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
- Overseas Disclosures
- Website Not Intended for Children
- Third Party or Linked Websites
- Opting Out
- Data Retention, Access and Correction
- Contacting Us
- "Personal Information" means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.
- "Sensitive Information" means any health information or information relating to an individual's racial or ethnic background, sexual orientation or practices, criminal record, biometric information, religious, political or philosophical beliefs and membership of a union or political or professional association.
- "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 and/or Sensitive Information.
Collection and Use of Information
Things You Do and Information You Provide to Us
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; set up an account on either RetinaVue Portal; transmit Sensitive Information through the either RetinaVue Portal; complete surveys or upload pictures and/or messages in connection with Your interaction with the Services; and complete transactions via the Services (e.g., register warranties, request repairs or check repair status). Specifically, for Users of 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 Sensitive 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 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.
Information From Other Sources
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.
Information You Provide About Others
We may collect Personal Information about other individuals that You provide to Us, including on social media.
Information Collected by Automated Means
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, 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. We use this information to administer the 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 are working properly.
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 interfaces 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, 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. If You are logged into a social media website while browsing on the Website, 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.
Do Not Track
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.
Disclosure of Information
- 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 take reasonable steps to ensure that Your Personal Information is protected from misuse and loss and from unauthorised access, modification or disclosure. 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.
We may hold Your Personal Information (including Sensitive Information) in, and disclose Personal Information to, Our related bodies corporate and third party service providers located in countries outside Australia for some of the purposes listed above.
We take reasonable steps to ensure that the overseas recipients of Your Personal Information do not breach applicable privacy obligations relating to Your Personal Information. We may hold or disclose Your Personal Information (including Sensitive Information) outside of Australia as follows:
- As We are located in the United States of America, We may hold Your Personal Information (including Sensitive Information) in the United States of America;
- We may disclose Your Personal Information (including Sensitive Information) to Our related bodies corporate, located in the United States of America; and
- We may disclose Your Personal Information (including Sensitive Information) to Our data hosting and other IT service providers located in located in the United States of America.
Website Not Intended for Children
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.
Third Party or Linked Websites
You have choices about how We use and disclose Your User Information in connection with marketing efforts. For example, We will not use or share Your Sensitive Information for advertisements and direct marketing purposes unless You opt in and consent to Our use of Your Personal Information for direct marketing. 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.
If You have previously opted in to the use and sharing of Sensitive Information 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.
Data Retention, Access and Correction
We retain User Information as long as We consider it potentially useful for business purposes. We also keep information as otherwise required by law. Your Personal Information will be destroyed or de-identified when it is no longer needed for Our business purposes or when We are no longer required by law to retain it (whichever is the later).
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.
Accessing and Correcting Personal Information
You may request access to any Personal Information that We hold about You at any time by contacting Us (using the details in the 'Contacting us' section below). Where We hold information that You are entitled to access, We will try to provide You with suitable means of accessing it (for example, by mailing or emailing it to You). We may charge you a reasonable fee to cover Our administrative and other reasonable costs in providing the information to You. We will not charge for simply making the request and will not charge for making any corrections to Your Personal Information.
There may be instances where We cannot grant You access to the Personal Information that we hold about You. For example, We may need to refuse access to Your Personal Information if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, We will give You written reasons for any refusal.
If You believe that any Personal Information that We hold about You is incorrect, incomplete or inaccurate, then You may request that We correct it. We will consider if the information requires correction. If We do not agree that there are grounds for correcting Your Personal Information, then We will add a note to the Personal Information stating that You disagree with it.
If You believe that Your privacy has been breached, please contact Us using the contact information below and provide details of the incident so that We can investigate it. We will treat Your complaint confidentially, investigate Your complaint and aim to ensure that We contact You and that Your complaint is resolved within a reasonable time (and in any event within the time required by applicable law).
If Our response to Your complaint does not address Your concerns to Your satisfaction, You have the right to make a complaint to the Office of the Australian Information Commissioner.
The contact details for the Office of the Australian Information Commissioner are:
Phone: 1300 363 992 TTY: Call 133 677, then ask for 1300 363 992 Email: [email protected] Fax: +61 2 9284 9666 Post: GPO Box 5218
Sydney NSW 2001
Welch Allyn Australia (Pty) Ltd.
Unit 5, 38-46 South Street
Rydalmere NSW 2116
P.O. Box 381