Introduction

Stryker recognizes that the Personal Information it receives is held in a position of trust. Stryker seeks to fulfill that trust by adhering to general principles regarding the protection of personal information. This Privacy Statement explains how we collect, use, share, and protect information for all purposes as listed above and mentioned in this Statement.

Scope

This Privacy Statement applies to the Personal Information of consumers that is collected or used by Stryker UK Ltd and its affiliates (“Stryker”). This statement applies to all the personal information that Stryker collects when consumers interact with Stryker, such as when visiting our websites, using the products or services offered by Stryker, when purchasing Stryker products or services, when contacting customer service, and when interacting with Stryker as a business customer, supplier or business partner.

This includes, without limitation, all online and offline collections of all types of personal information. However, some Stryker collections involve types of data with special requirements (for example, health information) which require a different privacy notice. Whenever that is the case, Stryker will make it clear that the privacy notice concerned is different from this general privacy statement.

Information collection

Stryker may ask you to provide personal information for purposes including, but not limited to, the following:

• Buying Stryker products and services;
• Activating or registering certain products and services or enhancing functionality;
• Receiving information about Stryker products and services;
• Participating in Stryker online communities, including our social media channels/pages;
• Storing your preferences for future interactions and communications from Stryker;
• Helping us to develop products and services and create campaigns that are designed around you, optimize customer services and continuously improve our websites;
• Helping us to improve products and services, and allowing Stryker to keep you informed of, or involve you in the testing of, new products and services;
• Resolving consumer and/or product and services issues;
• Registering visitors of Stryker facilities or Stryker organized events and conferences;
• Contract or tender management;
• Receiving personalized messages, special offers and advertisements that are relevant to your personal interests, based on the information you have shared with us and on the information we have collected through cookies or similar techniques regarding your use of the Stryker websites/social media/blogs. For more information on how we use cookies, click here

Stryker maintains physical, technical, and administrative safeguards to protect your personal information and only allows disclosures as permitted by law to assist in providing products or services. We may also collect product and service information and provide these statistics to others in an aggregate form where the information has been de-identified.

Personal information collected may include:

• Contact information, such as name, address, email, telephone number, fax number, organization name, and/or job title
• Unique identifiers and preference information such as username, password, marketing preferences, internet protocol (IP) address, browser type, operating system, computer or mobile device, or navigation and clickstream behavior for online interactions
• Resume including work history, professional qualifications, publications, awards, references, completed trainings, signature
• Food restrictions, passport info for travel bookings or identification purposes, social security number (where required by law), bank account details, (emergency) contact persons, family information (where applicable and in accordance with local law)
• Creditworthiness, VAT number, product, purchase information history, request documentation
• Pictures, video and audio recordings where you have provided your permission
• Sensitive Personal Information, such as health information or reports of an individual end-customer, i.e. concerning product claims and investigations, patient pre and post-operative outcomes for research & statistical purposes, or criminal records for due diligence procedures in accordance with applicable law

Stryker will retain and use the personal information collected for above mentioned processes and processing purposes accordance with legal obligations.

Legal Basis

The legal basis Stryker uses to process Personal Information will be dependent on the processing purposes and the jurisdictional legal requirements. Where the Personal Information collected involved is of EU citizens, in general, we use the following basis:

• Consent (permission) to use the Personal Information, i.e. where this involves (digital) direct marketing activities and where we would like to use a photo, video or audio recording with identifiable individuals for external publishing;
• Establishment or performance of a contract, i.e. where we enter into a contract with a party and we collect contact information and signatures, as well as potential bank account details that may be linked to a representative of a company we do business with;
• Compliance with a legal obligation, i.e. where we need to disclose consumer details for compliance with (local or industry) laws such as the Physician Payments Sunshine Act or for compliance with the Medical Device Regulation;
• Legitimate interest of Stryker, i.e. where Stryker collects contact information and preferences, details for lodging and travel for attendees of Stryker organized events & trainings or third party hosted events & trainings in collaboration with Stryker;
• Public interest or for the exercise of public authority in strictly limited cases, i.e. where we would be required to cooperate with the Police or other government bodies in case of illegal conduct;
• For the establishment, exercise or defense of legal claims, i.e. for court cases;
• For scientific or research purposes, i.e. for clinical research studies with sufficient safeguards safeguarding confidentiality
• For preventative and occupational medicine, medical diagnosis pursuant to contract with healthcare professionals;
• For public interest in the public health to ensure high standards of quality and safety of healthcare and products;
• Where the individual chooses to disclose the Personal Information publicly by its own initiative.

If you choose not to provide the personal information we reasonably require, it may hinder Stryker’s ability to provide the information or services you have requested.

Cross-border Transfer

To the extent personal information is transferred out of the country where the owner of that personal information lives, such as to Stryker affiliates or business partners in other countries, including in the United States, different standards may apply to how your data is used and protected in those countries. Stryker has appropriate safeguards in place in accordance with applicable legal requirements to ensure that data is adequately protected irrespective of the country. This includes obtaining written assurances from any third party given access to your data so as to require them to adopt standards that ensure an equivalent level of protection for data as that adopted by Stryker and standardized corporate safeguards and contractual measures (based on the European Commission Model Clauses) for internal data transfers to Stryker affiliates in third countries which are deemed to provide an inadequate level of data protection.

Privacy Statement for children

Stryker will not collect personal information from anyone we know to be under the age of 16 without the prior, verifiable consent from his or her legal representative. Such legal representative has the right, upon request, to view the information provided by the child and/or to require that it be deleted.

How long we keep information

Stryker will retain your personal information for as long as reasonably necessary to comply with legal obligations or for no longer as required for legitimate business purposes.

Information sharing

Stryker may share personal information we have collected with companies or agents doing technological maintenance or working on our behalf to help fulfill business needs, including providing customer services and distributing marketing communications. Stryker may also share personal information with our affiliates.

Other service providers that may be used to perform certain functions on our behalf and to whom personal information may be disclosed in order to perform their intended function include call-center support, sending or processing postal or electronic mail or analyzing or hosting information on cloud-based servers.

Stryker does not share your personal information with unaffiliated third parties for their own direct marketing purposes.

Security

The security and confidentiality of your personal information matters to us. For this reason, Stryker has physical, technical and administrative controls in place to protect your Personal Information from unauthorized access, use and disclosure. Stryker evaluates these safeguards on an ongoing basis to help minimize risks from new security threats as they become known.

Rights

You can contact us directly any time at the address below to update your personal information. Certain personal information may still be retained in accordance with our internal record retention procedures and processes or to the extent necessary to comply with applicable law.

You, as a Data Subject with personal information held by Stryker, have the right to request from Stryker:

(1) Access to your personal information
(2) Rectification or Erasure of your personal information;
(3) Restriction of Processing;
(4) Halting of Processing based on an objection;
(5) Data portability – The ability to move personal information to another company or organization; and,
(6) To withdraw your consent for processing.

Updates to Privacy Statement

This Privacy Statement may be amended at any time. If material changes are made in how personal information is collected, used, disclosed, or otherwise processed, this Statement will be updated and notices will be provided when/where appropriate. Any material changes to this Privacy Statement will be effective at the time of our posting of the notice of the update. Where required to do so by law, Stryker may seek your prior consent to any material changes we make to this Privacy Statement.

The Statement was last updated on [21-06-2018]

Contact

If you have any questions, complaints, or comments about this Privacy Statement, please contact us. Stryker will use reasonable efforts to respond to you as soon as possible.

Send mail to:
Stryker UK Ltd
Attn.: Compliance Officer
Stryker House Hambridge Road
Newbury, Berkshire RG14 5AW

europe.privacy@stryker.com

If we fail to respond to your complaint within a reasonable period of receiving it in writing, or if you are dissatisfied with the response that you receive from us, you may lodge a complaint with the data protection authorities in your home country.