Requirement: Pixels on USA website = LinkedIn, Google Retargeting, Eloqua, etc
Legal Guidance, Gaps and/or Requirements
- Deletion – No specific legal requirement in USA (only EU/GDPR)
- Optin vs Optout – No specific legal requirement to get opt-in approval à some 3rd-parties may require opt-out option (EG, LinkedIn)
- Requirement – Be more specific/accurate, include some examples so a layman can understand
Siemens Healthcare GmbH Commitment to Data Privacy Protection
Protecting the security and privacy of your personal data is important to Siemens Healthcare GmbH (”Siemens Healthineers”); therefore, we conduct our business in compliance with applicable laws on data privacy protection and data security. We hope the policy outlined below will help you understand what data Siemens Healthcare GmbH may collect, how Siemens Healthcare GmbH uses and safeguards that data and with whom we may share it.
Through our websites (the "Siemens Healthineers Website"), Siemens Healthcare GmbH will not collect any personal data about you (e.g. your name, address, telephone number or e-mail address), unless you voluntarily choose to provide us with it (e.g. by registration, survey), respectively, provide your consent, or unless otherwise permitted by applicable laws and regulations for the protection of your personal data. From time to time, we may collect personal data about you indirectly from sources other than through our own websites. The personal data that we collect from various sources may be combined.
Use of Third Party Analytics
On our Web site we may use variety of third party analytics, and “pixel tracking” (also referred to as “web beacons”), in order to constantly improve the site, identify errors, and/or customize the information included in the site. For this purpose certain data may be stored such as the Web site visited, including its metadata, the Internet pages referring to Siemens, the time at which the Web site was called up and the browser used. In order to exclude your computer or device from third party data aggregation and analysis occasioned by your visit to this Web site, please click here. This will set an exclusion cookie in your browser. While it contains no personal data, it enables third parties to recognize your preference going forward. If you delete this exclusion cookie or change your computer or Internet browser, you must set the exclusion cookie again.
Purpose of Use
When you do provide us with personal data, we usually use it to administer your use of the site, respond to your inquiry, process your order or provide you access to specific information or offers, or verify your identity. Also, to support our customer relationship with you:
- we may store and process personal data and share it with our worldwide affiliates to better understand your business needs and how we can improve our products and services; or
- we (or a third party on our behalf) may use personal data to contact you about a Siemens Healthcare GmbH offer in support of your business needs or to conduct online surveys to understand better our customers' needs.
If you choose not to have your personal data used to support our customer relationship (especially direct marketing or market research), we will respect your choice.
We may employ third party companies and individuals to host or support our websites, applications, or the services to which they relate. These third parties may have access to your personal data to perform such tasks. We do not sell or otherwise market your personal data to third parties that are unaffiliated with Siemens Healthcare GmbH.
To the extent required to help us fulfill your orders or requests, we may share personal data with others, such as our business partners, vendors, service providers, distributors, customers, postal/logistics companies, or customs agents/authorities.
We may transfer your personal data and process it outside your country of residence. We may transfer your personal data if we sell or transfer all or a portion of our business or assets, including to any successor company whether via merger or otherwise.
Siemens Healthcare GmbH will collect, use or disclose personal data supplied by you online only for the purposes disclosed to you, unless the disclosure:
is a use of the personal data for any additional purpose that is directly related to the original purpose for which the personal data was collected,
is necessary to prepare, negotiate and perform a contract with you,
is required by law or the competent governmental or judicial authorities,
is necessary to establish or preserve a legal claim or defense,
is necessary to prevent fraud or other illegal activities, such as willful attacks on Siemens Healthcare GmbH information technology systems.
Communications or Utilization Data
Through your use of telecommunications services to access our Website, your communications data (e.g. Internet protocol address) or utilization data (e.g. information on the beginning, end and extent of each access, and information on the telecommunications services you accessed) are technically generated and could conceivably relate to personal data. To the extent that there is a compelling necessity, the collection, processing and use of your communications or utilization data will occur and will be performed in accordance with the applicable data privacy protection legal framework.
Non-Personal Data Collected Automatically
When you access our websites, we may automatically (i.e., not by registration) collect non-personal data (e.g. type of Internet browser and operating system used, domain name of the Website from which you came, number of visits, average time spent on the site, pages viewed). We may use this data and share it with our worldwide affiliates to monitor the attractiveness of our websites and improve their performance or content.
"Cookies" – Information Stored Automatically on Your Computer
When you view one of our websites, we may store some data on your computer in the form of a "cookie" to automatically recognize your PC next time you visit. Cookies can help us in many ways, for example, by allowing us to tailor a Website to better match your interests or to store your password to save you having to re-enter it each time. If you do not wish to receive cookies, please configure your Internet browser to erase all cookies from your computer's hard drive, block all cookies or to receive a warning before a cookie is stored.
In addition, we may advertise using online marketing technology. In doing so, a third-party will place or read a unique ad-serving cookie on your computer or device and will use non-personal information about your browser and your activity at this site to serve Siemens ads on their content network. The ad-serving cookie is a persistent cookie. Please click here for more information about remarketing or to opt-out of the remarketing cookie.
Siemens e-mail communications may include web beacons to determine whether the emails have been opened or whether any included links have been clicked on.
Do Not Track
At this time our Web sites do not recognize or respond to “Do Not Track” browser signals. For more information on “Do Not Track”, please visit your browser’s support page.
Siemens Healthcare GmbH will not knowingly collect personal data from children without insisting that they seek prior parental consent if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent pursuant to local law and regulations or to protect a child. The definition of “child” or “children” should take into account applicable laws as well as national and regional cultural customs.
To protect your personal data against accidental or unlawful destruction, loss or alteration and against unauthorized disclosure or access, Siemens Healthcare GmbH uses technical and organizational security measures.
Links to Other Websites
Siemens Healthineers Website contain links to other websites. Siemens Healthcare GmbH is not responsible for the privacy practices or the content of other websites.
Questions and Comments; Changes
Status: October 2018
Protecting the security and privacy of your personal data is important to Siemens Healthineers. Therefore, the Siemens Healthineers company referred to under “Corporate Information” and Siemens Healthcare GmbH (hereinafter individually or jointly referred to as “Siemens Healthineers”) provide their Service in compliance with applicable laws on data privacy protection and data security.
“Seismic” is a cloud-based sales enablement platform used by Siemens Healthineers worldwide to manage and share marketing content. Seismic is operated on behalf of Siemens Healthineers by Seismic Software, Inc. with registered seat in San Diego CA, USA.
You may use Seismic LiveSend to access marketing content sent by Siemens Healthineers employees as part of your (company’s business) relationship with Siemens Healthineers.
In the following, we provide information on the kinds of data collected by Seismic, the purposes for which we use such data, and the parties with which we share such data, where applicable.
The following categories of personal data will be processed:
“Personal Data” include your e-mail address as provided during your relationship with Siemens Healthineers.
“Usage Data” is information collected during a viewing session (such as information about the start and duration of a session, the time spent on each page of the marketing content, your operating system and web browser).
Seismic uses the following types of Cookies:
These are Cookies that are required to provide you with features or services that you have requested. Disabling these Cookies will encumber the Seismic Services’ performance and may make certain features and services unavailable.
These Cookies allow Seismic to understand how visitors use the site. This includes information about the number of visitors to the site, what pages visitors view on the site and how long visitors are viewing pages on the site.
Session Cookies and Persistent Cookies
The types of Cookies described above may be “session Cookies” which are temporary Cookies that are only stored on your device while you are visiting the site or “persistent Cookies” which are Cookies that are stored on your device for a period of time after you leave the site. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie. Seismic use persistent Cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Seismic Services, how often you return, how your use of the Seismic Services.
At any time, you can decide to opt out of tracking by clicking here.
Purpose of processing
The purpose of collecting and processing your data is to help us understand how the marketing content resonated with you to improve your experience while interacting with Siemens Healthineers and to create more relevant content in the future.
We will only collect and process your data in line with the purpose listed above.
Sharing of data
Insofar as you have provided your consent or when we are otherwise legally entitled to do so, we will share your personal data with Group Companies of Siemens Healthcare GmbH, where applicable, for the purposes indicated above.
For the purpose of processing, your data are shared with Seismic Software, Inc and their subcontractors.
These recipients may possibly be located in countries outside of the European Economic Area (“third countries”), in which applicable laws do not offer the same level of data privacy protection as in your home country.
In such cases, Siemens Healthineers takes measures to ensure an appropriate level of data privacy protection, such that your personal data are shared with external recipients in third countries only if the recipient has (i) entered into EU Standard Contractual Clauses or (ii) implemented Binding Corporate Rules in its organization.
Data is shared only in connection with and in compliance with applicable laws and regulations. We do not sell or otherwise market your personal data to third parties.
Unless explicitly indicated otherwise at the time of the collection of personal data (e.g. within a consent form accepted by you), we erase personal data if the retention of the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed and no statutory retention obligations under applicable law (such as tax or commercial law) require us to further retain personal data.
Right to withdraw consent
If you no longer want to receive email messages of this kind and be deleted from the system that generated this email, please click here. Siemens Healthineers GmbH may only further process the personal data where there is another legal ground for the processing.
Data Protection Contact
Siemens Healthineers will respond to all legitimate requests for information and where applicable, to correct, amend, or delete your personal data.