Data Privacy Policy
Data Privacy Policy
INTRODUCTION
In effect: January 17, 2024
This Privacy Policy describes how UNOQUIP collects and processes information about you that directly or indirectly identifies you ("Personal Data"), alone or in combination with other information made available to us, in connection with your interactions with us through our website www.unoquip.com, or through any mobile sites, applications ("apps"), widgets, conferences, events, electronic newsletters, communications or other services (collectively the "Services") that link to, incorporate or provide a copy of this Privacy Policy to you (collectively, the "Services"). By continuing to use the Services, you agree to this Privacy Policy. We consider the protection of your personal information and privacy to be a very important issue. As such, we invite you to read this Privacy Policy carefully.
The Privacy Policy covers how we respect your privacy rights regarding the processing of your Personal Data in connection with the Services and/or for the purposes described in this Privacy Policy. In this Privacy Policy, the terms "we", "us" or "our" refer to UNOQUIP as the data controller.
THIRD-PARTY LINKS
Please note that if you access a link or website of a third party from our Services, you may need to refer to the privacy policies of those third parties. UNOQUIP provides the links for your convenience, but does not review, control, or monitor the privacy practices of websites operated by others. Neither are we responsible for websites operated by third parties or your business dealings with them. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.
CHANGES TO THE PRIVACY POLICY
We keep our Privacy Policy under regular review. We may change or update this Privacy Policy from time to time by posting a new Privacy Policy on this website. If we decide to make a significant change to our Privacy Policy, we will post a notice on the homepage of our website for a period of time after the change is made. We encourage you to review this Privacy Policy each time you visit the website.
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
MINORS
This website is not designed or intended for use by children under the age of 18. We do not knowingly collect any Personal Data on this website relating to children under the age of 18.
CONTROLLER
UNOQUIP GmbH (collectively referred to as "we", "us" or "our" in this Privacy Policy) is the controller and responsible for your personal data.
CONTACT DETAILS
If you have any questions about this Privacy Policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: UNOQUIP GmbH
Email address: privacy(at)unoquip.com
Postal address: Schützengraben 20, 8200 Schaffhausen, Switzerland
WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
The data we receive, and how we use it, depends on what you do when visiting our website or using our Services. We collect and use non-personal data (information that does not identify you personally) differently to your Personal Data.
Personal Data is information that can specifically identify you, including but not limited to:
- first name, maiden name, last name
- address, telephone number, e-mail address or other contact information
- personal health information
- date of birth or age
- social media username or profile
- interests and qualifications
- IP (Internet Protocol) address when such address is associated with a specific user
HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect Personal Data about our users in two ways:
- Direct interactions: When you directly provide information to us, i.e.: by entering personal information on certain pages of the website. For example, you may fill out a registration form for a particular service, participate in a survey, or complete a contact form.
- Automated technologies or interactions: Using automated means, specifically through cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website. For more information about cookies, please click here.
HOW AND WHY WE PROCESS YOUR PERSONAL DATA?
We will only use your personal data when the law allows us to. If and to the extent required by applicable law, we rely on one or more of the following legal bases:
- Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
We will process your Personal Data from our websites for many reasons, including:
- to respond to your requests or inquiries
- to complete a transaction
- to personalize your experience
- to perform website analytics and measure website performance
- to track and monitor adverse events and other activities related to medical device reporting
- to maintain the website, including for security purposes
Several places on our website require Personal Data if you choose to use them, including surveys, registration, and content sharing features (i.e., “E-mail to a Friend” links). UNOQUIP and its business partners (such as service providers or other third parties who provide certain services to UNOQUIP) collect this information about you only if you voluntarily provide it to us. Please be aware that certain features of this site may not be available to you if you elect not to provide certain Personal Data. Any Personal Data you provide to us on our website will be used in accordance with this Privacy Policy.
HOW DOES UNOQUIP USE PERSONAL DATA?
We may use the Personal Data that you have shared with us through this website and relevant Services (other than sensitive personal data, which is discussed separately below) for the following purposes:
- to respond to your requests
- to provide the services or information you request
- to resolve and track the status of any consumer and/or product or service issues
- to enter into, or perform a contract with you (e.g., in case you wish to order products or services from us)
- to enable you to participate in our online communities, including social media and blogs
- to contact you with information that might be of interest to you – see the Marketing and Education section below
- in other ways to which you expressly consent
UNOQUIP may also use your Personal Data to the extent necessary to achieve the following legitimate interests, so long as compatible with your rights and expectations of privacy:
- for analytical purposes in order to research, develop and improve programs, products, services and content
- to allow you to create a UNOQUIP online account; the information you provide may be used for the purposes of (i) setting up, administering, and securing your account, (ii) managing password restoration and renewal and (iii) account usage.
- to anonymise your Personal Data by removing any personal identifiers (your name, e-mail address, etc.) so that it may be used for other purposes; in this case, the anonymised information would no longer identify you and may be treated like other non-personal data. to enforce this Privacy Statement and other rules about your use of this website
- to protect our rights or property
UNOQUIP also has legal grounds to use your Personal Data:
- as necessary to protect someone's health, safety, or welfare; and
- in order to comply with a law or regulation, court order or other legal process
Where required by law, we will ask you to "opt-in" or affirmatively consent to the processing of your Personal Data for a particular purpose. For example, where the law so requires, we will only send you newsletters if you have subscribed to them.
WHAT IS SPECIAL CATEGORY DATA / SENSITIVE PERSONAL DATA?
Some types of Personal Data are subject to additional protection. Depending on the applicable data protection laws, such data is called Special Category Data or Sensitive Personal Data (hereafter "Special Category Data"). Special Category Data is Personal Data revealing or relating to your health (such as your product use history), genetic or biometric data, your racial or ethnic origin, religious or philosophical beliefs, sex life or sexual orientation, political opinions, trade union membership, data relating to administrative and criminal proceedings or sanctions or to social assistance measures.
HOW DOES UNOQUIP TREAT SPECIAL CATEGORY DATA?
UNOQUIP will only collect and process your Special Category Data:
- in ways for which you have given your explicit consent
- to protect the vital interests of you or another person, in cases where your explicit consent cannot be given or reasonably requested
- according to applicable laws which include suitable and specific measures to safeguard your fundamental rights and interests
- where the processing is necessary for medical purposes and we are, under the circumstances, under a duty of confidentiality equivalent to the duty of confidentiality of a health professional
to establish, exercise, or defend a legal claim
For example:
We may collect Special Category Data directly from you when you voluntarily provide it to us for a particular purpose (i.e.: when you contact us with a question or suggestion about our products and services).
We may also collect Special Category Data about patients through healthcare professionals who we work with to provide therapy or technical support for our products or services to you.
We may collect Special Category Data as required by Swissmedic, European, and other governmental authorities in order to assure safe and effective use of our products and services.
We may collect Special Category Data about participants 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 tied to you in any way. Therefore, the non-personal information that we collect through this website does not identify you as 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 linked directly to our website
- the date and time you access our website
- which pages you have visited on our website
- the search terms you use
- the links on which you click
If you visit our website to read or download information, such as information about a health condition or about one of our products, we may collect certain non-personal information from your computer. This information is collected from your computer's web browser. If you only read or simply click to download information on our website, we do not collect or learn your name, e-mail address, home address, or any other personal information about you. For more information about how we use cookies to collect information about visitors to our website, please click here.
WHAT DOES UNOQUIP DO WITH NON-PERSONAL INFORMATION?
We are always looking for ways to better serve you and improve our products, services, and website experience. We will use non-personal information from you to make this website more useful to visitors. We may also use non-personal information for other business purposes. For example, we 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
- provide information on how our site is used, such as "traffic statistics" and "response rates" to third parties
DIRECT MARKETING AND EDUCATIONAL MATERIALS
UNOQUIP may wish to provide you with educational materials or other information about our products and services, as well as information about clinical trials or the products and services of others that might be of interest to you, based on the information you have shared with us and that we have collected through cookies or similar techniques regarding your use of the UNOQUIP website, social media and blogs. For more information on how we use cookies, and your choices in that regard, please click here.
We will ask you to "opt-in" or affirmatively consent to the use of your Personal Data for the purposes of such communications, in accordance with applicable laws.
If at any time you decide not to receive any educational, commercial, or promotional information related to our products and services or regarding the products or services of our affiliates or service providers, please email us at the contact details listed below and mention “OPT-OUT” in the subject of your email. Alternatively, you may use the opt-out procedure provided in any relevant message you receive from us.
Please note that if you opt not to receive promotional messages from us, we may still continue to send you relevant information for other lawful purposes, such as to administer any account you may have with us, to respond to your requests, to execute agreements with you, or to provide you with information that UNOQUIP is required by law to provide, i.e.: regarding product recalls.
SURVEYS
From time to time, we may invite you to participate in a survey to determine customer satisfaction levels, identify areas of potential improvement or to carry out market research. If and to the extent a legal basis is required by applicable law, we may send you a specific invite to participate in such a survey on the basis of our legitimate interests in conducting the survey, or on the basis of your prior “opt-in” consent to receive such communications, in accordance with applicable laws. You may opt-out of receiving any such future communications in the manner detailed in the section above.
The Personal Data that is collected for the purpose of the survey may include your email address, phone number, survey results, and any free-text message you may have written in the survey.
We process your Personal Data as part of the survey for carefully considered and specific business purposes which are in our legitimate interests and which we believe also often benefit you, based on our assessment that our legitimate interests do not override your freedom and data protection rights.
The business purpose of collecting your Personal Data is to reply to survey feedback you may have provided, specifically:
- Should you have indicated an issue which we need to take action to resolve
- In order to gain further insight to the experience you have described
- To inform you of any action we might take internally to resolve your issue or enhance your experience
DOES UNOQUIP EVER SHARE PERSONAL DATA WITH THIRD PARTIES?
UNOQUIP will not share your Personal Data with a third-party except as described in this Privacy Policy.
In the ordinary course of business, we may share some personal information with UNOQUIP affiliates or third parties that we hire to perform services or functions on our behalf.
For example, we may:
- use different vendors or suppliers to ship products that you order on our website. In these cases, we provide the vendor with information to process your order such as your name and mailing address
- use a service provider to administer certain newsletter or informational mailings that you have signed up for, and provide access to your email address for this purpose
- use a third-party application or platform to allow us to manage and keep track of our communications with you
- use our company affiliates or third-party service providers to provide services relating to your Personal Data, i.e.: we may store your information on a secure server based at our affiliate’s or service provider’s site outside Switzerland, UK or the EU/EEA. For more information on the circumstances in which we may transfer your information to other countries, please see the Transfer section below
- use a third-party application or platform to conduct surveys, which can include storage of the survey feedback.
In all cases we will not share more information than is necessary, and we will not authorize any third parties to keep, disclose or use your information except to provide the requested services in line with the purposes set out above.
Please note that subject to applicable laws, we may disclose your Personal Data if we believe we are required to do so to comply with any law, regulation, court order, legal or government request. In the unlikely event that all or part of our business is acquired by a third party, your information may be transferred to the new corporate owner insofar as relevant to the business in question and subject to appropriate safeguards being in place.
In addition, we may use and disclose your Personal Data to third parties if necessary to:
- enforce this Privacy Policy and the other rules about your use of this website
- protect our rights or property
- protect someone's health, safety or welfare
- comply with a law or regulation, court order or other legal process
- investigate or take action in cases of suspected fraud or illegal activities
In addition, please keep in mind that certain areas of our website may be interactive in nature and allow you to post information that other users can see. If you do not wish to have information viewed publicly, please do not use those sections of the website.
DO WE TRANSFER PERSONAL DATA TO OTHER COUNTRIES?
In certain cases, UNOQUIP may transmit Personal Data collected on this website to our affiliates or third-party service providers in other countries, but only in furtherance of the purposes set out in this Privacy Policy. In cases where Personal Data is transmitted from Switzerland, the UK or the EU/EEA to other countries we will ensure that safeguards equivalent to those provided by Swiss and European data protection laws are in place.
For more information on the safeguards implemented by UNOQUIP please contact privacy(at)unoquip.com.
The Personal Data we collect from you is processed primarily in Switzerland, but also in the European Union, in particular in Denmark. In addition, your Personal Data may also be processed, accessed, and stored in the following countries where UNOQUIP operates:
- Australia
- Bosnia-Herzegovina
- Iceland
- New Zealand
- Norway
- UK
If we transfer your Personal Data to external companies in other jurisdictions, we will ensure that we protect your Personal Data by applying the level of protection required by applicable data privacy laws by implementing adequate technical and organizational measures. In the event that your Personal Data is transferred to and processed by a service provider based in a third country (countries outside the EU/EEA and Switzerland that do not have a level of data protection comparable to European Union and Swiss data protection law, as determined by a competent data protection authority), UNOQUIP protects your Personal Data through the use of EU/UK GDPR Standard Contractual Clauses or other methods consistent with applicable law. If, in the future, these Standard Contractual Clauses should be declared null and void and/or revised by the UK Parliament or the European Commission or not be recognised by the Swiss Authorities anymore, we will adopt other applicable and/or approved instruments in order to provide the appropriate safeguards required for transfers to third countries and we will conclude these agreed instruments in a written and legally binding form.
HOW LONG WILL WE KEEP YOUR PERSONAL DATA FOR?
We will only keep your Personal Data for so long as is reasonably necessary to fulfil the purposes for which we are allowed to use them, as set out in this Privacy Policy.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
For example, if you tell us that you no longer wish to receive a newsletter from us, we will immediately delete your email address from our mailing list. For more information on when you can ask us to delete your data see below under “Your Rights”.
YOUR RIGHTS
You have a number of rights under data protection laws in relation to your personal data.
At any time and depending on the data protection laws applicable to you, you may have the right to:
- Request access to your Personal Data (commonly known as a “subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are processing it in compliance with applicable laws.
- Request correction of the Personal Data that we hold about you. This enables you to correct any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your Personal Data in certain circumstances. This enables you to request us to delete or remove Personal Data where there is no good reason for us to continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- You also have the right to object any time to the processing of your personal data for direct marketing purposes (see section on DIRECT MARKETING AND EDUCATION MATERIALS) for details of how to object to receiving direct marketing communications).
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data's accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
In case we are processing your personal information in an automated manner as part of a service to you or based on your consent then you also have the right to request a copy of your information in a structured, commonly used, and machine-readable format (known as the right to “data portability”).
Such requests can be sent to privacy@unoquip.com or in writing to:
UNOQUIP GmbH
c/o Data Protection Manager
Schützengraben 20
8200 Schaffhausen
Switzerland
Please note that we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to assess which of the rights apply to you and to speed up our response.
If we have based our collection or use of your personal information on your consent then you also have the right to withdraw your consent at any time in the same way as it was given, or by sending a request in the above manner.
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 no longer receive any promotional material as described in the section DIRECT MARKETING AND EDUCATIONAL MATERIALS above.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
WHAT ABOUT WEBSITE SECURITY?
Security is very important to us. We also understand that security is important to you. We use industry standard measures to protect your personal information from accidental loss, unauthorised use or access, disclosure, alteration, or destruction.
In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
COMPLAINTS
You have the right to make a complaint at any time to the competent authority:
For Switzerland: Federal Data Protection and Information Commissioner (FDPIC), contact details available at www.edoeb.admin.ch.
For UK: Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).
For EU/EEA member states: the competent authority can be looked up in the European Data Protection Boards (EDPB) comprehensive list (https://edpb.europa.eu/about-edpb/about-edpb/members_en).
In any case, we would appreciate the chance to deal with your concerns before you approach the relevant authority so please contact us in the first instance.