Privacy Notice

(Ver la política de privacidad en español)

1. Notice

ICU Medical, Inc. ("ICU Medical") with its corporate headquarters at 951 Calle Amanecer, San Clemente, CA 92673, California, USA (email: ethicsandcompliance@icumed.com) and its affiliates take your right to privacy seriously and are committed to protecting the confidentiality of your personal information. This Website Privacy Notice (the "Notice") provides information as to how we maintain the privacy of personal information submitted on our website (the "Site"), as well as the methods by which we maintain the security of our site. This Notice covers all personal information processed by us, which means information that (either in isolation or in combination with other information) enables you to be identified directly or indirectly. In accordance with the EU General Data Protection Regulation ("GDPR"), ICU Medical is the controller of your personal information.

2. Collection of Information

Visitors to the Site can access the Site's home page, and browse some areas of the Site, without disclosing any personal information. The Site will collect information provided to us by your browser, including the website you came from (known as the referring URL), the type of browser you use, the time and date of access, and other information that does not personally identify you. In addition, the Site may also automatically collect information about you, such as your IP address and domain name. We may also explicitly and with your consent request data from you (e.g. for printing requests).

3. Use of Cookies

The Site uses cookies to identify a user as the user moves through our Site. Cookies are small files which your browser allows to be placed on your computer's hard drive that identifies the computer you are using (session-based IDs and/or persistent cookies). We may use such cookies to personalize our Site and to track your usage. Your browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you. If your browser is set to reject cookies, sites that are cookie-enabled will not recognize you when you return to the site, and some site functionality may be lost. The help section of your browser will tell you how to prevent your browser from accepting cookies.

4. How We Process Information

We may use aggregate data about visitors to our Site for product and service development and improvement and for market analysis. We may provide information from our Site in aggregate form, with identifying information removed, to third parties. For the purposes of the GDPR, processing of personal information is necessary for our legitimate interests to maintain and develop our Site and to market, provide and improve our products and services.

5. Disclosure of Information

Your personal information may be shared with third parties in certain circumstances: ICU Medical's group: We may share your personal information among our group of companies in order to conduct the activities described in this Notice. Our service providers: We use third parties to perform services on our behalf or to assist us the activities described in this Notice such as infrastructure and IT service providers and external auditors and advisers. We will only provide our service providers with personal information, which is necessary for them to perform their services, and we require them not to use your information for any other purpose. Third parties permitted by law: We reserve the right to disclose your personal information as required by law, when disclosure may be necessary to comply with a regulatory requirement, judicial proceeding, court order, or legal process served on us, or to protect the safety, rights or property of our customers, the public or ICU Medical and its affiliates. We may also disclose your personal information to our business partners for printing and shipping documentation manuals. Third parties connected with business transfers: We may transfer your personal information to third parties in connection with a reorganization, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Notice. We will not sell your personal information to third parties.

6. U.S. Transfer

Information collected through this Site will be transferred to the U.S., which may not have an adequate data protection standard compared to the jurisdiction of your residence (e.g. the EU). For the purposes of the GDPR, we either request your consent into the transfer or we have put in place appropriate safeguards for personal information, including, where relevant, by entering into EU standard contractual clauses (or equivalent measures) with the party outside the EU (available here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en).

7. Legal Basis (GDPR)

If provided, we process your personal information on the basis of consent (Article 6 (1) a) GDPR). Otherwise, we base our processing on legitimate interests as defined in Sections 4 and 5 of this Notice (Article 6 (1) f) GDPR).

8. Security of Information

We use current technical security measures to safeguard your personal information from unauthorized access or disclosure and require our business partners to follow the same standards if personal information is disclosed to them.

9. Storage of Information

We will only store your personal information in accordance with storage periods as required or permitted by applicable laws and regulations (e.g. statutory periods of limitation).

10. Children

The Site is not intended for persons under 16 years of age and we do not knowingly solicit or collect personal information from or about children. Our products are intended for use by providers of healthcare, and we do not knowingly market our products or services to children.

11. User Rights

We support your personal information rights. Please contact ethicsandcompliance@icumed.com to request further information and to access, rectify, erase ('right to be forgotten') or restrict processing regarding your personal information. Where we have sought your consent to process your personal information, you may withdraw that consent. However, withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

You may object to the processing of your personal information where based on legitimate interests. Unless your objection is directed solely against direct marketing by us, you have to justify that you are in a special situation, which makes the processing of your personal information based on legitimate interests unacceptable for you.

We may continue processing your personal information even after withdrawal of consent or objection if the processing is lawful according to other applicable laws and regulations as there may be. However, please take into account that without processing your personal information, we may not be able to provide and ship printed documentation manuals. You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. A list of local data protection authorities in European countries is available here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

12. California privacy rights

If you are a California ("CA") resident, please note the following about how we collect, use and disclose your personal information, including additional rights you may have to your personal information:

  • CA Personal Information. Consistent with the "Collection of Information" section above, we may collect certain categories of information about California residents, such as:
    • Identifiers: name, address, phone number, e-mail address, account username, account password, information collected via cookies, and IP address;
    • Internet or Other Electronic Network Activity: browser, time and date of access, operating system, application version, device ID, and pages shown.
  • Sources of CA Personal Information. Consistent with the "Collection of Information" and "Use of Cookies" sections above, personal information is provided directly by you (or by the devices you use) when you visit our Site.
  • Use of CA Personal Information. Consistent with the "Disclosure of Information" section above, we may use your personal information as follows:

Categories of Personal Information

Business or Commercial Purposes

Sources of Personal Information

Categories of Third Parties Personal Information is Shared With

Identifiers

To maintain and develop the Site; to market, provide and improve products and services; marketing activities

Consumers and their devices

ICU Medical's group

Internet or Other Electronic Network Activity

To maintain and develop the Site; to market, provide and improve products and services; marketing activities

Consumers and their devices

ICU Medical's group

  • CA Personal Information Sold or Disclosed For Business Purposes.
    • Sharing Personal Information for Business Purposes: In the preceding twelve months, we may have shared the following categories of personal information for business purposes: Identifiers and Internet or Other Electronic Network Activities.
    • Sale of Personal Information: We do not share your CA Personal Data with the parties listed in this notice in a manner that constitutes a "sale" under California law.
  • California Privacy Rights. As a California resident and subject to certain exceptions, you may have the right to access, correct (rectification), and/or delete your personal information. You also have the right to request information about the personal information we have disclosed for business purposes, by contacting us at ccpa_request@icumed.com.

To protect your privacy and security, we will verify your identity before responding to such request and may request you provide us your name and email address through a Verifiable Consumer Request. You will not be penalized for exercising your rights to your personal information.

Access Notice in Alternative Formats

Consumers who need assistance accessing the notice in an alternative format can do so by contacting Legal at (949) 366-2183.

13. Changes to this Notice

Changes may be made to this Notice from time to time. Any changes will be effective immediately upon the posting of the revised Notice.

Issue date: November 22, 2018

Last updated: December 18, 2019