Privacy Policy - NGC Medical

Introduction

Please read this information carefully

This Privacy Policy sets forth how N.G.C. Medical S.r.l., located at Via Salvo d’Acquisto 8/14, Turate (CO) (“NGC”), uses information that it collects about users through this website, as well as any mobile websites, applications (“apps”), widgets, conferences, events, electronic newsletters, communications, or other services (hereinafter “Services”) linked to this Privacy Policy. This Privacy Policy does not apply to situations where you have been notified that an alternative privacy statement applies, nor does it apply to other NGC or Medtronic Group websites to which NGC belongs.

This Privacy Statement does not apply to data processing activities related to current or prospective NGC employees or applicants. The Employee Privacy Policy or Applicant Privacy Policy can be obtained by writing to ngc[at]ngcmedical.com.

You should read the Privacy Policy posted on other Medtronic Group websites at the time of your visit. This website and this Privacy Policy are intended for a specific audience located in Italy.

We intend to deal with information fairly and in line with expectations and encourage you to read and consider the information provided in this Privacy Policy.

What information is collected about you

The information that is received and how it is used depends on what you do when you visit our website or using our Services. We collect and use non-personal information (information that does not identify you personally) differently than personal information.

Personal Information

Personal information is information that can specifically identify you, such as:

first and last name
address, telephone number, email address or other contact information
medical device serial number
personal health information
date of birth or age
username or social media profile
interests and qualifications
internet Protocol (IP) address when such address is associated with a specific user

We collect personal information about our users in two ways:

1) when you provide information to us directly, e.g. by entering personal information on certain pages of the website, filling out a registration form for a particular service, participating in a survey, or completing a contact form.

2) using automated means, specifically through cookies. Cookies are small text files that are placed on each user’s computer by websites that are visited. They are widely used to make websites work or work more efficiently, as well as to provide information to the owners of each website. For more information about cookies, click here.

How does NGC use personal information?

NGC may use the information you share with it through this website relevant Services (other than sensitive information, which is discussed separately below) for the following purposes:

to respond to your requests
to provide you the services or information you request
to allow you to register certain products or services or improve their functionality
to resolve and track the status of any issues related to consumers and/or products or services
to manage relationship with patients and facilitate any necessary follow-up (e.g., by storing relevant information and preferences for a reasonable amount of time)
to enter into or perform a contract with you (e.g. if you wish to order products or services from NGC)
to enable you to participate in NGC’s online communities, including social media and blogs
to contact and provide you information that may be of interest to you (see further the Marketing and Training section below)
to publish nominative value transfer data in accordance with industry ethics regulations based on explicit consent
in other ways to which you consent

NGC may also use your personal information to the extent necessary to achieve the following interests, as long as they are compatible with privacy rights and expectations:

for analytical purposes in order to research, develop and improve programs, products, services and content
to anonymize information by removing any personal identifiers (name, e-mail address, social security number, etc.) so it may be used for other purposes. In this case, the anonymized information will no longer identify you and may be treated like other non-personal information. For more details please see the relevant section below.
to enforce this Privacy Policy and other policies relating to the use of this website
to protect your rights or property

NGC also has legal grounds to use your personal information:

if necessary to protect someone’s health, safety, or welfare
in order to comply with a law or regulation, court order, or other legal process.

Where required by law, we will ask for your express consent to process your personal data for a specific purpose. For example, if required by law, we will only send newsletters if you have subscribed to them.

What is sensitive information

Some types of personal information are sensitive information. Sensitive information is personal information that reveals or relates to health (such as device serial number or date of an implant), genetic or biometric data, racial or ethnic origin, religious or philosophical beliefs, sex life or sexual orientation, political opinions or trade union membership.

Does NGC treat sensitive information differently from other personal information?

NGC will only collect and process sensitive information:

• in ways for which you have given explicit consent

• to protect the vital interests of you or another person, in cases where explicit consent cannot be given or reasonably required

• in accordance with applicable laws that include suitable and specific measures to safeguard your fundamental rights and interests

• when the processing is necessary for medical purposes and NGC are under a duty of confidentiality equivalent to that of a healthcare professional

• to pursue a legal claim

Some examples:

• It is possible to collect sensitive information directly from you when you voluntarily provide it for a particular purpose (e.g., in the case of a question or suggestion about products and services;

• It is also possible to collect sensitive patient information through healthcare professionals who partner with NGC to provide therapy or technical support for our products or services;

• It is possible to collect sensitive information as required by the U.S. Food and Drug Administration, European and other governmental authorities in order to ensure the safe and effective use of our products and services;

• It is possible to collect sensitive information about individuals who have explicitly consented to participate in clinical trials, studies and other research initiatives.

Non-personal information

Non-personal information is information that cannot identify you or be linked to you in any way. Therefore, the non-personal information that is collected through this website does not identify an individual person and will not be linked to you.

It may include information such as the following:

• the type of web browser software you use (for example, Internet Explorer)

• the name of the domain from which you access the Internet

• the Internet address of the website from which you link directly to the NGC website

• the date and time you access to the website

• which pages you visited on the website

• the search keys you use

• the links that you click

If you visit this website to read or download information, such as information about a health condition or a product, certain non-personal information may be collected. This information is collected by each user’s web browser. If you read or simply click to download information, we do not collect information about your name, e-mail address, home address or any other personal information. For more information on how cookies are used to collect information.

What does NGC do with non-personal information?

NGC is always looking for ways to provide better service and improve its products, services and website experience. Non-personal information will be used to make this site more useful to visitors. Non-personal information may also be used for other business purposes. For example, NGC may use non-personal information or aggregate non-personal information to:

• create reports for internal use to develop programs, products, services or content

• adapt or improve the information or services provided

• share or sell information with third parties

• provide information about how the site is used, such as “traffic statistics” and “response rates” to third parties

Direct Marketing and Educational Materials

NGC may wish to provide educational materials or other information about its products and services, as well as information about clinical trials or third-party products and services that may be of interest to you, based on information you have shared with NGC that has been collected through cookies or similar techniques regarding your use of NGC’s websites, social media and blogs. For more information on how cookies are used and your choices in that regard.

Consent to the use of personal information for the purposes of such communications is required in accordance with applicable law.

If at any time you decide to not receive any educational, marketing, or promotional information related to NGC’s products and services or the products or services of its affiliates or service providers, please email us at the contact detail listed below and mention “OPT-OUT “in the subject line of the email. Alternatively, you may use the opt-out procedure provided in each relevant message that is sent by NGC.

Please note that if you choose not to receive promotional messages from NGC, NGC will still be able to continue to send relevant information for other lawful purposes, such as managing any of your accounts, responding to your requests, executing agreements with you, or providing you with information that NGC is required by law to provide, e.g., regarding product recalls.

Surveys

From time to time, NGC may invite users to participate in a survey to determine customer satisfaction levels, identify areas of potential improvement, or carry out market research. In such cases, NGC will send users a specific invitation to participate in such a survey based on NGC’s legitimate interests in conducting the survey or based on their prior “opt-in” consent to receive such communications in accordance with applicable law. Users may opt out of receiving any such future communications in the manner described in detail in the section above.

Personal information that is collected for the purpose of the survey may include email address, phone number, survey results, and any free text messages that users may have written in the survey.

NGC processes users’ personal information as part of the survey for carefully considered and specific business purposes that are in its legitimate interests and which, in NGC’s view, are also often benefit the users, based on the assessment that NGC’s legitimate interests do not override the freedom and data protection rights of users.

The business purpose for collecting user data is to reply to survey feedback that users may have provided, specifically:

• if users have indicated an issue that NGC needs to take action to address;

• to receive further information about the experience described by users;

• to inform users of any actions NGC may take internally to resolve the issue or improve the experience.

Does NGC share personal information with third parties?

NGC will not share personal information with third parties, except as described in this Privacy Policy.

We may share some personal information with NGC affiliates or third party companies hired to perform services or functions on our behalf.

Some examples:

– the use of third-party vendors to ship products ordered on our website. In these cases, NGC will provide the vendor with information to process your order such as your name and address;

– the use of a service provider to manage newsletters or informational mailings that you have subscribed and provide your email address for this purpose;

– the use of affiliated companies to provide services related to your personal information;

For example, we may store information on a secure server based on an affiliate’s site in Europe or the United States. For more information on the circumstances in which information may be transferred to other countries, please see the relevant section below.

However, no more information will be shared than is necessary and no third parties will be permitted to retain, disclose, or use any information except to provide the requested services consistent with the purposes set forth above.

Please note that under applicable laws, we may disclose personal information if we believe we are required to do so to comply with any law, regulation, court order, legal or governmental request. In the unlikely event that all or part of NGC’s business is acquired by a third party, information may be transferred to the new corporate owner insofar as relevant to that business and subject to appropriate safeguards.

In addition, you may use and disclose personal information to third parties as necessary to:

• enforce this Privacy Policy and other rules about the use of this website

• protect the company’s property rights

• protect someone’s health, safety or welfare

• comply with a law or regulation, court order or other legal process

• investigate or take action regarding suspected fraud or illegal activities

Also, please keep in mind that certain areas of the website may be interactive and allow you to post information that other users can see. If you do not wish the information to be publicly displayed, please do not use those sections of the website.

Transfer of personal information to other countries

In certain cases, NGC may transmit personal information collected on this website to affiliates or third party service providers in other countries, but only to fulfill the purposes set forth in this Privacy Policy. In cases where personal information is transmitted from Europe to other countries, guarantees equivalent to those provided by European data protection laws will be in place. For more information on the security measures implemented contact ngc[at]ngcmedical.com.

Personal data retention times

Personal information is retained only for as long as necessary to fulfill the purposes for which there is an authorization to use it, as set forth in this Privacy Policy. For example, if you indicate that you no longer wish to receive the newsletter, we will immediately remove your email address from our mailing list. If you participate in a program through this website, we will delete the personal information you have provided as part of that program within a reasonable period of time after its completion (e.g., six months after completion would be considered reasonable unless there are legitimate reasons to retain some of the information for a longer term (e.g., if necessary for validation or to meet recordkeeping obligations).

Future Changes to the Privacy Statement

This Privacy Policy was last revised on October 1, 2021. We may change this Privacy Policy at any time and for any reason. If we make a significant change to our Privacy Policy, we will post a notice on the home page of our website for a period of time after the change is made. You are encouraged to review this Privacy Policy each time you visit the Website.

Privacy of other websites

This website may contain links to other websites. Some of these websites may be operated by NGC affiliates and some may be operated by third parties. This Privacy Policy does not apply to other websites, including other Medtronic Group websites. Therefore, whenever you leave this website, you should review the privacy practices applicable to the information provided on the other sites. Links are provided for your convenience, but we do not review the privacy practices of websites operated by others. NGC is not responsible for websites operated by third parties or business dealings with them.

Special Rules about Children’s Privacy

NGC cares about protecting the online privacy of children. We do not intentionally collect personal information (such as a child’s name or email address) from anyone under the age of 16 without the consent of someone holding parental responsibility. Anyone who believes that personal information has been collected from someone under the age of 16 should contact NGC immediately.

Site Security

Security is very important to NGC as well as to each user. Industry standard measures are used to protect personal information from loss, misuse and unauthorized access, disclosure, alteration or destruction. However, no website or e-mail transmission is 100% secure, and we encourage users to take special care in deciding what information to send or request via e-mail and to take appropriate precautions such as keeping all usernames and passwords in use confidential.

User Rights

At any time, you may exercise your right of access, rectification and, as the case may be, erasure of any personal information relating to you, or limit the processing of your personal data, in accordance with applicable laws.

You also have the right at any time to object, due to particular situations, to any use or processing of your personal information.

Where personal information is processed automatically as part of a service provide to you or pursuant to your consent, you also have the right to request a copy of the information in a structured, commonly used, computer-readable format (known as the right to “data portability”).

Such requests may be sent to ngc[at]ngcmedical.com or in writing to N.G.C. Medical S.r.l., located at Via Salvo d’Acquisto 8/14, Turate (CO). Please note that you may be required to provide proof of identity (such as a copy of your ID card or passport) before each request can be fulfilled.

If the collection or use of your personal information is based on your consent, you have the right to withdraw that consent at any time in the same manner in which it was given by submitting a request in the manner set forth above.

You may also, at any time, free of charge and without having to provide any justification, opt-out of any direct marketing campaigns and request to stop receiving promotional materials as described above.

Our Data Protection Officer can be contacted by email by writing to europeanDPO[at]medtronic.com.

If you are not satisfied with the handling of your request, you may contact the Data Protection Authority. See also: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

How to contact NGC

If you have any questions or comments about this Privacy Policy, please make contact through the website or via the contact details listed in the User Rights section above.