Privacy Policy

DRG International, Inc. Privacy and Cookie Policy

Last Updated: May 23, 2019

OUR COMMITMENT TO PRIVACY

DRG International, Inc, and its affiliates (“DRG”) are committed to your privacy.  We want you to be familiar with how we collect, use and disclose information. This Privacy and Cookie Policy (“Policy”) describes our practices in connection with information that we collect online and offline:

WHAT INFORMATION WE COLLECT

Personal Information” is information that identifies you as a natural person or relates to an identifiable natural person.  We may collect and process the following Personal Information:

  • Personal contact information such as name, address, telephone number and email address;
  • Business contact information such as business address, telephone number and email address;
  • Information necessary to provide you with our products and services;
  • Instructions, comments, and opinions you provide when you contact us directly by email, telephone or mail;
  • Payment and transaction information for billing purposes.

Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual.  We may collect and process the following Other Information:

  • Browser and device information;
  • Information collected through cookies, and other technologies.  For more information regarding our use of cookies, please review our section on “Information About Cookies” below;
  • Demographic information and other information provided by you that does not reveal your specific identity;
  • Information that has been aggregated in a manner such that it no longer reveals your specific identity.

If we are required to treat Other Information as Personal Information under applicable law, then we will collect, use and disclose it for the purposes for which we collect, use and disclose Personal Information as detailed in this Policy.

HOW WE COLLECT PERSONAL AND OTHER INFORMATION

We and our service providers may collect Personal Information online in a variety of ways in connection with our products and services, including:

  • Through our websites (“Websites”); 
  • Through social media properties (“Our Social Media”);
  • Through HTML-formatted email messages that we send to you that link to this Policy (“Emails”);
  • Through the products and services we provide to you; and
  • Through our registration process for newsletters and other events. 

We also may collect Personal Information offline in a variety of ways in connection with our products and services, including

  • When you participate in a contractual arrangement for our products and services; 
  • When you provide information in conjunction with our products and services; or
  • When you interact with us at an event.

We also may collect Personal Information from other sources, including:

  • Publically available databases; 
  • Joint marketing partners, when they share the information with us;
  • Entities to which we provide products and services, which may include your employer;
  • Referral sources; and
  • Social media platforms.

Information About Cookies

We need to collect Personal Information in order to provide our products and services to you.  If you do not provide the information requested, we may not be able to provide our products and services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with our products and services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

We and our service providers may collect other information in a variety of ways.   As you navigate through this site, certain anonymous information can be passively collected (that is, gathered without your actively providing the information) using various technologies, such as cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream).

A “cookie” is a bit of information that a Web site sends to your Web browser that helps the site remember information about you and your preferences.

“Session” cookies are temporary bits of information that are used to improve navigation, block visitors from providing information where inappropriate (the site “remembers” previous entries of age or country of origin that were outside the specified parameters and blocks subsequent changes), and collect aggregate statistical information on the site. They are erased once you exit your Web browser or otherwise turn off your computer.

“Persistent” cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (such as passwords), helping to determine what areas of the Web site visitors find most valuable, and customizing the Web site based on your preferences on an ongoing basis. Persistent cookies placed by this site on your computer may hold personally identifiable information, but only if you have registered or have otherwise consented to the retention of personally identifiable information you have provided at the site. Otherwise, our site’s server only knows that an unidentified visitor with your cookie has returned to the site.
You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. To learn more about cookies and how to specify your preferences, please search for “cookie” in the “Help” portion of your browser.

“Internet tags” (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the Web site server information such as the IP address and browser type related to the visitor’s computer. Tags may be placed both on online advertisements that bring people to the site and on different pages of the site. Such tags indicate how many times a page is opened and which information is consulted.

“Navigational data” (log files, server logs, and clickstream data) are used for system management, to improve the content of the site, market research purposes, and to communicate information to visitors.

Your Internet browser automatically transmits to this site some of anonymous information, such as the URL of the Web site you just came from and the Internet Protocol (IP) address and the browser version your computer is currently using.  An IP address is a number assigned to your computer by your Internet service provider so you can access the Internet and is generally considered to be non-personally identifiable information, because in most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user’s computer). The IP address can be used to diagnose problems with a server, report aggregate information, determine the fastest route for your computer to use in connecting to a site, and administer and improve the site.

This site may use and combine such passively collected anonymous information to provide better service to site visitors, customize the site based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve the site for your use. Such information is not combined with personally identifiable information collected elsewhere on the site unless you have consented.  If we do combine Other Information with Personal Information, we will treat the combined information as Personal Information as long as it is combined

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.

You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

 HOW WE USE PERSONAL INFORMATION

We and our service providers use Personal Information for legitimate business purposes, including:

  • Providing Products and Services.
    • To contact individuals (including employees of institutional customers) in connection with providing our products and services.
    • To respond to inquiries and fulfill requests and orders from our customers and others.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

  • Providing you with our newsletter and/or other marketing materials and facilitating social sharing
    • To send you our newsletters, publications, and mailings related to our events that we think may be of interest to you.
    • To send you information about our products and services and other news about our company.

We will engage in this activity with your consent or where we have a legitimate interest.

  • Providing the functionality of our Products and Services and fulfilling your requests
    • To provide our products’ and services’ functionality to you, such as arranging access to your registered account, and providing you with related customer service. 
    • To respond to your inquiries and fulfill your requests and orders, when you contact us via one of our online contact forms or otherwise (e.g., when you send us questions, suggestions, compliments or complaints, or when you request other information about our products and services).
    • To send administrative information to you, such as information regarding our products and services and changes to our terms, conditions and policies.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

  • Accomplishing our business purposes
    • For data analysis, for example, to improve the efficiency of our products and services. 
    • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements. 
    • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft. 
    • To meet our legal and regulatory obligations. 
    • For enhancing, improving, or modifying our current products and services. 
    • For identifying usage trends, for example, understanding which parts of our products and services are of most interest to users. 
    • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
    • For operating and expanding our business activities, for example, understanding which parts of our products and services are of most interest to our users so we can focus our energies on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

HOW WE DISCLOSE PERSONAL INFORMATION

We disclose Personal Information:

  • To our affiliates for the purposes described in this Privacy Policy
    • You can consult the list and location of our affiliates listed at the bottom of this page. Subject to local requirements, this information may be used to provide legal and related services offered by our other legal entities and for all the purposes outlined in this Privacy Policy.
    • DRG International, Inc. is the party responsible for the management of the jointly-used Personal Information.
  • To our third party service providers, to facilitate services they provide to us
    • These can include providers of services such as website hosting, product and services-related consulting and monitoring, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
  • By using our products and services, you may elect to disclose Personal Information
    • On message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media.  Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
  • Disclosure to public authorities
    • Additionally, the company may be required to disclose Personal Data in response to lawful requests by public authorities to comply with national security or law enforcement requirements.

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

    • To comply with applicable law and regulations including laws outside your country of residence.
    • To cooperate with public and government authorities, including authorities outside your country of residence.
    • To cooperate with law enforcement.
    • For other legal reason such as to enforce our terms and conditions and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
    • In connection with a sale, merger or business transaction.

SPECIAL NOTIFICATION FOR INDIVIDUAL CALIFORNIA USERS

Individual California Users (as defined below) may request information about our disclosures of certain categories of Personal Information to third parties (i.e., our affiliates) for such third parties’ direct marketing purposes.

As noted above, we may disclose Personal Information to affiliates of DRG International, Inc.  which may use this information for all purposes outlined in this Policy. Because separate legal entities are considered “third parties” for purposes of California Civil Code Section 1798.83, and certain communications from our affiliates might be viewed as promoting their products and services, we are providing the following information for California residents who have provided us with their Personal Information during the creation of or during the course of an established legal services relationship that is primarily for personal, family, or household purposes (“Individual California Users”).

Individual California Users must submit their requests to us either by email at the following email address: [insert email address].

We will provide a list of the categories of Personal Information disclosed to third parties (i.e., our affiliates) for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.

HOW LONG WE RETAIN PERSONAL INFORMATION

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

    • The length of time we have an ongoing relationship with you and provide our products and services to you (for example, for as long as you have an account with us);
    • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions or communications for a certain period of time before we can delete them); or 
    • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). 

WHAT SECURITY MEASURES WE USE

We have implemented internal policies and technical measures to protect Personal Information from loss, accidental destruction, misuse or disclosure. Such internal policies and technical measures include: 

    • The use of pseudonymization and encryption of personal data where appropriate;
    • Procedures and controls to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
    • Procedures and controls to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
    • Procedures for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing; and
    • Procedures to ensure that data is not accessed, except by individuals in the proper performance of their duties.  

WHAT CHOICES YOU HAVE

You have choices regarding marketing-related communications. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the unsubscribe instructions in any such message or by contacting us by email at [insert email address]. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

PRIVACY RIGHTS FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA AND SWITZERLAND

If you are resident in the European Economic Area or Switzerland, under European or Swiss law you have the following rights in respect of your Personal Information that we hold:

    • Right of access. You have the right to obtain confirmation of whether, and where, we are processing your Personal Information; information about the categories of Personal Information we are processing, the purposes for which we process your Personal Information and information as to how we determine applicable retention periods; information about the categories of recipients with whom we may share your Personal Information; and a copy of the Personal Information we hold about you.
    • Right of portability. You have the right, in certain circumstances, to receive a copy of the Personal Information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
    • Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete Personal Information we hold about you without undue delay.
    • Right to erasure. You have the right, in some circumstances, to require us to erase your Personal Information without undue delay if the continued processing of that Personal Information is not justified.
    • Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your Personal Information if the continued processing of the Personal Information in this way is not justified, such as where the accuracy of the Personal Information is contested by you.
    • Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your Personal Information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
    • If you are resident in France, you also have the right to set guidelines for the retention and communication of your Personal Information after your death.

If you wish to exercise one of these rights, please contact us at [insert email address].

EU residents also have the right to lodge a complaint to theirr local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. Swiss residents have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner at: https://www.edoeb.admin.ch/?lang=en.  

Residents in other jurisdictions may also have similar rights to the above. Please contact us at [insert email address] if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties.

This includes any third party operating any website or service that have a link on our website.  The inclusion of a link on our website does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media.

USE OF OUR SERVICES BY MINORS

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.

CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. By using our products and services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

Some of the non-EEA countries are recognized by the European Commission and Switzerland as providing an adequate level of data protection according to EEA or Swiss standards.  For transfers from the EEA or Switzerland to countries not considered adequate by the European Commission or Switzerland, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission or contracts approved by the Swiss Commissioner, to protect your Personal Information. You may obtain a copy of these measures by sending a request to [insert email address].  We also may transfer your Personal Information to other countries pursuant to your consent.

UPDATES TO THIS POLICY

The “LAST UPDATED” legend at the top of this Policy indicates when this Policy was last revised.  Any changes will become effective when we post the revised Policy on our website.  Your use of our website following these changes means that you accept the revised Policy.

HOW TO CONTACT US

DRG International, Inc. is the company responsible for collection, use and disclosure of your Personal Information under this Policy.

If you have any questions about this Policy, please contact us at:

DRG International, Inc. Global Headquarters

Attention: Corporate Communications

841 Mountain Avenue Springfield, NJ  07081 USA
Tel: +1-973-564-7555
Fax: +1-973-564-7556
Email: [email protected]

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

AFFILIATES

For purposes of this Privacy and Cookie Policy, these entities are considered to be “affiliates” of DRG International, Inc.:

DRG Diagnostics GmbH

 

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