Last Update: April 1, 2019
This Policy describes the types of information A-CURE may collect from you or that you may provide when you visit our website, a-cure.org (the “Website”), when you fill out a form, or contact us through the Website, and explains how we collect, use, maintain, protect, and, in some circumstances, disclose that information.
Certain information we collect is necessary to complete our contractual or legal obligations, others are required for us to operate the Website. In some instances, the information we collect may be done only with your consent.
The information we receive, and how we use it, depends on what you do when visiting the Website, how your browser is configured, and what information you provide to us. We collect and use your personal information differently than your non-personal information (information that is not identifiable to you personally).
WHAT IS PERSONAL INFORMATION?
Personal information is information we collect through the Website that we can use to specifically identify you, such as your:
- Telephone number
- E-mail address
- Work address
- Work and schooling history, including the name of your current institution
- Scientific abstracts or other relevant work product
We also collect your IP address when you use the Website, which in some circumstances can be considered personal information. Other than the IP address, we do not automatically collect personal information, though in some places on the Website you have the opportunity to send us such information about yourself. For example, you may fill out a registration form, a survey, an e-mail form, or an application for a scholarship.
HOW DO YOU COLLECT INFORMATION ABOUT ME?
Information You Give Us:
A-CURE receives and stores information you enter on the Website or give us in any other way.
Examples of the information you may give A-CURE includes:
- Information that you provide by filling in forms or applications on and through the Website, including your name, e-mail address, mailing address, work address, zip codes, telephone numbers, usernames and passwords, your work and schooling history, the name of your institution, and work product
- Information you provide when you contact us through the Website or by e-mail
- Records and copies of your correspondence (including postal and e-mail addresses), if you contact A-CURE
- Your responses to surveys that we might ask you to complete
- Your search queries on the Website
We use the information that you provide for such purposes as responding to your requests, keeping you informed of news and information about A-CURE, customizing future visits to our site, improving the Website, providing updates on new videos and resources on the Website, and communicating with you. We share this information with our sponsor, Abiomed, Inc. (“Abiomed”), but it will only be used for the purposes of promoting and supporting A-CURE and its mission.
If you do not want us to have this information, you can choose not to provide it to us, but then you might not be able to take advantage of many of A-CURE’s services or features. See “What Are My Choices?”
Automatic Information We Collect:
The Website collects a set of general data and information each time you visit. The information includes:
- Your browser type and the version used
- Your operating system
- The website from which you accessed the Website (so-called referrers)
- The links within the Website that you visit while accessing the Website
- The date and time you accessed the Website
- Your Internet Protocol (IP) address
- Your Internet service provider
- The country from which you are accessing the Website
- Other similar data and information required for security purposes in the case of attacks on our information technology systems
We do not attempt to draw any conclusions about you from this general information. Instead, we use this information to:
- Deliver the contents of the Website correctly
- Optimize the content of the Website and the advertising for it
- Improve the long-term functionality of our information technology systems and the technology of the Website
- Recognize you when you return to the Website
- Monitor and respond in case of a cyber attack
- Provide information to law enforcement authorities in the event of a cyber attack
In general, we use this information to improve the security and performance of the Website as well as to evaluate and improve the services we offer on the Website.
HOW DOES A-CURE KEEP AND USE PERSONAL INFORMATION?
We may keep and use personal information we collect from you through the Website to provide you with access to the Website. In addition, A-CURE may keep and use your personal information to:
- Respond to your requests
- Personalize your access to the Website, for example, by telling you about new features that may be of interest to you
- Develop records, including records of your personal information
- Contact you with information and updates that might be of interest to you
- Relay information about symposiums
- Develop and improve services and content
- Protect our rights or property
- Protect someone’s health, safety or welfare
- Comply with a law or regulation, court order or other legal process
In some instances, we de-identify or aggregate data by removing personal information (such as your name, e-mail address, etc.). Once de-identified or aggregated, the data is no longer attributed to a single unique individual. De-identified or aggregated information is non-personal information that we may treat like other non-personal information.
DOES A-CURE EVER SHARE PERSONAL INFORMATION WITH THIRD PARTIES?
A-CURE values the information it has about its customers, and is not in the business of selling it to others. We do share information with our sponsor, Abiomed, but it will only be used for the purposes of promoting and supporting A-CURE and its mission. We also occasionally need to share your information for the purpose of conducting our business with you or to comply with legal obligations. For example, under certain circumstances, A-CURE may need to disclose collected personal information in order to:
- Disclose to trusted third parties, who are bound by contractual obligations to keep personal information confidential, to support our business, and to use it only for the purposes for which we disclose it to them
- Comply with any court order, law, legal process, or to respond to any government or regulatory request, including requests related to laws outside of your country of residence
- Carry out our obligations and enforce our rights arising from any contracts entered into between you and us
- Protect the rights, property, or safety of A-CURE, its employees, customers, or others
- Enforce our terms and conditions
- Permit us to pursue available remedies and/or limit the damages that we sustain
- Fulfill our recordkeeping obligations and practices
- Fulfill any other purpose disclosed by us when you provide the information
- Comply with your instructions or, if allowed to do so, with your consent
We may also need to provide the collected personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of A-CURE’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by A-CURE about the Website’s users is among the assets transferred.
Sharing With Our Partners
In order to register for an event or symposium, you will leave A-CURE’s website and will be forwarded to our service provider Cvent, Inc. (“Cvent”). Cvent is based in the U.S. and is certified under the EU-U.S. and Swiss-U.S. Privacy Shield. Cvent’s certification can be viewed at https://www.privacyshield.gov/list. In addition, we have concluded a data processing agreement with Cvent. For further information on data protection at Cvent, please go to https://www.cvent.com/en/privacy-policy.
VIDEOS POSTED ON THE WEBSITE
We may post video footage from past events on public areas of the Website. By registering for an event through the Website, you are agreeing that video footage of you can be made public. Please be aware that we cannot control the actions of other users of the Website who might access this content. Therefore, we cannot and do not guarantee that your video footage will not be viewed by unauthorized persons.
WHAT IS NON-PERSONAL INFORMATION?
If you visit the Website to read or download information, such as information about an upcoming symposium, we may collect certain non-personal information about you from your computer. This information is collected from your computer’s web browser. If you only read or download information on the Website, we do not collect or learn your name, e-mail address, or other information directly identifying you.
“Non-Personal Information” is any information about you that does not reveal your specific identity, does not directly relate to an individual, and cannot be readily connected back to an individual such as:
- Browser and device information
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other similar information provided by you
- Usage data including information about how you use the Website
- Information from a referring website
- Marketing and communications data including your preferences in receiving marketing from us and your communication preferences
- Your zip code, postal code or area code when they are not connected to other personal information
- Aggregated information
- Personal information that has been de-identified
WHAT DOES A-CURE DO WITH NON-PERSONAL INFORMATION?
Because non-personal information cannot identify you or be tied to you, there are no restrictions on the ways that we can use or share non-personal information. We will use non-personal information from you to help us make the Website more useful to visitors. We also will use non-personal information for other business purposes. For example, we may use non-personal information or aggregate de-identified personal information to:
- Create reports for internal use
- Develop programs, services or content
- Customize the information or services that are of interest to you
- Share it with or sell it to third parties
- Provide aggregated “traffic statistics” and “response rates” to third parties
Under some circumstances, we also collect information about your use of the Website by using what are known as browser cookies. Cookies are small text files that are saved to your computer automatically and that store certain settings and data to share with our system about your browser. Cookies help us to improve the Website and to be able to offer you a better service more tailored to you by recognizing your device and making pre-settings available to you. In general, a cookie contains the name of the domain from which the cookie data was sent as well as information about the age of the cookies and an alphanumerical identifier.
In the cookies we use, only the data explained above about your use of the Website will be stored. There is no association with you personally. Instead, an identification number is assigned to the cookie (“cookie ID”). The cookie ID will not be connected with your name, your IP address or with similar data that would allow the cookies to be connected with you.
If you do not wish to use browser cookies, you can set up your browser so that the storage of cookies is not accepted. Please note that in this case you may only be able to use the Website to a restricted extent or not at all. If you only want to accept our own cookies, but not the cookies of our service providers and partners, you can choose to block third-party cookies in your browser settings.
MIGHT I ENCOUNTER ANY THIRD PARTY COOKIES?
A-CURE does not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
WHAT ABOUT GOOGLE ANALYTICS?
The Website uses Google (Universal) Analytics, a web analytics service provided by Google, Inc. (“Google,” www.google.com), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses “cookies,” which are text files placed on your computer to help the Website analyze how users interact with the sites. The information generated by the cookies about your use of the Website will be transmitted to and stored by Google on servers in the United States.
For further information please visit: http://www.google.com/analytics/terms/gb.html
Use of Google Tag Manager:
We also use the Google Tag Manager, another service of Google, Inc. on the Website.
Through the Google Tag Manager we arrange various codes and services in a structured and simplified way. The Google Tag Manager implements or “triggers” the tags. When a tag is triggered, Google may process information (including personal data). Google may also transmit this information to a server in a third country.
In particular, the following information, which in some circumstances may be personal information, is provided by the Google Tag Manager:
- Online markings (including cookie identifiers)
- IP address
Google processes the data on our behalf to trigger the deposited tags and the services on the Website. Google may transfer this information to third parties, if this is required by law or if third parties have commissioned this data on behalf of Google. Google also has a legitimate interest in the collected (personal) data to optimize its own services.
You can find more detailed information about the Google Tag Manager on the Website https://www.google.com/tagmanager/use-policy.html and under https://policies.google.com/privacy?hl=en.
By using Google Analytics and integrating the Google Tag Manager we aim to provide a faster and more stable service on the Website. These Google services allow us to optimize the loading times of the Website and better understand how users interact with them. Our legitimate interest in doing so is to allow us to improve the Website’s performance and to enhance our services for visitors to the Website.
Data Processing Addendum:
We have concluded an appropriate data processing addendum with Google in order to fulfill privacy requirements under the GDPR.
If You Wish to Opt-Out of Google Analytics and Google Tag Manager:
You can also opt-out from being tracked by Google Analytics and Google Tag Manager in the future by downloading and installing Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout) for your current web browser.
If you have deactivated individual tracking services (e.g. by setting an opt-out cookie), the deactivation will impact all affected tracking tags that are part of Google Analytics and the Google Tag Manager.
If you decide to opt-out, please be aware that the deactivation may mean that you cannot use all the features of the Website.
WHAT CHOICES DO I HAVE?
You can always choose not to input your information, even though it might be needed to take advantage of our services.
You can decline to accept cookies, set your browser to block cookies, or erase our cookies from your computer, though doing so may prevent some aspects of the Website from working properly.
You can prevent data collection by Google Analytics and Google Tag Manager by clicking on the following link: https://tools.google.com/dlpage/gaoptout. This places an opt-out cookie, which prevents the future collection of your data when visiting this (or other) websites. This opt-out cookie must be stored permanently on your computer. If you delete this opt-out cookie or it is deleted automatically via browser settings, you will have to install this opt-out cookie again when visiting the Website in the future.
If you no longer want to receive e-mail or other mail from A-CURE, please press the unsubscribe button on any of our e-mails or contact us at email@example.com.
If you want to exercise your rights over your data pursuant to GDPR or any similar law, please e-mail us at firstname.lastname@example.org.
WHAT ABOUT PRIVACY ON WEBSITES LINKED FROM A-CURE.ORG?
We may provide links to other companies on the Website. These external website addresses contain information that was published by organizations that are independent from us. They are used to provide additional information as a service for visitors to our Website.
DOES A-CURE EVER COMMUNICATE DIRECTLY WITH VISITORS TO THE WEBSITE?
If you provide us with your contact information through one of our contact, registration, or application forms, we may contact you periodically by e-mail, mail or telephone to provide information consistent with the information you requested in completing that form. We may also contact you to provide updates and information regarding upcoming events, new content on the Website, and other A-CURE services.
In addition, some of the features on the Website allow you to communicate with us using an online form. If your communication requests a response from us, we will send you a response via e-mail. The e-mail response or confirmation may include your personal information, including personal information about your name, address, etc. We cannot guarantee that our e-mails to you will be secure from unauthorized interception.
We may also contact you in case it is required by regulators to inform you of crucial information about products updates.
ARE THERE SPECIAL RULES ABOUT CHILDREN’S PRIVACY?
A-CURE cares about protecting the online privacy of children. We will not intentionally collect any personal information (such as a child’s name or e-mail address) from children under the age of 13. If you think that we have collected personal information from a child under the age of 13, please contact us at email@example.com.
WHAT ABOUT WEBSITE SECURITY?
We secure the Website and other systems through technical and organization measures against the loss, destruction, access, amendment or distribution of your data by unauthorized persons. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from this site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
CONTACT VIA THE WEBSITE
As required by law, the Website contains information that provides a means of e-mail contact to our company as well as other means of directly communicating with us. If you contact us by e-mail or other electronic means, the personal data you transmit is stored automatically. Such personal data will be stored for the purposes of responding to your inquiry and to provide updates and information regarding upcoming events, new content on the Website, and to help promote A-CURE’s mission. If you use the contact form on the Website for your inquiry, you will be asked to give your prior consent to the storage and usage of your personal data. This personal data will not be passed on to third parties other than our sponsor, Abiomed. However, this personal data will only be used for the purposes of promoting and supporting A-CURE and its mission.
HOW LONG DO YOU KEEP MY DATA?
In principle, we delete personal data when there is no requirement for further storage. A requirement may exist, in particular, if the data is still needed in order to be able to fulfill contractual obligations, to check warranty claims and, if applicable, guarantee claims and to grant or defend them. In the case of statutory retention obligations, deletion is only considered after the expiration of the respective retention period.
CAN I ACCESS, CORRECT OR DELETE MY DATA?
You may send us an e-mail at firstname.lastname@example.org to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to access, change or delete information if we believe that doing so would violate any law or legal requirement, cause the information to be incorrect, or if we are not legally obligated to so.
If you wish to delete your video footage from the Website please e-mail us at email@example.com, but please be aware that copies of your video footage may remain viewable in cached and archived pages, or might have been copied or stored by other Website users.
YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section § 1798.83 permits users of the Website that are California residents to request certain information regarding A-CURE’s disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to firstname.lastname@example.org.
GDPR (EUROPEAN GENERAL DATA PROTECTION REGULATION)
If you are a European Union resident, or are otherwise a data subject covered by the European Union’s General Data Protection Regulation (GDPR) or similar laws in other countries, you may have certain rights in relation to your personal information.
Data Privacy Contact (representative) for European Union:
Abiomed Europe GmbH
Neuenhofer Weg 3
Tel.: +49 241 8860 -0
Fax: +49 241 88660 – 111
Legal Basis For the Processing of Personal Data:
We process your personal data only pursuant to the following legal basis:
- Your prior consent
- To fulfill contractual obligations
- Legitimate interests of A-CURE or Third Parties
In cases where we rely on legitimate interests for the processing of personal data those interest are described in this Policy under the relevant heading.
Data Processing Outside the European Union/European Economic Area:
A-Cure is based in the United States. Therefore, data entered into our Website will be transferred to the United States.
European Union Data Subject Rights Pursuant to GDPR:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You may also have the right to ask us to delete or remove your personal information 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 information 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 information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also may have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal information to you or to a third party (“Data Portability”). This enables you, or a third party you have chosen, to seek to have your personal information provided 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.
- Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Complain to a data protection supervisory authority about the processing of personal data by us.
You will not have to pay a fee to exercise any of these rights. However, we may charge a reasonable fee if your request is repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests in a timely manner. Occasionally it may take us longer 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. We may also need to contact you about your request to verify your identity, confirm certain information, or clarify the request before we can fulfill the request.
If you are a European Union resident, or are otherwise a data subject covered by GDPR or a similar law, and would like to exercise these rights, or if you have questions about your rights please contact us at email@example.com or use the contact details of Abiomed Europe GmbH listed above.
HOW DO I CONTACT YOU?
C/O Abiomed, Inc.
22 Cherry Hill Drive
Danvers, MA 01923
Attn: Chief Compliance Officer
Tel.: +1 978.646.1400