Effective date: April 12, 2019
Varian Medical Systems, Inc. (including its affiliate entities, collectively “Varian”) is committed to respecting your privacy. As you use our mobile application (the “App”), our intent is that your experience is informative, convenient and secure. Varian is committed to responsibly managing the personal information provided, and we have adopted the following privacy statement to explain our commitment to your privacy. This privacy statement applies to the App and it discloses Varian's practices with respect to the type of information that we gather, the way we use information internally and our policy statement regarding sharing information with others. This privacy statement also describes how you can manage your personal information.
COLLECTION AND USE OF PERSONAL INFORMATION
You may use the App without registering but the information available to you on the App will be limited. If you choose to register for an account through the App, you will be asked for your business card information including your name, title, email address, business name, business address, phone number, and login credentials. When you download, install and use the App, we automatically collect information on the type of device you use, operating system version, and the device identifier. We use mobile analytics software to allow us to better understand the functionality of our App on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the App.
We, through our third-party tracking and analytics utility providers, maintain a log file. We track in the log file, your actions that are initiated or facilitated using the App, including the country which you are logging in from, user engagement data, your user details which you enter as part of registration, use of the App at Varian events, survey questions and responses. In addition, the log files may generally capture, record and store data concerning your use of the App. Access to this data is restricted to those providers and those who administer our network and mobile apps.
OTHER USES OF PERSONAL INFORMATION
When you download and use the App, we automatically collect information on the type of device you use, the location of use and the operating system version. When you use the App, we and/or a third-party provider may also collect and share between us location-based information from event registration to assist you in finding relevant information regarding your conference location, the localized language of the App, or to otherwise provide you with event-specific content or services. If you do not wish to have a provider process your data, please do not register for the App. We also use a customer relationship management provider. Your information will be integrated and stored into this system for the purpose of generating lead information, and tracking your interactions with Varian and the App.
COMMUNICATIONS FROM THE APP
When using the App, you can affirmatively opt into push notifications on your device. If you no longer wish to receive push notifications you may go to your device settings and make the appropriate changes to opt out. For all other communications from Varian on the App you opt in or opt out of them on the App, or you may contact us at firstname.lastname@example.org.
INFORMATION SHARED WITH OUTSIDE PARTIES
Any information that you provide to us will be used for our purposes only as set out in this privacy statement. Except as specified in this privacy statement, your information will not be sold or shared with individuals outside the employ of Varian, or with other companies. We may share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us. For example, Varian uses third-party vendors for different uses such as event registration and credit card processing. When you sign up for these services, we will share information such as your personal information as necessary for a third-party to provide that service. Personal information collected via these sites are stored on the vendors' system, not with Varian. Third parties service providers are prohibited from using your personal information for any other purpose. Some of the parties to whom we disclose your information are located in countries, including the United States, that may not provide the same level of data protection as your home country. As required by law, we take appropriate steps to ensure that such recipients of your information are bound to duties of confidentiality, and Varian is certified to both the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (more information on which can be found in the “Participation in Privacy Protection Programs” section below).
Varian complies with applicable law and legal obligations to respond to governmental, law enforcement and court requests for personal information and other information and data about our visitors and their transactions. In certain situations, Varian may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Varian's Legal Department may access and use your personal information and other information or data to protect our rights, in the event of a dispute or in response to legal process, law enforcement inquiries or abuse of the App. If Varian is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personally identifiable information, as well as any choices you may have regarding your personally identifiable information. We may also disclose your personal information to any other third-party with your prior consent.
We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. We suggest that you change your passwords often and that your passwords include a combination of letters and numbers. If you have any questions about security on the App, you can email us at email@example.com.
MANAGING PERSONAL INFORMATION
If for any reason you wish to access, correct, update, or delete your personal information or profile please log on to the App in order to make these changes or by contacting us at firstname.lastname@example.org. Where provided for by law, you may also object to or request restriction of processing of your personal information, and request portability of your personal information held by Varian. In case there is a problem in exercising such rights using the App, please send an email to email@example.com. We will respond to your request to access, correct, or delete any personal information within 30 days. You may also have the right to lodge a complaint with the relevant data protection supervisory authority if you consider that our use of your personal information infringes applicable law.
We will retain and use your personal information in accordance with the purpose for which the data was originally collected or as needed to fulfill the purposes set out in this privacy statement, in accordance with applicable laws. Also, we will retain and use personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We maintain your personal information on servers and computers located in the United States and operated under our direct supervision and control. If you request information from us which best falls under the expertise of a foreign office, we may forward your contact information to that office so that office may respond to your request directly. Otherwise, we do not forward your personal information outside the United States.
PURPOSE OF USING PERSONAL INFORMATION
Varian may use and otherwise process personal information for a number of reasons. Unless otherwise stated or apparent for the context, Varian’s legal basis to do so under applicable law (including European and other worldwide privacy laws) is that such processing is necessary in Varian’s or a relevant third-party’s legitimate interests. Such legitimate interests include those listed below and those set out elsewhere in this privacy statement: • Providing you with certain products, promotions, services, and information you request, including marketing; • Maintaining or administering services, performing business analyses, or for other internal purposes to improve the quality and use of the App; and • Localizing and personalizing the content you can access on the App.
We may also process your information in order to comply with our legal obligations, to perform a contract between us and you, or to establish and defend any legal claims. In some cases, our basis for processing will be because you have consented to our use of your information. You have the right to withhold or withdraw such consents at any time; if the means for doing so are not apparent from the context, please contact us at firstname.lastname@example.org or email@example.com. By using the App, you accept and consent to the practices described in this privacy statement. Where the foregoing consent does not apply or is not valid under applicable law, then Varian will rely on its other legal basis described in this privacy statement.
PARTICIPATION IN PRIVACY SHIELD
Varian participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.
Varian is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Varian complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Varian is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have any complaints regarding our compliance with this privacy statement, the EU-U.S. Privacy Shield Framework or the Swiss-U.S. Privacy Shield Framework you can first contact us at firstname.lastname@example.org. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted. You may lodge a complaint with the relevant data protection supervisory authority if you consider that our use of your information infringes applicable law.
When you sign into the App with a registered account, you will benefit from a more personalized experience in which you will have access to specified features of the App and can view private content pertinent to your user profile. Information may be collected: (1) to gather statistical data about App usage and (2) to understand user activity and the App engagement. If you opt in to receive marketing communications during the registration process: (1) you may receive communications about product updates, educational webinars, events, and corporate announcements that we believe are relevant to your interests and needs and (2) Varian may reach out to you to discuss any interests in Varian’s products and services that may appeal to you. You can opt out of receiving such electronic communications at any time by clicking on the unsubscribe link in an email communication and/or in the App settings or by contacting us at email@example.com. If you opt out of receiving electronic communications, we will only use your information to contact you to inform you of privacy related updates.
CHANGES TO THIS PRIVACY STATEMENT
Varian may decide to change this privacy statement from time to time to reflect changes to our information practices. When we do, we will notify you through the App or by email, as appropriate, so that you are always aware of the information we collect, how we use it, and under what circumstances we disclose it. We encourage you to periodically review this page for the latest information on our privacy practices.
OVERSIGHT AND QUESTIONS
We welcome comments and questions on this privacy statement. As stated above, we are dedicated to protecting your privacy, and we will make every reasonable effort to keep your information secure. If you have any questions or comments about this privacy statement you can contact us electronically at firstname.lastname@example.org. Additionally, you may contact us by writing via postal mail at the following address:
Varian Medical Systems, Inc.
Attention: Data Privacy Office
3120 Hansen Way, M/S G100
Palo Alto, CA 94304.