Last Updated: 19 Oct 2018
Alere Inc. respects the privacy of its customers and visitors to its website and applications, and is committed to protecting the privacy of the Personal Data (defined below) that you share with us.
2. What is Personal Data?
“Personal Data” is any information that identifies you or from which you could be identified, in particular by reference to an identifier such as a name, an identification number, location data, an online identified or one or more factors specific to the physical, psychological, genetic, mental, economic or social identity. Personal Data includes subsets of special categories of information that reveal information about your health, among other things.
3. Why does Alere process your Personal Data?
Alere processes your Personal Data:
- [to perform a contract with you, such as where you sign up or register for our services or download and use one of our mobile apps;
- to comply with local EU laws, such as in relation to product safety;
- to fulfil its legitimate business interest in doing so, such as for direct marketing, product development purposes or for research purposes or to defend Alere;
- to protect an individual’s vital interests, such as in relation to the provision of medical care;
- where there is a public interest to do so, such as for scientific research purposes or in relation to national health care services; or
- where you have consented to the processing of your Personal Data.]
Alere also collects health data about EU individuals who use Alere products, for medical device reporting, warranty and product support purposes. Under the GDPR, this is sensitive Personal Data. We will only process such sensitive Personal Data where you explicitly consent.
[If you are a child, we will only process your Personal Data if we have obtained consent from your parent(s) and/or guardian(s).]
4. Who does Alere share your Personal Data with?
Alere may share your Personal Data with its affiliate companies within its corporate group.
[Alere may also share your Personal Data with vendors with whom Alere contracts to carry out business activities for Alere. If Alere provides your Personal Data to vendors to assist us with our business activities, it is Alere’s practice to require those vendors to keep your Personal Data confidential and to use your Personal Data only to perform functions for Alere.
Alere may share your Personal Data with a third party in connection with the sale or transfer of one of its product lines or divisions so that the buyer can continue to provide you with information and services.
Alere reserves the right to disclose your Personal Data to respond to authorized information requests from government authorities, to address national security situations, or when otherwise required by law.]
5. Does Alere transfer your Personal Data outside of Europe?
We may need to transfer your Personal Data outside of the European Economic Area (“EEA”) to third countries which do not offer the same level of protection as required by the EEA. In order to safeguard your Personal Data we will only make such transfers on the basis of: (i) a decision of the European Commission that permits this; or (ii) EU-approved Standard Contractual Clauses. Please note, Alere and all subsidiaries and related entities have entered into intragroup data transfer agreements based on the EU Standard Contractual Clauses to transfer your Personal Data from the EEA to third countries, which includes the United States. To access or receive a copy of our intragroup data transfer agreement, please contact our EU data protection officer (details below).
6. How long does Alere store your Personal Data for?
Your Personal Data will be stored for as long as it is needed to provide you with: (i) the Alere service or product that you have requested; and/or (ii) access to the Alere Websites. Alternatively, your Personal Data will also be stored for as long as we require it to respond to your queries and concerns or in accordance with any legal requirements, including those in relation to product or medical device safety. For further information please contact your local customer care or our EU data protection officer using the details below.
7. What Alere does to keep Personal Data secure?
8. What rights do you have in relation to your Personal Data?
You may have the following rights in relation to your Personal Data:
- The right to rectify, or erase any wrong or incomplete Personal Data that Alere holds about you;
- The right to access the Personal Data that Alere holds about you;
- The right, in some cases, to object to the processing of your Personal Data where we process it on the basis of our legitimate business interests;
- Where you have provided your Personal Data to us with your consent or as part of a contract, the right to the portability of that Personal Data to another person or, if it’s technically feasible for us to do so, to another company;
- The right to lodge a complaint with your local data protection supervisory authority or to receive compensation for any damage you suffer; and
- The right to withdraw your consent to Alere’s processing of your Personal Data without detriment, where you have provided consent for Alere to process your Personal Data.
We may ask you for additional information to confirm your identity and for security purposes, before responding to any request you submit.
Where you have been asked to consent to the processing of your Personal Data, we will provide you with an opportunity to withdraw your consent. There may be several methods by which you can withdraw consent, such as by contacting us directly or by deleting an Alere mobile app from your smartphone. In each case you will be given information about how to withdraw consent. Any withdrawal of consent will not affect the lawfulness of the processing based on your consent before the withdrawal. Please also note that where you withdraw consent, Alere will only stop processing your Personal Data that relates to the withdrawal of consent.
Alere may still need to process Personal Data where:
- we are required to do so by law;
- we have a legitimate business interest to do so, such as in connection with the sale or transfer of our product lines or divisions;
- necessary to respond to authorized information requests from government authorities;
- necessary to address national security situations; or
- otherwise required by law to which we are subject.
9. Why do Alere Websites use “cookies” and other tracking technologies?
Alere may use “cookies” to collect other information during an individual’s visit to the Alere Websites, such as the particular site areas visited and the services utilized through our website. We collect this information to better tailor our site and our products to your interests and needs. Cookies may also be used to help speed up your future activities on our site. For example, a site can recognize that you have provided Personal Data to use and refrain from requesting the same information a second time. Most browsers are initially set to accept a cookie. Cookies may be disabled by the individual visitor, although refusal of cookies at the site may result in an inability to visit certain areas of the site or to receive personalized information when visiting the site.
In addition, we are constantly trying to improve how we promote our websites. To help us do this, we may measure the effectiveness of our web presence by determining when you accessed the Alere Websites, and what you clicked on within our site. Site measurement statistics may be used to personalize your website experience, as well as to evaluate – anonymously and on an aggregated basis – statistics about usage of the website. Information about your computer or device, such as your IP address (a number assigned to your computer whenever you surf the Internet), the type of Internet browser you are using, the type and version of operating system you are using and device model may also be collected and linked to your Personal Data. This is to ensure that the Alere Websites presents the best web experience for visitors, and that they are effective information resources.
Some of the pages an individual visits may also collect information through the use of pixel tags (also called clear gifs) that may be shared with third parties which directly support Alere’s promotional activities and website development. For example, website usage information about visitors to the Alere Websites may be shared with our third party advertising agency in order to better target Internet banner advertisements on the Alere Websites. The information collected through the use of these pixel tags is not, however, personally identifiable, although it could be linked to an individual’s Personal Data.
10. What types of cookies are operating on Alere Websites?
- Strictly necessary cookies: these are essential in order to enable you to move around the Alere Websites and use its features. Without these cookies, the services you have asked for cannot be provided.
- Performance cookies: also known as “analytical” cookies. These cookies allow us to recognize and count the number of visitors and to see how visitors move around the sites when they are using them. For example, they allow us to understand which pages are visited most often, and if they get error messages from web pages. All information collected by these cookies is aggregated and therefore anonymous.
- Functionality cookies: these cookies are necessary for our website to operate and allow us to remember what choices you make and provide enhanced, more personal features. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
12. Google Analytics
Some Alere Websites use Google Analytics to collect information about how users use the Alere Websites. The information generated by the cookie about your use of the Alere Websites will be transmitted to and stored by Google on servers in the United States. In case IP-anonymization is activated on this Website, your IP address will be partially used within the European Union. Only in exceptional cases will the full IP address be transferred to a Google server in the United States, and then shortened so it is only partially used there. The IP-anonymization is active on this Website.
13. Do I have to provide my Personal Data to Alere?
The provision of Personal Data to Alere is required to fulfil the terms of a contract you have with Alere, to provide you with a product or service you have requested or to comply with local laws, such as those relating to product or medical device safety. Any failure to provide such Personal Data will mean that Alere cannot provide you with the product or service you have requested.
14. Who can I contact?
To exercise any of your rights in connection with your Personal Data or if you have any questions or concerns as to the processing of your Personal Data, please contact our EU Data Protection Officer at http://www.abbott.com/eu-dpo.html.