TELEFLEX – WEBSITE PRIVACY POLICY 22/5/18

PRIVACY POLICY

Teleflex is committed to protecting and respecting your privacy. This Privacy Policy sets out how we, Teleflex Incorporated, 550 E. Swedesford Road Suite 400 Wayne, PA 19087-1603, USA, collect, use, process and disclose the personal data (Data) we collect from you or that you (i) provide to us on our websites (the Site(s)), (ii) when you provide information to us in the context of your business relationship with Teleflex as a client or supplier, or (iii) when your data is supplied to us by your employer who is a client or supplier of Teleflex.

Your Right to Object - Please note that you have a right to object to processing of your personal data where that processing is carried out for our legitimate interest. Please contact us if you wish to do so (see the Contact Us section below).

Please read the following carefully to understand our use of your Data.

1. Children under 13

Teleflex does not intend to collect personal information from children under age 13 without permission of the child's parent or legal guardian. Also, we do not provide any personal information to any third party (other than Teleflex’s agents) about our on-line visitors who indicate they are under 13 years of age. Online visitors under 13 years of age should not submit personal information to us without the explicit permission from their parent or legal guardian. If your child has submitted personal information, and you would like to request that such information be removed from our system, please see the “Contact Us” section below to make such a request and we will use reasonable efforts to comply with your request.

2. Information we may collect from you

This Privacy Policy applies to you, whether you are a current (or former) visitor to our Site, client, supplier, or an employee of a client or supplier. It also applies to third parties whose information you provide to us in connection with our relationship with you. Please ensure that you provide a copy of this Privacy Policy to any third parties whose Data you provide to us.

'Personal Data' is defined as any data relating to a living individual who can be identified directly from that data or indirectly in conjunction with other information.

We collect and process the following Data about you:

  • Your name, postal address, email address, telephone number, and/or any other information that you provide to us by filling in forms on our Site
  • Your IP address
  • Your domain name
  • Your browser type
  • Your referring URL
  • The pages you viewed
  • Time and date of your visit, the number of times you return to our site and other click-stream data
  • We may also ask for information if you report a problem with our Site
  • Your name, contact details, job description and any other information included in a contract between Teleflex and you, or your employer
  • Data which you or your employer provides to us when you or your employer supplies or purchases products and/or services.

Unless subscribing to a service, you are not obliged to provide us with your Data, but failure to provide us with your contact details may result in us being unable to respond to any questions or requests you submit to us via our website. We will tell you when we ask for information which is a contractual requirement or needed to comply with our legal obligations.

If you consent to the use of your Data for marketing purposes, tick the relevant box situated on the form on which we collect your Data. You have the right to withdraw your consent at any time. Please contact us if you wish to do so (see the Contact Us section below).

3. Purpose and Legal Basis for Processing your Data

We will hold, process and may disclose your Data for the following purposes:

Purpose for Processing Legal Basis for Processing
  • Improving the content, functionality and operation of our Sites and the goods and services we offer.
  • Ensuring the Sites are presented in the most effective manner for you and your computer.
  • Compiling statistical data on the use of our Sites.
  • Allowing you to participate in interactive features of our Sites, when you choose to do so.
  • This use of your data is necessary for our legitimate business interest in monitoring the utilization of our Sites and to improve its quality. We have carried out a balancing test to ensure that your interests are not overridden by this legitimate interest. For more information on this balancing test carried out by Teleflex please contact PrivacyOfficial@teleflex.com. Please note that you have a right to object to processing of your Data where that processing is carried on for our legitimate interest.
  • To send you information about our latest products, promotions and events.
  • To provide educational events and learning materials
  • This use of your data is necessary for the legitimate business interest we have in promoting our business, services and products. We have carried out a balancing test to ensure that your interests are not overridden by this legitimate interest. For more information on this balancing test carried out by Teleflex please contact PrivacyOfficial@teleflex.com. Please note that you have a right to object to processing of your Data where that processing is carried on for our legitimate interest.
  • To comply with requirements of regulatory agencies such as the United States Food and Drug Administration (FDA), the European Medicines Agency (EMA) and Medical Technology Associations, if necessary.
  • The processing is necessary for compliance with a legal obligation to which Teleflex is subject.
  • For products and claims administration.
  • To provide you with information in relation to our business relationship.
  • To notify you about changes to our business arrangement.
  • To fulfill the business arrangement between us and your employer.
  • To complete and contribute to any audits.
  • This use of your data is necessary for our legitimate business interest in managing our business including legal, personnel, administrative and management purposes and for the prevention and detection of crime. We have carried out a balancing test to ensure that your interests are not overridden by this legitimate interest. For more information on this balancing test carried out by Teleflex please contact PrivacyOfficial@teleflex.com. Please note that you have a right to object to processing of your Data where that processing is carried on for our legitimate interest.
  • The use of Cookies on our website
  • Your consent, which can be withdrawn at any time.

We may, from time to time ask for your consent to use your Data for a specific purpose. If given, this consent can be withdrawn at any time.

4. Cookies

When browsing the Sites, subject to your consent where required by applicable law, our servers collect certain information, such as your IP address, domain name, browser type, pages viewed and the time you visited our Sites, the number of times you return to our Sites and other click-stream data. This information may be compiled and/or analysed by us on an aggregated basis to measure our users’ habits. This helps us to measure the use of our Sites, improve the content, functionality and operation of our Sites and to better understand and serve our users. Teleflex does not sell, exchange or publish this information; however, it may be shared with employees and vendors who assist in the implementation and maintenance of our Sites.

Cookies are small data files that are created by your computer’s browser and stored on your computer’s hard drive when you visit a particular website. We may use cookies to deliver content specific to your interests and to otherwise specifically tailor your experience on our Sites. You can set your browser to notify you when you receive a cookie and decide if you want to accept it or not. If cookies are blocked, certain tasks or features of our Sites may not be functional.

Session cookies are used to store temporary data in memory which exists only for the duration of the user’s session. All information from them is removed completely whenever the session is finished. They are generally used to pass information from one Site to another. Teleflex uses session cookies to maintain an internal session identifier required by the underlying web technology, and to provide Site usage statistics.

Please note that we use the following types of cookies:

Type (What application uses the cookie)
Necessary cookies These are essential in order to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, our Site would not work properly and services cannot be provided.
Performance cookies These collect information about how visitors use the Site, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. We use these cookies to test different designs and features for our Site and we also use them to help us monitor how our visitors reach our sites.
Functional cookies These allow the Site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.

You can control the cookies placed and retained on your device. The Privacy Policy is provided to be transparent about our practices regarding the use of cookies and to allow you the opportunity to make an informed choice.

Where applicable, we will obtain your prior informed consent to use cookies and other tracking technologies which store or access information on your device. Most browsers accept cookies automatically but they can be set up to ask for your prior consent before an individual cookie is set on your device. This will give you control over your cookies, however, it may interfere with your browsing experience as some websites may not function properly and you may not be able to take advantage of all the features offered by our website.

For instructions on blocking and deleting cookies, see the privacy and help documentation of your specific browser’s website. If you use multiple devices and/or browsers you will need to disable cookies on each device and on each browser separately.

If you limit the ability of our Sites to set cookies, this may prevent you from using certain features of our Sites properly and your user experience – which will no longer be personalised for you – may deteriorate. You may also be able to opt-out from certain cookies through third party cookie management sites. Disabling cookies may prevent you from using certain parts of our Site.

You can find more information about cookies by visiting the following information websites: www.aboutcookies.org www.allaboutcookies.org

5. Special Categories of Personal Data

Unless we specifically request or invite it, we ask that you not send us, and you not disclose any personal data considered as 'special'. Special data includes information relating to an individual's:

  • Physical or mental health;
  • Religious, philosophical or political beliefs;
  • Trade union membership;
  • Ethnic or racial origin;
  • Biometric or genetic data; and
  • Sexual orientation.

If we process any special categories of your personal data we will do so on the basis of your explicit consent.

6. Disclosure of your Data

We will disclose the Data we collect as described in this Privacy Notice to the following third parties or agents:

  • Our subsidiary companies, https://www.teleflex.com/usa/investor/sec-filings/ (click on the link for Form 10k, Exhibit 21, under “SEC Filings”)
  • Service providers, including software service providers and data analytics service providers.
  • legal advisors, for the purposes of seeking legal advice or defending a legal claim .
  • auditors, for the purposes of complying with financial reporting requirements and other compliance purposes as necessary.
  • consultants and other non-affiliated third parties we use to support our business, and the management of the business relationship;
  • Our Internet Service Providers;
  • Regulatory agencies e.g. the U.S. Food and Drug Administration (FDA), European Medicines Agency (EMA) and Medical Technology Associations,
  • A buyer or other successor in the event of a merger, divesture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Teleflex and its affiliates' business, whether as a going concern or as part of a bankruptcy, liquidation or similar proceedings; and
  • in the event that we sell or buy any business or assets, in which case we may disclose your Data to the prospective seller or buyer of such business or assets

We may also disclose your Data if we are under a duty to disclose or share your Data in order to comply with any legal obligation, or where necessary to protect the rights, property, or safety of Teleflex, our clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We will inform you in advance if we intend to further process or disclose your personal data for a purpose other than the purposes set out in this Data Privacy Notice. We take all reasonable steps, as required by law, to ensure the safety, privacy and integrity of such data and information and, where appropriate, enter into contracts with such third parties to protect the privacy and integrity of such data and any information supplied. You can obtain further information concerning recipients of your personal data from PrivacyOfficial@teleflex.com, where applicable.

7. Transfer of Data outside the EEA

The Data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"), for the purposes described above. Those countries may not provide an adequate level of protection under European data protection law for the processing of personal data. Due to the global nature of our business, your Data may be disclosed to members of our group outside the EEA, including in particular in the USA. It may also be processed by personnel operating outside the EEA who work for us or for one of our suppliers who act on our behalf. We will ensure appropriate safeguards are in place to protect the privacy and integrity of such personal data. Please contact us if you wish to obtain information concerning such safeguards (see Contact Us below).

8. Your Rights under GDPR

If you are located in the EEA, you have the right to request access to, rectification, or erasure of your Data, or restriction of processing or object to processing of your Data, as well as the right to data portability, in accordance with applicable laws. The following is a summary of what these rights involve:

  • The right of access enables you to receive a copy of your Data.
  • The right to rectification enables you to correct any inaccurate or incomplete Data.
  • The right to erasure enables you to ask us to delete your Data in certain circumstances, for example where it is no longer necessary for us to process it or if you consider it is being unlawfully processed. Your request can be refused if the processing is necessary to comply with an EU or Irish legal obligation or for the exercise or defense of legal claims.
  • The right to restrict processing enables you to ask us to halt the processing of your Data in certain circumstances, for example if you want us to verify its accuracy or our legitimate interests in processing it.
  • The right to object enables you to object to your Data being processed on the basis of our legitimate interests (or those of a third party). We will stop such processing unless there are compelling legitimate grounds for the processing or the processing is necessary for the exercise or defence of legal claims. You also have the right to object to us processing your Data for direct marketing purposes.
  • The right to data portability enables you to request us to transmit Data, that you provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party.

However, these rights may not be exercised in certain circumstances, such as when the processing of is necessary to comply with a legal obligation or for the exercise or defense of legal claims. Any requests to exercise your rights should be addressed to PrivacyOfficial@teleflex.com. We will respond to your request in writing, including by electronic means, or orally if requested, within one month of receipt of your request. We may request proof of identification to verify your request. We have the right to refuse your request if it is manifestly unfounded or excessive, or if it is contrary to data protection legislation.

You have the right to lodge a complaint with the Data Protection Authority, in particular in the Member State of your residence, place of work or place of an alleged infringement, if you consider that the processing of your Data infringes the GDPR.

9. Data Retention

We will store your Data only for as long as necessary for the purposes of providing access to our Site and related services to you; for the performance of your or your employer's business relationship with Teleflex, as required by law, and for the exercise or defense of legal claims. Please contact us if you wish to obtain further information regarding retention policies (see the Contact Us section below).

10. Security and where we store your Data

We are committed to protecting the security of your Data. We use a variety of security technologies and procedures to help protect your Data from unauthorized access and use. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot warrant the complete security of any information that you submit to Us, nor can we warrant that information you supply will not be intercepted while being transmitted to us over the Internet and you do so at your own risk. We have implemented strict internal guidelines to safeguard your data at every level of our organization. We will continue to revise policies and implement additional security features as new technologies become available.

Where we have given you a password which enables you to access certain parts of our Site, you are responsible for keeping that password confidential. We ask you not to share your password with anyone.

Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to our Site. Any transmission of Data is at your own risk. Once we receive your Data, we use appropriate security measures to seek to prevent unauthorized access or disclosure.

11. Links to other sites

Our Site may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and we do not control or endorse the content of third party websites or otherwise accept any responsibility or liability for the content, security or privacy policies of those websites. Please check those policies before you submit any Data to those websites.

12. Disclaimer

You should not construe anything on this Site or any social media sites operated by Teleflex as medical advice. Information provided through the Site or social media sites is not intended to replace consultation with a qualified medical professional. Teleflex cannot answer specific medical questions in your e-mail requests or social media posts. You should consult a medical professional for diagnosis and treatment.

Teleflex does not practice medicine or provide medical services or advice and the information on this Site and social media sites operated by Teleflex should not be considered medical advice. Do not consult this Site in a medical emergency.

13. Changes to this Privacy Policy

We reserve the right to change this Privacy Policy from time to time at our sole discretion. If we make any changes, we will post those changes on our Site and update the “Last Updated” date at the bottom of this Privacy Policy.

14. Contact Us

Questions, comments, requests and complaints regarding this Privacy Policy and the Data we hold are welcome and should be addressed to PrivacyOfficial@Teleflex.com or sent in writing to Privacy Officer Teleflex Incorporated, 550 E. Swedesford Road Suite 400 Wayne, PA 19087-1603, USA. All requests will be processed in accordance with local law.

Last Updated: This policy was last updated May 2018