EIRMED PRIVACY POLICY

Effective Date/Date of Last Revision: March 24, 2022

  1. WHO WE ARE.
  2. HOW TO CONTACT US.
  3. WHY AND HOW WE COLLECT DATA.
  4. PROTECTING YOUR PRIVACY GENERALLY.
  5. CHILDREN’S PRIVACY.
  6. TYPES OF INFORMATION WE COLLECT.
  7. HOW WE USE YOUR PERSONAL DATA.
  8. INFORMATION WE SHARE WITH THIRD PARTIES.
  9. HOW TO ACCESS & CONTROL YOUR PERSONAL DATA.
  10. SECURITY.
  11. LINKS TO THIRD-PARTY SITES.
  12. SOCIAL MEDIA PLATFORMS.
  13. DATA RETENTION.
  14. ACCESSIBILITY.
  15. NOTICE TO NEVADA RESIDENTS.
  16. NOTICE TO CALIFORNIA RESIDENTS.
  17. NOTICE TO RESIDENTS OF THE EUROPEAN ECONOMIC AREA.

1. WHO WE ARE.

EirMed, LLC (“EirMed,” we,” “our” or “us”) is a leader in the design, engineering, manufacturing, assembly and packaging of medical devices.  EirMed provides information regarding medical devices through its white papers, blog, podcast and website at https://eirmed-devices.com  (“Site”).  EirMed provides a variety of services and information to our customers, prospective customers and website users (“Services”).  When operating our business and providing our Site and Services, we collect data from our customers, prospective customers and web site users.  

Some of the data we collect may be considered “personally identifiable information,” “personal information” or “personal data” under applicable law (collectively referred to in this Privacy Policy as “Personal Data”).  Generally, Personal Data is information that can be reasonably connected to an identified or identifiable individual.  It does not include deidentified or anonymized data.

The purpose of this Privacy Policy is to plainly and transparently disclose to you how we collect, use and share information, and how we attempt to safeguard the data you provide to us.  We are committed to securing data that we collect concerning you (“you”) and complying with applicable data protection and privacy laws.

2. HOW TO CONTACT US.

If you have any questions regarding data protection or your rights, please contact us:
EirMed
5120 Eagle Point Road
Menominie, WI 54751
715.235.1834
privacy@eirmed-devices.com

3. WHY AND HOW WE COLLECT DATA.

We collect, process and use Personal Data to allow you to utilize the functionality and features we provide on our Site, to provide you with products and Services, and to communicate with you. The legal basis for our collection of Personal Data is with your consent, for our legitimate business purposes and/or to comply with our legal and contractual obligations.  We obtain Personal Data directly from you, through cookies and other technologies, and from third parties as described in this Policy and any other privacy notices we may provide to you when you interact with us.

  • Information from you.  You provide data directly to us when you directly submit information to us, such as when you send us information through our contact form, request a quote or add comments to our blog posts or other content.    
  • Cookies & Technology.  We collect data by automatically recording how you interact with our website and applications using technologies like cookies. More information on cookies is provided below.
  • Information from our service providers.  For example, we may obtain information from our payment card vendors, shipping and fulfillment companies and resellers regarding your transactions.

4. PROTECTING YOUR PRIVACY GENERALLY.

  • Industry-Standard Protection. We utilize industry-standard security measures to safeguard the information we collect, maintain and use. These measures include technical and procedural steps to protect your data from misuse, unauthorized access or disclosure, loss, alteration or destruction. However, we do not guarantee the performance or adequacy of such security measures.
  • Limitation on Access.  Access to any Personal Data we collect and store is generally restricted to our employees and/or contractors who require it to perform a job or other contracted function. We require vendors and contractors we work with to use reasonable, industry standard protocols to maintain the confidentiality, security, and integrity of Personal Data. 
  • Payment & Distribution.  We currently do not collect payment card information or process payment cards.  We utilize a third-party vendor to process payments.

5. CHILDREN’S PRIVACY.

We do not intentionally collect any Personal Data from children under the age of sixteen (16).  We do not sell the Personal Data of children under the age of sixteen (16).

6. TYPES OF INFORMATION WE COLLECT.  

a. Information we collect from you.  We collect the following categories of Personal Data:

  • Contact information (first and last name, telephone number, electronic mail address, company name, phone number, billing address and shipping address).
  • Your inquiry information.
  • Any files you upload with quote requests or other contact forms.
  • Your order, return and warranty transactional information.
  • Any other information you provide to us.

b. Information We Collect Via Tracking Technology.  We use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”) to collect information as you navigate our websites.  Cookies are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets). 

We use Cookies to: (a) estimate audience size and usage patterns; (b) understand and save your preferences for future visits, allowing us to customize the online experience to your individual needs; (c) advertise new content, events and services that relate to your interests; (d) keep track of advertisements and search engine results; (e) compile aggregate data about website traffic and website interactions to resolve issues and offer better online experiences and tools in the future; and (f) recognize when you return to our websites. 

The Cookies we use collect the following types of Personal Data:

  • Usage Information. We collect information such as which areas of the sites you access, the frequency of access, and what you click on while using the sites.
  • Technical Information.  We collect technical information about your connection to our sites, including the Internet protocol (IP) address, browser type and version, browser plug-in types and versions.
  • Device Information. We collect information about the device you are using, such as hardware model, operating system, application version number.
  • Mobile Device Information. In addition to the device information listed above, when you access our sites on your mobile device, we collect and aggregate information about whether you are accessing the sites via a mobile device or tablet, device type, and carrier.
  • Location Information. We collect location information from site visitors on a city-regional basis. 

We set some Cookies ourselves and others are set by service providers. We use Cookies set by service providers to provide us with useful information to help us improve our sites, to conduct advertising, and to analyze the effectiveness of advertising.  

Google Analytics

We may use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Sites and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.
c. How To Opt-Out of Cookies & Learn More.  Cookies can be blocked by changing your settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the sites.  You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org.  You can also learn about which third parties have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

7. HOW WE USE YOUR PERSONAL DATA.

We use the Personal Data we collect to: 

  • Communicate with you;
  • Provide you with information, newsletters and promotional offers;
  • Provide our products and Services;
  • Provide support;
  • Improve our products and Services;
  • Maintain, improve and customize our Site and Services;
  • Defend our legal rights and the rights of others;
  • Efficiently maintain our business; and
  • Comply with applicable law.

8. INFORMATION WE SHARE WITH THIRD PARTIES.

We do not sell personal data.  We may share the information that we collect about you in the following limited ways:

a. With Service Providers.  We may share information with service providers who:

  • perform data services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.); 
  • prepare, deploy and analyze advertising content on our behalf;
  • provide other services on our behalf, such as accounting services, and other various services; 
  • process payment information on our behalf; and
  • provide shipping and/or fulfillment services on our behalf.

b. To Meet Our Legal Requirements or Exercise Our Rights.  We may share information with third parties in the following instances:

  • When we are required to do so by law.
  • In connection with any legal proceedings or prospective legal proceedings.
  • To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention.
  • When we reasonably believe it is appropriate to apply to a court or other competent authority for disclosure of that Personal Data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal data.
  • We may share information with other persons or entities as part of our own corporate transactions, such as during financing or any asset sale.

9. HOW TO ACCESS & CONTROL YOUR PERSONAL DATA.

We respect your privacy and provide ways for you to choose whether to share your information with us or any third parties.  

You may decline to provide information.  You have the right to decide not to share information with us.

Request deletion.  You may submit a request to update or delete your personal data by contacting us at us at privacy@eirmed-devices.com or through our online contact form.

PLEASE NOTE, HOWEVER, THAT IF YOU CHOOSE NOT TO PROVIDE US WITH CERTAIN INFORMATION OR ASK US TO DELETE YOUR INFORMATION, WE MAY NOT BE ABLE TO PROVIDE YOU WITH SOME OF OUR SERVICES.  IN ADDITION, IN SOME CIRCUMSTANCES, WE MAY NOT BE ABLE TO MODIFY OR DELETE DATA DUE TO OUR OWN OBLIGATIONS.

Review and request changes to your personal data.  You may use your account to access, correct, or view certain personal data we have collected which is associated with your account.   You may also contact us at privacy@eirmed-devices.com or through our online contact form to request information or changes.  

Marketing communications. You can always choose whether you wish to receive communications we send via email, SMS messages, telephone calls and postal mail.  To do so, contact us at privacy@eirmed-devices.com or through our online contact form.

Control Cookies.  You can learn more about which entities have currently enabled cookies for your browser or mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

10. SECURITY.

We take industry standard security measures to protect your information. Unfortunately, the transmission of information via the internet is not completely secure.  Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to or through our Site; any transmission is at your own risk. 

11. LINKS TO THIRD-PARTY SITES.

Our Site may contain links to other websites that may be of interest to you.  If you click on any of those links, you will leave our Site.  We are not responsible for third-party websites.  Therefore, please consult the terms of service and privacy policies of those sites when you visit them.

12. SOCIAL MEDIA PLATFORMS.

Contacting us on one of our social media platforms or directing us to communicate with you via social media, via direct message or other social media tools, are governed by this privacy policy as well as the privacy policy of the social media platform you use. As used herein, the term “Site” includes our social media accounts.  Interacting with our Site via social media includes features that may collect information about you such as your IP address and which page you are visiting on our site. Social media features and widgets may be hosted by a third party. Your interactions with those features are governed by the privacy policies of those third-party providers.

13. DATA RETENTION.

We will store your Personal Data for as long as: (a) you maintain an account with us; (b) you continue using our Site and Services; (c) your Personal Data is stored in our back up servers and/or services; and (d) as long as we are legally required to retain the Personal Data.

14. ACCESSIBILITY.  

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities.  If you wish to access this Privacy Policy in an alternate format, or would like to report an issue you are experiencing on our Site or Services, please email us at privacy@eirmed-devices.com or through our online contact form.  You expressly agree to attempt to resolve any and all issues with accessibility directly with us and in good faith prior to instituting any legal action against us.

15. NOTICE TO NEVADA RESIDENTS.

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to privacy@eirmed-devices.com or through our online contact form.

16. NOTICE TO CALIFORNIA RESIDENTS.

THE CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this does not apply to you.
This Notice to California Residents (“Notice”) applies to “Consumers” as defined by the CCPA and is a supplement to the other sections of our Privacy Policy. This Notice covers our collection, use, disclosure, and sale of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA through our website, as well as through all other websites, applications, products, services and other offerings we provide.  The vast majority of the data we collect and process is not subject to CCPA consumer rights because the data we collect and process is: (a) business-to-business information; (b) employee or personnel information; and/or (c) publicly available information (as defined by the CCPA).

a. COLLECTION AND USE OF PERSONAL INFORMATION

As set forth in Section 6 above, we collect certain categories of Personal Information from individuals, including individuals who reside in California. We collect Personal Information described in Section 6 from California residents for the purposes set forth in Sections 3 and 7, and may have disclosed such data to the categories of recipients set forth in Section 8.

b. SOURCES OF PERSONAL INFORMATION

We receive Personal Information from the information that you and others provide, your device(s), and from our partners. The categories of sources from which we’ve collected or received Personal Information include:

  • You: We collect the content, communications, and other information you provide when you interact with us, our website and our social media accounts, including when you sign up for an account, and message or communicate with us.  We collect information about how you interact with our App, and the time, frequency, and duration of your activities.
  • Your device(s) and technology: We collect information from and about the computers, phones, connected TVs, and other web-connected devices you use that integrate with our Sites, and we may combine this information across different devices you use.
  • Partners & Service Providers: We may receive information about you from our affiliates, vendors and services providers who assist us in fulfilling orders, processing payments, and providing other services.  We may also share information with our affiliates and service providers as identified in Section 8.

c. YOUR RIGHTS.  Under the CCPA, you have the following rights:

Number Description of your right
Right 1 The right to know what personal information we collect about you.  
Right 2 The right to know whether we sell or disclose your personal information, and if so, to whom.
Right 3 The right to say no to the sale of personal information.
Right 4 The right to access your personal information.  
Right 5 The right to receive equal service and pricing from us, even if you exercise your privacy rights.

Right to Know: You have the right to request that we disclose to you the Personal Information we collected about you in the 12-month period preceding your request.  This right includes the right to request: (1) specific pieces of PI we have collected about you; (2) categories of PI we have collected about you; (3) categories of sources from which the PI was collected; (4) categories of PI that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom your PI was sold or disclosed for a business purpose; and (6) the business or commercial purpose for collecting or, if applicable, selling your PI.

Right to Request Deletion: You have the right to request that we delete your Personal Information that we have collected from you.  Note that if you request that we delete your information, we may be unable to provide you with certain programs or services, and you may become ineligible for some of our programs and services.

Right to Opt-Out of the Sale of Personal Information:  The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.  We do not sell personal information.

Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

How to Exercise Your Rights: To exercise your “right to know”, “right to opt-out of sale” or your “right to request deletion,” email us at [insert designated email address] or through our online contact form.

Please note that to protect your information, we may need additional information from you to verify your identity before processing your request. 

Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We reserve the right to request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.SHINE THE LIGHT LAW:  If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third-parties’ direct marketing purposes (as those terms are defined in that statute).  EirMed does not sell or disclose information to third parties for their direct marketing purposes. 

17. NOTICE TO RESIDENTS OF THE EUROPEAN ECONOMIC AREA.   

The General Data Protection Regulation (“GDPR”) applies to individuals located in the European Economic Area (“EEA”).  The GDPR allows us to collect and use personal information from individuals within the EEA only for one or more of the following reasons:

  1. To fulfill a contract we have with you;
  2. When we have a legal duty;
  3. When it is in our legitimate interest; or
  4. When you provide consent.

We do not operate in the EEA or direct our Site or Services to those in the EEA.  However, we recognize some of our website users, customers and prospective customers may be located within the EEA.  If you reside in the EEA, you have a number of rights under data protection laws in relation to the way we process your Personal Data.  To the extent the GDPR may apply to you, you have certain rights, which are set forth below.  You may contact us directly to exercise any of these rights, and we will respond to any request received from you within one month from the date of the request. In exceptional circumstances we may need to extend this timescale, but we will always tell you in advance if we do, and our reasons why.

Number Description of your right
Right 1 A right to access personal data held by us about you, as well as information about how we are using your data.
Right 2 A right to require us to rectify any inaccurate personal data held by us about you.
Right 3 A right to require us to erase personal data held by us about you, and where the personal data has been made public, for other controllers processing the personal data to also erase links to, or copy or replication of, such personal data.  This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below). 
Right 4 A right to restrict our processing of personal data held by us about you.  This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.  
Right 5 A right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format.  You also have the right to require us to transfer this personal data to another organization, at your request.
Right 6 A right to object to our processing of personal data held by us about you (including for the purposes of sending marketing materials to you).
Right 7 A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products). 

If you have any concerns regarding our processing of your personal data, or are not satisfied with our handling of any request by you in relation to your rights, please get in touch with our team through the contact information provided in Section 2 of this Privacy Policy.  You may also reach out to your applicable Data Protection Authority (“DPA”) for more information.  There is a DPA located in each EU Member State.