Last Updated: July 20, 2020
THECIRCULATIONACADEMY Medical Corporation (“THECIRCULATIONACADEMY” or “we” or “us”) respects the privacy of its customers, business partners, and individuals whose personal information with which we are entrusted. This policy describes the types of data we may collect from you or that you may provide when you visit www.TheCirculationAcademy.com (”Site”) and our practices for collecting, using, and disclosing that data, including data that identifies or can be used to identify you (“personal information”). This policy applies to the information we collect:
- On this Site;
- In email, text, and other electronic messages between you and this Site;
- Through mobile and desktop applications you download from this Site that provides dedicated non-browser-based interaction between you and this Site; and
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
This policy does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by THE CIRCULATION ACADEMY or any third party; or
- Any third party, including through any application, content, or advertising that may link to or be accessible from or on the Site.
Please read this policy carefully to understand our practices regarding your personal information and how we will treat it. If you do not agree with this policy, your choice is not to use our Site. By accessing or using this Site, you agree to this policy to the extent permitted by applicable law.
We recommend that you read this policy in full to ensure you are fully informed. If you only want to access a particular section of this policy, however, then you can click on the relevant link below to jump to that section:
- Information We Collect and How We Collect It
- How We Use Your Information
- Disclosure of Your Information
- International Transfers of Your Information
- Legal Basis for Collection and Use of Your Information
- Choices About How We Use and Disclose Your Information
- Your Data Protection Rights
- Your California Privacy Rights
- Data Security
- Data Retention
- Changes to Our Policy
- How to Contact Us
Our Site is not intended for children under 16 years of age in the European Economic Area (“Europe”) or under 13 years of age in the United States (“children” or “child”). Children may not provide any information to or on the Site. We do not knowingly collect personal information from children. If you are a child, do not use or provide any information on this Site or on or through any of its features or register on the Site or provide any information about yourself to us. That includes your name, address, telephone number, email address, or any screen name or user name. If we learn we have collected or received personal information from a child without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child or need to verify parental consent, please contact us.
Information We Collect and How We Collect It
We collect several types of information from and about users of our Site, including information:
- by which you may be personally identified, such as name, postal address, email address, telephone number, fax number, Internet Protocol (“IP”) addresses, or cookie ID;
- that is about you but individually does not identify you, such as website statistics; and
- usage details.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies. Details appear below.
Information you provide
To the extent permitted under applicable law, the information we collect on or through our Site may include:
- Information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, applying for employment, updating information, downloading information, entering contests, subscribing to marketing communications, reporting problems with our Site, or asking us questions.
- Details you provide to us when you interact with us using social media.
- Information you furnish in any interactive areas of this Site.
- Records and copies of your correspondence (including email addresses), if you contact us online or offline (for example, by telephone, fax, or text).
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of any transactions you carry out through our Site and of the fulfillment of your orders.
- Your search queries on the Site.
INFORMATION WE COLLECT AUTOMATICALLY
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Site and its contents to you, including facilitating navigation and more effectively displaying information.
- To provide you with information, products, or services that you request from us.
- To provide you with notices about your account.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- To notify you about changes to our Site.
- To allow you to participate in any interactive features on our Site.
- To respond to reviews, comments, or other feedback that you provide to us.
- To support and personalize our services, websites, mobile services, and advertising, and to remember your preferences.
- To protect the security and integrity of our services, content, and our business.
- To comply with applicable legal or regulatory requirements and our policies, and to protect against criminal activity, claims, and other liabilities.
- In any other way we may describe when you provide the information, including consideration for employment.
- To fulfill any other purpose for which you provide it.
- For any other purpose with your consent.
- For any other lawful purpose for which you provide the information.
Disclosure of Your Information
We may disclose personal information that we collect or you provide as described in this policy:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To a potential buyer or another successor (and its agents and advisors) in the event of a proposed merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of assets, provided that we inform the recipient it must use your personal information only for the purposes disclosed in this policy.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including responding to any government or regulatory request.
- If we believe disclosure is necessary for the purposes of fraud protection.
International Transfers of Your Information
Personal information collected through this Site may be transferred to, and processed in, other countries that might not, to the extent legally permissible, provide an equivalent level of protection as the data protection laws in your home country. We have taken appropriate safeguards, however, to require that your personal information will remain protected in accordance with this policy. These include the use of standard data protection clauses adopted by supervisory authorities and approved by the European Commission to safeguard transfers, as well as other contractual protections.
Legal Basis for Collection and Use of Your Information
The legal basis for the collection and use of your personal information, if you are in Europe, are the following, as further described above in How We Use Your Information:
- Your consent for one or more specific purposes.
- As necessary for legitimate interests not overridden by your interests or fundamental rights and freedoms.
- As necessary for compliance with a legal obligation to which we are subject.
- As necessary to protect your vital interests or those of another person.
- As necessary for a contract to which you are a party or to take steps at your request before entering into a contract.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us, including:
- Promotional Offers from the Company. If you do not wish to have your contact information used by THE CIRCULATION ACADEMY to promote our products or services, you can opt out by contacting us. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
Your Data Protection Rights
You have the following data protection rights:
- If you wish to access, correct, update, or request the deletion of your personal information, you can do so at any time by contacting us.
- In addition, if you are in Europe, you can object to the processing of your personal information, ask us to restrict the processing of your personal information, or request the portability of your personal information. Again, you can exercise these rights by contacting us.
- You have the right to opt out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt out of other forms of marketing (such as postal marketing or telemarketing), please contact us.
- Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- Finally, you have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in Europe, Switzerland, and certain non-European countries (including the U.S. and Canada) are available here.
We respond to all requests from individuals to exercise their data protection rights in accordance with applicable law.
Your California Privacy
Rights California Civil Code Section § 1798.83 permits users of our Site who are residents of California in the United States to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to our Site, you are responsible for keeping this password confidential. Do not share your password. Be careful about giving out information in public areas of the Site. It may be viewed by others.
Unfortunately, the transmission of information by the internet is not completely secure. We undertake reasonable efforts to protect your personal information. We cannot guarantee its security.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you a service you requested or to comply with applicable legal, tax, or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Changes to Our Policy
We may update this policy in response to changing legal, regulatory, technical, or business developments. When we update our policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material policy changes if required by law. To the extent permitted by law, your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. You can see when this policy was last updated by checking the date beside Last Updated.
How to Contact Us
To ask questions or comments about this policy and our privacy practices, including information regarding how to access or update your data or limit its user or disclosure, contact us as follows:
Zoll Medical Corporation
269 Mill Road
Chelmsford, MA 01824
Attn: Data Protection Officer
THE CIRCULATION ACADEMY Medical Corporation is the data controller the legal entity that determines the purposes and means of processing personal data on this website, known Europe as the data controller.