We recognize the importance of your privacy and maintaining the confidentiality of your Personal Data. This Privacy Statement describes how Medline Industries, LP, and affiliated companies (“we”, “us”, “our” or “Medline”) may collect, use, store, process, disclose, or transfer Personal Data collected from you or third parties, both online and offline, in connection with our products, websites, applications, clinical trials, and online ecommerce platforms (collectively, the “Services”) as well as information we collect directly from you when you engage with us by email, phone, survey responses, reporting quality issues, while attending events and webinars, to request materials or information about Medline, and when you visit any of our locations.
We follow this Privacy Statement in accordance with applicable law in the places where we operate. In some cases, we may provide an additional data privacy notice specific to certain products, practices, or regions. Please read this Privacy Statement carefully, together with any other privacy notice we may provide to you, so that you are aware of how and why we are using Personal Data.
This Privacy Statement does not apply to Personal Data that we collect and process in the context of your past, present, or potential employment or other employment relationships with us. Employees and job applicants will receive additional privacy notices to supplement this Privacy Statement. This Privacy Statement does not apply to Personal Data that we collect and process that is governed by the Health Insurance Portability and Accountability Act (HIPAA).
Respecting the privacy of our customers, suppliers, and employees is essential. To ensure compliance and to align with the values of Trust, Transparency, and Reasonableness, we follow the following principles when handling your Personal Data:
• TRUST
° We collect and use only what we need to achieve our business objectives and dispose of Personal Data when no longer necessary. We gain your trust by doing what we say we will do and act consistently with our promises.
TRANSPARENCY
° We tell you how we use your Personal Data and whom we will share it with.
• REASONABLENESS
° If we collect it, we protect it by ensuring appropriate security controls are in place to prevent unauthorized access and use.
° We honor your preferences and communicate with you in a timely manner.
More detail on how we achieve Trust, Transparency and Reasonableness is found by clicking the links below.
We are committed to treating your Personal Data with care and integrity. Privacy matters to Medline not only because we have legal and ethical obligations to treat Personal Data carefully and in accordance with laws and company policy, but because Medline understands that privacy is important to you.
Personal Data includes any information that could be used to identify you directly or indirectly, when combined with other information in Medline’s possession.
We collect and process your Personal Data in a lawful manner for the legitimate business purposes listed in the chart below, under the legal basis of fulfilling our contractual obligations to you, with your consent, when needed, and consistent with our legitimate business interests, for example, to enable us to run our business successfully. These interests are described in more detail under the purposes listed below.
We collect the following categories of Personal Data for the purposes listed in the chart below.
| Category of Personal Data | Purposes of Collection |
|---|---|
| Name, Contact Information, and other Identifiers. Identifiers such as a name (including prefix or title), postal address, unique personal identifier, online identifier, internet protocol address, email address, phone number, or other similar identifiers. | We use this information for the following legitimate business purposes: – providing you with products and services. – fulfilling our contractual obligations. – managing and responding to customer service inquiries. – managing our business relationship. – creating user profiles to personalize your experience. – improving our products and services. – sending marketing communications. |
| Professional or Employment-Related Information. This includes the name of your company, your professional roles and responsibilities, job title, and business contact information. | We use this information for the following legitimate business purposes: – providing you with products and services. – fulfilling our contractual obligations. – managing our business relationship. – creating user profiles to personalize your experience. – sending marketing communications. – providing information on educational opportunities. |
| Financial Information. This may include account details collected in connection with your purchase information. | We use this information for the following legitimate business purposes: – providing you with products and services. – fulfilling our contractual obligations. – managing our business relationship. |
| Internet or other electronic network activity. This includes, but not limited to, your interaction with websites, applications, and your online preferences. | We use this information for the following legitimate business purposes: – providing you with products and services. – managing our business relationship. – creating user profiles to personalize your experience. – improving our products and services. – sending marketing communications. |
| Geolocation Information. Precise geographic location information about a particular individual or device. | We use this information for the following legitimate business purposes: – providing you with products and services. – managing our business relationship. – improving our products and services. – sending marketing communications. |
| Audio, electronic, or visual Information. This may include pictures of your head and shoulders or voice recordings from customer service. | We use this information for the following legitimate business purposes: – providing you with products and services. – managing and responding to customer service inquiries. – managing our business relationship. – improving our products and services. |
| Other information that you provide. You may provide other categories of information, including sensitive Personal Data, that we do not request in your communications with us. | We will limit our collection and processing of sensitive Personal Data to the extent possible. Please only provide the necessary information in your communications. |
In addition to the purposes listed above, we may process any of the categories of Personal Data listed above for the following legitimate business interests to:
We collect your Personal Data directly from you when you register as a customer, sign up for educational materials or events, or engage with us by email, phone, or survey responses. When we have not received the Personal Data from you, we might have received it from other sources such as:
Medline has not sold and will not sell your Personal Data.
Medline is an international organization with affiliates across the world. The data we collect through the job application process may be stored and processed in any country where we have facilities or in which we engage service providers, including in the U.S. and where our affiliates operate. For a complete list of companies associated with Medline, please contact us at the address, email, or phone number as stated in the “How to Contact Us” section below. Medline may need to disclose and transfer Personal Data outside of your home country where we collect it from you where necessary, proportionate, and consistent with the purpose for which it was collected. We may transfer data from all categories listed in the chart above to the following parties for the following purposes:
The data privacy laws in the countries we transfer your Personal Data to may not be the same as the laws in your home country. For Applicants located in the European Economic Area (EEA), the European Commission recognizes that some countries outside the EEA have similar data protection standards. The full list of these countries is available here. In instances where your Personal Data is transferred to countries not on this list, Medline implements appropriate measures to protect your Personal Data such as data transfer agreements that incorporate standard data protection clauses consistent with applicable legal requirements.
Your Personal Data held by us will be kept confidential in accordance with applicable Medline policies and procedures. We have put in place reasonable technical and organizational security measures that are designed to help protect your Personal Data from loss or unauthorized disclosure. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Medline limits access to your Personal Data to those employees, service providers, agents, contractors, and other third parties who have a legitimate business need, in accordance with our instructions and subject to a duty of confidentiality.
Medline will only keep your Personal Data for as long as it is necessary to fulfill the above-mentioned processing purposes, or as required to comply with applicable legal requirements. After the original purpose of collection has ended, your Personal Data will be deleted or rendered anonymous, unless: (i) it is necessary to satisfy Medline’s audit requirements, (ii) to meet Medline’s legal obligations, or (iii) to fulfill other legitimate interests. We consider the following criteria to determine the appropriate retention period for your Personal Data: the nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, and applicable legal requirements. If Personal Data is needed for a legal claim, Medline will retain this data for as long as the issue is active and up to the time when the statute of limitation has expired.
In some circumstances, you can ask us to delete your Personal Data (see the section on “Your Rights” below).
Medline websites, applications, and other Personal Data collection points are not intended for use by children under the age of 18, and we do not knowingly collect Personal Data from anyone under the age of 18.
You may have certain rights with respect to how your data is handled. These rights vary depending on your local law and depending on Medline’s reason for processing your Personal Data. Please note that certain Personal Data or requests may be exempt pursuant to applicable laws and regulations. We will respond to your request consistent with applicable law. In your request, please make clear which rights you are exercising and what treatment or limitation you would like us to apply to your Personal Data.
For your protection, we limit the information we provide you to only to the information associated with your request, and we may need to verify your identity before processing your request. We will try to comply with your request as soon as reasonably practicable. Depending on the above, you may have the right to:
In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer collect, process, or transfer your Personal Data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
We may offer a different price, rate, level, or quality of goods or services to you in exchange for you providing your contact information, such as an email address, where that price or difference is directly related to the value provided to the business by the consumer’s data. We will only enter you into an incentive or incentive program if you opt-in, and you may opt-out at any time.
We collect information about your online interactions with us through tracking and data-collection technologies such as cookies, web beacons and pixels, APIs, web services, scripts, browser analysis tools, and server logs. You can choose to opt-in, opt-out or decline cookies at any time; however, if you choose to opt-out of or decline cookies, not all elements of our websites, applications and services may function as intended, so your experience may be affected. To the extent that your local laws consider the information collected by cookies and other technologies as Personal Data, we will treat that information to the standards set out in this Privacy Statement. If the retention period of a cookie or pixel is not noted, then the default is twelve (12) months, unless a shorter retention period is required by law.
A “cookie” is a unique numeric code that is transferred to your computer to track your interests and preferences and to recognize you as a return visitor. A “pixel tag” (also known as a web beacon) is a transparent graphic image placed on a website, email, or advertisement that enables the monitoring of things such as user activity and site traffic, including the collection of data about the website or mobile application you were visiting before and after you came to our websites and applications. To learn more about cookies and other data-collection technologies, please visit “All About Cookies.”
We classify our cookies into the following categories:
Audiences
We also use Facebook custom audience tools. This allows us to provide personalized advertising to you when you use Facebook’s platforms by matching the email address we hold for you with the email address Facebook holds for you to show you the most relevant Medline advertisements. We only do this where you have given us consent.
Sometimes we may also share your email address with our advertising service provider partners to build lookalike models. This allows us to generate similar audiences of prospective customers (who may have similar interests or demographics to you) through advertising platforms like Google, based on data that the advertising platform holds about other people. If you wish to opt out of similar audiences in Google, you can do so here.
Questions, comments, requests, or complaints regarding this Privacy Notice and/or our use of your Personal Data should be addressed to the contact information below.
Medline Industries, LP
Attn: Privacy Office
Three Lakes Drive
Northfield, IL 60093
Email: MedlinePrivacyOffice@Medline.com
Call Toll-Free: (844) 249-1979
For Applicants located in the European Union, you may contact us at the following address:
Medline International B.V.
Nieuwe Stationsstraat 10
6811 KS Arnhem
The Netherlands
Phone: +31 (0) 26 – 312 7227
Fax: +31 (0) 26 – 312 7208
E-mail: DataProtectionEU@medline.com
Applicants in Germany may also contact our Data Protection Officer at the following address:
Philipp M. Moehrle Datenschutzbeauftr./ Dipl. Wirtschaftsjurist/ MCSE
– BECHTLE Datenschutz Competence Center –
Bechtle GmbH IT-Systemhaus Parkstraße 2-8, 47829 Krefeld
Tel.: 02151 – 455 – 836
Fax: 02151 – 455 – 77810
eMail: philipp.moehrle@bechtle.com
http://www.bechtle.com
Geschäftsführer: Karl-Heinz Empel
HRB: 9925, AG Krefeld
Sitz der Gesellschaft: Krefeld
If you have any complaints regarding this Privacy Notice, you may also contact your local data protection authority.
We may update this statement to reflect changes in the way we process Personal Data. We will notify you about such changes in the way we use your Personal Data in compliance with applicable law.
This Privacy Statement was last updated on 15 June 2022.