Effective Date: October 28, 2016
LINKS TO SPECIFIC TOPICS
- Overview and Definitions
- Collection and Use of Information
- Social Media
- Do Not Track
- Disclosure of Information
- Your California Privacy Rights
- Website Not Intended for Children
- Third Party or Linked Websites
- Opting Out
- Data Retention
- Contacting Us
- "Personal Information" means information that identifies an individual (e.g., name, address, telephone number).
- "Protected Health Information" ("PHI") means individually identifiable health information that is created or received by a covered entity (e.g., a hospital or doctor) and relates to the past, present or future physical or mental health or condition of an individual, the provision of health care to an individual, or the past, present or future payment of the provision of health care to an individual (e.g., medical record number, health plan beneficiary number). PHI is further defined by the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") and is subject to the protections of HIPAA.
- "Sensitive Personal Information" means any Personal Information that communicates biometric or health data; government-issued identification number including social security number, driver's license number or state-issued identified number; credit or debit card number (except to the extent used to make a purchase), bank account or other financial information; and other information that is deemed sensitive under applicable law.
- "User," "You," and "Your" means any visitor or user who interacts with Services.
- "User Information" means Your and/or Your patients,' clients,' employees' or other individuals' Personal Information, PHI and/or Sensitive Personal Information.
We may collect and store User Information that is voluntarily provided to Us when You interact with the Services, including, without limitation, when You visit the Website or the Welch Allyn Home Website; set up or update a consumer account on the Welch Allyn Home App or set up or update a clinician account on the Welch Allyn Home Portal; set up an account on either RetinaVue Portal; activate or use Your Welch Allyn Home Device or sync it with the Welch Allyn Home App; transmit PHI through the Welch Allyn Home App or either RetinaVue Portal; complete surveys or upload pictures and/or messages in connection with Your interaction with the Services; and complete purchases and other commercial transactions (e.g., register warranties, request repairs or check repair status) via the Services. Specifically, for Users of the Welch Allyn Home App, the information You provide Us may include, without limitation, Your first name, last name, e-mail address, physical address, telephone number, gender, date of birth, certain health information, social media information, location (GPS) information, transmission data related to syncing a Welch Allyn Home Device to Your account (e.g., mobile device manufacturer, operating system, Welch Allyn Home App version) and information regarding how You use and interact with the Welch Allyn Home App). Specifically, for Users of the Welch Allyn Home Portal or either RetinaVue Portal, the information You provide Us may include, without limitation, Your facility or practice name, primary contact information, national provider identifier, and Your patients' or clients' first name, last name, gender, date of birth, and certain health information.
We also may send You information We think may be of interest to You, such as notices of conferences or trade shows, sweepstakes, incentive programs, and other promotions. Additionally, We may display relevant advertisements or send marketing communications We think may be relevant to You. You may opt out at any time by clicking on the unsubscribe link within any advertisement or marketing material You receive, sending Us an e-mail, or writing to Us at the address listed below, or as We may otherwise advise.
If You transact business with Us by purchasing products on the Website, We collect information about the transactions. This includes Your payment information, such as Your name, telephone number, e-mail address, credit or debit card number, card type, expiration date, discount code, billing information, shipping information, and other related information. We use a third-party payment processor to facilitate any purchase made on the Website and Our vendor may retain limited information in order to respond to fulfillment questions or inquiries, communicate with You about Your account, and for other business purposes.
If You transact business with Us by purchasing Welch Allyn Home Devices on the Welch Allyn Home Website, We collect information about the transactions. This includes Your payment information, such as Your name, telephone number, e-mail address, credit or debit card number, card type, expiration date, discount code, billing information, shipping information, and other related information. For purposes of order fulfillment, We share some of that information with our distributors and they may retain limited information in order to track shipments, process returns, and for other business purposes. We use a third-party payment processor to facilitate any purchases made on the Welch Allyn Home Website and Our vendor may retain limited information in order to respond to fulfillment questions or inquiries, communicate with You about Your account, and for other business purposes.
If You contact Us via telephone, e-mail, fax, postal or courier service, any of the Services, social media, or in any other way, We may retain the correspondence and the information it contains. This information may be used to respond to Your inquiry, notify You of Our offerings, for marketing purposes, or for other business purposes. If You do not wish to receive notifications about Our offerings, or otherwise want to restrict the use of information You provide to Us, You may opt out at any time by clicking on the unsubscribe link within any advertisement or marketing material You receive, sending Us an e-mail, or writing to Us at the address listed below, or as We may otherwise advise.
We may combine information that You give Us with other information about You from other sources, such as vendors, service providers, business partners, affiliates, health care professionals, other third parties, and prior transactions and communications. This may include, but is not limited to, information from co-marketing partners, product referrals, and or other interactions. We also may combine that information with data that is publicly available and data from third parties. This information may be used to provide You with information that may be of interest to You. If You do not wish to receive these notifications, You may opt out at any time by clicking on the unsubscribe link within any advertisement or marketing material You receive, sending Us an e-mail, or writing to Us at the address listed below, or as We may otherwise advise.
We may collect Personal Information about other individuals that You provide to Us, including on social media.
We may collect information related to the physical location of Your Welch Allyn Home Device and/or the mobile device on which the Welch Allyn Home App is installed, including, without limitation, GPS signals, device sensors, Wi-Fi access points, satellite, and cell tower IDs. We may collect this type of data to provide personalized location-based services, such as identifying a doctor with an office in Your Welch Allyn Home Device's location when the Welch Allyn Home App is accessed. We may aggregate this information to display usage trends. For example, We may aggregate search results and trends in a particular geographic area and display those aggregate results.
We also may share the physical location of Your Welch Allyn Home Device and/or mobile device on which the Welch Allyn Home App is installed, combined with information about what advertisements You viewed and other information We collect, with Our marketing partners to enable them to provide You with more personalized content and to evaluate the effectiveness of advertising campaigns. Additionally, We may share de-identified location-based information for any purpose not prohibited by applicable law. In some instances, You may be permitted to allow or deny such uses and/or sharing of such information, but if You choose to deny permission for such uses and/or sharing, We and/or Our marketing partners may not be able to provide You with the applicable personalized services and content.
We and Our third-party service providers may use a variety of technologies, such as cookies, web beacons, and other tracking technologies that automatically collect and store certain information whenever You interact with the Website or the Welch Allyn Home Website, view or click on advertisements, or visit Our social media pages. This includes log data that automatically records information about Your visit, such as Your browser type, operating system, the URL of the page that referred You, the different actions You performed, and the IP address You used to access pages on the Website or the Welch Allyn Home Website. We use this information to administer the Website and the Welch Allyn Home Website, analyze trends, provide You with an experience that is relevant to Your location based on the IP address, gather information about visitor movements, help diagnose potential problems with Our server, investigate actual or potential security incidents, and ensure the Website and the Welch Allyn Home Website are working properly. If You use the Welch Allyn Home App, We also automatically collect information related to Your mobile device operating system name and version, device manufacturer and model, mobile device identifier, browser language, and the version of the Welch Allyn Home App You are using. We use this information for purposes such as ensuring that the Welch Allyn Home App functions properly and to understand usage of the Welch Allyn Home App.
We may assign Your computer or mobile device one or more cookies to facilitate access to the Services, and to personalize Your online experience. A cookie is a small text file that is stored on a user's computer or mobile device for record keeping purposes. Cookies can be either session cookies or persistent cookies. A flash cookie is similar to a cookie, but it can store more complex data in order to remember settings, preferences, and usage. Cookies can be either session cookies or persistent cookies. We may use both session cookies (which expire once You close Your browser) and persistent cookies (which stay on Your devices until You delete them) to: (1) allow You to use the Services without having to re-enter Your user name and password; (2) provide You with a more personal and interactive experience; (3) monitor usage of the Services; (4) manage the Services; and (5) improve the Services. These cookies may be delivered by Us or by third parties.
We also work with other companies who use tracking technologies to serve ads on Our behalf across the Internet. These companies may collect information about Your interaction with Us to present You with opportunities to purchase Our products and services. Retargeting cookies also are used to present You with Welch Allyn advertising on other websites based on Your interaction with the Services.
The Website, the Welch Allyn Home Website, and the Welch Allyn Home App interface with social media websites such as Facebook, Twitter, LinkedIn, and YouTube, and may use social media plugins (such as the Facebook "Like" button) to facilitate social media functions. When You visit the Website or the Welch Allyn Home Website, or use the Welch Allyn Home App, the operator of a social media plugin may set cookies or other tracking technology on Your browser, enabling that social media operator to recognize individuals who visit the Website, the Welch Allyn Home Website, or use the Welch Allyn Home App. If You are logged into a social media website while browsing on the Website or the Welch Allyn Home Website, or using the Welch Allyn Home App, the social media plugins may allow the social media website to receive information about Your visit, including the pages that You viewed, and connect the visit to Your User Information.
Some browsers have a "Do Not Track" feature that lets You tell websites that You do not want to have Your online activities tracked. These features are not yet uniform, and We currently are not able to respond to those signals.
- We may transfer Your information to Our distributors, agents, third parties, or service providers to conduct Our business. For example, third parties and service providers working with Us may handle the processing of credit card payments, shipping, customer service, data management, e-mail distribution, market research, information analysis, promotions management, social media marketing, and similar services. We also may use cloud service providers to host the Services and store data, and these service providers inform Us that they apply security measures they consider adequate for the protection of the information within their system. They have access to User Information needed to perform their functions.
- We may disclose Your information if We believe it is needed to comply with the law (e.g., search warrant, subpoena or court order), respond to a governmental or regulatory request; to address disputes or claims; to protect the security or integrity of the Services; to enforce an agreement We have with You; or to protect Our rights, property or safety, or the rights, property or safety of Our employees or others;
- We may transfer information to address emergencies or acts of God;
- We may transfer Your information in anticipation of and in the course of an actual or potential sale, reorganization, consolidation, merger, or amalgamation of all or part of Our business or operations in which case Your information may be provided to the purchaser or resulting entity;
We also may share or sell aggregated, de-identified data with partners and the public in a variety of ways, such as by providing research or reports about medical health. When We provide this information, We perform appropriate procedures so that the data does not identify You or Your patients or clients and We contractually prohibit recipient of the data from re-identifying it back to You or Your patients or clients.
We are committed to taking reasonable efforts to secure the information that We collect, and We use a variety of security technologies and procedures to help protect against unauthorized access to or alteration, disclosure, or destruction of data. We restrict access to User Information to certain individuals and organizations that need to know the information in order to operate, develop, or improve Our services. We are committed to taking appropriate disciplinary measures to enforce Our employees' privacy responsibilities.
California law permits Our customers who are California residents to request certain information about Our disclosure of Personal Information to third parties for their direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. To make such a request, please email Us or write to Us at the address listed below, and indicate in the subject line that You are a California resident making a "California Shine the Light" inquiry.
The Services are not intended for use by or targeted at children under 13, and We do not knowingly or intentionally collect information about children under 13. We may provide links to third-party websites that allow children under the age of 13 to register for use of the website, or are targeted at children under 13. In such instances, the third-parties are responsible for ensuring that their websites comply with applicable laws, regulations, and rules.
You have choices about how We use and disclose Your User Information in connection with marketing efforts. You may unsubscribe from Our other marketing communications by clicking on the unsubscribe link located on Our e-mails, by sending Us an e-mail, or writing to Us at the address listed below. For California residents, please consult the "Your Privacy Rights" section above for additional considerations.
If You have previously opted in to the use and sharing of PHI for marketing purposes, and wish to change Your preferences, You may do so by sending an e-mail at the address listed below. Please note that if We receive Your opt-out request after having shared Your information with a third party for direct marketing purposes or having otherwise transferred or disposed of Your information, We may not have the ability to control the use of such information by any third party. If You opt out of receiving marketing-related messages from Us, We still may send You service-related communications.
We retain User Information as long as We consider it potentially useful for business purposes. We also keep information as otherwise required by law.
Updating or Deleting User Information
You may update Your account or profile at any time through the applicable Service. You also may delete Your account or profile from the applicable Service. Please note that deleting Your account or profile does not delete User Information previously submitted through the applicable Service. If Users of the Welch Allyn Home App delete the Welch Allyn Home App altogether, their User Information will be deleted from the Welch Allyn Home Portal in ninety (90) days; any such User Information already transferred from the Welch Allyn Home Portal into your electronic medical record by Your doctor, however, will not be affected by such deletion.
Welch Allyn, Inc.
4341 State Street Road
Skaneateles Falls, New York 13153
Attn: Marketing Communications/Privacy