ICU Medical

ICU Medical California Consumer Privacy Act Privacy Policy

Last updated: April 25, 2024

We, ICU Medical, Inc. (“ICU Medical”) issue this California Consumer Privacy Act Privacy Policy ("CCPA Privacy Policy") to provide information about how we collect, use, disclose and otherwise process California residents' personal information and rights that California residents may have under the California Consumer Privacy Act of 2018 ("CCPA"). This CCPA Privacy Policy only applies to you if you reside in California. This CCPA Privacy Policy does not reflect our processing of California residents' personal information where an exception under the CCPA applies.

1. Our Personal Information Practices over the Preceding 12 Months

The table below sets out the categories of "personal information" and "sensitive personal information" (as defined by the CCPA) that we collected from California residents over the preceding 12 months, their source, and to whom and for what purpose we may have disclosed the information. The table is followed by a description of the purposes for which we collected personal information from: (1) users of ICU Medical's websites, mobile applications and cloud-based services and communication platforms ("Online Users"); (2) our prospective, current and past employees and other personnel (collectively, "Employees").

Category of personal information Did we collect? If so, from what source? Did we disclose? If so, to whom and for what purpose?
General categories of "personal information" as defined under the CCPA
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers. Yes, from Online Users and Employees. Yes, to our service providers who provide services to us in accordance with service provider contracts. We also sold and shared IP addresses and cookie identifiers to our online advertising partners with Online Users' consent.
Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information, but excluding publicly available information that is lawfully made available to the general public from federal, state, or local government records. Yes, from Online Users and Employees. Same as above.
Characteristics of protected classifications under California or federal law. Yes, from Employees. N/A
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No N/A
Biometric information Yes, from Employees. N/A
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website application, or advertisement. Yes, from Online Users and Employees. Yes, to our service providers who provide services to us in accordance with service provider contracts. We also sold and shared this information to our online advertising partners with Online Users' consent.
Audio, electronic, visual, thermal, olfactory, or similar information. No N/A
Professional or employment-related information. Yes, from Employees. N/A
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99). Yes, from and Employees. N/A
Inferences drawn from any personal information to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. No N/A
Categories of "sensitive personal information" as defined by the CCPA
A consumer's social security, driver's license, state identification card, or passport number. Yes, from Employees N/A
A consumer's account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. No N/A
A consumer's precise geolocation. No N/A
A consumer's racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership. Yes, from Employees N/A
The contents of a consumer's mail, email, and text messages unless the business is the intended recipient of the communication. No N/A
A consumer's genetic data. No N/A
The processing of biometric information for the purpose of uniquely identifying a consumer. Yes, from Employees N/A
Personal information collected and analyzed concerning a consumer's health. No N/A
Personal information collected and analyzed concerning a consumer's sex life or sexual orientation. No N/A

We use the personal information that we collect from Online Users for the purposes listed at Section 3 (Processing Your Information) of our online Privacy Notice which includes our Notice at Collection to Online Users. We use the personal information that we collect from Employees for the purposes listed here in our Job Applicant Privacy Notice and California Employee Privacy Notice at Collection, which we issue to Employees on onboarding.

We do not have actual knowledge that we sell or share the personal information of California residents under 16 years of age. We do not use sensitive personal information for purposes other than those referred to in Subsection 1798.121(a) of the CCPA.

2. Your Rights under the CCPA

As a California resident, you have the following rights under the CCPA:

  • The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you. You may only exercise your right to know twice within a 12-month period.
  • The right to delete personal information that we have collected from you, subject to certain exceptions.
  • The right to correct inaccurate personal information that we maintain about you.
  • The right to opt-out of the sale or sharing of your personal information by us. The CCPA defines “sale” as disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third-party for purposes of cross-contextual behavioral advertising. While we do not “sell” Personal Information for monetary consideration, we may "sell" and "share" online identifiers and usage data with third-party advertising networks, analytics providers, and social networks. We do not disclose this information unless you consent to our use of marketing cookies. If you would like to change your cookie preferences, use the "Do Not Sell or Share My Personal Information" link in the footer of our website homepage.
  • The right to limit our use or disclosure of sensitive personal information to purposes specified in Subsection 1798.121(a) of the CCPA. We do not use sensitive personal information for purposes other than those specified in Subsection 1798.121(a) of the CCPA.
  • The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee's, applicant's, or independent contractor's right not to be retaliated against for the exercise of their CCPA rights.

3. How to Exercise Your CCPA Rights

  • Methods of Submission and Instructions: To submit a request to exercise your rights to know, delete or correct, please use this form. Alternatively, you can send an email to ccpa_request@icumed.com or call 1-800-824-7890 (toll free). We will respond to your request as required by the CCPA. If we deny your request, we will explain why.
  • Verification: Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may designate an authorized agent by taking the steps outlined under "Authorized Agent" further below. In your request or in response to us seeking additional information, you, or your authorized agent, must provide sufficient information to allow us to reasonably verify that you are, in fact, the person whose personal information was collected which will depend on your prior interactions with us and the sensitivity of the personal information being requested. We may ask you for information to verify your identity and, if you do not provide enough information for us to reasonably verify your identity, we will not be able to fulfil your request. We will only use the personal information you provide to us in a request for the purpose of verifying your identity and to fulfill your request.
  • Authorized Agents: You can designate an authorized agent to make a request under the CCPA on your behalf if the authorized agent is a natural person or a business entity registered with the Secretary of State of California, we receive a written authorization stating that you have authorized the authorized agent to submit a request on your behalf which has been signed by you and the authorized agent, and we have verified the identity of you and the authorized agent. If you provide an authorized agent with power of attorney pursuant to California Probate Code sections 4121 to 4130, it may not be necessary to perform the above steps, and we will respond to any request from the authorized agent in accordance with the CCPA.

4. Contact Us

If you have questions or concerns about our privacy policies or practices, please contact us:

ICU Medical, Inc.
951 Calle Amanecer
San Clemente, CA 92673
Toll Free: (800) 824-7890
EthicsandCompliance@icumed.com

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