ICU Medical California Consumer Privacy Act Privacy Policy

Last updated: October 2026

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, as amended by the California Privacy Rights Act ("CPRA") (collectively, "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.

This CCPA Privacy Policy supplements our general Online Privacy Notice, which covers any information not included here.

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 have collected, and may continue to collect, from California residents who are users of ICU Medical's websites, mobile applications and cloud-based services and communication platforms ("Online Users") over the preceding 12 months, their sources, and to whom and for what purpose we may have disclosed the information.

Please also refer to our Online Privacy Notice for more information on how we may disclose your personal information.

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, or other similar identifiers.	Yes	Yes, to our service providers who provide services to us in accordance with service provider contracts, and online advertising partners for our marketing and advertising efforts.
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, address, telephone 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	Same as above.
Characteristics of protected classifications under California or federal law.	No	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	No	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	Yes, to our service providers who provide services to us in accordance with service provider contracts, and online advertising partners for our marketing and advertising efforts.
Audio, electronic, visual, thermal, olfactory, or similar information.	No	N/A
Professional or employment-related information.	No	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).	No	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.	No	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.	No	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.	No	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. How We Process Your Personal Information

We use the personal information that we collect from Online Users for the purposes listed at Section 3 (The Business and Commercial Purposes for Which We Use Your Personal Information) of our Online Privacy Notice.

To the extent we collect any sensitive personal information, we use such sensitive personal information only as necessary in connection with the performance of services and the provision of goods, compliance with federal, state, or local laws, and as otherwise permitted by the CCPA. We do not use sensitive personal information to infer characteristics about you.

3. Categories of Personal Information We Sell or Share

We allow certain online advertising partners to collect information about you through cookies, trackers and other technologies which they use to deliver targeted advertisements and assist us with advertising-related analytics. For more information about our use of cookies and other tracking technologies, please visit Section 5 (Cookies and Other Tracking Technologies) of our Online Privacy Notice.

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 in the traditional sense, our advertising activities may be considered as “selling” or “sharing” as such terms are defined under the CCPA. Therefore, we may sell or share for cross-context behavioral advertising the following categories of Personal Data with third-party advertising networks, analytics providers, and social networks:

Identifiers
Internet or other electronic network activity information

We do not sell or share for cross-context behavioral advertising any of the other categories of personal information we collect, and we do not knowingly sell or share the personal information of California residents under 16 years of age.

4. Retention of Personal Information

We retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) as required by a legal obligation to which we are subject to; or (iii) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).

5. Your Rights under the CCPA

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

The right to know or access what personal information we have collected about you, including the categories of personal information we have collected, sold, shared or disclosed for a business purpose; 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 sold, shared, or disclosed personal information; and the specific pieces of personal information we have collected about you
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. 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 "Your Privacy Choices" link in the footer of our website.
The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA.

6. 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 must 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.

7. Do Not Track

Your browser or extension may allow you to automatically transmit Do Not Track signals. Except as outlined in this CCPA Privacy Policy or as required by law, we do not respond to such signals.

8. California Shine the Light Law

Under California’s Shine the Light law, customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. We do not disclose your personal information to unaffiliated third parties solely for their own direct marketing purposes.

9. 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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