Introduction

DeRoyal Industries, Inc. and its subsidiaries and affiliates (collectively, “DeRoyal”) recognizes the importance of protecting the privacy and security of your information. We have made material changes to our privacy Policy (“Privacy Policy”) that apply with respect to information that you provide to us on or after the date indicated above.

We may periodically update this Privacy Policy to cover newly offered website features, products or services and how it may affect our use of information about you. We will alert you about any changes by updating the “Last Updated” date at the top of this Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices. 

Please read the full Privacy Policy.  By using this website, you are in agreement with the terms of this Privacy Policy and upon submitting any information via this website, you are consenting to the collection, use and disclosure of that information in accordance with this Privacy Policy. Your use of this site is also subject to our Legal Notices.

Scope of this Privacy Policy

This Privacy Policy applies to all who directly interact with DeRoyal (such as over the telephone or in person at a trade show) as well as all who visit and use DeRoyal’s websites, mobile applications or other digital services that link to this Privacy Policy (“DeRoyal Sites” or “Sites”). Whenever you directly interact with DeRoyal or use a DeRoyal Site, we encourage you to review the terms of this Privacy Policy. References in this Privacy Policy to “DeRoyal,” “we,” “our” or “us” are references to the entity that is responsible for the collection and use of your Personal Information, which is generally the entity that obtains your Personal Information in each case. This entity may also be referred to as the data controller.

If you do not agree with the practices described in this Privacy Policy, please do not provide us with your Personal Information or otherwise interact with DeRoyal or DeRoyal Sites.

This Privacy Policy does not cover information collected by any other company, third-party site or third-party application that may link to, or that can be accessed from, our website.

Collection of Personal Information

“Personal Information” means any information that can be used to identify an individual person.  This can be information that relates to you, describes you, is reasonably capable of being associated with you, or could reasonably be linked, directly or indirectly, with you or your household.  We collect several categories or Personal Information  when you interact with DeRoyal or DeRoyal Sites, including information you provide, information collected automatically from your device and information obtained from third party sources. When you visit and voluntarily interact with DeRoyal and/or DeRoyal’s Sites, we collect Personal Information as follows:

• Your first and last name;
• Residential and billing address;
• Company name;
• Job title and/or occupational role;
• Social media name and profile;
• Internet Protocol (IP) address;
• Contact details (e.g., telephone number, fax number, e-mail address);
• Purchase and ordering history;
• Purchasing and reimbursement information;
• Marketing preferences; or
• Other information you voluntarily provide.

When you visit our Site(s), we collect your data using cookies based on your cookie settings. (See Cookies and Other Technologies Section). When you contact us via the website or DeRoyal’s WebTools, we may also collect information from you. We may ask you to provide certain Personal Information at various times and places on our Site(s), such as when you place an order or request additional information. In some cases, if you choose not to provide us with the requested Personal Information, you may not be able to access all of the Site or participate in all of its features.

We may collect Personal Information from you when you:

• Register, subscribe, or create an account with us;
• Purchase products from DeRoyal through our Site(s);
• Open, click on, or respond to our e-mail offers;
• When you voluntarily provide us with information through our feedback forms or surveys, which we may then link to Personal Information that we previously collected about you;
• Contact customer service to speak with a representative or make use of our customer support tools;
• Sign-up for our e-mail updates and newsletters;
• Connect, link or “share” our Site(s) via social networking sites; or
• Provide ratings or reviews of our products and services.

Sharing of Personal Information

DeRoyal does not and will not buy or sell your personal information.

Sharing with DeRoyal Affiliates and Subsidiaries

DeRoyal is a global company and, as such, it may share Personal Information with its affiliates and subsidiaries for the purposes described in this Privacy Policy.  For more information about DeRoyal’s affiliates and subsidiaries, please contact us below.

Sharing with Third Parties

We share your Personal Information with third party service providers that provide services to help us with our business activities and functionalities related to the DeRoyal Sites, such as hosting our DeRoyal Sites, providing IT system administration and user support services, offering customer service, human resources administration or processing payments. These third parties are restricted from using your Personal Information in any way other than to provide services for us and we require them to provide an adequate level of protection for your Personal Information.  For more information about DeRoyal’s service providers, please contact us at legal@deroyal.com.

Sharing for Other Purposes

We may also share your Personal Information to ensure high standards of quality and safety of health care, our medical products or medical devices.  As such, we may share Personal Information to comply with our legal or regulatory obligations including, but not limited to, our obligations related to adverse event reporting, post-market surveillance, product safety and other reporting obligations or to respond to lawful requests by public authorities, including meeting national security or law enforcement requirements, (e.g. to investigate fraud or respond to a government request).  We may also disclose your Personal Information to third parties as necessary to investigate potential data incidents, or to protect the rights, property or safety of us, the users of DeRoyal Sites or others.

Use of Personal Information

We may use your Personal Information to ensure high standards of quality and safety related to health care, our medical products or medical devices. Providing your Personal Information to DeRoyal is voluntary. You may always refuse to provide your Personal Information to us.  If you decide not to provide us with your Personal Information, then we will not be able to communicate with you and provide you with certain information, products, or services.  If we have collected your information with your consent, you can always withdraw your consent by contacting us using the contact information provided at the end of this Privacy Policy. 

Depending on how you choose to interact with us (whether offline of through a DeRoyal Site), and subject to DeRoyal’s other legal obligations, we may use your Personal Information for the following purposes:

• Fulfilling our customer or vendor contractual relationships to be able to deliver goods and services, or to process payments;
• Establishing an online WebTools account for you at your request;
• Responding to your questions, which may include employment inquiries or providing you with our product and service updates;
• Providing you with information about DeRoyal products, services and programs or other marketing or advertising communications, or to enable you to participate in surveys or questionnaires. Some of this information we collect and use with your consent and some of this information we collect and use for our legitimate business purposes of communicating with you and providing you with information about our business;

• Managing, operating, maintaining and securing our websites, network systems, and other assets, to provide you with the features and various functionalities of DeRoyal Sites; 
• Complying with our legal or regulatory obligations, including applicable retention obligations and for purposes of:

• fraud prevention, public safety, adverse event reporting, post-market surveillance, product safety and other reporting obligations;
• responding to lawful requests by public authorities, including meeting national security or law enforcement requirements, e.g. to investigate fraud or respond to a government request;
• investigating potential breaches, or to protect the rights, property or safety of us, the users of our DeRoyal Sites or others; and
• Where permitted by law, we may also enhance or combine information about you, including your Personal Information, with information about you that we obtain from third parties for the same purposes described above. Your Personal Information may also be used for profiling for the same purposes described above. You may object to this profiling by contacting us below.

If you give us Personal Information of a third party or individual, you represent that you have provided notice to, and received authorization to provide such Personal Information from that third party or individual.

You will be able to withdraw your consent or exercise your rights in relation to this information at any time as permitted or required by applicable law. Note that withdrawal of your consent will not affect the lawfulness of our uses or sharing of that information before you withdrew your consent.

In the event that we use your Personal Information for purposes not specified in this policy, we will inform you about the specific purposes for processing your Personal Information and, when required, our basis for doing so at the time we collect the Personal Information from you to the extent required by law.

When collecting Personal Information directly from you, we do so for the following lawful purposes and legitimate business interests:

Personal Data CATEGORY	Purposes of Processing	LAWFUL BASIS AND LEGITIMATE INTERESTS OF COLLECTION
Contact Information, which includes your name, home and billing address, company name, job title, email address, fax number and phone number	To administer your account, authenticate you as a user, and communicate with you	To process transactions requested by you, respond to your inquiries, to meet contractual obligations, legitimate interests, and to manage your consent, where applicable
Demographic Information, which  includes your age, household information, product preferences and other interests	To better understand and analyze our customer population, support our operations including inventory and product management, to deliver relevant offers and ads, to improve our products and services including the DeRoyal Sites	Legitimate interests; to obtain your consent, where applicable
Purchase Information, which includes payment card information, purchase details and other transaction information	To process purchases or returns you make via telephone, fax, email or online; deliver purchased products; improve our e-commerce platform, personalize your customer experience and improve our marketing efforts	To process transactions requested by you, respond to your inquiries, to meet contractual obligations, legitimate interests, and to obtain your consent, where applicable
Employment Application Information, which includes your contact information, employment and education history, and other information you include in your CV/resume or application materials, as well as information collected for background checks where required	To process and evaluate job applications you submit to DeRoyal directly or through DeRoyal Sites and to communicate with you about your job applications and requests	Legitimate interests; to obtain your consent, where applicable
Health Information	To provide products and services to you and/or your health care provider    For research, trending, analysis, and reporting, development and quality improvement of products and services, improving the quality of patient care and/or inclusion of information in an electronic data repository or domestic and international regulatory submissions	To comply with federal, state or local laws and regulations or other legal obligations to which DeRoyal is subject; to meet contractual obligations; legitimate interests; to obtain your consent, where applicable

When Personal Information is automatically collected from you, we do so for the following lawful purposes and legitimate business interests:

Personal Data CATEGORY	Purposes of Processing	LAWFUL BASIS OF COLLECTION
Cookies, Analytics and Other Technologies	To manage our DeRoyal Sites and email messages and to collect and track information about you and your activities online over time and across different websites and online channels	Legitimate interests; to obtain your consent, where applicable
Location Information, which includes latitude, longitude, date and time.	To offer you certain location-based services, and to conduct analytics to improve the DeRoyal Sites.  You may disable the collection of your location information in your device’s settings. Please be advised that we may not be able to provide location-based services to you if you choose to do so.	Legitimate interests; to obtain your consent, where applicable
Log Files including IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data	To maintain the security of the DeRoyal Sites, for fraud detection, and to protect our rights	Legitimate interests

When Personal Information is obtained from third party sources, we do so for the following lawful purposes and legitimate business interests:

THIRD PARTY SOURCE	Purposes of Processing	LAWFUL BASIS OF COLLECTION
Business partners and service providers	To assist us with certain processes and transactions in the maintenance of our business	To comply with legal obligations, to meet contractual obligations, legitimate interests, and to obtain your consent, where applicable
Public Databases, credit agencies	To assist us with certain processes and transactions in the maintenance of our business	To process transactions, to prevent fraud, Legitimate interests; to obtain your consent, where applicable

DeRoyal’s legitimate interests in your Personal Information include the following:

• Understanding how the DeRoyal Sites are used;
• Adapting the DeRoyal Sites to usage patterns;
• Improving the DeRoyal Sites;
• Providing business information about DeRoyal; and
• Providing security for the DeRoyal Sites 

If you wish to restrict any of the above-mentioned processes, you or your authorized agent may submit a privacy request form and a DeRoyal representative will respond. Alternatively, you may contact DeRoyal via telephone at 1-888-938-7828 in the U.S. or 1-865-938-7828 outside the U.S. during the business hours of 8:00 a.m. and 5:00 p.m. Eastern time and ask for Legal Services.

Please note that we must take reasonable steps to verify your identity before implementing your request. Our response will be in accordance with applicable law and within a reasonable period of time.

Cookies and Other Technologies

The DeRoyal Sites utilize various technologies in order to provide you with certain services and functionalities as follows.

Cookies

We do not provide your Personal Information to any third party for their own direct marketing purposes.

Like many websites, DeRoyal Sites may use "cookies." A cookie is a small file that is transferred to your computer's hard drive to help improve content (for example, it helps us determine which parts of the site are popular and which are less popular, so we may improve these areas in the future) and customize website content for our visitors. We will combine cookie information with Personal Information you have submitted to us for the sole purpose of authenticating authorized users of our Web Tools.  Cookie information will not be combined with Personal Information you have submitted for any other purpose. You may set your browser to reject cookies and to let you know when a cookie is being placed on your computer.

As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and to administer the site.  

Use of cookies may vary with the unique features of DeRoyal Sites. Generally, we use cookies and the other tracking technologies discussed in this section to better understand in the aggregate how our visitors interact with our Site(s), to provide a streamlined online experience by remembering your preferences and movement on the Site(s), improve our Site(s), fulfill purchase orders and contracts with our business partners, confirm receipt of and response to our electronic communications with you, and provide effective customer service.

Do Not Track

Unless such information is provided voluntarily for this purpose, DeRoyal does not track the users of this website over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

Internet Protocol (IP) Addresses

Internet protocol (IP) addresses are unique identifiers automatically assigned to each computer when logging onto the Internet. We collect IP address information from any visitor to our DeRoyal Sites and log them for system administrative purposes only. IP addresses are not used for identification. This information helps us to prepare aggregate demographic information and other information regarding the use of this Site and to improve its functions. We do not link IP addresses to any information that is personally identifiable.

Google Analytics

Google Analytics is an element of the DeRoyal Sites. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the DeRoyal Sites, the IP address, and the type of operating system used to access the DeRoyal Site. By downloading and using a browser plugin provided by Google, available at https://tools.google.com/dlpage/gaoptout, you can choose to opt out of Google Analytics.

Social Media Features

The DeRoyal Sites include links that will take you to DeRoyal’s social media pages located on social media sites like Facebook, Twitter, Instagram, YouTube and LinkedIn. Our pages on social media sites are governed by the privacy policy of the company providing such site.

Social Media Terms of Use

Links

Our DeRoyal Sites may contain links to other websites whose information practices may be different from ours. You should consult the other sites' privacy notices as we have no control over information that is submitted to, or collected by, these third parties, and our Privacy Policy does not cover activities occurring at other websites.

Your Rights

In certain circumstances, local data protection laws and other local laws (including the CCPA and GDPR) give you rights with respect to your Personal Information. These rights differ by country/region. We will handle any request to exercise your rights in accordance with applicable law.

Under applicable data protection law, you may have certain rights with respect to your Personal Data, including the following:

• Request disclosure of certain information to them about our collection and use of their personal information over the past 12 months. They may make this request for free, twice per year. Once we receive a verifiable data subject access request, we may disclose to them (a) the categories of Personal Information collected about them; (b) the categories of sources for the Personal Information collected about them; (c) DeRoyal’s business or commercial purpose for collecting that Personal Information; (d) the categories of third parties with whom DeRoyal shared the Personal Information; (e) the specific pieces of Personal Information collected about them (also called a data portability request); and (f) if DeRoyal disclosed their Personal Information for a business purpose, a list identifying the categories that each type of recipient obtained.
• Request the deletion of their personal information collected and maintained by us or a third party; however, this right does not apply where we need to retain the personal information to provide goods or services, to carry on anticipated or reasonable internal purposes, comply with the law, detect or resolve issues of security or functionality, or other limited reasons.
• Request the transfer of their personal information to themselves or another entity in a portable format.
• Request the correction of any inaccurate personal information collected by us.
• Non-discrimination for having exercised their rights under the CCPA, unless otherwise permitted by the CCPA (as in the case of financial incentives, etc.).

DeRoyal does not utilize automated decision-making processes, such as profiling.

As another example, European Union residents are entitled to:

• Right to access the Personal Information we collect and process;
• Right to correct inaccurate Personal Information;
• Right to erasure of Personal Information, in limited circumstances;
• Right to restriction of processing of Personal Information, in limited circumstances;
• Withdrawing your consent at any time. Note that withdrawal of your consent will not affect the lawfulness of our uses or sharing of that information before you withdrew your consent;
• The right to data portability, which includes certain rights to the transferability of your Personal Information so that you can store and re-use it for your personal use, and you can ask us to provide it to another entity;
• The right to object to our using and disclosing your Personal Information for certain purposes, including our legitimate interests and for purposes of direct marketing.  You can object at any time to the processing of your Personal Information for direct marketing purposes and you can do so by "opting-out" of marketing or promotional communications in accordance with the unsubscribe instructions included in the specific communication.  If you are unable to object by opting-out in this manner, please send an e-mail to legal@deroyal.com or contact us using the contact details provided below in order to exercise your right to object. If you have questions about how we determine processing is for our legitimate interests or if you want to object to our processing on that basis, please contact us at legal@deroyal.com or using the contact details provided below.  If you believe we are using, disclosing or otherwise processing your Personal Information in a way that is not in accordance with the applicable law, you can submit a complaint to the data protection authority in your country.

If you wish to restrict any of the above-mentioned processes, you or your authorized agent may submit a privacy request form and a DeRoyal representative will respond. Alternatively, you may contact DeRoyal via telephone at 1-888-938-7828 in the U.S. or 1-865-938-7828 outside the U.S. during the business hours of 8:00 a.m. and 5:00 p.m. Eastern time and ask for Legal Services.

Please note that we must take reasonable steps to verify your identity before implementing your request. Our response will be in accordance with applicable law and within a reasonable period of time.

Data Retention

Your Personal Information will only be kept for as long as we reasonably consider necessary for achieving the purposes set out above or for as long as we are legally required to keep it. Please contact us at legal@deroyal.com or use the contact details provided below for further details of applicable retention periods.

Minors

DeRoyal Sites are not directed to children under the age of 16, and we do not knowingly collect Personal Information from children under the age of 16. If you think that we have collected Personal Information from a child under the age of 16, please contact us below. As required by law, if we collect Personal Information from a minor age 16 or older on the basis of consent, we require parental consent and may require affirmative authorization depending on the county/region where you reside.

Security

DeRoyal is a global company. We have reasonable and appropriate security measures in place to protect against the loss, misuse, and alteration of any Personal Information we receive about you through the DeRoyal Sites. We maintain reasonable security standards to protect the Personal Information that we maintain. If you have any questions about the security of your Personal Information, you can contact us at legal@deroyal.com or using the contact details provided below.

International Data Transfers

DeRoyal may transfer your Personal Information within our family of companies and/or to the third parties discussed in this policy. Your Personal Information may be transferred to, stored, and processed in a country other than the one in which it was collected. We may transfer your Personal Information outside the European Economic Area (“EEA”) and when we do so, we rely on appropriate or suitable safeguards recognized under data protection laws.

With your Consent:  With respect to our Services operated from servers in the United States, if you are located outside of the United States, please be aware that the personal information we collect will be processed and stored in the United States, a jurisdiction in which the data protection and privacy laws may not offer the same level of protection as those in the country where you reside or are a citizen.

Adequacy Decision:  With respect to our Services operated from servers in the EEA, we may transfer your Personal Information from the EEA to countries which the European Commission has approved as providing adequate protection to personal information.

Standard Contractual Clauses:  The European Commission has adopted standard data protection clauses, which provide safeguards for personal information transferred outside of the EEA. With respect to our Services operated from servers in the EEA, we generally use Standard Contractual Clauses when transferring Personal Information from a country in the EEA to a country outside the EEA that does not have an adequacy decision.

In addition, we may transfer your Personal Information outside the EEA if the transfer is necessary to establish, exercise or defend legal claims.

Complaints

DeRoyal is committed to ensuring that complaints and disputes concerning DeRoyal's privacy practices are investigated and resolved. Privacy questions or complaints may be submitted to DeRoyal by email, telephone or post office mail using the contact details provided at the end of this Privacy Policy.