Cochlear Website Privacy Policy
Effective December 1, 2002
Our Commitment To Privacy:
Your privacy is important to us. To better protect your privacy we provide this Privacy Policy explaining online information practices of Cochlear Limited and its subsidiaries and affiliates (referred to as "we" and "us" in this Privacy Policy) and the choices you can make about the way your information is collected and used. To make this Privacy Policy easy to find, we make it available as a link from our home page and from every page on our web site. [Australian specific statement: Cochlear is bound by the Australian National Privacy Principles and complies with them as required by Australian privacy laws]. This notice does not apply to handling by Cochlear of personal information relating to its employees or former employees, which are subject to separate policies.
The Information We Collect:
This notice applies to all information collected or submitted on the Cochlear Website. If you are a user residing in the USA or Canada, you may order products from our online catalog. In addition, you can be part of the Nucleus Forum, receive company information, apply for employment or participate in surveys. The types of personal information collected are:
Name
Address
Email address
Phone number
Fax number
Credit/Debit Card Information (if you choose to transact with us online)
Audiologist
Implant Data
Health Data
In this document, we may refer to some or all of your personal information as:
Personal Data. (This is information from which your identity is apparent or can reasonably be ascertained either directly or indirectly, including by reference to an identification number or one or more factors specific to your physical, physiological, mental, economic, cultural or social identity).
Sensitive Personal Data (is Personal Data which is sensitive and includes information regarding your physical or mental health or condition).
Consents regarding your data:
You unambiguously consent and agree to the following:
1. Your Personal Data and Sensitive Personal Data may be collected, processed and stored by Cochlear in the United States and by Cochlear subsidiaries and affiliates located in other countries as stated below (including under the heading "How we use and disclose information").
2. You understand the purposes for which your Personal Data and Sensitive Personal Data is being collected. The purposes for which Personal Data and Sensitive Personal Data collected at various points on this Website are used are set forth below. If you are uncertain or have any concerns about how data entered by you will be used or disclosed do not enter that data.
a. Cochlear Connection: Candidate Registration
b. Cochlear Connection: Connect with a Recipient
These pages collect Personal Data and Sensitive Personal Data. . Personal Data and Sensitive Personal Data collected through these pages is used to pair up, for communication purposes, potential customers with existing customers. This is done at the special request of our potential customers and exisiting customers. They indicate they would like to participate in this program by completing the above forms –that facilitate communication between individual recipients and between individual recipients and potential recipients To do this, Personal Data and Sensitive Personal Data is shared with one or more Cochlear implant recipients or potential recipients. The information is also used by us for long term medical and marketing research into trends relating to the submitted data and to enhance our products and Website.
c. The Nucleus Forum
The Nucleus Forum is a public e-mail discussion group for individuals considering a Cochlear implant, and individuals who have a Cochlear implant. Personal Data and Sensitive Personal Data is sent by these individuals to us via e-mail and covers topics related to the Cochlear implant experience. The information provided by individuals who participate in the Nucleus Forum is also used by us for long term medical and marketing research into trends relating to the submitted data and to enhance our products and Website. Statements sent to the Nucleus Forum are deemed to be the personal opinions of the writers and do not necessarily represent our opinion. You agree that information (including Personal and Sensitive Personal Data) you submit to the Nucleus Forum will be handled in accordance with our obligations under applicable privacy laws, but will otherwise be treated on the basis that you have consented to its disclosure to other users having access to the Nucleus or that it has been made public as a result of steps deliberately taken by you in your participation in the Forum discussion group].
d. Submit Your Story
Submit Your Story is a page through which Nucleus recipients can publicly share their stories and photos with friends, family and Nucleus candidates through the Cochlear websites. We post this information on the Nucleus Family page of our Website. In addition, we use the stories for long term medical and marketing research into trends relating to the submitted data and to enhance our products and Website. You agree that information (including any Personal Data and Sensitive Personal Data) you submit through this page will be handled in accordance with our obligations under applicable privacy laws, but will otherwise be treated on the basis that you have consented to its disclosure to other users having access to the Nucleus or that it has been made public as a result of steps deliberately taken by you in your participation.
e. Purchases from Product Catalog and Service Contracts.
United States and Canadian residents may order from our Product Catalog and Service Contracts. We use this information to identify and ship products you wish to purchase. The information is also used by us for long term medical and marketing research into trends relating to the submitted data and to enhance our products and Website. In addition to the consent to collect and process your data stated above, you agree that the collection and processing of the data is necessary for the performance of a contract to which you are a party or for taking steps at your request with a view to entering into a contract. In Certain cases, Personal Data, Including Sensitive Personal Data is collected, processed or transferred to parties related and/or not related to us at your request in order to perform a service or otherwise undertake an activity for and at your request. The parties we transfer information to may or may not be in the United States.
The Way We Use and Disclose Information: We use the information you provide about yourself only for the purposes stated above and to enable Cochlear to manage the use or proposed use by recipients of its implant products and related services. We do not share the information with outside parties except to perform a service or task you have requested ("service providers"). For example, we use the information you provide when placing an order in the online catalog (for users to whom this service is available) only to complete that order. We do not share this information with service providers except to the extent necessary to complete that order. In some cases, where it is necessary to perform a service or task you have requested, Personal Data and Sensitive Personal Data may be shared with a service provider located outside the country from which your Personal Data is collected. Information you provide may be shared with and stored by Cochlear Ltd, and subsidiaries or affiliates of Cochlear Ltd, including subsidiaries or affiliates located in countries other than the country from which you submit that information.
In addition, in the case of recipients of Cochlear implants, depending on the circumstances in which you provide Personal Data or Sensitive Personal Data to us, to handle your request, we may disclose your Personal Data or Sensitive Personal Data to your parent, guardian or carergiver (if applicable), your clinic or the hospital at which you receive treatment, audiologist, your doctor, your health insurer and other health service providers and government regulators.
If you do not provide Personal Data we may be unable to perform the service or task you have asked us to provide or you may be unable to access certain facilities provided in connection with this Website.
Your Personal Data may be used by Cochlear to provide you with information about Cochlear's products and services. If you do not want your Personal Data or Sensitive Personal Data used for this purpose, please contact us at info@cochlear.com
If you participate in the Nucleus Forum, we may use your email address in order to deliver Nucleus Forum Peer Counseling and Support information.
We use non-identifying and aggregate information to better design our Website. For example, we may track information so that we can tell that X number of individuals visited a certain area on our Website, or that Y number of men and Z number of women filled out our registration form, but we would not disclose anything that could be used to identify those individuals.
In addition, we automatically track certain information about you. This information includes your domain name and IP address, your browser version, your operating system, the URL you came from, the pages you visit within the Site, and the URL to which you go upon leaving the Website. We use this information, in an aggregate form only, to monitor Site performance, utilization of features and services, traffic trends, and browser versions.
We may use Personal Data to determine the demographics of our users and to distribute statistics and general marketplace information. These demographics will always represent aggregate information and never identify a specific user.
The Site includes links to other web sites ("Linked Sites"). Except as expressly stated herein, we shall not share personally identifiable information about users with the operators of such Linked Sites, but may provide aggregate information regarding users to such operators. We are not responsible for the privacy practices or the content of the Linked Sites and hereby expressly disclaim all responsibility and liability that may arise therefrom. Links to and from the Website to the Linked Sites does not constitute an endorsement by Cochlear of any Linked Site or its content.
We also use a technology called "cookies" which can be used to provide tailored information from a Website. A cookie is an element of data that is sent to your browser and stored on your system. You may be able to set your browser to refuse a cookie or to notify you when you receive a cookie, giving you the chance to decide whether to accept it.
Our Commitment To Data Security:
To maintain data security and ensure the correct use of information, we have put in place procedures to safeguard and secure the information we collect online. However, you acknowledge that you are aware of security and privacy limitations, including but not limited to (1) the possible limitations or failures of security, privacy and authentication measures and features in this system; and (2) that data or information may be subject to third party eavesdropping or tampering.
Our Commitment To Children's Privacy:
Protecting the privacy of the very young is especially important. Any information collected openly on the Website from children is kept strictly confidential within Cochlear. Any use of such information by Cochlear will not identify individual children. No data will be released to any third party. If a person of 15 years or less registers to use the Nucleus Forum they should advise a parent or guardian that they are so registered.
How You Can Access Or Correct Your Information:
You can access all personal information that we collect online.
You can request correction of factual errors in personal information collected online about you which is held by us by sending us a request by e-mail at info@cochlear.com . If we agree with you, we will take reasonable steps to correct that information. If we do not agree with you, at your request, we will take reasonable steps to associate with any record of the Personal Data that you claim to be incorrect, a statement setting out your claim.
To protect your privacy and security, we will also take reasonable steps to verify your identity before making corrections.
How To Contact Us:
Should you require any further information about how we handle or have other questions or concerns about this Privacy Policy, please send an email to info@cochlear.com.
Updates to this Privacy Policy:
We may update or amend this Privacy Policy at any time by posting the amended Privacy Policy to the Website.