BSC complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. BSC has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view BSC’s certification, please visit www.export.gov/safeharbor. Furthermore, Boston Scientific abides by the Generally Accepted Privacy Principles (GAPP), as set forth below:
Generally Accepted Privacy Principles (GAPP):
- Management. Boston Scientific has a program designed to protect personal data in its possession or control. This is done through a variety of privacy and security policies, processes and procedures. This program is overseen by Boston Scientific's Chief Privacy Officer.
- Notice. To the extent Boston Scientific collects personal data directly from you, Boston Scientific will ensure that you receive or have access to a notice that describes the privacy practices associated with the collection.
- Choice and consent. To the extent Boston Scientific collects personal data directly from you, Boston Scientific will inform you about what data handling choices you might have.
- Collection. Boston Scientific will only collect personal data needed to satisfy business purposes or legal or regulatory requirements.
- Use, retention, and disposal. Boston Scientific uses personal data for a variety of business purposes, which includes regulatory reporting, quality systems management, customer and technical support, system maintenance, data compilation and analysis, data hosting, event reporting, program analysis and maintenance and other related purposes. Boston Scientific retains personal data for only as long as necessary to fulfill the stated purposes, consistent with applicable data retention schedules and thereafter appropriately disposes of such information.
- Access. Boston Scientific will provide access, as requested and if feasible, to personal data it might have about you.
- Disclosure to third parties. Boston Scientific discloses personal data to the participating healthcare providers, regulatory authorities, service providers, etc., in the course of its business. These third parties are required to handle personal data in a confidential manner and to maintain adequate security to protect the information from loss, misuse, unauthorized access or disclosure, alteration, and destruction.
- Security for privacy. Boston Scientific employs administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the personal data that it creates, receives, maintains, or transmits.
- Quality. Boston Scientific attempts to maintain accurate, complete, and relevant personal data.
Information We Collect and How We Use It
Personal data is data that can be used to identify or contact you, such as your name, email address, telephone number or similar information. BSC only collects personal data that you choose to share with us, such as when (1) contacting us via the Site (or requesting information), (2) submitting your resume online in response to a job posting, (3) registering online for an event or course or, (4) upon registration for access to those areas of our Site intended only for licensed medical professionals.
We may also collect the following information from you:
- Information about your business such as company name, company size, business type
- Medical condition
- Demographic information such as age, education, gender, interests and location
- Contact information such as email address and phone number
We use this information to:
- Send you requested product or service information
- Send you product updates
- Respond to your questions
- Administer your account
- Conduct surveys or other research and analysis
- Send you a newsletter
- Send you marketing communications
- Improve our Site and marketing efforts
- Display content based upon your interests
- Enable you to post your resume, search job postings, and contact or be contacted by prospective BSC representative or agents
If you are a licensed medical professional, to register, you must provide us with certain personal data which may include your name, profession, email address, postal mail address, title, Medical ID and clinical affiliation. We will use this personal data to review and verify your registration information. We may use your personal data to send periodic transactional, marketing, or promotional notices to you or notify you of any changes to this Policy. You can always opt-out of receiving marketing or promotional communications from us by following the "opt-out" procedures described below or on the specific marketing or promotional message.
If your personal data is submitted through the Site when applying for a position with BSC, your personal data will be used solely for the purpose of evaluating and accepting you for the position. We may retain your personal data for a period of time, but only for the purpose of considering your application for current or future positions at BSC or as necessary to comply with the law. This information may be shared within BSC as well as with third parties contracted by us to assist BSC with talent acquisition related activities.
We may provide you the opportunity to participate in surveys on our site. If you participate, we may request certain personal data from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and email address) and demographic information (such as city, state or country). We use this information to understand what type of information visitors look for on the site, whether or not they are able to find it, what additional content would be useful on the site, and other information that can be used to help optimize user experience.
We may use third parties to conduct these surveys or contests. The third party would be prohibited from using our users’ personal data for any purpose inconsistent with the management of such surveys or contests.
With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
From time to time, the Site may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
If you contact BSC via the Site, we will only use your personal data contained in your email to respond to your specific inquiry, request, or comments in the email. We may retain your email for a period of time, but will not use any of your personal data for any purpose other than responding to your email, unless such additional use is required or permitted for us to comply with the law.
General Information and Accuracy
Any information you provide to BSC must be true, accurate, current, non-misleading, and consistent and relevant for the purpose for which you are providing the information. If you are a registered user, you must have the authority to provide the information submitted to and through the Site, and understand and agree that we may from time to time verify such authority.
The Site automatically tracks certain information about your behavior while visiting the Site. The information gathered includes the URL from which you accessed this Site, and which URL you visit next. We collect and store this aggregate information in order to measure the Site's performance and improve the Site's design and functionality. We may also share this aggregate information with third parties to illustrate how the Site is used and for other marketing purposes.
If you are a registered user, we may use your Usage Data with or without your personal data, in order to measure the Site's performance and improve the Site's design and functionality. We may share aggregate Usage Data with third parties to illustrate how the Site is used and for other marketing purposes. See also "Cookies", below.
Session cookies are temporary bits of information that are erased once you exit your web browser or 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. They store information on your computer for a number of reasons, such as retrieving certain information you have previously provided (i.e., username and password), helping to determine what areas of the Site you find most valuable, and customizing the Site based on your preferences on an ongoing basis. Persistent cookies placed on your computer by this Site may hold personal data, but only if you are a registered user or have otherwise consented to the provision of personal data in accordance with the terms of this Policy. Personal data would be used for things like simplifying the login process or serving personalized content on the site. Otherwise, the Site's server only knows that an unidentified visitor with your cookies has returned to the Site. In addition to customization, persistent cookies will be used to provide you with better service on the Site, to compile and analyze statistics and trends, and to otherwise administer and improve the Site for your use. Subject to applicable law and in accordance with the terms of this Policy, information gathered through the use of persistent cookies on the Site may also be shared with third parties who assist us with the management or optimization of our Sites and the delivery of enhanced user experience.
3rd Party Tracking
Social Media Widgets
The Site may also use clear gifs (also known as web beacons) in combination with cookies, in order to help Site operators understand how visitors interact with the Site. A clear gif is typically a transparent graphic image (usually 1 pixel by 1 pixel in size) that is placed on the Site, which allows the Site to measure the actions of a visitor who opens the page that contains the clear gif. BSC uses clear gifs to measure traffic and related behavior, and to improve your experience when visiting the Site. We also use clear gifs to manage the content available on the Site. Clear gifs are not tied to personal data.
We use local shared objects, also known as Flash cookies, to store your preferences such as volume control, or display content based upon what you view on our site to personalize your visit. Third parties, with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity, use Flash cookies to collect and store information.
Flash cookies are different from browser cookies. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies, go to www.macromedia.com
Behavioral Targeting / Re-Targeting
In addition to the disclosures described throughout this Policy, and subject to applicable law, we and our third parties may disclose your personal data:
- To unaffiliated third parties that are under contract to perform services for or on behalf of BSC. Examples of such services are third parties 1) maintain our computer databases; and 2) perform marketing activities;
- To other persons as permitted by applicable law or regulation; and
- To law enforcement personnel and agencies, or as part of a legal process, in order to protect our property or in furtherance of an investigation regarding a breach of the Site rules and policies, unauthorized access to or use of the Site or any other illegal activities.
Any access to such information will be limited to the purpose for which such information was provided to our affiliate, subsidiary or third party. Our affiliates, subsidiaries and third parties may be located throughout the world. Accordingly, information may be sent worldwide to countries which provide varying levels of privacy protection. Nevertheless, the affiliates, subsidiaries and third parties are required to uphold and maintain BSC’s policies with respect to privacy and the treatment of your personal data regardless of their locations or the laws of the countries they are based in.
Consent to Processing Outside Home Country
By using our Site, or providing information to BSC, you understand and unambiguously consent to the collection, use, disclosure and retention of information in the United States and other countries and territories, for the purposes set forth in this Policy. You hereby consent to the collection, use, disclosure and retention by BSC of your personal data as described under this Policy, including but not limited to the transfer of your personal data between BSC's third parties, affiliates and subsidiaries in accordance with this Policy. For further certainty, any consent relating to a right to transfer information referred to in this paragraph shall be deemed to include your consent to the transfer of the applicable personal data to a jurisdiction which may provide a different level of privacy protection than that available in your own country.
To "opt-out" of (1) having your Site provided personal data disclosed to third parties for marketing purposes, or (2) any other consent previously granted for a specific purpose concerning your personal data on this Site, send an e-mail to BSC at firstname.lastname@example.org. To "opt-out" of receiving a particular marketing or promotional communication, follow the unsubscribe instructions included in the specific communication.
Access and Choice
If you are a registered user or have provided BSC with your personal data, you may request to review, change or delete information previously provided to us by modifying your profile at the Login Screen or by sending an e-mail to email@example.com. Requests for changes to or deletions of your personal data should be made by you directly. We will respond to all access requests within 30 days.
We will retain your information for as long as your account is active or as needed to provide you services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Other Web Sites
BSC takes seriously the security of the information it collects. BSC has therefore implemented technology and security policies and procedures intended to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to, such information, reasonably appropriate to the nature of the data concerned.
When you enter sensitive information (such as personal health information), we encrypt the transmission of that information using secure socket layer technology (SSL) We follow generally accepted standards to protect the personal data submitted to us through our Sites, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at firstname.lastname@example.org.
Our Site is not intended for use by individuals under the age of 18, and BSC does not knowingly collect personal data from those in this age group. If you are under 18, please discontinue the use of our Site. If we become aware that someone under the age of 18 has registered, we will expunge any related personal data from our records.
BSC may, in its sole discretion, update this Policy at any time and from time to time, by posting the amended Policy on this Site. The amended Policy shall be effective upon posting, and your access to or use of the Site following an update shall be deemed consent to the revised Policy. We urge each visitor to refer back to this page regularly and especially prior to providing or updating any personal data. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. This Policy was last updated on April 30, 2012.
Contact, Questions, Comments, Complaints
If you would like to communicate with BSC regarding privacy issues or have questions, comments or complaints about this Policy or Site, please contact us using one of the following ways:
Global Compliance – Privacy Office
4100 Hamline Avenue – Mail Stop 3-302
Saint Paul, MN 55112 (USA)
If contacting us does not resolve your issue or complaint, you may raise your issue or complaint with TRUSTe by Internet here, or by fax at 1-415-520-3420 or mail to TRUSTe Safe Harbor Compliance Dept., click for mailing address. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, click here or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English. For human resources data we have agreed to cooperate with Data Protection Authorities.