Purpose

Z0LL Data Systems, Inc. (“ZOLL”) respects the privacy of its customers, employees, business partners, individuals whose personal information with which we are entrusted, and others. ZOLL collects and uses any collected personal information in accordance with the laws and regulations of the countries in which the information is collected, and in which it does business.

ZOLL complies with the EU-U.S. Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. ZOLL has certified that it adheres to the Privacy Shield Principles with respect to such data.

If there is any conflict between the policies in this privacy policy and the data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

Scope

ZOLL is committed to subject all personal data received from the European Union and Switzerland in reliance on the Privacy Shield to the Privacy Shield Principles. This policy applies to such data except for human resources data, which is addressed in a separate policy available to affected employees.

Types of Data

ZOLL provides online services that our customers use to operate aspects of their businesses. These services include tools for patient care, fleet management, records management and communications, among others. In providing these online services, ZOLL processes data our customers submit to our services or instruct us to process on their behalves. While ZOLL’s customers decide what data to submit, it typically includes information about their patients, customers, employees and users of our service, such as health, medication, demographic, billing and contact information.

Collection and Use

ZOLL processes data submitted by customers for the purpose of providing ZOLL’s online services to them. To fulfill this purpose, ZOLL may access the data to provide those services, to correct and address technical or service problems, to follow instructions of the ZOLL customer who submitted the data, to implement ZOLL’s software and hardware solutions or in response to contractual requirements.

Inquiries and Complaints

In compliance with the Privacy Shield Principles, ZOLL commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact ZOLL at:

Attn: Privacy Officer
ZOLL Data Systems, Inc.
11802 Ridge Parkway #400
Broomfield, CO 80021-5059

ZDCyberTeam@zoll.com

ZOLL has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Third Party Disclosures

ZOLL uses a limited number of third-party service providers to assist us in providing our services to customers. These third party providers offer customer support to our customers, assist with the transmission of data and provide data storage services. These third parties may access, process or store personal data in the course of providing their services. ZOLL maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our Privacy Shield obligations, and ZOLL remains liable for the onward transfer of personal data to agent third parties unless we can prove we were not a party to the events giving rise to the damages.

Rights to Access Data and Limit Its Use and Disclosure

You have the right to access personal data about you, and to limit use and disclosure of your personal data. With our Privacy Shield certification, ZOLL has committed to respect those rights. Because ZOLL personnel have limited ability to access data our customers submit to our services, if you wish to request access, to limit use or to limit disclosure, please provide the name of the ZOLL customer who submitted your data to our services. We will refer your request to that customer, and will support that customer as needed in responding to your request.

Powers of Investigation and Enforcement

ZOLL is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Legally Required Disclosures

ZOLL may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Amendment

ZOLL may amend this policy, consistent with the requirements of the Privacy Shield. We will post notice of any such amendment that is material at www.zolldata.com for 60 days.