Privacy Notice - Corporate
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Coloplast’s Global Privacy Notice

General

In the course of its global business Coloplast A/S, Holtedam 1, 3050 Humlebaek, Denmark and its affiliated companies and subsidiaries (“Coloplast”) is collecting and using personal information. For information on the Coloplast entity that is responsible for collecting and processing in your country please consult the contact details below (How to contact us?).

Coloplast’s collection and use of personal information covers information about Coloplast’s employees, customers, partners, health care professionals, end-users, job applicants, persons acting on behalf of any of the previous, and other persons that engage with Coloplast. Coloplast’s Global Privacy Notice applies to this collection and use of personal information in general, but Coloplast may make specific notices for certain collection and use. Coloplast complies with applicable data privacy law, including the EU General Data Protection Regulation (“GDPR”).

The purpose of this page is to give you – if you are a person Coloplast has information about – easily accessible information about Coloplast’s collection and use of your personal data. By clicking the topics below you will find more information about the different aspects of Coloplast’s handling of personal data:

Where is the information collected?
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Where is the information collected?

Coloplast may collect information about you from different sources.

  1. Information we collect from direct interaction with you (e.g. in meetings or phone calls)
  2. Information we collect when you visit our sites, exchange e-mails with us, use our online forms and services, or engage with us on social media and other platforms
  3. From other sources (e.g. hospitals and health care providers that request products for you)
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How do we process the information?
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How do we process the information?

Coloplast is processing personal information for a variety of purposes, depending on the nature of the relationship we have with you. For illustration see the following examples:

Type of relationship For what purpose(s) do we collect and use information about you? On what legal basis do we process this information? For how long do we keep this information? 
Contact persons with our customers and business partners (e.g. health care professionals)    To communicate and exchange products and services with our customers and partners. To comply with contractual obligations and to pursue our legitimate interest in communicating with customers and partners, cf. articles 6(1)(b) and (f) of GDPR. As long as we have an active relationship with the contact person. A relationship is deemed active for five years after the last interaction with the contact (e.g. calls, orders, e-mails, letters, events). Data about transactions is kept in accordance with applicable local law.
To maintain and improve our offerings. To pursue our legitimate interest in improving our services and offerings, cf. article 6(1)(f) of GDPR. As long as required pursuant to applicable quality and safety rules and requirements. Under the current EU medical device regulation we delete information about complaints and incidents 10 years after the product in question has ceased to be on the market (i.e. at least 10 years after Coloplast has ceased selling the product). For implantable devices the period is 15 years.
To comply with quality and safety requirements (in case of reported incidents). To comply with legal obligations and ensure high standards of product quality and safety, cf. articles 6(1)(c) and 9(2)(i) of GDPR. Data about transactions is kept for documentation purposes in accordance with applicable local law, e.g. law within the field of bookkeeping, tax or limitation of actions. Data regarding health information will be processed as long as consent from the user applies. Users will be asked to re-consent periodically (typically with 3-5 year intervals). Data will be deleted if a user withdraws consent or does not re-consent upon request.
Users of our products    To deliver products and services To comply with contractual obligations and on basis of consent, cf. articles 6(1)(a), 6(1)(b) and 9(2)(a) of GDPR. Data about transactions is kept for documentation purposes in accordance with applicable local law, e.g. law within the field of bookkeeping, tax or limitation of actions. Data regarding health information will be processed as long as consent from the user applies. Users will be asked to re-consent periodically (typically with 3-5 year intervals). Data will be deleted if a user withdraws consent or does not re-consent upon request.
To provide support and customer programmes To comply with contractual obligations and on basis of consent, cf. articles 6(1)(a), 6(1)(b) and 9(2)(a) of GDPR. As long as consent from the user applies. Users will be asked to re-consent periodically (typically with 3-5 year intervals). Data will be deleted if a user withdraws consent or does not re-consent upon request.

To maintain and improve our offerings.

On basis of consent, cf. articles 6(1)(a) and 9(2)(a) of GDPR.  As long as consent from the user applies. Users will be asked to re-consent periodically (typically with 3-5 year intervals). Data will be deleted if a user withdraws consent or does not re-consent upon request. 
To maintain and improve our offerings. To comply with legal obligations and ensure high standards of product quality and safety, cf. articles 6(1)(c) and 9(2)(i) of GDPR. As long as required pursuant to applicable quality and safety rules and requirements. Under the current EU medical device regulation we delete information about complaints and incidents 10 years after the product in question has ceased to be on the market (i.e. at least 10 years after Coloplast has ceased selling the product). For implantable devices the period is 15 years.
Job applicants    

To handle job applications.

To evaluate the application and if relevant take additional steps to make an employment contract, cf. article 6(1)(b) of GDPR. For details please see our recruitment privacy notice.  
To maintain and improve our recruiting processes. To pursue our legitimate interest in improving our recruitment processes, cf. article 6(1)(f) of GDPR.
To communicate about future job offerings. On basis of consent from applicants that have signed up for information on future job offerings, cf. article 6(1)(a) of GDPR.
Recipients of newsletters and marketing materials  To deliver newsletters and marketing materials (brochures etc.). To comply with contractual obligations and to pursue our legitimate interest in communicating with recipients, cf. articles 6(1)(b) and (f) of GDPR – and where consent is obtained for sending newsletters – article 6(1)(a) of GDPR. As long as the recipient is enrolled to receive materials. Data will be deleted if a recipient unsubscribes. 
To maintain and improve our offerings. To pursue our legitimate interest in improving our services and offerings, cf. article 6(1)(f) of GDPR.
Visitors on social media platforms To market Coloplast’s products and services and to communicate with actual and potential customers. This includes tracking and analyzing traffic on our social media sites (statistics cookies) and providing
tailored and targeted advertising (marketing cookies).
On basis of consent for your use of the social media platform in question and to the placement of cookies, cf. article 6(1)(a) of GDPR, and to pursue our legitimate interest in improving our services and offerings, cf. article 6(1)(f) of GDPR. Posts, comments or likes on our social media platforms will be deleted if you decide to delete them from your profile.  Statistical data do not contain personal information. However, you are free to delete cookies on your device, including statistics and marketing cookies, which means that we will no longer collect data through the said cookies. For further information about cookie retention and guidance on how to delete cookies, please refer to our cookie policy available here. For further information about the social media platforms processing of your personal data, please refer to the social medias’ privacy notices.
Visitors on websites     To enable website functionality (necessary cookies). On basis of consent for cookies from website visitors, cf. article 6(1)(a) of GDPR and to pursue our legitimate interest in improving our services and offerings, cf. article 6(1)(f) of GDPR. See consent options and details in the cookie declaration.     

See details for each type of cookie in the cookie declaration.

   
To allow use of visitor preferences (preference cookies)
To track and analyze traffic on websites and social media sites (statistics cookies).
To provide tailored and targeted advertising (marketing cookies).

 

In case you wish to request our provision of services, products, newsletters and other materials or apply for a job we need certain personal information to handle your request. You are not obligated to provide the information, but we cannot handle your request if you refrain.

Coloplast protects your personal information and will only allow it to be used for the mentioned purposes. Coloplast will not sell your personal information to third parties or in similar ways send it to third parties for their exploitation. Coloplast does not make use of automated decision-making, such as profiling, that will affect you as a person.

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Who is handling the information?
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Who is handling the information?

Coloplast is responsible for handling your personal information for the specific purposes mentioned above. All personal information is handled on a need to know basis only. In some cases the information is stored or handled by third party processors that assist Coloplast with a specific service, such as hosting and IT service providers, and recruitment firms (in case of job applicants). The third party processors will only process the information in accordance with Coloplast’s instructions and for Coloplast’s purposes. They will not share the information with others, and they will delete the information when their tasks are completed. 

We may disclose your personal data to third party controllers in order to fulfill our legal or contractual obligations. This includes the transfer of information to:

  1. logistics firms when information is needed to distribute products ,
  2. local authorities when reimbursement, fees, sponsorships or grants (e.g. to health care professionals) must be reported
  3. payers (hospitals, insurers, public bodies and similar parties paying for health care) when information is required by the payer to cover the costs of health treatment

If public authorities request access to your information we make a legal assessment of the request, and if applicable law requires us to disclose the information, we will comply with the request. You will be notified in accordance with applicable law in the event of any such disclosure of your information.

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How is transfer of information handled securely?
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How is transfer of information handled securely?

Coloplast and its hosting providers maintain servers around the world and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. An adequate level of protection is ensured by use of the standard contractual clauses on data protection adopted by the EU or to an EU-approved certification mechanism on data protection where required. For further information about this please consult Coloplast’s Data Protection Officer (details below).

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What are your rights?
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What are your rights?

Under GDPR you have the following rights in respect of the data we process about you:

• Right to access

You are entitled to get access to the data we are processing about you.

Right to rectify

You are entitled to have rectified any inaccurate data we are processing about you.

• Right to erasure

In certain situations you are entitled to have your data deleted before the general time for deletion according to our retention rules.

• Right to restrict processing

In certain situations you are entitled to restrict our processing of your data. In such cases we are only entitled – apart from storage – to process such data for handling legal claims, to protect the rights of another natural person, or for reasons of important public interest.

• Right to withdraw consent

In certain situations, Coloplast may be collecting and using your personal information on basis of your explicit consent. If this is the case, you will have received a specific written notice from Coloplast that will contain further details. You are entitled to withdraw any such consent at any time, and Coloplast will then cease to use such personal information.

• Right to object

In certain situations you are entitled to object to our processing of your data.

• Right to data portability

In certain situations you are entitled to receive your data in a structured, commonly used format and have it transferred to a third party on your request.

If you want to exercise any of these rights please send an e-mail to privacyrequests@coloplast.com. For other queries or questions related to our use of your data please refer to the How to contact us section below.

In the event you are dissatisfied with our processing of your personal information you may file complaints to Coloplast’s Data Protection Officer. You are also entitled to file complaints with the relevant supervisory authority. In Denmark the relevant authority is the Danish Data Protection Agency. You can read more on the official website where you can also access the guideline on subject rights. You can access a complete list of European supervisory authorities here.

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Social medias
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Social medias

Coloplast and the individual social media are joint data controllers in the processing of your personal data. Coloplast complies with the guidelines of the European supervisory authorities concerning joint controllership and Coloplast attempts to ensure that you receive information on the processing of your personal information when you visit our sites on the social medias. This notice is a supplement to the general privacy policy issued by the social medias individually. Both Facebook and LinkedIn have published an addendum on the joint controllership which you may go to by clicking here (Facebook or LinkedIn).  

How do we process your personal data through social medias?

Coloplast uses your personal data such as behavior (e.g. based on your likes, comments or visits) or other information available on the social medias to develop, improve and protect our products and services and to perform research activities and statistics. Coloplast processes your personal data on the basis of our legitimate interest in being able to improve our products and services, cf. article 6(1)(f) of GDPR.

The social medias collect statistical data on the visitors behavior for their own purposes through cookies and pixels on your device when you visit the sites. Each cookie contains a unique identification code which remains active for a certain period, unless it is deleted prior to expiry of such period. You can read more about the social medias processing of personal data by visiting their privacy policies (Facebook or LinkedIn) and cookie policies (Facebook or LinkedIn).

How do we share your personal data?

Coloplast will at no point disclose your personal data collected via social medias to third parties.

The social medias may share your personal data internally among its subsidiaries and externally among its partners using analytical services, advertisers, other individuals, surveying partners and researchers and academics. Such transfers may include transfers to countries outside EU. For more information, please refer to the social medias’ terms and conditions and privacy policies linked to above.

How do I use my rights towards the social medias?

The social medias general set-up dictate that you must contact the social media in question if you wish to exercise your rights. This is owing to the fact that only the social medias are, in pure functional terms, capable of taking the steps necessary to comply with most of your requests. If, however, you are of the opinion that Coloplast is capable of complying with your request, please do not hesitate to contact us.

If you are a Facebook user, you may exercise your rights by changing your private settings (link) or configure your preferences (link) in order to have an influence on how your personal data will be collected and processed when you visit and use the Facebook Site. If you are a LinkedIn user, click here (link) to change your settings or here (link) to exercise your rights.  

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How to contact us?
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How to contact us?

The Coloplast companies that use your information are data controllers. Click here to find contact details for the Coloplast companies in the different countries. Coloplast A/S acts as representative for any Coloplast companies that are required to appoint a representative pursuant to article 27 of GDPR.

Coloplast has appointed a group Data Protection Officer. Inquires to the Data Protection Officer may be directed to:

E-mail: dataprotectionoffice@coloplast.com

Coloplast A/S

Holtedam 1, 3050 Humlebaek

Denmark

Attn: Data Protection Officer

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Updates and legal information
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Updates and legal information

Coloplast reserves the right to make changes to this privacy notice. These changes will take effect immediately upon posting. For your convenience, the last revised date of the current notice will be posted at the bottom of this page.

This privacy notice shall, save for mandatory local law, be governed and construed in accordance with the laws of Denmark and be subject to the jurisdiction of the courts of Denmark.

Version: 12 Febuary 2021

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