the following basis:

  • Consent to use the personal information, e.g. where this involves (digital) direct marketing activities and where we would like to use a photo, video or audio recording with identifiable individuals for external publishing;
  • Establishment or performance of a contract, e.g. where we enter into a contract with a party and we collect contact information and signatures, as well as potential bank account details that may be linked to a representative of a company we do business with;
  • Compliance with a legal obligation, e.g. where we need to disclose customer details for compliance with (local or industry) laws such as the Physician Payments Sunshine Act, the Medical Device Regulation and with FDA and other governmental guidance, directions, regulations, and laws, including HIPAA, where applicable;
  • Legitimate interest of Medicrea, e.g. where Medicrea collects contact information and preferences, details for lodging and travel for attendees of Medicrea organized events & trainings or third party hosted events & trainings in collaboration with Medicrea;
  • Public interest or for the exercise of public authority in strictly limited cases, e.g. where we would be required to cooperate with the police or other government bodies in case of illegal conduct;
  • For the establishment, exercise or defense of legal claims, e.g. for court cases;
  • For scientific or research purposes, e.g. for clinical research studies with sufficient safeguards safeguarding confidentiality;
  • For preventative and occupational medicine, medical diagnosis pursuant to contract with healthcare professionals;
  • For public interest in the public health to ensure high standards of quality and safety of healthcare and products; and
  • Where the individual chooses to disclose the personal information publicly by its own initiative.

If you choose not to provide the personal information we reasonably require, it may hinder Medicrea’s ability to provide the information or services you have requested.

Privacy Statement for Children

Medicrea will not collect personal information from anyone we know to be under the age of 16 without the prior, verifiable consent from his or her legal representative. Such legal representative has the right, upon request, to view the information provided by the child and/or to require that it be deleted.

Retention of Information

Medicrea will retain your personal information for as long as reasonably necessary to comply with legal obligations or for no longer as required for legitimate business purposes.

Disclosure of Information

Medicrea may share personal information we have collected with companies or agents doing technological maintenance or working on our behalf to help fulfil business needs, including providing customer services and distributing marketing communications. Medicrea may also share personal information with our subsidiaries and affiliates.

Other service providers that may be used to perform certain functions on our behalf and to whom personal information may be disclosed in order to perform their intended function include call-center support, sending or processing postal or electronic mail or analyzing or hosting information on cloud-based servers.

Medicrea does not share your personal information with unaffiliated third parties for their own direct marketing purposes.

Security

The security and confidentiality of your personal information matters to us. For this reason, Medicrea has physical, technical and administrative controls in place to protect your personal information from unauthorized access, use and disclosure. Medicrea evaluates these safeguards on an ongoing basis to help minimize risks from new security threats as they become known.

Rights

You may request details of personal information which we hold about you. If you believe that any personal information we are holding about you is incorrect or incomplete, please contact us as soon as possible, at the address below. We will promptly correct any personal information found to be incorrect.

You may always choose to object to the collection or use of your personal information or to have your information erased. If you would like a copy of the information held about you for your own use or to transfer to another party, or if you wish to exercise any other right, please contact us at privacy@medicrea.com.

IF YOU ARE A CALIFORNIA RESIDENT, PLEASE SEE OUR PRIVACY NOTICE FOR CALIFORNIA RESIDENTS FOR ADDITIONAL INFORMATION REGARDING YOUR RIGHTS AND CHOICES.

Updates to Privacy Statement

This Statement may be amended at any time. If material changes are made in how personal information is collected, used, disclosed or otherwise processed, this Statement will be updated and notices will be provided when/where appropriate. Any material changes to this Statement will be effective at the time of our posting of the notice of the update. Where required to do so by law, Medicrea may seek your prior consent to any material changes we make to this Privacy Statement.

The Statement was last updated on 9/23/2020

Contact

If you have any questions, concerns or comments about this Statement, please contact us. Medicrea will use reasonable efforts to respond to you as soon as possible.

Send email to:
privacy@medicrea.com

If we fail to respond to you within a reasonable period of receiving it in writing, or if you are dissatisfied with the response that you receive from us, you may lodge a complaint with the data protection authorities in your home country.

California Privacy Policy

Effective Date: January 1, 2020

Introduction

This Privacy Notice for California Residents (“Notice”) describes the privacy practices of Medicrea and its affiliates and subsidiaries (collectively, “Medicrea,” “we,” “our,” or “us”) in connection with the information we collect about California residents and households (“you” or “Consumers”). This Notice applies to all the personal information that Medicrea collects when customers interact with us, such as when visiting our websites, using or purchasing our products or services, contacting customer service and when interacting with us as a business customer, supplier or business partner (collectively, the “Services”). This Notice supplements our general Privacy Statement and further describes our privacy practices as required by the California Consumer Privacy Act of 2018 (“CCPA”). This Notice does not apply to California residents travelling outside of California.

Collection and Use of Information

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with consumers (“personal information”). Specifically, Medicrea may collect the following categories of personal information from you:

  • Identifiers, such as name, address, email, telephone number, fax number, social security number, passport number;
  • Demographics, such gender, income level, or age;
  • Online activity information, such as Internet Protocol (“IP”) address or browsing history;
  • Location information that you provide or that we collect via your device, subject to your settings;
  • Inferences regarding preferences or other characteristics;
  • Transaction information, such as password and purchase histories;
  • Payment information, such as payment card numbers;
  • Audio, electronic, visual, thermal, olfactory, or similar information, such as pictures, video and audio recordings where you have provided your permission;
  • Biometric information;
  • Professional or employment-related information, such as employer, job title, work history, professional qualifications, publications, awards, and references;
  • Education information;
  • Sensitive personal information, such as health information or reports of an individual end-customer (e.g., concerning product claims and investigations, patient pre- and post-operative outcomes for research & statistical purposes, or criminal records for due diligence procedures in accordance with applicable law).

We may collect personal information about you from a variety of sources, including:

  • From You: We collect information that you submit to us. For example, when you use the Services, register to receive information, products or services available through the Services or interact with us in other ways, we will collect any information you voluntarily provide, and we may also request optional information to support your use of the Services. We also collect any information that you voluntarily enter into any postings, comments, or forums within the Services. If you send an e-mail to us, we will collect your e-mail address and the full content of your e-mail, including attached files and other information you choose to provide to us.
  • From Your Devices: When you use our Services, we may collect information about the devices you use to access the Services, including hardware model, operating system and version, IP address and other unique device identifiers, mobile network information, and information about the device’s interaction with our Services. We also collect information about how you use our Services, including your access times, browser types, and language. This type of data enables us to understand how often individuals use parts of the Services so we can analyze and improve them. To collect this information, we use cookies and web beacons, and other similar technologies. To learn more about how we automatically receive and record information when you interact with the Services, please see our COOKIE DISCLOSURE in our general Privacy Statement.
  • Location Information: We may collect different types of information about your location, including general information, such as the city, state, and/or zip code associated with your IP Address, and, if you agree, more specific location information that is provided through the GPS functionality on mobile devices used to access the Services. We may use such location information to customize the Services, including advertising that is presented to you. In order to do this, your location information may be passed along to our affiliates, agents, vendors or advertisers.
  • Social Media Networks and Other Third Parties: We may obtain information about you or your use of the Services from third parties and sources, such as our vendors, like web hosting providers, analytics providers, or advertisers. You may give us permission to access your information from services offered by third parties, including social media networks. The information we obtain from third party services depends on your account/privacy settings with those third parties and the third parties’ privacy policies, so please check those policies and adjust your settings to meet your preferences. When you access the Services through social media networks and other third-party platforms, you are authorizing Medicrea to collect, store and use such information and content in accordance with this Notice. Please keep in mind that any information provided to us by a third party may also be subject to that third party’s privacy policy.

Medicrea may process the personal information we collect for one or more of the following purposes:

  • To deliver products and services;
  • To activate or register certain products and services or enhance functionality;
  • To send information about Medicrea products and services;
  • To allow you to participate in Medicrea online communities, including our social media channels/pages;
  • To store your preferences for future interactions and communications from Medicrea;
  • To help us develop products and services and create campaigns that are designed around you, optimize customer services and continuously improve our websites;
  • To improve our products and services;
  • To resolve consumer and/or product and services issues;
  • To register visitors of Medicrea facilities or Medicrea organized events and conferences;
  • To fulfill the requirements of our contract or agreements;
  • To send you personalized messages, special offers and advertisements that are relevant to your personal interests; and
  • To comply with any applicable law, regulation, legal process, or governmental request.

Disclosure of Information

We may disclose your personal information in the following circumstances:

  • With your consent. We may share or disclose your information if you ask or authorize us to do so.
  • Among group companies. We may share your information with our affiliated and subsidiary companies and other partners or collaborators for the purposes of processing, analyzing, or storing your information or otherwise as needed to provide the Services to you or achieve other purposes for which we collect information, in each case, consistent with the terms of this Notice.
  • With service providers. We engage service providers to perform a variety of services and functions for us, such as data storage, order fulfillment, customer service, call-center support, transmitting emails, and managing digital content. We may share your information with such service providers on the condition that the service providers use your information only on our behalf and pursuant to our instructions.
  • To comply with legal requirements and to protect you, us and others. Notwithstanding anything to the contrary in this Notice, we reserve the right to retain and disclose your information at our discretion if we believe in good faith that such retention and disclosure is necessary to: (i) comply with relevant laws or to respond to subpoenas, warrants, or similar process served on us; (ii) protect and defend our rights or property, you, or third parties; or (iii) ensure the safety and security of our Services, systems and of our customers and third parties.
  • In connection with a business transfer: In the event we go through a business transition such as a merger, acquisition by another company, bankruptcy, reorganization, or sale of all or a portion of our assets, your information may be sold or transferred as part of that transaction. You acknowledge that such transfers may occur and are permitted by this Notice and that the new entity may continue to process your information as set forth in this Notice.
  • If the information has been aggregated, de-identified or otherwise does not identify you personally: We may share or disclose information that has been aggregated, de-identified or otherwise does not identify you or information that you choose to make public. This Notice does not limit our use or disclosure of de-identified information (i.e., information from which your name and any other personally identifying information has been removed) in any way, and we reserve the right to use and disclose such information to our partners, advertisers, and any other third parties at our discretion.

We may disclose the following categories of personal information for our business purposes:

  • Identifiers;
  • Demographics;
  • Online activity information;
  • Location information;
  • Inferences regarding preferences or other characteristics;
  • Transaction information;
  • Payment information;
  • Audio, electronic, visual, thermal, olfactory, or similar information;
  • Biometric information;
  • Professional information;
  • Education information; and
  • Sensitive personal information.

Medicrea does not and will not sell your personal information (including the personal information of minors under the age of 16).

Your Rights and Choices

California law grants its residents certain rights regarding the collection and use of their personal information. Subject to certain limitations, Consumers have the following rights:

  • Right to know. You have the right to know and request information about the categories and specific pieces of personal information we have collected about you within the last 12 months, as well as the categories of sources from which such information is collected, the purpose for collecting such information and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed your personal information.
  • Right to delete. You have the right to request the deletion of your personal information, subject to certain exceptions.
  • Right to non-discrimination. You have the right to not be discriminated against for exercising any of the above-listed rights. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information.

If you are a California resident and would like to exercise your rights, please submit your request at privacy@medicrea.com. Please note that we may require additional information from you in order to honor your request, and there may be circumstances where we will not be able to honor your request. For example, if you request deletion, we may need to retain certain personal information to comply with our legal obligations or other permitted purposes.

California residents may also request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their “personal information” (as defined under the California Online Privacy Protection Act), if any, for their direct marketing purposes in the prior calendar year, as well as the type of “personal information” disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to privacy@medicrea.com.

Updates to this Notice

Medicrea reserves the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on this website and update the Notice’s effective date. Your continued use of the Services following the posting of changes constitutes your acceptance of such changes.

The Statement was last updated on 3/19/2020