Privacy & Cookies Statement
Organ Recovery Systems, Inc. (“ORS”) provides this Privacy & Cookies Statement to explain our practices regarding the collection and processing of certain individually identifiable information about ORS clients and other online visitors (collectively, “Personal Information”). As such, this Privacy & Cookies Statement applies to Personal Information that we collect via our websites (individually and collectively, “Site”), as well as through trade shows, seminars, conferences, and other offline means.
Summary of Information Practices
As a business-to-business (“B2B”) organization, we collect Personal Information to better serve our clients and carry out our commercial relationships.
We use Personal Information to perform transactions, maintain and improve our Site, develop new products and services, provide personalized services, carry out our obligations, enforce our rights, and fulfill other business and legal compliance obligations.
We share Personal Information, as necessary, to perform transactions, maintain and improve our Site, develop new products and services, provide personalized services, carry out our obligations, enforce our rights, and fulfill other business and legal compliance obligations.
You have control over how we use Personal Information for direct marketing to you and other limited purposes.
We use, and allow certain third parties to use, cookies to administer and improve the Site and we provide choices on the use of such cookies.
Data Subject Rights
With respect to Personal Information, you have the right to access, rectification, erasure, restriction of processing, or portability, where required by applicable law.
We maintain technical and organizational measures to protect Personal Information from loss and unauthorized access, use, destruction, modification, or disclosure.
Cross-Border Data Transfers
Our Site is operated in the United States (“US”). If you are located outside the US, Personal Information will be transferred to the US, a jurisdiction that may not provide an equivalent level of protection as your home jurisdiction. Cross-border transfer is therefore necessary for the conclusion or performance of a transaction that you are requesting, and for the establishment, exercise, and defense of legal claims.
We provide other information via this Privacy & Cookies Statement regarding the legal basis for collecting and processing Personal Information, the consequences of not providing Personal Information, automated decision-making, do not track (“DNT”) signals, data retention, third party websites, employee and contractor privacy issues, and changes to this Privacy & Cookies Statement.
Please contact us as detailed below with any questions or comments regarding this Privacy & Cookies Statement.
Collection of Personal Information
We collect the following categories of Personal Information:
- Basic information: Name and contact information (e.g., email address, telephone number), and any other Personal Information that you submit to us during the course of business.
- Marketing information: Data gathered from you, as well as marketing partners, security partners, advertisers, and various technologies, such as cookies, pixel tags and databases.
- Transaction information: Data required to fulfill order requests, including billing and account information.
- Device information: Internet Protocol (IP) address, unique device identifier (UDID), location, LifePort device ID and location, information collected through cookies and similar technologies, and data about usage of our Site. Note, however, that we do not consider device information to be Personal Information except where we can link it to you as an individual, or where applicable law provides otherwise.
You are not required to provide all of the Personal Information identified in this Privacy & Cookies Statement to use our Site or to interact with us, but some functionalities will not be available if you do not provide certain Personal Information. In particular, if you do not provide certain Personal Information, we may not be able to respond to your requests, perform a transaction with you, or provide you with marketing that we believe you would find valuable.
Use of Personal Information
We collect Personal Information for the following purposes:
|Processing Purposes||Categories of Personal Information|
|Provide personalized services||
|Performing transactions and responding to your product and service requests, including providing client service and addressing client satisfaction issues||
|Managing client and supplier accounts and relationships, and maintaining our business operations||
|Maintaining and improving our Site and making the Site more intuitive and easy to use||
|Developing and improving our organ preservation products and services, including performing analysis and research and development||
|Protecting the security and effective functioning of our Site and information technology systems||
|Providing relevant marketing||
|Addressing our compliance and legal obligations and exercising our legal rights||
Sharing of Personal Information
We share Personal Information with the following categories of recipients for the following purposes:
- Organ Recovery Systems, Inc.: We share Personal Information with ORS as necessary in order to carry out the purposes identified above.
- Certain third parties: We share Personal Information with certain third parties, as detailed below, to enable such third parties to perform functions under our instructions. We require such parties, by contract, to provide reasonable security for Personal Information and to process such data only on our behalf.
- Contractors and service providers: We share Personal Information with contractors and service providers to carry out the purposes identified above, in particular to make our Site or products or services available to you, provide personalized services, or to provide assistance with logistics, mailing services, or regulatory compliance.
- Auditors, advisors, and financial institutions: We share Personal Information with auditors for the performance of audit functions, with advisors for the provision of legal and other advice, and with financial institutions in connection with payment and other transactions.
- Certain acquiring or acquired entities: We share Personal Information with any corporate purchaser or prospect, to the extent permitted by law, as part of any merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Information would be transferred as an asset of ORS.
- For legal reasons: ORS will share Personal Information with outside parties if we have a good-faith belief that collection, access, processing, preservation, or disclosure of the information is reasonably necessary to comply with any applicable law, regulation, legal process, or enforceable governmental request; to detect, prevent, or address fraud, security, or technical issues; and to protect against harm to the rights, property or safety of our employees, our clients, or the public as permitted by law.
- Where information is anonymized or pseudonymized: ORS may share information publicly and with our trusted business partners when the data is de-identified in a manner which prevents others from using the information to link data to an individual.
You have control regarding our use of Personal Information for direct marketing. You can manage, review, and update your information on our Site, as well as opt-out of marketing communications by using the link provided at the bottom of the communications. As further detailed below, you may contact us to exercise your data subject rights, including regarding Personal Information used for marketing, here.
In accordance with applicable law, we use, and allow certain third parties to use, various technologies to collect, store, and process information, including cookies, pixel tags, databases, and similar tracking technologies (collectively, “cookies”) on our Site.
- What are cookies? Cookies are small amounts of data that are stored in your web browser, on your device, or on the webpage you are viewing. Some cookies are deleted once you close your web browser (“session cookies”), while other cookies are retained on your device (until they are erased) even after closing your web browser so that you can be recognized when you return to a website (“persistent cookies”). More information about cookies and how they work is available at: www.allaboutcookies.org.
- Strictly Necessary Cookies: Session cookies that are required for the operation of our Site (e.g., cookies that enable you to login to secure areas of our Site).
- Analytical/Performance Cookies: Session cookies that allow us to recognize and count the number of users of our Site, and help us to improve the functionality of our Site (e.g., cookies that allow us to analyze how users navigate through our Site, which helps us to determine whether users are able to easily find what they are seeking). Note that our Site uses Google Analytics for these purposes.
- What are your options if you do not want cookies on your device? To exercise choices with regard to certain cookies (e.g., disable, delete), you can review your Internet browser settings, typically under the “Help” or “Internet Options” sections. Please note that our Site relies on some cookies to function properly. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important features or functions of this Site, and you may be required to re-enter your login details.
To learn more about certain cookies used for interest-based advertising, including through cross-device tracking, and to exercise choices regarding such cookies, please visit the following websites (or your device settings for mobile applications):
Digital Advertising Alliance (http://optout.aboutads.info/)
Network Advertising Initiative (http://optout.networkadvertising.org/)
EU Interactive Digital Advertising Alliance (http://www.youronlinechoices.eu)
Digital Advertising Alliance-Canada (http://youradchoices.ca/choices/)
Data Subject Rights
Where required by applicable law, you have the right to obtain confirmation that we maintain certain Personal Information about you (and the right to verify its content, origin, and accuracy), as well as the right to access, rectify, erase, restrict processing (i.e., withdraw consent without affecting the lawfulness of processing based on consent before its withdrawal), or port such data. In particular, you have the right to object to our use of Personal Information for direct marketing purposes, and certain other purposes, at any time. You also have the right to lodge a complaint with the competent data protection supervisory or similar authority in your jurisdiction. Note, however, that we may retain certain Personal Information as required or permitted by applicable law.
We maintain technical and organizational measures to protect Personal Information against loss and unauthorized access, use, destruction, modification, or disclosure, appropriate to the level of risk and sensitivity of the Personal Information. However, you also have an important role in protecting your Personal Data because no degree of preventive security measures can guarantee against compromise. You should not share your user name or password with anyone, and you should not reuse passwords across more than one website. If you have reason to believe that the data you have shared with us has been breached, please immediately notify us here.
Cross-Border Data Transfers
Our Site is operated in the US. If you are located outside the US, Personal Information will be transferred to the US, a jurisdiction that may not provide an equivalent level of protection as your home jurisdiction. Cross-border transfer is therefore necessary for the conclusion or performance of a transaction that you are requesting, and for the establishment, exercise, and defense of legal claims.
- Legal Basis for Processing Personal Information. We rely on the following legal grounds for the processing of Personal Information:
- Performance of a transaction with you (e.g., responding to your order requests);
- Compliance with legal obligations (e.g., keeping records to substantiate tax liabilities);
- Consent where required by applicable law (e.g., for the purposes of using certain cookies in limited jurisdictions); and
- For our legitimate business interests (e.g., where necessary to maintain our business generally or, subject to your objection rights, provide relevant marketing).
- Automated Decision-Making Without Human Intervention. We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects or otherwise significantly affects you.
- Do Not Track (“DNT”) Signals Sent via Browsers. Given the divergent practices of organizations that offer browsers, and the lack of a standard in the marketplace, we do not respond to DNT signals at this time.
- Retention of Personal Information. We retain Personal Information collected and processed for marketing purposes for as long as you accept marketing communications from us but, upon request, we will securely delete such data in accordance with applicable law. We retain Personal Information collected and processed for all other purposes for no longer than the period necessary to fulfill the purposes outlined herein, and as otherwise needed to address tax, corporate, compliance, and litigation (and other legal rights) obligations.
- Third Party Websites. This Site contains links and references to other websites administered by unaffiliated third parties; any such third party websites are not governed by this Privacy & Cookies Statement. When you follow a link to visit a third party website, you will be subject to the privacy and security practices of the unaffiliated third party administrator. We encourage you to familiarize yourself with the privacy and security practices of any such third parties before providing Personal Information on their websites.
- Social Media. The Site also includes Social Media features, such as LinkedIn, Facebook, Twitter, and YouTube. These features may collect your IP address and/or which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social Media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy statement of the company providing it.
- Employee, Contractor and Applicant Privacy Issues. Employees, contractors and applicants are informed about our privacy and security practices through internal company policies and procedures.
- Changes to the Privacy & Cookies Statement. We may update this Privacy & Cookies Statement from time to time as our business (including privacy and security practices) changes, or as required by law. The effective date of our Privacy & Cookies Statement is provided herein, and we encourage you to visit our Site periodically to stay informed about our privacy and security practices. We will post the most current version of our Privacy & Cookies Statement on our Site and ask for your consent to the changes, as required by law.
If you have any questions or comments about this Privacy & Cookies Statement, or if you would like to request rights or a copy of the appropriate safeguards concerning Personal Information, you may contact us here.
Updated: September 6, 2019