Privacystatement

We believe it is important to be a responsible partner in society and to act with integrity toward our employees, customers, business partners and shareholders, as well as the broader community. In pursuing our business objectives, we always strive to do so responsibly to ensure that we are doing the right thing. This means that if you are aware of ethical violations related to Alphatron Medical activities, please report your concerns. Further information can be found in the Whistleblower Reporting Policy.

Why we process your personal data
We process your personal data for the following purposes:

• Investigating possible violations of our Business Rules or a threat to Alphatron Medical’s business integrity;
• Taking any action that may be necessary to conduct business responsibly and in compliance with local laws and regulations.

What personal data we process
If you report a problem in accordance with our whistleblower reporting policy, we process the following categories of personal data:

• If you disclose your identity: your name, phone number, email address, the best time to contact you, and your relationship with Alphatron Medical (former employee, vendor, customer or other), if you choose to provide this information.
• The name and other personal information of individuals you mention in your report, if you are willing and able to provide this information.
• Details about the incident you are reporting (time, place, location, circumstances, description of what happened, possible effects on Alphatron Medical’s entity and whether management is aware of it).

Legal basis for processing
The legal basis on which we rely to process your personal data for the purposes described in this section is our legitimate interest, in particular our need to conduct business responsibly and in compliance with local laws and regulations and to protect fundamental rights such as the right to liberty and security, the right to property, the right to defense, the freedom to do business.

With whom we share your personal data
Your personal information will be recorded. This means that the information may be shared with the assigned investigator(s), internal oversight body, Security Officer, Confidential Advisor and in some situations members from outside Alphatron Medical (forensic auditors, legal counsel) who need this information to ensure compliance with legal or regulatory obligations, or as input for subsequent legal proceedings.

We work to high standards when it comes to processing your personal data. Therefore, please contact us (you will find the privacy contact form in the relevant section of this privacy notice), We will do our best to address your request. Your privacy request and your personal data will be formally recorded in an electronic file and this will initiate an internal process aimed at fulfilling, to the extent possible, your request.

Why we process your personal data
We process your personal data to comply with the privacy and data protection laws and regulations to which we are subject.

What personal data we process
If you submit a privacy request to us, we need certain information from you to be able to respond to your request, and to handle your request adequately. In particular, we need the following information:

• Your email address;
• Your relationship with Alphatron Medical (customer, job applicant or other).

In addition, if you wish, you may also disclose to us your full name, your country, your preferred language, and any other information you decide to include in your application.

Legal basis for processing
The legal basis on which we rely to process your personal data for the purposes described in this section of the Privacy Statement is our need to comply with the privacy and data protection laws and regulations to which we are subject.

Our recruitment process is designed to help us find people who share our passion for improving lives through meaningful innovation and to help you find out if Alphatron Medical is the right place for you. This process includes the following activities:

• Apply for jobs on our careers website;
• Interacting with us (for example, with our recruiters) for job opportunities.

Why we process your personal data
We process your personal data for the following purposes:

• Enabling you to submit job applications through the career website;
• Assessing your skills, qualifications and suitability to work for Alphatron Medical based on the position you applied for and/or for other career opportunities;
• Depending on the country of employment and based on what is permitted by applicable law, verifying your information, including through reference checks and, if applicable, background checks.
• Communicating with you about the hiring process;
• In accordance with applicable laws and regulations, we are subject to and cooperate with regulators and law enforcement agencies.

What personal data we process

Depending on the specific recruitment activity, we process the following categories of personal data:

• Contact information (such as full name, email address, phone number, country of residence, home address, other contact information);
• Data about your skills and qualifications included in resumes, cover letter or other documentation provided to us in your application (such as educational history, work experience, transcripts);
• Data necessary to conduct background or employment checks, if permitted by applicable law (such as documents to prove your identity or qualifications);
• Information about the type of work you are seeking or looking for, current and/or desired salary and other terms related to compensation and benefits, willingness to relocate or other work preferences;
• Information necessary to make an employment offer (such as bank information to process salary payments, emergency contact information to know who to contact in case of an emergency at work);
• Details of how you heard about the position for which you are applying;
• Data derived from assessments or questionnaires completed by you (such as your response to written assessments);
• In certain cases, you may participate in optional video interviews. In this case, we may process your image or other data captured by your camera.
• Information related to previous applications you may have submitted to Alphatron Medical.
• Information you disclose that we believe is relevant to your application or a possible future application (such as your information in your LinkedIn profile).
• If you are referred, we process information that the person you refer provides about you.
• Where required or permitted by local law, we may also process information of a sensitive nature, such as disability information, as relevant to the performance of your job.

Legal basis for processing
The legal bases on which we rely to process your personal data for the purposes described in this section are:

• our need to perform a contract to which you are subject, or to take pre-contractual steps at your request.
• our legitimate interest, in particular our need to conduct business responsibly and in accordance with local laws and regulations, and to protect fundamental rights, such as the right of defense, the right to property and the freedom to do business.
• our need to comply with legal obligations to which we are subject.

your consent, to send you news and updates on Alphatron Medical job openings and recruiting activities via email, and to keep your information in our talent pool and contact you for career opportunities.

Who is the custodian of your personal data
The controller of your personal data for the purposes described in this section is the Alphatron Medical-affiliated company of the country you wish to recruit and Alphatron Medical Group B.V.

If you need help and support from Alphatron Medical, please contact our Alphatron Medical-affiliated support team via email, websites, phone, self-service portal or social media. They will do their best to answer your questions and provide you with the support you need.

Why we process your personal data
We process your personal data for the following purposes:

• to answer your questions and provide you with necessary support, including keeping you informed of the progress of your case and work order (this may include scheduling, delivery remote/field service activities, including ordering parts, if you are a business customer);
• to verify your identity and support you;
• to deal with any subsequent issues that may arise from your request, such as for establishing, exercising or defending against legal claims;
• to improve, repair and customize our products and services;
• to meet compliance, regulatory, and quality standards and regulations.
• To ask you if you would like to receive promotional emails and newsletters from Alphatron Medical (more information the “Participate in our marketing initiatives” section).

What personal data we process
If you have a question or request our support, we need some information from you, such as your name, e-mail address, phone number, or other information necessary to handle your question or request.

Legal basis for processing
The legal bases on which we rely to process your personal data for the purposes described in this section are:

• Our need to perform a contract to which you are subject, or to take pre-contractual steps at your request.
• Our legitimate interest, particularly our need to conduct business responsibly and in accordance with local laws and regulations, and to protect fundamental rights, such as the right of defense, the right to property and the freedom to do business.
• Our need to comply with legal obligations to which we are subject.

At Alphatron Care Connectors, you can go to our self-service portal to request support, or you can do so with the support of our customer service representatives.

Why we process your personal data
We process your personal data for the following purposes:

• To comply with SLA related service;
• To enable you to ask your support question and provide you with a status;
• To contact you in case of delivery problems or to obtain additional necessary information to fulfill your service request.

What personal data we process
We process the following categories of personal data:

• Contact information (such as your first name, last name, address, phone number);
• Information necessary to evaluate your service request.

Legal basis for processing
The legal grounds on which we rely to process your personal data for the purposes described in this section are our need to enter into and perform a contract with you, or to take pre-contractual steps at your request.

If you actively communicate about us or our brands on social media and other public external sources (for example, if you share a comment about an Alviscan product or if you tag AMiS or Alphatron Medical in your post), we may process personal data about you that you make publicly available. For example, we may analyze and monitor publicly available opinions or statements you make about Alphatron Medical.

Why we process your personal data
We process your comments or messages (which may contain your personal data) for the following purposes:

• To respond to your comments and questions or provide you with the necessary support. If your question or comment relates to Alphatron Medical solution manufactured by one of our partners, we may provide your personal data to the relevant brand licensing partner so that they can answer your question or provide you with the requested support.
• To gain an overall understanding of what people say about us and our brands and therefore improve our products and services accordingly.

What personal data we process
For the purposes described above, we may process any information about you contained in comments or other content about Alphatron Medical that you make public on social media and other public external sources. This may include information such as your name (or nickname), profile picture, country.

Legal basis for processing
The legal basis on which we rely to process your personal data for the purposes described in this section is our legitimate interest, particularly our need to conduct business responsibly and in accordance with local laws and regulations, and to protect our fundamental right to conduct a business.

We regularly organize physical and digital events, such as seminars, workshops or trade shows, meetings and webinars. If you wish to attend one of our events, we will ask you to provide your personal data (such as your contact information).

Please note that we do not publish participant lists for our events, but in exceptional cases your contact information may be visible to other participants.

Sometimes our events are recorded. If we are recording, and you are a presenter, your presentation with image and sound will be captured in the recording. If you are a participant, in some cases you may decide to share your image and audio during the session, for example, if you choose to interact in a question and answer (Q&A) session. For some events, we sometimes publish the recording on our website or social media channels.

Why we process your personal data
Wij verwerken uw persoonsgegevens voor de volgende doeleinden:

• To organize the event, facilitate it, and provide you with acceptable service. This may include activities such as contacting you about the logistics of the event, handling any dietary requirements or access arrangements you may need (if we do this, we do not share this information in an identifiable manner with the event venue, and remove it after the event), providing you with access to event content (e.g., a link to the recording after the event is over);
• To contact you after the event for commercial opportunities with Alphatron Medical or for other events that may interest you.

What personal data we process
We process the following categories of personal data:

• Contact information, such as your name and email address, country;
• Professional information, such as your company name, position, specialty;
• Product/services interest

Legal basis for processing
Unless otherwise required by applicable law, the legal basis on which we rely to process your personal data for the purposes described in this section is our legitimate interest, in particular our need to protect fundamental rights, such as the right to property and the freedom to conduct a business.

Unless otherwise required by applicable law, we collect information about dietary preferences or other access requirements only with your consent, as this type of information is considered a special category of personal data.

Who is the controller of your personal data
The controller of your personal data is the Alphatron Medical-affiliated company of the country where you visited our facilities.

If you wish, you can participate in our marketing initiatives and promotions. Below we provide an overview of our marketing initiatives and explain for each initiative how we process your personal data.

Promotional (e-)mail

Why we process your personal data and what personal data we process.
You can choose to receive promotional emails from Alphatron Medical. This means that if you give us permission, we will send you promotional (e-)mails.

• If you have accepted the advertising cookies while browsing our website, we will track your interactions with our websites to see what interests you.
• If you give us permission to receive promotional (e-)mails, we will send you such promotional emails. We track whether you open, read or click on the content of the promotional e-mail you received from us.
• If you give us your consent to receive promotional communications through our special forms published on our websites or social media pages, we will use the data you provide us through these forms (such as your name and (e-)mail address, your position or company name, specialty or area of care in case you subscribe through the customer forms aimed at professionals or customer representatives), as well as information about your country to send you promotional messages that are relevant and of interest to you.

Please note that we may combine the data we collect about you from the above-mentioned sources and place them in one or more segments (groups that share certain characteristics) in order to tailor our promotional (e-)mails to your interests.

Legal basis for processing
The legal grounds on which we rely to process your personal data for the purposes described in this section are:

• Your consent; as a general rule, we will only send you promotional messages if you have given your prior consent; Of course, you can withdraw this consent to receive our promotional emails that are personalized to you at any time. You can do this by clicking the unsubscribe button at the bottom of the promotional e-mail you received from Alphatron Medical and you will be automatically unsubscribed.
• Our legitimate interest, particularly our need to protect fundamental rights such as the freedom to conduct business.

Who is the custodian of your personal data
The controller of your personal data is the Alphatron Medical-affiliated company of the country where you have signed up to receive promotional (e-)mails and Alphatron Medical Group B.V.

Advertising on social media
We use social media to keep you informed about new and existing products and services.

Why we process your personal data and what personal data we process
As mentioned above, we process your personal data to reach you – via social media – with promotional communications and about our events.

If you are a representative of an existing or potential customer or business partner, we may use your personal information to connect with you – via social media (e.g. LinkedIn) – for commercial opportunities.

Legal basis for processing
The legal grounds on which we rely to process your personal data for the purposes described in this section are:

• Your consent; this applies when before we collect your behavior on the website and place the relevant cookies and similar technologies on your device; and when we use your consent to receive marketing communications;
• Our legitimate interest, particularly our need to protect fundamental rights, such as the right to property and the freedom to do business. This applies when we process your personal data to build your (potential) customer profile and connect with you via social media for commercial opportunities.

Who is the custodian of your personal data
The controller of your personal information is the Alphatron Medical affiliated company of the country where you have signed up to receive promotional emails and Alphatron Medical Group B.V.

When you visit our websites, we place cookies and other similar technologies on your browser or device that help us to enable the technical and functional management of our websites (including ensuring information security), to improve the design, and performance of our websites, and to better understand visitor behavior on our pages. These cookies and other similar technologies may collect data such as your IP address, your operating system, your browser type, and your device type (e.g., PC, smartphone).

Some cookies are always enabled when you visit our websites and you cannot disable them unless you change your browser settings. We call these “strictly necessary cookies.” Without these cookies, the services you request cannot function as intended. We use these cookies to ensure that our websites work correctly and meet the needs and interests of the public. For example, we use these cookies to monitor when a website is unavailable or to ensure the security of our websites. The legal grounds on which we rely to process your personal data in this context are our legitimate interest, in particular our need to protect fundamental rights, such as the right of defense, the right to property and the freedom to conduct business.

We use performance cookies (such as analytics) to collect aggregate statistical information about how our website is performing and to improve the performance of our website accordingly. You can turn them on or off at any time. We only use them if you have agreed to do so. For example, we use these cookies to get a general picture of how visitors use our websites (i.e., which web pages you visit most often, the number of visitors to different parts of a website) or to conduct user surveys on our website in general or on specific parts of our website.

We also use functional cookies to tailor our websites to your needs by remembering choices you make. You can enable or disable these at any time. We only use them if you have agreed to do so. For example, we use these cookies to remind you of your settings on our website (such as your username, language or the region you are in) and to provide more enhanced, personalized features. These cookies do not collect information about you that will be used for advertising purposes. The legal grounds on which we rely to process your personal data in this context is your consent.

Please read our cookie consent tool to learn more about the specific cookies we use.
You can change your cookie settings at any time through our cookie consent tool.

As a medical device supplier and medical system manufacturer, we are subject to legal obligations regarding the marketing, making available on the market or putting into service of medical devices for human use and accessories for such devices. Therefore, we continuously process personal data to comply with our legal obligations.

Why we process your personal data
We process your personal data for the following purposes:

• Reporting serious incidents to health authorities, having established the causal link between that incident and the device, or where such a causal link is reasonably possible;
• Analyzing and reporting on a statistically significant increase (whether in frequency or severity) in non-serious incidents or adverse events that may affect the risk-benefit analysis of the device;
• Analyzing, investigating and taking corrective actions in the field as necessary, with respect to serious incidents.

What personal data we process
We process the following categories of personal data:

• Log files
• Contact information related to incident reporters
• Information about individuals in the incident, complaint, or other feedback.
• Log files or medical images, which may include patient information such as age, gender, weight.

Please note that we do not have access to directly identifiable information about patients as it is kept confidential by the relevant healthcare provider and is not required for the processing we undertake.

Legal basis for processing
We process your personal data to fulfill a legal or regulatory obligation to which Alphatron Medical is subject when we (a) report adverse events to competent authorities, and (b) trends of statistically significant increase (in frequency/seriousness) of non-serious incidents, and when we handle complaints;

We process your personal data for the performance of an activity carried out in the public interest when we investigate incidents to determine the cause and require preventive, corrective measures for safety in practice; detect trends of statistically significant increase (in frequency/seriousness) of non-serious incidents.

How long we keep your personal data
Alphatron Medical is obliged as a supplier to keep the technical documentation of their devices current and available to the competent authorities for a period of at least 10 years after the last device covered by the same declaration of conformity was placed on the market.

Who is the custodian of your personal data
The controller of your personal data is the Alphatron Medical-affiliated company that is the manufacturer of the medical device as indicated on the regulatory label of the respective device.

If you have a commercial relationship with Alphatron Medical – as a supplier or potential supplier, business customer or partner – we want to ensure that our relationship with you is based on transparency, clear accountability and trust. To manage this relationship with you and to ensure compliance with applicable laws, we may process personal data.

Why we process your personal data
We process your personal data for the following purposes:

• To communicate with you, for example, by responding to your requests or sending transaction messages;
• To initiate, plan and maintain our (contractual) relationship with the customer, supplier or business partner you represent, for example by entering into contracts, processing payments, accounting/billing, managing credit, managing shipments and deliveries, handling repairs;
• [if you are a business customer] To provide you with the requested product and services, such as providing technical support;
• [if you are a business customer] To give you access to our Customer Service Portal to provide training or demo sessions to you or your representatives;
• [if you are a business customer] To extend credit to you at your request.
• To ensure compliance with our Business Rules and other applicable laws and regulations to which we are subject, such as conducting screenings to assess compliance and (commercial or credit) risks associated with potential business relationships or collecting/responding to quality complaints regarding our medical devices.

What personal data we process
To manage our business relationship with you and ensure compliance with applicable laws, we process the following categories of personal data:

• Contact information, such as full name, position, business email, business address, business phone number;
• Payment information, such as data needed to process payments;
• Publicly available data, such as information relating to owners, majority shareholders and senior management or executives of our suppliers and business partners collected from trusted, publicly available sources;
• Information you provide to us, such as when you communicate with an Alphatron Medical representative;
• Information about individuals submitting quality complaints, including medical professionals, such as name, email address, mailing address.
• Device data, such as log files.

Legal basis for processing
The legal bases on which we rely to process your personal data for the purposes described in this section are:

• Our need to perform a contract to which you are subject, or to take pre-contractual steps at your request.
• Our legitimate interest, particularly our need to conduct business responsibly and in accordance with local laws and regulations, and to protect fundamental rights, such as the right of defense, the right to property and the freedom to do business.
• Our need to comply with legal obligations to which we are subject.

To the extent necessary, we may have the need to fulfill other legal and business purposes.

In this context, we may process personal data.

Why we process your personal data
We process personal data for the following purposes:

• Execution of business processes and internal management. This purpose includes activities such as conducting (internal) audits and investigations, managing alliances, ventures, mergers, acquisitions and divestitures, reorganizations or divestitures and integration with buyers.
• Development and improvement of applications, products and/or services. This purpose includes activities such as the development and improvement of products, systems and/or services.
• Security and protection of interests and/or assets of Alphatron Medical. This purpose includes activities related to the security and protection of the interests and/or assets of Alphatron Medical and its customers, corporate clients and business partners, including ensuring the security and integrity of their business sector. In particular, it includes activities such as detecting, preventing, investigating and combating (attempted) criminal or offensive behavior directed against Alphatron Medical, its employees or other persons, activities such as those related to health and safety, authentication of the status of our customers, suppliers or business partners, and access rights, and activities such as deploying and maintaining technical and organizational security measures.
• Protection of Alphatron Medical’s intellectual property rights. This purpose includes activities such as filing and managing intellectual property rights of Alphatron Medical and it may require the processing of personal data of inventors and other individuals.
• Creating and disclosing promotional materials. This purpose includes activities such as using photos and videos (which may contain data about individuals) in promotional materials, which may be disclosed to customers or made available online.
• Compliance with Legal Obligations. This purpose includes the Processing of Personal Data in connection with the performance of a task carried out to comply with a legal obligation to which Alphatron Medical is subject, including providing Personal Data to government agencies or supervisory authorities, including tax authorities and other competent authorities for the industry in which Alphatron Medical operates.
• Defense of Legal Claims. This purpose includes activities such as preventing, preparing for, or participating in litigation.

What personal data we process
Depending on the specific purpose, we process different categories of personal data (such as contact information and any other information necessary to fulfill the above purposes).

Legal basis for processing
The legal bases on which we rely to process your personal data for the purposes described in this section are:

• Our need to perform a contract to which you are subject, or to take pre-contractual steps at your request.
• Our legitimate interest, particularly our need to conduct business responsibly and in accordance with local laws and regulations, and to protect fundamental rights, such as the right of defense, the right to property and the freedom to do business.
• Our need to comply with legal obligations to which we are subject.
• The consent of the individuals involved;
• Any other legal basis permitted in any case by applicable law.

Please note that unless we need your personal data to comply with laws and regulations, you are not required to provide your personal data to us. Obviously, if you choose not to do so, in many cases we will not be able to provide you with the products or services you have requested, or respond to any requests….