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PHC Europe, a Member of PHC Group About PHC Europe B.V. Privacy and Cookie Notice

Privacy Policy

PHC Europe

Privacy and Cookie Notice

This Privacy and Cookie Notice (‘the Notice’) applies to personal data obtained via our website https://www.phchd.com/eu/biomedical or in the context of establishing and maintaining business relationship with you.

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Controllers & scope

The website is hosted by PHC Holdings Corporation, Japan, the parent company of PHC Europe B.V. For the purpose of this Notice, the controllers of the personal data processed are PHC Holdings Corporation, with registered address at 15F DAI-ICHI LIFE HIBIYA FIRST 1-13-2 Yurakucho, Chiyoda-ku, Tokyo 100-8403, Japan, jointly with PHC Europe B.V. with the registered address at Eikdonk 1, 4825 AZ Breda, Netherlands (‘we’ and ‘us’).

Need help quickly?
Questions and requests regarding this Notice should be addressed to the Data Protection Officer at dp_office@phchd.com.

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.

The categories of personal data subject to processing

The categories of personal data depend on the source and can include the following:

  • Personal data provided to us directly by you;
  • Personal data provided to us by our business partners (e.g. distributors);
  • 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);
  • 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.
How we use this data (contract + legitimate interests)

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.

Direct marketing (legitimate interest / consent where required)

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)

This personal data 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

This personal data 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).
How we use publicly available sources

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:

View the technical information we may collect
  • 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.

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, 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.

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:

When we may share data
  • 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.

Your inquiry will be registered in our CRM system.

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.

Retention periods

We 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.

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, the types of browsers and internet service providers used, visit times and duration, pages visited, referring pages and exit pages. This information, commonly referred to as log-file data, helps us measure the popularity, traffic and effectiveness of different areas of our website and enables us to provide visitors with 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, provided that your browser settings allow this.

8.4 Cookies and similar technologies provided by other companies

We also use cookies and similar technologies provided by other companies to collect web-traffic information such as the time and date of a visit, IP address and browser information. These technologies may store your preferences and other information on your device, helping to save time during subsequent visits by reducing the need to enter the same information repeatedly.

In most circumstances, the information collected cannot identify you directly as an individual. Although this data could potentially contribute to your identification, we do not use it for that purpose.

8.5 Facebook Pixel

In some countries, we use Facebook Pixel to show you useful and relevant advertisements and to optimise our advertising. You can control how data is used to show you advertisements by using the tools described below.

If you have a Facebook account

You can use your Facebook ad preferences to understand why you are seeing a particular advertisement and to control how information is used to show you advertisements. To show more relevant advertisements, Facebook may use data that we and other partners provide about your activity outside Facebook company products, including activity on websites and apps. You can control whether Facebook uses this data through your Facebook ad settings.

If you do not have a Facebook account

You may opt out of online interest-based advertising from Facebook and other participating companies through the relevant advertising-industry opt-out service available in your region, including the Digital Advertising Alliance in the United States, the Digital Advertising Alliance of Canada, or the European Interactive Digital Advertising Alliance in Europe. You may also be able to manage these preferences through your mobile-device settings.

Please note that advertising blockers and tools that restrict our use of cookies may interfere with these controls.

8.6 Matomo Analytics

To provide you with the best possible experience on our website, we need to collect and process certain information. Depending on your use of our services, this may include the following:

Information provided when you contact us

When you contact us by email or through a form, for example to request support, ask a question, submit a comment or report a problem, we may collect your name, email address, message and other information you provide. We use this data exclusively in connection with responding to the inquiry we receive.

Usage data

When you visit our website, we may store information including:

  • 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;
  • device information, including device type, operating system and screen resolution;
  • language and country information; and
  • the type of web browser used during your visit.

We process this usage data in Matomo Analytics for statistical purposes, to improve our website and to detect and prevent misuse.

Cookies used by Matomo

We use cookies, which are small data files 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 your web-browser settings. Cookies that have already been stored can be deleted at any time.

Consent for Matomo processing
The processing of personal data with Matomo is based on explicit consent. We do not process personal data with Matomo unless you have given us clear and unambiguous consent.

9. Your rights

If you are a resident of the EEA or Switzerland, you have the following rights:

  • the right to be informed as to whether your personal data is being processed by us;
  • the right to know the purposes of the processing, the categories of personal 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.

Exercise your rights
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 Europe B.V., Eikdonk 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.

In the Netherlands, the supervisory authority is the Dutch Data Protection Authority (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 by post to PHC Europe B.V., 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 email. Please check this page regularly for any updates or changes to our Notice.