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Privacy Policy

This statement includes information about:

 

Global Data Privacy Policy


Purpose

Kinetic Concepts, Inc. (“KCI”), is committed to protecting the Personal Data entrusted to it by persons or organizations, under normal business operations.

KCI acknowledges its duty to abide by laws, regulations and standards promulgated by organizations and legal entities to which it is subject, with respect to its business practices for securing Personal Data.

This Policy is intended to emphasize KCI’s principles and to provide guidance in all situations where Personal Data (as defined herein) is managed. It shall take precedence over any another KCI policy, standard, guideline or procedure that may conflict with this Policy, as they relate to matters set forth herein.

Scope

The scope of this Policy extends to all operations, and all to employees, contingent workers, contractors and agents, of KCI and its subsidiaries, regardless of location. It encompasses:

  • Personal Data used in managing KCI’s workforce, providing goods and services, conducting clinical and market research, and processing commercial transactions with customers, employees and suppliers
  • The management of Personal Data for as long as it is in KCI’s possession or control, including receipt or processing, collection, use, security, preservation, transfer, retrieval, storage and disposition

Assignment of Responsibility

All officers, directors, managers, employees, contingent workers, contractors and agents of KCI and its subsidiaries are responsible for understanding and complying with the provisions of this Policy and any and all related policies, procedures, standards and guidelines, as applicable to their respective job duties.

Definitions

“KCI” means, collectively, Kinetic Concepts, Inc. and all of its worldwide subsidiaries and affiliates including, but not limited to, KCI USA, Inc. and KCI International, Inc., and LifeCell Corp.

“Non-agent third parties” means any third party that processes Personal Data on behalf of and under the instruction of KCI.

“Personal Data” means any information or set of information that identifies or can reasonably be used to identify, distinguish or trace an individual’s identity, such as his or her name, government-issued number, biometric records, etc., alone, or when combined with other personal or identifying information which is linked or linkable to a specific individual, such as date and place of birth, mother’s maiden name, etc.

Personal Data does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal identification.

Policy Statements

  • KCI assumes responsibility for using any and all reasonable means to prevent Personal Data entrusted to it from being lost, misused, improperly managed, publicly displayed, or otherwise compromised, thereby placing the privacy of the individual at risk.
    As required by laws, statutes or governing principles, KCI will
    • Inform individuals about the purposes for which it collects and uses Personal Data about them,
    • Offer individuals the opportunity to choose whether or not Personal Data may be shared or used outside the expressed purpose for which it was originally collected,
    • Transfer Personal Data to non-agent third parties only where consistent with prior notice and consent of the individual or as required by law, and
    • Provide individuals reasonable access to and, if found to be in error the right to direct corrections or changes to, their Personal Data.
  • KCI will not transfer Personal Data in its possession or control to any agent who cannot demonstrate commitment to compliance with data privacy rules equivalent to those described in this Policy.
  • It is KCI’s intention to avoid collecting more Personal Data than is required to effectively conduct business and comply with the law.
  • Personal Data that comprises all or part of a “Record,” as defined in the KCI Corporate Records Policy and Procedures, shall be managed and disposed of in accordance with that policy and its related schedules and procedures.
  • Personal Data contained within documents that are not “Records” is considered transitory information, and must be securely disposed of when no longer needed, except in the case of duty to preserve information relevant to a legal proceeding, audit or investigation.
  • KCI will employ technical and procedural measures to protect Personal Data, ensuring appropriate levels of security and restrictions to access, to Personal Data it manages.
  • Notwithstanding anything to the contrary herein, KCI’s commitment to this Policy may be suspended as necessary to meet legal, governmental, national security or public interest obligations from time to time

Related Documents

KCI’s published policies and procedures, located on the KCI Central Website, relating to specific areas of Data Privacy Compliance such as KCI HIPAA Privacy Policies and Procedures, KCI Safe Harbor Policy, KCI Identity Theft Policy, KCI Records Retention Policy, and KCI Global IT Compliance & Risk Management Policies include additional guidance for handling Personal Information. Where these policies impose more specific or detailed responsibilities upon KCI, such responsibilities remain intact.

Violations

Any instance of non-compliance with this Policy or with any supporting procedures, standards and guidelines may constitute a violation, the consequences of which may include disciplinary action, up to and including termination, and/or civil and criminal penalties.

A KCI team member who observes or suspects a violation of this Policy should promptly report the matter to the KCI Compliance Department, the KCI Legal Department, or by calling the KCI AlertLine.

KCI prohibits retaliation against any individual who makes a good faith report of a compliance issue.

If you have any questions regarding Data Privacy, please contact us at privacy.office@acelity.com

 

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KCI Web site Privacy Policy

This Privacy Policy is currently being reviewed and updated based on the new EU General Data Protection Regulation.

Privacy is very important to KCI. We also understand that privacy is very important to you. This Privacy Policy tells you how we protect and use information we gather through this KCI Web site based in tSingapore. Some KCI affiliates and subsidiaries (as defined in the Terms of Use) operate other Web sites. This Privacy Policy does not apply to other KCI Web sites. You should review the privacy policy posted on other KCI Web sites when you visit them. This Privacy Policy and Web site are intended for a United States audience.

By using this site, you agree to the terms of this Privacy Policy. Whenever you submit information via this site, you consent to the collection, use and disclosure of that information in accordance with this Privacy Policy. You may be subject to additional terms that may apply when you access particular services or materials on certain areas in this Web site, or by following a link from this Web site.

This site is not intended for children under the age of 13. KCI will not knowingly collect personally identifiable information via this site from visitors in this age group. Parents are encouraged to talk with their children about the use of the Internet and the information they disclose to Internet sites. Please contact KCI if you think we may have collected information from a child in this age group.

As you use this site, certain anonymous, non-personal information can be passively collected (collected without you actively providing the information) using technologies such as, but not limited to, “cookies”, “Internet tags”, “Internet Protocol Addresses (IP)”, “Web beacons” and “Navigational data” collection methods. Non-personal information may include, but is not limited to, the following:

  • the type of web browser software you use (for example, Netscape Navigator or Internet Explorer)
  • the name of the domain from which you access the Internet
  • the Internet address of the Web site from which you linked directly to our Web site
  • the date and time you access our Web site
  • the search terms you use
  • the links on which you click
  • personal information that has been made non-personal or anonymised (i.e., information that no longer reflects or references an individually identifiable user)
     

Your Internet browser automatically transmits to this site some of this information, such as the URL of the Web site you just accessed prior to this site, and the IP address and browser version your computer uses. The use of cookies, Web beacons and Internet tags can be used to collect this information from your computer. We may place a text file called a cookie in the browser files of your computer when you visit. The cookie may be stored on your computer’s hard drive. The information we collect using cookies is non-personal information. You may be able to set your computer to refuse cookies altogether, but certain features of the site may not work without them. KCI may use this information for such things as providing better site service, customisation of the site based on user preferences, compilation of statistics and trends, market research and other uses to improve this site an d our service to visitors. This information is not combined with personally identifiable information collected in other parts of this site, unless you have consented. You may also choose to allow us to personalise your visits to the site, in which case we will ask you for certain personal information to make your visits to our site more helpful to you. When this information is combined with the non-personal information we collect as described above, KCI will be able to tell that you have visited our site before and can personalise your access to the site, for example, by telling you about new features that may be of interest to you or to help you automatically visit your country of origin.

As mentioned above, KCI will use non-personal information from you to help us make this site more useful to visitors. KCI will also use non-personal information for other business purposes. For example, we may use non-personal information or aggregate non-personal information to:

  • create reports for internal use to develop programs, products, services or content
  • customise 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
     

In the ordinary course of business, KCI will share some personal information with companies that we hire to perform services or functions on our behalf. For example, we may use different vendors or suppliers to ship you products or information that you order (or request) on our Web site. In these cases, we provide the vendor with information to process your order such as your name and mailing address. In all cases in which we share your personal information with a third party, we will not authorise them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide. We will not sell, exchange or publish your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition. If you so request or otherwise consent by using a reply, feedback or “contact me” feature of this site, KCI may use information collected from this site to communicate with you, in addition to the other purposes specified in this Privacy Policy.
In the ordinary course of business, KCI will share some personal information with companies that we hire to perform services or functions on our behalf. For example, we may use different vendors or suppliers to ship you products or information that you order (or request) on our Web site. In these cases, we provide the vendor with information to process your order such as your name and mailing address. In all cases in which we share your personal information with a third party, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide. We will not sell, exchange or publish your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition.
KCI may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law or regulation. KCI may cooperate with law enforcement authorities in investigating and prosecuting Web site visitors who violate our rules or engage in behaviour which is harmful to other visitors (or illegal).
KCI may disclose your personal information to third parties if we feel that the disclosure is necessary to:

  • enforce this Privacy Policy and the other rules about your use of this Web site
  • protect our rights or property
  • protect someone's health, safety or welfare
  • comply with a law or regulation, court order or other legal process
     

KCI may contact you periodically by e-mail, mail or telephone if you agree to that contact to provide information regarding programs, products, services and content that may be of interest to you. In addition, some of the features on this Web site 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 health, your name, address, etc. We cannot guarantee that our e-mails to you will be secure from unauthorised interception.
Please be aware that Internet transmissions, to include emails, are never totally secure. Information you submit to this site via the Internet or through email may not be secure; however, we will take reasonable steps to protect any personally identifiable information you may transmit to us from unauthorised access and misuse. KCI cannot guarantee or warrant this Web site or its security components against breaches of security, the interruption of the system or user error and misuse.

Except for certain personal information that may be specifically requested in the Web site for a specific purpose, KCI discourages the submission of confidential or proprietary information to this Web site. KCI does not generally request or require such information and has no obligation of any kind with respect to such information. Any such information you submit to this Web site via the Internet, email or other electronic means is not considered confidential and may be used for various purposes by KCI without limitation to include, but not be limited to, developing, manufacturing and marketing products.

This site may contain links or references to other Web sites. Please be aware that we do not control other Web sites and that, in any case, this Privacy Policy does not apply to those Web sites. We encourage you to read the privacy policy of every Web site you visit, whether sponsored or affiliated with KCI or not.

If you have any questions or concerns about this Privacy Policy or the information practices of this site, please contact us at privacy.office@acelity.com

If this Privacy Policy changes, the revised policy will be posted on this site. Please check back periodically, and especially before you provide any personally identifiable information. This Privacy Policy was last updated on 03/01/2009.
 


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