Global Regulations

Permobil has an international presence, with offices and facilities in multiple jurisdictions. For more information regarding our compliance with your country’s data protection regulation, please contact us.

To offer our Products, we may need to transfer your Personal Information to recipients in countries other than the country in which the information was originally collected, such as when Permobil personnel and third parties acting on our behalf access, use and process your Personal Information in a country that is different from the country where you reside. Those countries may not have the same data protection laws as the country in which you initially provided the information.

When we transfer your Personal Information to other countries, we protect that Personal Information as described in this Notice, in the manner required by applicable data transfer regulations, and as disclosed to you at the time the data is collected.

Permobil uses approved Model Contractual Clauses (Article 46.2 GDPR), (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en) for the international transfer of personal information collected in the European Economic Area and Switzerland.

Permobil acts as either a Controller or Processor of your Personal Information. We adhere to the guidelines set by the General Data Protection Regulation (GDPR) throughout our company and as described in this Notice.

How Permobil Processes Personal Information Under the GDPR

Purpose and/or Activity Type of Personal Information Source of Personal Information Legal Basis for Processing
To provide you with My Permobil solutions or provide access to our website. Identity Information
Contact Information
Measurement Information
Sign-in Information
Limited Health Information
Location Information
Directly from you or from your dealer or clinician.

Consent

To manage our relationship with you which will include notifying you about changes to our terms of business or this notice Identity Information
Contact Information
Directly from you or from your dealer or clinician. Legitimate Interests: ensuring we can notify you about changes to our terms of business or this notice
To interact with governmental or regulatory bodies or other authorities in relation to you Identity Information
Contact Information
Directly from you or from your dealer or clinician.

Legal or Regulatory Obligation

To manage and protect our business, including improving data security, troubleshooting data and systems, system maintenance and testing, data hosting, managing our offices and other facilities Identity Information
Contact Information

Technical Information
Usage Information

Directly from you or from your dealer or clinician. Legitimate Interests: ensuring the efficient and secure running of our business, including through office and facilities administration, maintaining information technology services, network and data security, fraud prevention and improving or reorganising our infrastructure
To invite you to take part in marketing or other promotional events, or client seminars or similar events, and to manage your participation in them Identity Information
Contact Information
Directly from you or from your dealer or clinician. Legitimate Interests: ensuring our end user records are up to date, promoting our products and services, identifying ways to grow our business
To send you marketing (including paper and electronic marketing communications) or to contact you by other means to offer you our products and services Identity Information
Contact Information
Directly from you or from your dealer or clinician. Legitimate Interests: promoting our products and services, identifying ways to grow our business

Permobil does not perform any known automated decision-making, including profiling.

Your Right to Lodge Complaints

You always have the right to lodge a complaint with the relevant supervisory authority where you live, work or where an alleged infringement of the GDPR has occurred. You can find the relevant authority in your country at the following link: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

As a medical device manufacturer, Permobil may act as a health care provider when determining the proper type or size of the device that is needed for a particular patient. For more information about our HIPAA related practices, please contact us at: privacy@permobil.com.

Current privacy laws in the US are sectoral and state based. Because of this, describing our privacy practices for each state or sector would be cumbersome for you to read and we want to ensure that you can find the information you need to make decisions about your Personal Information. For this reason, we are describing our practices in only a few of the states where we do business. Regardless, we will treat all Personal Information according to all sectoral and state specific privacy laws and practices that apply to our business. For more information, please contact us.

Your California Privacy Rights

THIS SECTION OF OUR PRIVACY NOTICE IS FOR U.S. CALIFORNIA STATE RESIDENTS and applies solely to visitors, users, and others who reside in the state of California (“California Residents”). The terms in this section have the same meaning as defined in the California Consumer Privacy Act of 2018 (CCPA) and other applicable California privacy laws.

CCPA permits California residents to certain privacy rights as they relate to the collection, security, quality, access, use and disclosure of your personal information.

We will not discriminate against you for exercising any of your rights under CCPA, including:

• Denying goods or services.
• Charging different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Providing a different level or quality of goods or services.
• Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Your CCPA Defined Personal Information

To learn about the categories of information we collect, please see "What Information Do We Collect About You" above. To learn about the categories of sources of information we collect, see "How Do We Collect Your Personal Information" above. To learn about how we use and share your information, see "How Do We Use Your Information?" above. For more information about our practices related to the CCPA, please contact us at privacy@permobil.com.

Requests to Know or Delete CCPA Defined Personal Information

You have the right to request that we disclose what Personal Information we collect, use, disclose and sell including categories of Personal Information collected, categories of sources and third parties, our purposes, and specific pieces of Personal Information we collected about you.

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions such as completing transactions, security reasons, legal compliance and other internal lawful uses.

To request this information please submit a verifiable consumer request to us by either:

• Calling us at 1.800.736.0925 or
• Emailing us at privacy@permobil.com and asking for a Consumer Request Form
• Completing and submitting the Data Subject Request Form on our website

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. To make a request, you must provide enough information to allow us to reasonably verify that you are the person about whom we collected Personal Information or that you are an authorized representative.

We will respond to your request within forty-five (45) days of when we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

Selling CCPA Defined Personal Information

We do not and will not sell your Personal Information to third parties. If we change that practice in the future, we will update our privacy policy and provide an opt-out link pursuant to the CCPA. We will treat any information that we collected prior such a change as though you opted-out of the sale of your Personal Information

Direct Marketing

California Civil Code Section 1798.83 permits California residents 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 at: privacy@permobil.com.

Tracking Signals

California law requires that we disclose how Permobil responds to web browser "Do Not Track" signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information (as that term is defined in California law) about a consumer's online activities. Our Products do not currently support "Do Not Track" codes. That is, Permobil does not currently respond to or take any action regarding "Do Not Track" requests.

Your Rights Under the Personal Information Protection and Electronic Documents Act (PIPEDA)

1. Accountability - We are responsible for the personal information under our control. Our Privacy Officer oversees our privacy program.
2. Identifying purposes - We explain why we collect the personal information we ask for. When we authorize other parties to collect information on our behalf, they do the same. Learn more about how we use your personal information.
3. Consent - We need your permission to collect, use, and disclose personal information, with some exceptions. The exceptions are determined by law and can include times where legal, medical, or security reasons make it impossible or impractical to seek consent. You can give consent in writing, as well as verbally, electronically, or through authorized representatives. In certain circumstances, it’s also implied. Learn more about consent.
4. Limiting collection - We only collect your personal information in fair and legal ways. The information we collect is limited to identified purposes. Learn more about how we use your personal information.
5. Limiting use, disclosure, and retention - We only use or disclose your personal information for the reasons it’s collected. We use it for other purposes you consent to, or when it is required or allowed by law. We keep the information only for as long as we need to, or as required or allowed by law. Learn more about how we use your personal information.
6. Accuracy - Any personal information that we collect, use, or disclose should be as correct, complete, and up-to-date as possible for the reasons it is used. If your contact information changes, please contact us right away.
7. Safeguards - To protect your personal information from intrusion, release, or misuse, we use security safeguards that match the sensitivity level of the information. Learn more about our Data Protection and Security Safeguards.
8. Openness - We make information about our privacy policies and how we manage your personal information available to you.
9. Individual access - If you submit a request, we tell you what personal information about you we have, and how we use and disclose it. We give you access to the information, with certain exceptions allowed by law. You may verify the accuracy and completeness of your information and request changes, if appropriate. Learn more about accessing your information.
10. Inquiries and concerns - Contact us if you have any questions or concerns about our privacy policies and practices.

Opting Out of Third Party Advertising

If you reside in Canada, you may be able to use the tool developed by the Digital Advertising Alliance of Canada to opt out of third-party advertising. By using this tool, you can obtain a list of parties that may target advertisements based on your online web-browsing activities. It also allows you to opt out of their use of your information for that purpose. You can find the tool at the following link: https://youradchoices.ca/choices/.

Because Permobil has a presence in Australia, we are required to meet the requirements of Australia’s Privacy Act in relation to the collection, security, quality, access, use and disclosure of personal information. For more information about our practices related to the Australian Privacy Principles (APPs), please contact us at: privacy@permobil.com.

How to Make a Complaint Under the Australian Privacy Principles

If you believe that your privacy has been compromised, or if you feel that we have breached the APPs or mishandled your personal information, you are entitled to make a complaint by contacting us. If you are dissatisfied with how we handle any complaint you raise under this Privacy Notice, you may wish to contact the Office of the Australian Information Commissioner.

Because Permobil has a presence in Japan, we are required to meet the requirements of Japan's Act on the Protection of Personal Information (APPI) in relation to the proper handling of Personal Information. For more information about our practices related to Japan's APPI, please contact us at: privacy@permobil.com

Because Permobil has a presence in New Zealand, we are required to meet the requirements of New Zealand’s Privacy Principles in relation to the collection, security, quality, access, use and disclosure of Personal Information. For more information about our practices related to New Zealand’s Privacy Principles, please contact us at: privacy@permobil.com.

If you are a New Zealand resident, and you are dissatisfied with how we handle any complaint you raise under this Privacy Notice, you may wish to contact the Office of the Privacy Commissioner.

Because Permobil has a presence in Singapore, we are required to meet the requirements of Singapore's Personal Data Protection Act (PDPA) in relation to the collection, security, access, quality, use and disclosure of Personal Information. For more information about our practices related to Singapore's PDPA, please contact us at: privacy@permobil.com.

Because Permobil has a presence in South Korea, we are required to meet the requirements of its Personal Information Protection Act (PIPA) in relation to the collection, use and disclosure of Personal Information. For more information about our practices related to South Korea’s PIPA, please contact us at: privacy@permobil.com.


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