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Vintens Compression App Privacy Policy

PRIVACY POLICY VINTENS® COMPRESSION APP

Introduction

HARTMANN USA, Inc., 481 Lakeshore Parkway, Rock Hill, SC 29730 USA ("Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:

  • The types of information we may collect or that you may provide when you download, install, onboard on and access, or use the Vintens Compression APP (the "App").
  • Our practices for collecting, using, maintaining, protecting, and disclosing “personal information”, which means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked directly or indirectly, with a particular consumer or household.

    This policy applies only to information we collect in this App, and in email, text, and other electronic communications sent through or in connection with this App.

    This policy DOES NOT apply to information that:

  • We collect offline or on any other Company apps or websites, including websites you may access through this App.
  • You provide to or is collected by any third party, including other apps (see Third-Party Information Collection).

    Other third parties and apps may have their own privacy policies, which we encourage you to read before providing information on or through them. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, onboard on, or use this App. By downloading, onboarding on, or using this App, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this App after we revise this policy means you accept those changes, so please check the policy periodically for updates.

    Adults only

    The App is intended to be used by adults only. Therefore, we have instructed treating physicians or health care professionals to only provide the QR code for registering to the app to persons who are 18 years of age or older. Nevertheless, we would like to highlight again that you are not allowed to register to the App if you are under 18, and therefore do not download, install or use the App. If we learn we have collected or received information from or about a person under 18, we will delete that information. Since we never knowingly collect information from or about a person under 18, we do not knowingly transfer that information any other party under any circumstances, including transfers that would meet the definition of “sell” or “share” under California law. If you believe we might have any information from a person under 18, please contact us at:

    HARTMANN USA, Inc. 481 Lakeshore Parkway Rock Hill, SC 29730 USA or

    (toll-free) 1-800-243-2294 or

    https://www.hartmann.info/en-us/contact/report-product-complaint

    Information We Collect and How We Collect It

    We collect information from and about users of our App:

    Information You Provide to Us

    When you download, onboard, or use this App, we may ask you provide information:

  • By which you may be personally identified, such as:
    • information that you provide by filling in forms in the App (this includes information provided at the time of onboarding on the App and subsequently when answering questions to enable us to provide you with advice), such as
    • restriction of functions you send to us when requesting assistance with service and complaints;
  • your responses to surveys that we might ask you, especially to complete for research purposes or product improvement;
  • records and copies of your correspondence in connection with requests for assistance with our service and complaints, if you contact us;
  • ·or any other personal information that the app collects.

    Information We Collect Through Automatic Data Collection Technologies

    As you navigate through and interact with our App, including when you download, access, or use the App, we may use automatic data collection technologies to collect certain information about your internet connection, mobile device's unique mobile device identifier (Device ID), operating system and token within the QR code scan.

    If you do not want us to collect this information, do not download the App or delete it from your mobile device.

    Third-Party Information Collection

    When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your mobile device. These third parties [may] include:

  • Your mobile device manufacturer.
  • Your mobile service provider.

    These third parties may use tracking technologies to collect information about you when you use this app. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different apps and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

    But ultimately, we do 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.

    How We Use Your Information

    We use information that we collect about you or that you provide to us, including any personal information, to:

  • Provide you with the App and its contents, and any other information or services that you request from us.
  • Share surveys with you and subsequently evaluate them. If the surveys are not anonymous, we will obtain your consent beforehand. Consent is always voluntary.
  • Fulfill any other business or research purpose for which you provide it.
  • Carry out our obligations and enforce our rights arising from the business relationship with you.
  • Notify you when App updates are available, and of changes to the services we offer or provide though it.

    Disclosure of Your Information

    We may disclose aggregated information about our users, and information that does not identify any individual or mobile device, without restriction.

    In addition, we may disclose personal information that we collect or you provide:

  • To contractors, service providers (in particular PAUL HARTMANN AG in Germany to provide support in case of complaints and maintain the IT Infrastructure), and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To our affiliate HARTMANN EU in order to provide support.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

    We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce our rights arising from any contracts entered into between you and us, including the End User License Agreement Vintens Compression APP, and for billing and collection.
  • We may also transfer or assign personal information as a result of, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our COMPANY, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection. If we are involved in defending a legal claim, we may disclose personal information that is relevant to the claim to third parties as a result of, or in connection with, the associated legal proceedings.
  • oname and user name in the onboarding phase, whereby the information is only stored locally on your mobile device, or
    • information about risk factors (contains also health information), your age, your mobility level (including limitations), daily lifestyle habits, etc. you provide to us that enables us to provide you with advice in the App on how to use compression products or on how to tailor lifestyle habits to improve your (health) condition (advice phase), whereby the information is only stored locally on your mobile device;

Your Privacy Rights

You have the following rights regarding your personal information:

  • The Right to Know/Access. You can request the following information about how we have collected and used your personal information:

o the categories of personal information we collected;

o the categories of sources from which we collected personal information;

o the business or commercial purpose for collecting, selling, or sharing (as applicable) that personal information;

o the categories of third parties with whom we disclose personal information; and

o a copy of the personal information that we collected about you in a portable, readily usable and machine-readable format.

  • The Right to Correct. You can request that we correct inaccurate personal information that we maintain about you.
  • The Right to Delete. You can request that we delete the personal information we collected from you.
  • Right to Limit Processing of Sensitive Personal Information. You have the right to ask that we limit how we process your sensitive personal information, subject to exceptions.
  • The Right to Data Portability. You have the right to obtain your personal data in a portable, and to the extent technically feasible, readily useable format, which you can use to transmit your data to another entity.
  • The Right to Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment.
  • The Right to Appeal You may appeal our decision to your request regarding your personal information. To do so, please contact us in any of the ways list below. We respond to all appeal requests as soon as we reasonably can, and no later than legally required. Click here to review our appeals process.

If you direct us not to sell/share your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes. We reserve the right to confirm your identity to process your requests. This is a security measure to, for example, help ensure we do not disclose information to a person who is not entitled to receive it.

You may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

We try to respond to all legitimate requests within 30 days of your request. Occasionally it may take us longer than 30 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.

We note, however, that these rights, and rights listed elsewhere in this privacy policy, may not be absolute, and in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

How to Exercise These Rights

For the right of correction and deletion, you can review and change your personal information by logging into the App and using the relevant function.

If you delete the App, all personal information stored on the local storage place on your mobile device will be deleted at the same time.

Please see below for contact information to exercise the remaining rights.

Data Security

Basically, the personal information you provide is only stored locally on your mobile device, which means that the existing data security measures delivered by your mobile device manufacturer are crucial for appropriate protection of your personal Information.

Also, the safety and security of your information also depends on you. This includes closing the App after opening it or locking your mobile device when not in use.

We have implemented reasonable security features designed to protect personal information. While we try our best to safeguard personal information once we receive it, please understand that no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. When we engage service providers or vendors to process personal information, we take steps to ensure that they do so securely, in accordance with our instructions and under appropriate contract terms that we have in place with them.

Retention

Personal information you provide in the App is only stored locally on your mobile device, which means that the existing data retention policies are controlled by your mobile device manufacturer. When you delete your profile or the App all information is deleted.

Personal information you provide for requesting services or within surveys are deleted immediately after request is completed or surveys are evaluated, unless longer retention periods are required in particular by applicable laws or regulations.

We may retain personal information collected through automatic data technologies for as long as necessary for the purposes for which the information was first collected and any other business purpose, including, but not limited to, legal, archival, accounting, and/or audit purposes.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users' personal information, it is our policy to notify you through a notice on the App's home page.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

HARTMANN USA, Inc. 481 Lakeshore Parkway Rock Hill, SC 29730 USA or

(toll-free) 1-800-243-2294

To register a complaint or concern, please use this link

ADDITIONAL NOTICE TO RESIDENTS OF THE UNITED STATES

This Section provides additional information required by the laws of certain states in the United States, including but not limited to California and Colorado. Our collection of personal information has not changed during the last 12 months.

As explained in this Privacy Notice, we do not “sell” or “share” any personal information as those terms are defined under California privacy law. The following chart provides information about the categories of personal information we collect, how we collect it, why we collect it, with whom we share it, and how long we retain it.

Category

What we collect

How we collect it

Why we collect it

With whom we share it

How long we retain it

Identifiers

Name, user name, or other similar identifiers.

For more information please see the Personal Information We Collect section of the Privacy Policy.

Collected online or offline when you directly provide it to us, through your use of our services, or from third parties.

We collect this information for the purposes listed in the How We Use Your Information section of the Privacy Policy.

Shared with our business partners and service providers as described in the Disclosure of Your Information section above.

Personal information you provide is only stored locally on your mobile device, which means that the existing data retention policies are controlled by your mobile device manufacturer. When you delete your profile or the App all information is deleted.

Internet or other similar network activity

Internet connection, mobile device's unique mobile device identifier (Device ID), operating system, and token within the QR code scan.

For more information please see the Information We Collect and How We Collect It section of the Privacy Policy.

Collected online when you directly provide it to us, through your use of our services, or from third parties.

We collect this information for the purposes listed in the How We Use Your Information section of the Privacy Policy.

Shared with our affiliates, subsidiaries, partners, sponsors, vendors, and service providers as described in the Sharing Personal Information section above.

Personal information you provide is only stored locally on your mobile device, which means that the existing data retention policies are controlled by your mobile device manufacturer. When you delete your profile or the App all information is deleted.