Privacy and Cookie Notice
This Privacy and Cookie Notice (‘the Notice’) applies to personal data obtained via our website https://phceu.phcbi.phchd.com/or in the context of establishing and maintaining business relationship with you.
The website is hosted by PHC Europe B.V., whose parent company is PHC Holdings Corporation, with registered address at 15F DAI-ICHI LIFE HIBIYA FIRST 1-13-2 Yurakucho, Chiyoda-ku, Tokyo 100-8403, Japan. For the purpose of this Notice, the controller of the personal data processed remains PHC Europe B.V. with the registered address at Eikdonk 1, 4825 AZ Breda, Netherlands (‘we’ and ‘us’).
1. The aim of this Policy
The aim of this Notice is to explain which categories of personal data we collect, for what purpose and to outline how we handle such data.
2. The categories of personal data subject to processing
The categories of personal data depend on the source and can include the following:
1.1. Personal data provided to us directly by you;
1.2. Personal data provided to us by our business partners (e.g. distributors);
1.3. Data obtained from publicly available sources (e.g. public records, online publications), including references to such information received via reputable service providers (e.g. providers of credit risk and due diligence solutions);
1.4. Data related to your online visit, stored and retrieved in the form of cookies.
2.1 Personal data provided to us directly by you
Personal data belonging to this category may be provided to us at a trade fair, a conference, a seminar or similar event; via our website or per e-mail.
Our website offers you the opportunity to submit an inquiry about our products and services or share feedback; to request a quote; to subscribe to our newsletter, to register for a webinar or a training course; to complete an online questionnaire or a customer survey etc.
Depending on the type of online communication, this personal data may include:
your name;
title;
your contact details (e.g. e-mail address, phone number);
the name of the organisation you represent and its location;
if you apply for a job at PHC EU.
We process your personal data, to enable us to perform the contract entered into between you and us and for our legitimate business interests including for statistical purposes:
This data may be used to process your requests for a product or service; respond to your inquiries, including for customer services support; deliver relevant content and recommendations or to enable you to comment on the quality of products and services provided. It may also be used to send you some marketing communications relating to our business, which we think may be of interest to you as well as messages containing company news, product or service information. We may also use this data for research regarding the effectiveness of our online channels of communication and related marketing, advertising and sales efforts.
For our legitimate business purposes relating to direct marketing, and where required, on the basis of your consent, we may process also your personal data:
to invite you to participate in surveys or opinion groups or other promotional and marketing activities concerning our products and services, including in conjunction with selected third party partners; and
to measure and understand the effectiveness of advertising we may serve and to deliver relevant advertising.
2.2 Personal data provided to us (with your permission) by our business partners (e.g. distributors) may include:
your name;
your title;
your contact details (e.g. e-mail address, phone number);
area of expertise (e.g. department that you belong to or research project you are involved in);
the name of the organisation you represent and its location.
This information will be used for the following purposes:
compliance with applicable local legal and regulatory requirements, e.g. to ensure effective response where corrective measures are required;as necessary if we need to issue a safety notice or corrective action related to any of our products or services:
to report events to governmental or regulatory authorities that are responsible for medical devices;
management of customers’ feedback (including complaints) related to quality and performance of our products;
training and product management support, insofar as such training and support are required;
compliance with trade controls (e.g. in the situations where a purchaser is expected to confirm the identity of the end-user and the intended mode of application of the products to be supplied).
2.3 Data obtained from publicly available sources
Personal data obtained via this channel may include:
Name;
Information relating to your career;
Numbers of shares held (where applicable);
Date of birth, the country of origin and other personal data that may appear on the official lists of parties subject to sanctions or restrictions from time to time;
References to relevant publications and announcements (including negative publicity, where applicable).
We use publicly available sources (e.g. business registers, online publications) as well as services of some reputable providers of credit risk and due diligence solutions to:
manage our existing and prospective business partner relationships and associated business risks;
comply with applicable legal obligations, industry standards and corporate policies related, e.g. to prevent and detect money-laundering activities, prevent bribery and modern-day slavery, trade controls etc.;
carry out research and analyses aimed at protection and improvement of our business.
2.4 Data related to your online visit stored and retrieved in the form of cookies
When you use our website, we will automatically receive technical information, including:
the name of your internet service provider;
the website that you used to link to our website;
the websites that you visit from our website;
the type of device you use, a unique device identifier (such as your device IMEI number, MAC address of the device’s wireless network interface, or the mobile phone number used by the device, mobile network information);
your operating system; and
software version number, IP address, the type of browser you use, the country and language code and time zone setting.
3. Marketing
We may contact you to tell you about products and services that we feel may be of interest to you or that are similar to those that you have already purchased or enquired about.
You may be contacted by us, PHC EU, by a distributor of PHC EU products, or by one of our selected partners, in each case where you have consented to receive these communications.
You may opt out of receiving our marketing communications at any time by contacting us at marketing@eu.phchd.com or by using the unsubscribe link in any of our communications.
We will continue to contact you for non-marketing related purposes where we need to issue a field corrective or safety notice, or to where we need to send certain information to you under a legal, regulatory, or ethical requirement.
4. Sharing your Personal Data
We do not rent or sell your personal data to anyone. We do not disclose personal data of our website visitors outside the PHC Group of companies unless for the following reasons:
our selected partners where you have chosen to participate in surveys, opinion groups or other marketing-related initiatives relating to your use of our products and services;
a prospective seller or buyer in the event of a sale or purchase of our business or asset so that the buyer can continue to provide you with information and services;
we also share your personal data with data processors that we engage to provide services for us. Where we provide your personal data to data processors, they are required to keep your personal data confidential and secure, and must only use your personal data as instructed by us (e.g. supply of products; rendering of technical services; maintenance of the corporate IT infrastructure etc.). This is subject to the condition that the companies in question are under a contractual obligation to protect personal data entrusted to them and not use it for any other purposes than those specified in this Notice; and
our distributors, business partners, or service providers, including for marketing purposes or where you have chosen to share your personal data through features and functionality provided via our website.
If you ask us for a price quote, we may share your contact details with all of the distributors operating in your country to give you the opportunity to compare sales prices and get the best possible deal. However, you have the possibility to expand or restrict the list of the recipients of your inquiry among the distributors manually.
For product-related inquiries the geographical location of the inquirer usually determines which parties handle your inquiry. Inquiries received from the Netherlands, UK, Germany, France or Italy may be handled by our colleagues directly or be forwarded to one of our distributors, depending on the circumstances and the nature of the inquiry.
We may also disclose your personal data where required to respond to authorized requests from government authorities or where required by law, including for national security. Where we are required by law, we may also disclose your personal data where it is necessary to enforce or apply our Website Terms of Use, this Notice or other agreements, to investigate or protect the rights, property or safety of PHC EU and our group companies, our products and services and our customers, distributors or business partners or to prevent or take action regarding illegal activities or fraud, situations involving potential threats to the safety of any person or as evidence in litigation. Your personal data may be subject to foreign laws and may be accessible by foreign governments, courts, law enforcement and regulatory agencies.
If you ask us for a price quote, we may share your contact details with all of the distributors operating in your country to give you the opportunity to compare sales prices and get the best possible deal. However, you have the possibility to expand or restrict the list of the recipients of your inquiry among the distributors manually.
Your inquiry will be registered in our CRM system.
5.Transfer of your personal data outside the EEA
Please note that if you are based in any of the countries belonging to the European Economic Area (‘EEA’), your personal data will be stored on servers located within the European Union (‘EU’). Transfer of your personal data to our representatives or affiliates located in third countries outside the EU will only take place where
based on the decision of the European Commission, the third country in question ensures an adequate level of protection of personal data; or
appropriate safeguards have been provided in accordance with applicable laws.
6. Retention periods
PHC EU will store your information for as long as we have to by law, and where there is no legal requirement, we will only store it for as long as necessary to fulfil the purposes for which it was collected as described in this Notice.
To determine the appropriate period for storing personal data, we take into account the personal data in question; its nature and sensitivity; the purpose of processing; the potential risk of harm in the case of a data breach; and the applicable legal requirements. If your personal data have been used for the purpose of establishing and maintaining a business relationship, such data will be stored until such relationship lasts plus a retention period stipulated by applicable commercial and tax laws. In your own interest, we will keep a permanent record of your request (including a minimum amount of your personal details) in a designated database.
7. Keeping your Personal Data Secure
In order to protect your privacy, we
implement and maintain appropriate administrative, technical and physical measures to prevent unauthorized disclosure, use, modification or destruction of the personal data in our possession;
conduct regular training seminars on key principles of the protection of personal data for the relevant members of the staff;
regularly review the established policies and procedures, including those related to reporting of information security breaches, to ensure a swift and adequate response.
8. Data related to your online visit stored and retrieved in the form of cookies
Our website tracking program collects aggregate information about the number of visitors, types of browsers used, Internet Service Providers used, visit times and length, pages visit, referring pages and exit pages (commonly known as log files). This information helps us measure popularity, traffic, and effectiveness of various areas of this website and helps us to offer our visitors a better browsing experience.
8.1 What are cookies?
Cookies are small pieces of data generated by a website you visit and stored on your computer or mobile device if the browser's settings allow it.
We use the following cookies on our website:
Strictly necessary cookies: Required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, to move around the website and to use its features
Analytical/performance cookies: Allowing PHC EU to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies: These recognise you when you return to our website. This enables us to personalise our content for you, for example, your choice of language or region.
Marketing cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
We use cookies and similar technologies for the following purposes:
to improve our website security;
to identify you when you sign-in to our website and remember your preferences;
to analyse how you use our Website by tracking specific actions on our website;
to collect anonymous statistical information on how visitors use our website so that we can make improvements to its usability and to improve content delivery value;
to allow you to share pages with social networks like Twitter, Facebook and LinkedIn;
to allow you to participate in interactive features of our website, when you choose to do so;
to determine the effectiveness of our online campaigns in terms of both sales and user activity on our website;
to optimize our advertising by ensuring we can deliver on other websites advertising to those who visit our website;
to allow us to assess the success of our advertising by identifying events (such as registrations, checkouts, etc.) on our website which happened as a direct result of our advertising; and
to make sure our advertising on other websites is relevant to you.
We also use cookies and similar technologies provided by other companies to collect web traffic information such as time, date, IP address, and browser, so that we can store your preferences and other information on your device and save you time on subsequent visits by eliminating the need to repeatedly enter the same information. In most circumstances the information captured cannot identify you as an individual. This data could possibly lead to your identification, but we do not use it to do so.
Facebook Pixel: In some countries we use Facebook Pixel to show you useful and relevant ads and to optimize our advertising. You can control how we use data to show you ads by using the tools described below.
If you have a Facebook Account: You can use your Facebook ad preferences to learn why you are seeing a particular ad and control how we use the information we collect to show you ads. To show you better ads, Facebook uses data that we and other partners provide Facebook about your activity off Facebook company products, including websites and apps. You can control whether Facebook uses this data to show you ads in your Facebook ad settings.
If you do not have a Facebook Account: You can opt out of seeing online interest-based ads from Facebook and other participating companies through the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Interactive Digital Advertising Alliance in Europe or through your mobile device settings. Please note ad blockers and tools that restrict our cookie use may interfere with these controls.
Browser cookie controls: In addition, your browser or device may offer settings that allow you to choose whether browser cookies are set and to delete them. For more information about these controls, visit your browser or device’s help material. Certain parts of our website may not work properly if you have disabled browser cookie use.
Matomo: In order for us to provide you with the best possible experience on our website, we need to collect and process certain information. Depending on your use of the Services, this may include:
When you contact us by email/form. For example, if you want to ask for support, send us questions or comments, or report a problem, we collect your name, email address, message, etc. We use this data exclusively in connection with answering the inquiries we receive.
Usage Data – when you visit our website, we store: the website from which you visited us, the parts of our website you visit, the date and duration of your visit, your anonymised IP address, information from the device (device type, operating system, screen resolution, language, country you are in, and type of web browser) you during your visit, and more. We process this usage data in Matomo Analytics for statistical purposes in order to improve our site and to detect and prevent any misuse.
Cookies – We use cookies (small data files that are transferred from websites to computers or devices) for record-keeping purposes and to improve the functionality of our website. You can enable or restrict the transmission of cookies by changing the settings of your web browser. Cookies that have already been stored can be deleted at any time.
The processing of personal data with Matomo is based on explicit consent. We do not process any personal data with Matomo unless you give us unambiguous explicit consent.
Google Ads Conversion Tracking: We use Google Ads conversion tracking to track actions that people take on our website after clicking on one of our online ads. For example, with Google Ads conversion tracking set up, we can see which one of our Google Ads advertisements generates the most interactions on our websites.
To disable Google Ads conversion tracking, toggle off the ”Marketing Cookies” in the Cookie Preference Centre that can be found on our website.
Opting out: You may refuse to accept cookies by altering the settings on your internet browser (for example Internet Explorer, Chrome and Firefox). Please note that if you choose not to permit cookies some areas of our website may not function properly or be accessible.
In general, by consulting the help menu item in your internet browser, instructions on how to disable or delete cookies is available. Most browsers are set-up to accept these cookies automatically. In addition, you can deactivate the storing of cookies or adjust your browser to inform you before the cookie is stored on your computer. You may also use self-regulation programs available in your jurisdiction to manage the way that companies other than Google advertise to you, such as the EU-based Your Online Choices.
We also analyse how users interact with the website without using cookies. You may still ask us not to aggregate and analyse the actions you take on the website. Although this will prevent us from learning from your interactions with the site, and creating a better experience for you and other users.
9. Your rights
If you are a resident of the EEA, you have the following rights:
the right to be informed as to whether your personal data is being processed by us;
the purposes of the processing, the categories of the processed data being processed and the recipients to whom the data has been disclosed;
the right to rectify, complete, update, block or delete personal data that is inaccurate, incomplete, or expired;
the right to object to us processing your personal data;
the right to receive any personal data we hold about you in a structured and commonly used machine-readable format and / or have it transmitted to another company.
Before complying with any of your requests listed above, we may have to confirm your identity for security reasons.
To exercise any of your rights in connection with your personal data, please contact PHC EU by email at dp_office@phchd.com or by post to PHC EU of Eidonk 1, 4825 AZ Breda, the Netherlands. If you are located in the EEA, you have the right to lodge a complaint about how we process your personal data with the supervisory authority in your country, including in the Netherlands the Dutch Data Protection Authority (de Autoriteit Persoonsgegevens).
10. How to contact us
Questions, and requests regarding this Notice should be addressed to the Data Protection Officer at dp_office@phchd.com or to PHC EU Eikdonk 1, 4825 AZ Breda, the Netherlands. If you contact us, we will do our utmost to address any concerns you may have about our processing of your personal data.
11. Updates to this Notice
Any changes we make to our Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Notice.