Privacy Policy

Effective on: 5/9/2024

Last updated on: 6/17/2024

Transonic Systems, Inc., including its affiliates Transonic Europe B.V., Transonic Asia Inc., and Nipro-Transonic Japan JV, (collectively, “Transonic”, “we”, “us”, and “our”) takes the protection of personal data (“Personal Data”) very seriously.

Please read this privacy notice (the “Notice”) to learn what we are doing with your Personal Data, how we protect it, and what privacy rights you may have under applicable data protection and privacy laws.

Privacy Summary
Our Contact Information:	Transonic Systems, Inc. Address: 34 Dutch Mills Road, Ithaca, New York, 14850 Phone number: +1 607-257-5300 Email address: DataPrivacy@transonic.com
GENERAL INFORMATION
Do we collect Personal Data?	YES. Some categories include names, email addresses, and contact information. Click here to learn which categories of Personal Data we collect and how we obtain them.
TRACKING
Do we use cookies or similar tracking technologies on our website?	YES. Click here to read our cookie notice.
PRIVACY RIGHTS
Can you request a copy of the Personal Data we have collected about you?	YES. Click here to learn how.
Can you withdraw your consent to our processing of your Personal Data?	YES. Click here to learn how.
Can you request to have your data deleted?	YES. Click here to learn how.
Do we discriminate against you for exercising your privacy rights?	NO. Click here to learn more about your right not to be discriminated against.
SECURITY
Do we protect your Personal Data?	YES. Click here to learn more about how we protect your Personal Data.

What Is Covered by this Privacy Notice?

This Notice applies when we act as a data controller of your Personal Data. This means we decide why we collect your Personal Data and how we use it.

This Notice addresses you (the ‘data subject’) when we collect your Personal Data and applies when you are:

A customer representative, including a prospective or past customer representative.
A supplier representative, including a prospective or past supplier representative.
A website visitor to Transonic’s owned and operated websites, including www.transonic.com.
An individual who has created a customer login account, or interacted with us via our social media pages.
An individual who has agreed to receive marketing from, us and who may be included in our mailing lists.
An individual who has signed up for our webinars or workshops.

This Notice does not apply to:

Human Resources Personal Data: This Notice does not apply to the Personal Data of employees, job applicants, contractors, business owners, directors, officers, and medical staff of Transonic.
Information Which Does Not Constitute Personal Data: If we do not maintain information in a manner that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual, such information is not considered Personal Data and this Notice will not apply to our processing of that information.
Information collected by our Customers who use our devices: Our customers purchase Transonic products and may use those products to collect, store, and analyze patient data. We do not have access to this data, and we do not process it for our customers. We are therefore neither a data controller nor a data processor of this data as we never access it. When you give your data to one of our Customers, please consult their privacy notice, rather than this Notice.
External websites or services: Our website may contain links to other websites. We are not responsible for the handling of your Personal Data by those websites and recommend you review the privacy notices of those websites.

What Can You Find in this Notice?

This Notice tells you, among other things:

What Personal Data we collect about you and how we obtain it;
For what purposes we use that Personal Data;
The legal bases for processing your Personal Data;
How long we keep your Personal Data;
With whom we share your Personal Data;
Your rights about the Personal Data we collect about you and how you can exercise those rights;
How we protect your Personal Data; and
How to contact us.

What Personal Data We Process and How We Obtain It

The table below describes the categories of Personal Data we have collected about you in the last twelve months.

Personal Data We Collect, Process, or Store	How We Obtain It
Identifiers A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account name	You provide it directly to us when asking a question, filling in a form, or commenting about our products. We receive it from other companies within our corporate group. You sign up for our webinars or workshops. You agree to receive marketing communication from us. You provide it to us directly at Tradeshows.
Commercial information Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	You provide it to us when you interact with us, or we infer it from your purchase history. We receive it from other companies within our corporate group.
Internet or other similar network activity Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	You interact with our website or social media pages.
Professional or employment-related information Job title, professional contact information.	You provide it directly to us when asking a question, filling in a form, commenting about our products. We receive it from other companies within our corporate group. You sign up for our webinars or workshops. You agree to receive marketing communication from us. You provide it to us directly at Tradeshows.
Inferences drawn from other Personal Data Profile reflecting a person's preferences.	You provide it directly to us when asking a question, filling in a form, or commenting about our products. You interact with our website or social media pages.

Transonic manuals are stored within a gated section of our website, meaning that you must enter your name, email address, and institution, in order to be granted access to this section of the website. On receiving your request for access, Transonic staff will verify that you are a customer of Transonic prior to granting your request access. If you wish to obtain a manual without providing personal information, please contact us to request a hardcopy manual.

If you choose not to provide the information we request, you can still visit most of the Transonic website, but you may be unable to access certain options, offers, and services.

Cookies: We use cookies on our website. A “cookie” is a small file stored on your device that contains information about your device and you. We may use cookies to personalize your online experience. For more information about our use of cookies, please see our cookie notice.

We use session and persistent cookies. Session cookies are deleted when you close your browser. Persistent cookies may remain even after you close your browser, but always have an expiration date. Most of the cookies placed on your device though are first-party cookies, which are placed directly by us. Other parties may also set their own (third-party) cookies through our website. Please refer to the policies of these third parties to learn more about the way in which they collect and process information about you.

If you would prefer not to accept cookies, you can change the setup of your browser to reject all or some cookies. Note, if you reject certain cookies, you may not be able to use all features of our services. For more information, please visit https://www.aboutcookies.org/. You may also set your browser to send a Do Not Track (DNT) signal. For more information, please visit https://allaboutdnt.com/. Please note that our website does not have the capability to respond to “Do Not Track” signals received from web browsers.

For What Purposes Do We Use Your Personal Data?

We process your Personal Data for the following purposes:

To provide you with the products that you request from us.
To respond to your requests or questions about our products or our business.
To communicate with you on the status of delivery of our products.
To inform you about changes to our products (such as updates to our software or new products in development), and services, or to inform you of any safety notices regarding our products.
To send you marketing communications about our business which we think may interest you.
To ensure the quality of our products, services, and support, including warranty support where applicable.
To invite you to participate in or inform you of our webinars.
To create, maintain, and secure your customer account with us.
To manage our customer base and generally manage our business.
To receive services from you related to our business where we request it.
To address legal issues. This may include (i) complying with our obligations to retain certain business records for minimum retention periods; (ii) establishing, exercising, or defending legal claims; and (iii) detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of Transonic websites or products; (iv) protecting Transonic’s rights or property, or yours or others’ health, safety, welfare, rights, or property; and (v) responding to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To maintain the integrity and security of our websites, products, features, databases, services and business and to prevent and to detect any security threats, fraud or other criminal or malicious activity that might compromise information.
To personalize your experience on our website. We analyze your behavior on the website in order to improve our website and to adapt our range of products and services to your preferences (for example to only send information about hemodialysis related products to hemodialysis providers and not to cardiothoracic surgeons).

We do not perform automated-decision making.

Lawful Bases for Processing

We must have a valid reason to use your Personal Data. This is called the "lawful basis for processing".

When we act as a data controller, we may process your Personal Data on the basis of:

Your consent;
The need to perform a contract with you;
Our legitimate interests or those of a third party, such as our interest in marketing our products and services;
The need to comply with certain laws and regulations (such as the requirements to be able to contact customers of medical devices for field safety notices); or
Any other ground, as required or permitted by law.

When we rely on legitimate interests as a lawful basis of processing, you have the right to ask us more about how we decided to choose this legal basis. To do so, please use the contact details provided here.

Where we receive your Personal Data as part of providing our products or services to you to fulfill a contract, we require such Personal Data to be able to carry out the contract. Without that necessary Personal Data, we will not be able to provide the services to you.

How Long We Keep Your Personal Data

We will retain your Personal Data for as long as is necessary to fulfill the purpose for which we collected your Personal Data and any other permitted linked purpose and in compliance with our data retention policies. For example, we will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
If you are a customer representative, we retain your information to contact you regarding our ’necessary updates, recalls, or field safety notifications. Regarding ‘Leads’ (people who have expressed interest and opted-in to communications from Transonic), Transonic will routinely purge leads who have not interacted with our promotional material for 5 years. Anyone may opt out of communications with Transonic at any time.
Generally, we retain usage data for a shorter period, except when this data is used to strengthen the security, or to improve the functionality of our services, or we are legally obligated to retain this data for longer time periods.

If your Personal Data is used for more than one purpose, we will retain it until the purpose with the longest retention period expires; but we will stop using it for the purpose with a shorter retention period once that period expires. Our retention periods are also based on our business needs and good practice.

Sharing Personal Data with Third Parties

In the last twelve months we have shared your Personal Data with our business service providers:

Cloud service providers
Email service providers
Web analytics providers
Project management tool providers

We may disclose your Personal Data to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). If we have to disclose your Personal Data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your Personal Data.

We may also disclose your Personal Data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring. Finally, we may disclose your Personal Data to our subsidiaries or affiliates, but only if necessary for business purposes, as described in the section above.

We reserve the right to use, transfer, and share aggregated, anonymous data for any legal purpose. Such data does not include any Personal Data. The purposes may include analyzing usage trends or seeking compatible advertisers, sponsors, and customers.

Where Do We Store and Transfer Your Personal Data

Transonic is headquartered in New York, the United States of America (“U.S.”), and its data centers are in the U.S. We also use many U.S.-based service providers, suppliers, and distributors. This means that your Personal Data is primarily stored in the U.S. by us, our business service providers, our suppliers, and distributors.

However, we operate globally through our subsidiaries, service providers, suppliers, and distributors. This means that we may store and transfer your data to our subsidiaries, service providers, suppliers, and distributors who are in different countries if it is relevant to the delivery of the products or services, or to respond to requests from you.

Some of these third parties may be located outside of the European Economic Area (“EEA”) and the United Kingdom (“UK”). In some cases, the European Commission may have determined that in some countries, their data protection laws provide a level of protection equivalent to European Union law. You can see here the list of countries that the European Commission has recognized as providing an adequate level of protection for personal data. We will only transfer your Personal Data to third parties in countries not recognized as providing an adequate level of protection to personal data when there are appropriate safeguards in place. These safeguards may include the Standard Contractual Clauses as approved by the European Commission under Article 46.2 of the GDPR.

What Privacy Rights Do You Have?

You have specific rights regarding your Personal Data that we collect and process. Please note that you can only exercise these rights with respect to Personal Data that we process about you when we act as a data controller or as a “business”. To exercise your rights with respect to information processed by us on behalf of one of our Customers, please read the privacy notice of that Customer.

In this section, we first describe those rights and then we explain how you can exercise those rights.

Right to Know What Happens to Your Personal Data

This is called the right to be informed. It means that you have the right to obtain from us all information regarding our data processing activities that concern you, such as how we collect and use your Personal Data, how long we will keep it, and who it will be shared with, among other things.

We are informing you of how we process your Personal Data with this Notice.

We will always try to inform you about how we process your Personal Data. However, if we do not collect the Personal Data directly from you, the GDPR exempts us from the obligation to inform you (i) when providing the information is either impossible or unreasonably expensive; (ii) the gathering and/or transmission is required by law, or if (iii) the Personal Data must remain confidential due to professional secrecy or other statutory secrecy obligations.

Right to Know What Personal Data Transonic Has About You

This is called the right of access. This right allows you to ask for full details of the Personal Data we hold about you.

You have the right to obtain from us a copy or access to the Personal Data and certain related information, including confirmation of whether or not we process Personal Data concerning you and, where that is the case.
Once we receive and confirm that the request came from you or your authorized agent, we will disclose to you:

The categories of your Personal Data that we process;
The categories of sources for your Personal Data;
Our purposes for processing your Personal Data;
Where possible, the retention period for your Personal Data, or, if not possible, the criteria used to determine the retention period;
The categories of third parties with whom we share your Personal Data;
If we carry out automated decision-making, including profiling, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you;
The specific pieces of Personal Data we process about you in an easily-shareable format;
If we rely on legitimate interests as a lawful basis to process your Personal Data, the specific legitimate interests; and
The appropriate safeguards used to transfer Personal Data from the EEA or the UK to a third country, if applicable.

Under some circumstances, we may deny your access request. In that event, we will respond to you with the reason for the denial.

Right to Change Your Personal Data

This is called the right to rectification. It gives you the right to ask us to correct, without undue delay, anything that you think is wrong with the Personal Data we have on file about you and to complete any incomplete Personal Data.

Right to Delete Your Personal Data

This is called the right to erasure, right to deletion, or the right to be forgotten. This right means you can ask for your Personal Data to be deleted.

Sometimes we can delete your information, but other times it is not possible for either technical or legal reasons. If that is the case, we will consider if we can limit how we use it. We will also inform you of our reason for denying your deletion request.

Right to Ask Us to Limit How We Process Your Personal Data

This is called the right to restrict processing. It is the right to ask us to only use or store your Personal Data for certain purposes. You have this right in certain instances, such as where you believe the data is inaccurate or the processing activity is unlawful.

Right to Ask Us to Stop Using Your Personal Data

This is called the right to object. This is your right to tell us to stop using your Personal Data. You have this right where we rely on a legitimate interest of ours (or of a third party). You may also object at any time to the processing of your Personal Data for direct marketing purposes.

We will stop processing the relevant Personal Data unless: (i) we have compelling legitimate grounds for the processing that override your interests, rights, or freedoms; or (ii) we need to continue processing your Personal Data to establish, exercise, or defend a legal claim.

Right to Port or Move Your Personal Data

This is called the right to data portability. It is the right to ask for and receive a portable copy of your Personal Data that you have given us or that you have generated by using our services, so that you can:

Move it;
Copy it;
Keep it for yourself; or
Transfer it to another organization.

We will provide your Personal Data in a structured, commonly used, and machine-readable format. When you request this information electronically, we will provide you with a copy in electronic format.

Right Related to Automated Decision Making

To turn off personalized advertising, please change your cookie settings. Refer to our cookie notice.

Right to Withdraw Your Consent

Where we rely on your consent as the legal basis for processing your Personal Data, you may withdraw your consent at any time. If you withdraw your consent, our use of your Personal Data before you withdrew it is still lawful.

If you have given consent for your details to be shared with a third party and wish to withdraw this consent, please also contact the relevant third party in order to change your preferences.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. We will not:

Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties;
Provide you a different level or quality of goods or services; or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

How Can You Exercise Your Privacy Rights?

To exercise any of the rights described above, please submit a request by either:

Calling us at +1 607-257-5300 (U.S.); +31 (0) 43 407 7200 (EU)
Contacting us by email at DataPrivacy@transonic.com;
Writing to us at: Transonic Systems Inc., 34 Dutch Mill Rd., Ithaca NY 14850
Filling out this online form.

Verification of Your Identity

In order to correctly respond to your privacy rights requests, we need to confirm that YOU made the request. Consequently, we may require additional information to confirm that you are who you say you are.

For requests submitted via password-protected accounts, your identity is already verified. For requests sent by other means, we will verify your identity by asking you about information that matches information already held by us about you.

We will only use the Personal Data you provide in a request to verify your identity or authority to make the request.

Verification of Authority

If you are submitting a request on behalf of somebody else, we will need to verify your authority to act on behalf of that individual. When contacting us, please provide us with proof that the individual gave you signed permission to submit this request, a valid power of attorney on behalf of the individual, or proof of parental responsibility or legal guardianship. Alternatively, you may ask the individual to directly contact us by using the contact details above to verify their identity with Transonic and confirm with us that they gave you permission to submit this request.

Response Timing and Format of Our Responses

We will confirm the receipt of your request within ten (10) business days, and in that communication we will also describe our identity verification process (if needed) and when you should expect a response unless we have already granted or denied the request.

Please allow us up to a month to reply to your requests from the day we receive your request. If we need more time (up to 90 days in total), we will inform you of the reason why and the extension period in writing.

If we cannot satisfy a request, we will explain why in our response. For data portability requests, we will choose a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without difficulty.

We will not charge a fee for processing or responding to your requests. However, we may charge a fee if we determine that your request is excessive, repetitive, or manifestly unfounded. In those cases, we will tell you why we made that determination, and provide a cost estimate before completing your request.

Privacy of Children

The services are not directed at, or intended for use by, children under the age of 13.

Data Integrity & Security

We are strongly committed to keeping your Personal Data safe. We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect your Personal Data from unauthorized processing. Unauthorized processing includes unauthorized access, exfiltration, theft, disclosure, alteration, or destruction.

Contact Us

If you have any questions about this Notice or our processing of your Personal Data, or want to submit a verifiable consumer request, please write to our Privacy Team:

Transonic Systems Inc.
34 Dutch Mill Rd.
Ithaca NY 14850
+1 607-257-5300

DataPrivacy@transonic.com

EU specific questions can be directed to:

Transonic Europe B.V.
Business Park Stein 205
6181 MB Elsloo
The Netherlands
+31 (0) 43 407 7200