Ortho-Clinical Diagnostics, Inc. Global Privacy Notice

Ortho-Clinical Diagnostics, Inc. Global Privacy Notice

This privacy notice provides information about Ortho-Clinical Diagnostics, Inc.’s privacy practices. We are fully committed to collecting, using, disclosing, retaining, and disposing of your personal data in compliance with the EU General Data Protection Regulation and other applicable laws, rules, and regulations.

   1. Full Privacy Notice

   2. Introduction

   3. Who is Ortho?

   4. What are our legal bases for processing your personal data?

   5. What types of personal data so we collect and how do we collect it?

   6. How do we use your personal data?

   7. With whom do we share your personal data?

   8. International transfers of data subject data

   9. Our EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework Commitments

   10. How long do we retain your personal data?

   11. How can you access and correct your personal data?

   12. What are your individual rights and freedoms?

   13. Supplementary country-specific privacy information - Colombia

   14. Children’s online privacy protection

   15. Third-party sites, services, and links to other websites

   16. Privacy notice updates

   17. How to contact us

 

 

 

 

 

 

 

 

1.   Full Privacy Notice

2.   Introduction

Ortho-Clinical Diagnostics, Inc. are committed to protecting data subject rights and freedoms in compliance with the European Union’s General Data Protection Regulation (EU GDPR). This privacy notice provides transparency regarding Ortho-Clinical Diagnostics, Inc.’s (hereafter referred to as “Ortho”) privacy practices. 

3.   Who is Ortho?

The name of our company is Ortho-Clinical Diagnostics, Inc.  Our principal place of business is 1001 US Route 202, Raritan, NJ, USA.  Ortho-Clinical Diagnostics, Inc. has been transforming in vitro diagnostics for more than 75 years. It’s made us a trusted partner of hospitals, hospital networks, blood banks, and labs around the world. Today, it’s empowering us to advise our customers as they prepare for what’s next.

Our purpose is simple: to improve and save lives with diagnostics. We do that by reimagining what’s possible. It’s what defines us.

If you have any questions about this Privacy Policy, please contact us at privacy@orthoclinicaldiagnostics.com or please write to the following address:

Ortho-Clinical Diagnostics, Inc.

Attn:  Privacy Office/Global Compliance
1001 Route 202
Raritan, NJ 08869

4.   What are our legal bases for processing your personal data?

Ortho relies on legitimate interests to send you important information regarding our website, changes to our terms, conditions, and policies and/or other administrative information.  We use the following legal bases for fairly, lawfully, and transparently processing your personal data:

Consent: You have consented to our processing of your personal data for one or more specific purposes as defined in the individual notice.

  • Contractual Obligation: 

 The processing of your personal data is necessary for the performance of a contract (e.g., commercial, procurement, employment); and
 At your request before entering into a contract (e.g., commercial, procurement, employment).

  • Legal Obligation: Ortho processes your personal data to comply with the law (e.g. request for regulatory agency, submission of mandatory spend transparency reporting).
  • Legitimate Interests:

The processing is necessary for the purposes of Ortho, or its business units’ legitimate interests (e.g., fraud prevention, network and information security).

Ortho understands your interests and individual rights and freedoms that require the protection of personal data, particularly when they apply to children that may override its legitimate interests.

5.    What types of personal data do we collect and how do we collect it?

The types of personal data that Ortho collects about you including contact data (e.g., name, email, phone, address) to facilitate business activities (e.g., sales, marketing). The personal data may be collected via various mediums (e.g. paper, email, telephone) depending on the following factors:

  • The products and the services that you use.
  • The products and the services to which you purchase/subscribe.
  • How you have interacted with us, both directly and indirectly.
  • Personal data obtained from third-party contractors and Ortho representatives with permission to share it with us.

Ortho uses the following collection methods to obtain your personal data:

  • Direct Collection: Our website may ask you to submit personal information (e.g., name, email address, phone number, etc.) for you to benefit from the specified features (such as newsletter subscriptions, tips/pointers, or order processing), or to participate in an activity (such as other promotions).  Ortho will provide you with notice of what personal data is required and what information is optional.
  • Indirect Collection and Use: Our website may automatically collect your personal data as you navigate around it. We collect personal data using the following technologies:
  • Cookies: Cookies are pieces of information stored directly on the computer you are using.  Cookies allow us to collect information such as browser type, time spent on the website, pages visited, and language preferences.  We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the website. You can access Ortho’s “Cookies’ Notice & Disclosure” policy at https://www.orthoclinicaldiagnostics.com/en-us/home/cookie-notice-disclosure.
  • We use cookies to recognize your computer or device, which makes your use of the website easier, like caching the content of your shopping cart.  We also use cookies to gather statistical information about website usage to improve continually its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it. 
  • You can refuse to accept these cookies by following your browser’s instructions; however, if you do not accept them, you may experience some inconvenience in your use of the Site.  You may also not receive advertising or other offers from us that are relevant to your interests and needs.  To learn more about cookies, please visit  http://www.allaboutcookies.org.
  • Pixel tags, web beacons, clear GIFs, or other similar technologies: These technologies track the actions of website users and e-mail recipients, measure the success of our marketing campaigns, and compile statistics about website usage and response rates.
  • IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider.  An IP address is identified and logged automatically in our server log files whenever a user visits the website, along with the time of the visit and the page(s) that were visited.  Collecting IP addresses is standard practice on the Internet and is done automatically by many websites.  We use IP addresses for purposes like calculating website usage levels, helping diagnose server problems, and administering the website.
  • Data Analytics: We may use data analytics tools to analyze your behavioral data observed while using the Ortho website. We use these tools to determine how customer and others (i.e., employees) use different device types to interact with the Ortho website. This data analysis will assist us in shaping our information architecture for the next generation of the Ortho website.
  • Device Information:  We may collect information about your mobile device, such as a unique device identifier.

7.   With whom do we share your personal data?

Ortho shares your personal information with our third-party partners as described below.

  • Our third-party partners with whom we offer a co-branded or co-marketed promotion;
  • Our third-party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, e-mail and direct mail delivery services, credit card processing, auditing services, and other services, to enable them to provide services; and
  • In addition, we use and disclose information we believe to be necessary or appropriate: 

To third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

As permitted by applicable law, including laws outside your country of residence;

To comply with legal process;

To respond to requests from public and government authorities, including public and government authorities outside your country of residence; and

To enforce our terms and conditions.

8.   International transfers of personal data

Ortho is a global company with its headquarters in the United States.  As such, we may transfer your personal data to the United States and to our affiliates and subsidiaries in the following regions:

  • North America (e.g., United States, Canada)
  • Latin America (e.g., Brazil, Colombia, Mexico)
  • Europe Middle East and Africa (e.g., United Kingdom, Italy, Germany)
  • Asia-Pacific (e.g., Australia, India, South Korea)   
  • China
  • Japan

We also transfer your personal data to our third-party service providers and our third-party partners located in different countries.  These countries may change from time-to-time and Ortho can provide its customers and others with current list upon request. We transfer information to operate efficiently, to improve performance, and to create redundancies to protect data for business continuity and disaster recovery purposes. We process your personal data to meet this Privacy Notice’s commitments and in compliance with all applicable laws, rules, and regulations.

Whenever Ortho transfers personal data beyond the country-of-origin, we will do so in compliance with all applicable laws, rules and regulations.  We will assess the risk associated with transferring personal data originating within the EU, UK, and the EEA to entities located within those jurisdictions not having the “adequate level of data protection” as determined by the European Commission. In these cases, we will use contracts that include EU Commission approved standard contractual clauses or rely on a recipient’s participation in the US Department of Commerce's EU-US Privacy Shield and Swiss-US Privacy Shield to ensure the safe and secure transfer of personal data outside of the EU, UK, or the EEA.

9.   Our EU-US Privacy Shield Framework and Swiss-US Privacy Shield Commitments

Ortho-Clinical Diagnostics, Inc. (and its affiliates Micro Typing Systems, Inc., Ortho-Clinical Diagnostics Transport LLC, and the Ortho Clinical Diagnostics Limited Liability Company) complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States, respectively.  Ortho-Clinical Diagnostics, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Ortho-Clinical Diagnostics, Inc. is responsible for the processing of personal data it receives, under both Privacy Shield Frameworks, and subsequently transfers to a third party acting as an agent on its behalf. It also complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. We may be liable under the Privacy Shield Principles if any of our third-party service providers process personal data in a way inconsistent with the Privacy Shield Principles, unless we prove it is not responsible for the event giving rise to damage.

We are subject to the investigatory and enforcement powers of the US Federal Trade Commission with respect to personal data received or transferred pursuant to the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework.  You can contact our global third-party dispute resolution provider, JAMS, (free of charge) at https://www.jamsadr.com/eu-us-privacy-shield if you have an unresolved privacy or data use concern that we have not addressed satisfactorily. Under certain conditions, you may invoke binding arbitration once you have exhausted other dispute resolution procedures. 

10.   How long do we retain your personal data?

Ortho retains your personal data for the period necessary for the following reasons:

  • To comply with its legal obligation (e.g., maintaining opt-out lists to fulfill advertising and marketing choices) or to comply with mandatory record retention or legal hold requirements;
  • To comply with individual consent, to resolve disputes, and to fulfill this Privacy Notice’s purposes, rights, and obligations.
  • To achieve Ortho’s genuine business needs and its legitimate interests for collecting the personal data.

Retention periods can vary significantly based on the type of personal data, pending or potential litigation, Ortho’s intellectual property or ownership rights, contract requirements, operational directives and needs, and historical archiving. We will delete using appropriate information security protocols so that it cannot be reconstructed or read when it no longer has a legal or a legitimate basis for retaining personal data. [For more information about our retention policies, please contact us at privacy@orthoclinicaldiagnostics.com.

11.   How can you access and correct your personal data?

You may contact us via email at privacy@orthoclinicaldiagnostics.com should you desire to correct or update your personal data in Ortho’s possession.  You can also submit requests to privacy@orthoclinicaldiagnostics.com if you desire to request access or the deletion of your personal data.

Of note, we may have to retain certain information for record keeping purposes, and/or to complete any transactions that you begin prior to requesting such change or deletion (e.g., when you make a purchase or enter into a promotion, you may not be able to change or delete the personal data provided until after the completion of such purchase or promotion).  We may also have to retain some personal data within our systems and other records where necessary with applicable law.

At your request and where all applicable laws, rules and requirements require us to do so, we will confirm what personal data that we have in our possession.  You may also have a legal right to obtain a copy of your personal data.  You can make such requests by submitting your written request to privacy@orthoclinicaldiagnostics.com. We may charge a processing fee for this service where permitted by law.  We will require evidence of your identity before fulfilling your request. We will respond to your request in compliance with the GDPR or other applicable laws, rules and regulatory stated timelines.

12.   What are your individual rights and freedoms?

The GDPR provides EU data subjects with the following individual rights and freedoms (in certain circumstances):

  • Right of Access: You have the right to obtain confirmation from us whether we are processing your personal data and to request access to it.
  • Right to Rectification:  You have the right to obtain from us the updating or correction of inaccurate personal data concerning you.  Considering the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  • Right to Erasure and to be Forgotten: You have the right to obtain from us the erasure of personal data concerning you without undue delay. We shall have the obligation to erase personal data without undue delay.
  • Right to Restriction of Processing:  You have the right to request from us the restriction of processing of your personal data.
  • Notification Obligation:  We must provide notification of any request for correction or erasure of your personal data or request for restriction of processing of your personal data to each recipient to whom your personal data has been disclosed.
  • Right to Data Portability:  You have the right to receive your personal data that you may have provided to us for a contract or with your consent in a structured, commonly used and machine-readable format and to ask us to share (port) this data to another organization.
  • Complaints:  You have a right to lodge a complaint with a supervisory authority.
  • Consent Withdrawal:  You have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
  • In addition to the above, you can object to the processing of your personal data in some circumstances (in particular, where we are not required to process your data to meet a contractual or other legal requirement).
  • These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to retain or have compelling legitimate interests in retaining.

13.   Supplementary country-specific privacy information - Colombia

Click here to see the Colombian privacy notice

14.   Children’s online privacy protection

Ortho is not engaged in marketing activities targeted directly to children and follows all applicable data protection laws with regards to the collection of personal data from children online. 

15.   Third-party sites, services, and links to other websites

This privacy notice does not address the privacy, information, or other practices of any third parties, including any third pary operating any site or web property (including, without limitation, any application) that is available through this website or to which this website contains a link.  The availability of, or inclusion of a link to, any such site or property on the website does not imply endorsement of it by us or by our business units. We recommend that you review the privacy notice for all third-party websites that you may visit. Our website also contains links to several websites that may offer useful information to our visitors. This privacy notice not apply to those sites, and we recommend that you communicate with them directly for information on their privacy policies.

16.   Privacy notice updates

We may update this privacy notice to reflect changes to our personal data processing activities. We encourage you to periodically review this page for the latest information on our privacy practices. 

17.   How to contact us

If you have any questions about this Privacy Notice, please contact us at privacy@orthoclinicaldiagnostics.com, or please write to the following address:
 
Ortho-Clinical Diagnostics, Inc.

Attn:  Privacy Office/Global Compliance
1001 Route 202
Raritan, NJ 08869
 

Effective Date: March 29, 2019

© Ortho Clinical Diagnostics 2019. Ortho Clinical Diagnostics, publishes this site and is solely responsible for its content. The availability of the products is subject to compliance with the regulatory requirements of each market.
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