Privacy Notice and Cookies

1. Introduction

Terumo is committed to protecting your privacy and Personal Data and to respecting your rights.

This Privacy Notice (this “Notice") describes how companies of the Terumo Europe group (Terumo Europe and affiliates, hereinafter referred as Terumo) collect, use, share, transfer, store and secure (collectively “process") your Personal Data, our customers, vendors, healthcare professionals, patients, clinical trial subjects, (website) visitors, shareholders and other contact persons (“Data Subjects").

The controller of your Personal Data is the Terumo affiliated company of the country with whom you are interacting with. You can find an overview of all Terumo entities on our website under following link.

This Privacy Notice is linked to the Terumo Global Privacy Notice that can be consulted here. If you have provided your Personal Data to a different company than Terumo Europe or Terumo Europe Affiliates, in this case, the Global Privacy Notice shall exclusively apply.

If we decide to change the way we process your Personal Data, we will post those changes in this Notice. For some changes, we will notify you more prominently and/or give you prior notice, depending on the legal requirements we will have to comply with. We reserve the right to make changes to our practices and this Notice at any time provided that we follow the procedures above.

This Notice may not address all possible data processing. In some cases, we may provide you with more detailed notice (such as sending you a notification or through other supplementary policies) in relation to the processing of your Personal Data

2. Basic principles

2.1. Compliance with laws: Terumo processes your Personal Data in accordance with applicable laws and regulations.

2.2. Use of Personal data: When Terumo collects your Personal Data, Terumo notifies the purpose to you. You can review the different purposes in the table at the bottom of this document. Terumo will not use your Personal Data for other purposes, unless the use for a compatible purpose is allowed by the applicable law and we have notified you in advance, or we have otherwise collected your consent.

2.3. Security of Personal Data: Terumo takes security measures technically and organizationally to prevent loss, destruction, falsification, divulgence or leakage to outside Terumo of and unauthorized access to your Personal Data. Such measures include access rights management, monitoring of access, anonymization, pseudonymization, careful selection of processors, written agreements with processors, training to our employees and other technically and commercially reasonable measures to provide appropriate protection of your Personal Data.

2.4. Types of information we collect: We may collect and use different types of information, depending on your relationship with Terumo for the purposes of processing and with the legal basis described in the table at the bottom of this document. In addition to the information types, we may collect and use other types of information relating to you that you may have voluntarily provided to us, or that we may have generated from information that was already in our possession.

2.5. Source of your information: We collect the Personal Data that you have voluntarily provided to us (for example by applying or registering for an event, visiting our booth by responding to a survey) or that was provided to us by the company or organization you work for, or by your treating doctor (in case of patients). In exceptional occasions, we may also receive or indirectly collect your Personal Data from other sources such as our business partners, or public sources such as social networks or public websites, especially to learn about your medical academic experience and scientific publications before interacting with you or requesting the provision of the services.

2.6. Retention period: We only keep your Personal Data for as long as it is necessary for the purpose listed on the table below or if it is required by law. However, we may be obliged to store some Personal Data for a longer time, taking into account factors including the establishment, exercise or defense of legal claims (e.g., for the purposes of a potential dispute). Whilst we continue to process your Personal Data, we will ensure that it is treated in accordance with this Notice. Otherwise, we securely erase or anonymize your Personal Data once it is no longer needed.

2.7. Data Subject's rights: Under the privacy laws you have certain rights in relation to the Personal Data we hold about you. This includes (in certain circumstances) the following rights:

To be informed about the processing of your Personal Data
To access your Personal Data

To rectify your Personal Data to ensure it is accurate and up to date
To delete your Personal Data

To restrict the processing of your Personal Data
To object to the processing of your Personal Data;

To lodge a Complaint about the processing of your Personal Data

To withdraw consent

Not to be subject to any decision that significantly affects you and is taken solely by automated processing, including profiling.
To transfer the data that we have collected to another organization, or directly to you.
You can request the exercise of your rights by contacting us at privacy@terumo-europe.com or at the address on the bottom of the document.
If we do not have any other proof of your identity before responding to your request, we may ask you to provide us with acceptable proof to verify the legitimacy of your request and whether all the conditions have been satisfied.

2.8. Results of unavailability of your Personal Data: Providing Personal Data to us is voluntary on your part. You can choose not to provide us your information, however if you do, we may not be able to provide you with the applicable products or services or answer your request.

2.9. Providing the information to third parties: Within Terumo we restrict access to your data to employees and any person acting under our authority on a need-to-know basis, who respect our confidentiality rules and comply with our instructions. Terumo will not sell your Personal Data to any third party. We may share your Personal Data only to third parties stipulated below:

The list of the Terumo Europe companies is available here: Contact
The list of the Terumo Group companies is available here;

Service providers or authorized Distributors: We may also share your Personal Data with our third-party service provides (such as IT services, hosting services, event management services) and authorized Distributors involved in providing our products or services to you. We carefully select these service providers and take steps to ensure that your Personal Data is adequately protected. All our service providers are bound by written contract to process Personal Data provided to them only for the purpose of providing the specific service to us and to maintain appropriate security measures to protect your Personal Data.

Health authorities, the administration of the hospital or supervisor : We may be required by law or industrial code of ethics to disclose your Personal Data to health authorities to comply with the regulations on such as vigilance, transparency reports, clinical trials, application for regulatory or internal approvals, product recalls and other reports.
Other authorities: We may also be requested to disclose your Personal Data as required by other authorities such as ministries, courts, tax agencies, local government offices under laws, regulations, court orders or administrative orders. In this case, only the information specifically requested is disclosed.

Acquirer, investor: We may disclose your Personal Data to our potential acquirer or investor in case of merger, acquisition, assignment, joint venture or other corporate transactions related to Terumo, if necessary for the conclusion of the operation.

2.10. Cross-Border Transfer of Personal Data: We are an international organization, operating globally, and in some cases, we may need to transfer your Personal Data to a country or a region outside the European Economic Area which may not guarantee the same level of protection as the GDPR or the applicable privacy legislation. Before transferring any Personal Data abroad, we will take all necessary measures in accordance with applicable laws and regulations to ensure that the recipient will safeguard the Personal Data respecting our policy and applicable laws.

When we transfer Personal Data from the European Economic Area:

To other companies of the Terumo Group: Any transfer of Personal Data to any of the entities of the Terumo Group, is based on an intra-group data transfer agreement which includes standard contractual clauses as approved by the European Commission to ensure that they provide appropriate safeguard as required by the Applicable Law to your Data.
To other service providers or recipients, we will only transfer Personal Data if appropriate and suitable safeguards for the protection of Personal Data are implemented, in particular, if the recipient entered into the EU Standard Contractual Clauses for the transfer of Personal Data to third countries with us.

2.11. Contact details:

If you have any questions or concerns about the way we collect, store and use your Data, don't hesitate to reach us at privacy@terumo-europe.com.

You can also contact Terumo Europe NV, Privacy Office, Interleuvenlaan 40, B-3001 (Company number: 0408.270.327 - RPR Leuven; VAT BE 0408.270.327)

We will deploy our best efforts to find a quick and fair solution to any concern that you may submit to us.

In addition, if you have reasons to believe that the Processing of your Personal Data by Terumo infringes the Applicable Laws, you have the right, at all times, to lodge a complaint with the supervisory authority of your choice. You can reach the Belgian Data Protection Authority through: www.dataprotectionauthority.be You can find the contact details of other authorities under this link.

TYPE OF DATA SUBJECT, PERSONAL DATA, PURPOSE AND LEGAL GROUND

Types of Data Subject	Type of information	Purpose of processing	Legal basis for the processing
Representatives or contact persons of customers and suppliers	Name of legal representative and/or contact person, mail and e-mail address, telephone number	Providing requested products and services	Contractual obligation
		Managing commercial relationships Sharing communications relating to our products or services Product and service improvement	Our legitimate interest to keep you informed about products or services of your interest
		Managing disputes	Legal obligation
Healthcare professionals	Name, E-mail address, telephone number, employer, role, specialization, registration number in a professional organization (only in certain countries) Hourly fee (only for consultants)	Managing our contract with you as a consultant Managing your participation in Terumo educational events Managing grants and donations requests Organizing travel and registrations at Terumo (internal) events	Contractual obligation
	Bank details (only for consultants)	Communicating our interaction with the HCP for transparency obligations	Legal obligation
	Professional background information to ensure proper setting of the contractual conditions		Legitimate interest of Terumo to comply with industrial codes
	Image and audio	If we are recording and you are a presenter, your audio and in some occasions your video will be captured in the recording. If you are an attendee, in some cases you may decide to share your image and audio if you ask a question or otherwise intervene in the session	Consent
Distributors and external sales representatives	Name Address Email address	Managing business relationships, commercial communications, including offers, orders, requests and inquiries	Execution of a contractual obligation
	Telephone number Backgrounds checking	Logistical organization with healthcare professionals	Legitimate interest to ensure required support to the users of the Terumo devices and services
		Conducting due diligence	Legitimate interest to ensure compliance of distributors Legal obligation
		Managing disputes	Legal obligation
Patients	Pseudonymized patient information including medical history for clinical trials, medical device vigilance or product and service quality improvement	Participation on Terumo sponsored clinical trials/studies	Your consent
	Health related data	To provide you with therapy, products or technical support or training	We are usually a processor for this activity. We receive your data to comply with our contractual obligation with the medical institution that supports your treatment
		Support for customer services	Your consent
Subscribers to / recipients of our marketing materials and/or newsletters	Name, title, email, job function, address, phone number country of practice, areas of interest and preferences, activity data, documents you have downloaded	Sending marketing communications relating to our products and services that you have requested	Consent. In each communication sent, you will find an unsubscribed link that you can use to withdraw your consent Our legitimate interest in maintaining and improving business relationships with our customers and in customizing our offerings and to tailor our communication
Inquires through Terumo’s websites or call centers	Name, E-mail address, telephone number	Responding to your questions, provide you with the required assistance.	Compliance with our legal or regulatory requirements Your consent (in case of processing sensitive data)
Reporters of adverse events. Surveillance	Data that indirectly identifies the patient or person exposed to an adverse health event, such as the person's age, year of birth, gender, weight, height or identification number. Data relating to the identification of the relevant product, such as the type of product used, serial number, date of implant;	carry out health vigilance activities, manage adverse health events and deal with complaints about our products.	Compliance with our legal obligations
Participants to Terumo surveys	Whenever possible, the survey will be anonymous. In case we need personal data we may collect your name, email address and telephone number, your opinion,	gather your feedback and help us determine customer satisfaction levels, identify potential areas for improvement in our products or services, or conduct market research.	Our legitimate interest or your consent
Participants to Terumo events	Name, country (of practice), clinic of practice, specialization, Activity data, e. g. attendance and duration of events you have attended, interactions you have had with us, documents you have downloaded. Information about our business relationship with you.	To allow your registration to Terumo events	Contractual obligation
		To identify your personal interest in our products and services and your business needs, and to improve our personal communications with you and business activities. This data is collected from various sources through which you interact with us, combined and divided into segments. Through the subsequent analysis and consolidation of the data, our offer and our contact are aligned with the interests determined for you and your profile created by us.	Your consent or our legitimate interest in maintaining and optimizing business relationships
Visitors of Terumo facilities	Name, e-mail address, telephone number, company you work for, picture Date and hour of visit, Terumo contact person Your image via CCTV	Providing you with a provisional batch to enable access to our offices	Our legitimate interest in ensuring the safety of our premises
		Ensuring you are aware and respect our security measures and guidelines	Legal obligation
		Ensuring facility or equipment security via CCTV (with the corresponding warning signs)	Our legitimate interest in ensuring the safety of our premises
Visitors of our website	IP address, device type, browser type, pages visited, date and time of the request, or that is transmitted to us through cookies. Please also review the cookies notice	To enable you to visit the websites, to improve and accelerate the presentation of the websites, to adapt and prepare the information offered for specific target groups and to design the websites according to user preference To perform website analytics performance	See cookies notice here
Shareholders	Name, Address, Email address , Telephone number	Managing shareholders’ meeting	Compliance with our legal requirements
		Sending communications (including our newsletter) relating to the company	Our legitimate interest in keeping shareholders informed

12. Cookies

12.1. What are cookies and why are they useful?

Our Website uses cookies. Cookies are small text files that may be stored on your computer (or other device allowing internet access) when you visit a website. You can find out more about cookies for example by visiting www.allaboutcookies.org.

We may use cookies for analytical purposes (to recognize, measure and track users of the Website in anonymous form, to compile anonymous statistics regarding our visitors and to analyse site usage, to determine what features of the Website they access, to verify the origin and duration of access), for usage purposes (to personalize your access to our Website, e.g. when you make a choice about your usage of the Website), to record your consents/refusals on the Website (e.g. consent/refusal to the use of cookies), for technical purposes needed by the internal workings of our servers (e.g. to distribute requests among multiple servers, authenticate users, keep track of information about user's session), or for functional purposes (e.g. store information that is needed by our applications to process and operate).

12.2. Which cookies do we use on our website? Our Web-site uses the following cookies:

Strictly necesssary cookies

Name	Origin	Function	Expiry
HCP policy	terumo-europe.com	Registers the visitor's choice (since it is essential and mandatory by law) whether he is a health care professional or not	Session
ASP.NET_SessionId	terumo-europe.com	Preserves the visitor's session state across page requests.	Session
WSS_FullScreenMode	terumo-europe.com	This cookie is used internally by the web site's owners, when uploading or renewing website content.	Session
OptandonConsent	terumo-europe.com	This cookie is uset by the cookie compliance solution from OneTrust. It stores information about the categories of cookies the site uses and whether visitors have given or withdrawn consent for the use of each category. This enables site owners to prevent cookies in each category from being set in the users browser, when consent is not given. The cookie has a normal lifespan of 1 year so that returning visitors to the site will have their preferences remembered. It contains no information that can identify the visitor.	1 year
OptanonAlertBoxClosed	terumo-europe.com	This cookie is set by websites using certain versions of the cookie law compliance solution from OneTrust. It is set after visitors have seen a cookie information notice and in some cases only when they actively close the notice down. It enables the website not to show the message more than once to a user. The cookie has a normal lifespan of 1 year and contains no personal information.	1 year

Functional cookies

Origin	Function	Expiry
hubspotutk	terumo-europe.com	This cookie name is associated with websites built on the HubSpot platform. Hubspot reports that its purpose is user authentication. As a persistent rather than a session cookie it cannot be classified as Strictly necessary.	5 months

Performance cookies

Name	Origin	Function	Expiry
_ga	www.googletagmanager.com	Registers a unique ID that is used to generate statistical data on how the visitor uses the website.	2 years
_gat	www.google-analytics.com	Used by Google Analytics to throttle request rate	1 day
_gid	www.googletagmanager.com	Registers a unique ID that is used to generate statistical data on how the visitor uses the website.	1 day
Collect	google-analytics.com	Used to send data to Google Analytics about the visitor's device and behavior. Tracks the visitor across devices and marketing channels.	Session

Name	Origin	Function	Expiry
_hjCachedUserAttributes	terumo-europe.com	Used in context with the web site's pop-up questionnaires and messengering. The data is used for statistical or marketing purposes.	1 day
_hjIncludedInPageviewSample	static.hotjar.com	Determines if the user's navigation should be registered in a certain statistical placeholder.	1 day
_hjAbsoluteSessionInProgress	static.hotjar.com	This cookie is used to count how many times a website has been visited by different visitors – this is done by assigning the visitor an ID, so the visitor does not get registered twice.	1 day
_hjFirstSeen	static.hotjar.com	This cookie determines if the user has first time visited.	1 day
_hjid	static.hotjar.com	Sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical purposes.	1 year
_hjTLDTest	static.hotjar.com	Detects the SEO-ranking for the current website. This service is part of a third -party statistics and analysis service.	Session
r/collect	doubleclick.net	This cookie is used to send data to Google Analytics about the visitor's device and behaviour. It tracks the visitor across devices and marketing channels.	Session
SPAnimationEnabled	terumo-europe.com	Detects whether website animated content should be enabled	persistent
__hstc __hssc __hssrc	hubspot	This cookie is associated with websites built on the Hubspot platform. It is reported by them as being used for website analytics.	few seconds 5 months Session
_mkto_trk	adobe marketo munchkin	This allows a website to track visitor behavior on the sites on which the cookie is installed and to link a visitor to the recipient of an email marketing campaign, to measure campaign effectiveness. Tracking is performed anonymously until a user identifies himself by submitting a form.	2 years

Targeting cookies

Name	Origin	Function	Expiry
VISITOR_INFO1_LIVE	youtube.com	This cookie is used as a unique identifier to track viewing of videos.	5 months
YSC CONSENT	youtube.com	Youtube is a Google owned platform for hosting and sharing videos. Youtube collects user data through videos embedded in websites, which is aggregated with profile data from other Google services in order to display targeted advertising to web visitors across a broad rage of their own and other websites.	1 year
VISITOR_PRIVACY_METADATA	youtube.com	Youtube is a Google owned platform for hosting and sharing videos. Youtube collects user data through videos embedded in websites, which is aggregated with profile data from other Google services in order to display targeted advertising to web visitors across a broad rage of their own and other websites.	5 months

Unknown cookies

Name	Origin	Function	Expiry
%40%40 _vs_id.acdb metaDCR-user	library.cirse.org

12.3. How can I delete cookies?

12.4. You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our Website if cookies are disabled. You also have the possibility to remove from your browser cookies set by the Website. Please refer to your browser instructions to learn more about how to adjust or modify your browser settings.

12.5. Hyperlinks

The Website may contain hyperlinks to third party websites, on which we do not have any control. We are not responsible for the use of your personal information by third party Websites accessible via the Website. We encourage you to read carefully the privacy policy and cookies policy of these third party websites before any use;

13. Contact us

If you have any questions or concerns about the way we collect, store and use your Data, don't hesitate to direct them to your contact person at Terumo, who will, where necessary, redirect them to our Privacy Office.

You can also reach us at privacy@terumo-europe.com by attaching a recto verso copy of your identity card to your request.