Ottobock Privacy Notice

We have been helping people maintain or regain their freedom of movement since 1919. For us, digitalizing the treatment process means protecting your freedom of movement in the digital world as well. It is therefore important for us to tell you what personal data we collect, how this data is used and what design options you have.

The success of Ottobock depends not only on the global networking of information flows between the Ottobock companies, employees, customers and patients, but above all on the trustful, secure handling of personal data.

This Privacy Notice is intended for US and Canadian residents only.

Responsible

Otto Bock HealthCare LP, 11501 Alterra Pkwy #600, Austin, TX 78758

Data Protection Officer

North America Data Privacy Coordinator: Amanda Finney

You may reach the North America Data Privacy Coordinator in the following manners:

  • E-mailing 

  • Sending a letter to the following address:

Ottobock
Attention: North America Data Privacy Coordinator
11501 Alterra Pkwy #600
Austin, TX 78758

Ottobock has also appointed a Global Data Privacy Officer: Bjoern Holland

You may reach the Global Data Privacy Office confidentially via the contact form

Secure provision of the Ottobock Shop

When you visit our Otto Bock HealthCare eCommerce Store (hereafter, "Ottobock Shop" or "Shop"), the web server temporarily collects the following information and stores such information in server log files:

  • Browser type and version,

  • Operating system used,

  • Referrer URL,

  • Browser string,

  • Hostname of the accessing computer,

  • Time of the server request, and

  • IP address.

Purposes:

Ottobock's interest is the secure and functional operation of the Ottobock Shop. The logged data is used for the purpose of data security, such as to defend against attempts of attack on our web servers. We reserve the right to carry out statistical evaluation of anonymous data records.

Legal basis:

We have a legitimate interest in ensuring data security and trouble-free operation.

Storage periods or criteria for determination:

The data will be deleted after 30 days.

Use of our Ottobock Shop

User Accounts and Registration

Access to our Ottobock Shop requires you to provide us with your corporate and personal data to create a User Account and to receive approval as an authorized Ottobock customer. By processing such data, we provide you with a personalized User Account enabling you to use our eCommerce platform. The eCommerce platform contains the following functionalities: order summary and history, preferred shipping, invoice addresses, payment information, shipping notifications, and product updates, etc.

The information that we collect as part of creating and maintaining your User Account may include (but is not limited to) the following:

  • Contact information

    • Your first and last name

    • Name of your business, clinic, or organization

    • Business address (for delivery and invoicing)

    • Email address

    • Phone/fax number

    • EIN/tax ID number

  • Payment information

    • Credit card/EFT account numbers

    • Billing and shipping address

    • Payment terms

  • Customer history

    • Record of orders and all relevant details (date of order(s), product(s) ordered, order value, customer lifetime value, patient name, shipping address, tracking numbers, refunds/returns processed, etc.)

Purposes:

We process data within your User Account to fulfil our contractual obligations and subsequent after sales services. This includes access to information on the full history of your transactions with Ottobock.

Legal basis:

The processing of the data is necessary for the performance of the contract between Ottobock and your Business or in order to take steps at your request prior to entering into a contract.

Storage periods or criteria for determination:

We will store customer financial information, general customer information, customer purchase orders and invoices, shipment letters, procedures, orders under contract, and customer letters and contacts via telephone and email for the duration of the time in which you maintain an active User Account.  Should you choose to disable or delete your User Account, we will retain all associated information for a period of 3 years, as required by our North America Record Retention and Destruction Policy. After this 3-year period, the information will be disposed unless we become aware of a pending or threatened legal claim or government investigation which may involve your data. No data related to a pending or threatened legal claim or investigation, complaint, audit, or proceeding may be destroyed during such pending or threatened legal claim or investigation, complaint, audit, or proceeding.

Termination of your registration:

As a user you will have the option to disable or terminate your User Account. At self-service or at request to Ottobock, you may change collected personal or corporate data in your account. In the case where processed data is required to fulfil performance of a contract or to actions associated with your request prior to entering into contract, a deletion may only be executed, if no other contractual or legal obligations prevail.

Order Processing

The Ottobock Shop allows you to purchase Products and Services. Subsequently required data is to be transmitted to and processed by Ottobock.

In case you order Products and Services by use of the Ottobock Shop, we process the following categories of data:

  • Order information

    • Product

    • Unit price

    • Quantity

    • Subtotal

    • Shipping charges

    • Specific information for individual production

  • Payment and shipping information

    • Billing and shipping address

    • Mode of shipment

Purposes:

We process your data for the purposes of order fulfilment, shipping and invoicing. Shipping information is transferred to the commissioned logistics partner where required for delivery. For payment processing, we transfer your payment information to the financial institution engaged. These institutions may only process your data for the fulfilment of the transaction. Shipping notifications and updates will be available through your User Account.

If you need to interrupt the Order Processing during the ordering process or are unable to complete the purchase, we will send you a reminder of the items you have placed in the shopping cart after a certain period of time, so that you can complete the process at a later time. This allows you to remember the items you have placed in the shopping cart without having to reassemble all the items in the web store. We use cookies for this purpose.

Legal basis:

The processing of the data is necessary for the performance of the contract between Ottobock and your Business or in order to take steps at your request prior to entering into a contract.

Storage periods or criteria for determination:

We will store customer financial information, general customer information, customer purchase orders and invoices, shipment letters, procedures, orders under contract, and customer letters and contacts via telephone and email for a period of 3 years, as required by our North America Record Retention and Destruction Policy. After this 3-year period, the information will be disposed unless we become aware of a pending or threatened legal claim or government investigation which may involve your data. No data related to a pending or threatened legal claim or investigation, complaint, audit, or proceeding may be destroyed during such pending or threatened legal claim or investigation, complaint, audit, or proceeding.

Promotional Material / Newsletter

If you are interested in news in the field of medical devices or in our products and services - in particular innovations, interesting campaigns and actions driven by Ottobock, you may agree to receive advertising such as our newsletter.

To send you the most suitable information in the requested promotional materials, we process the following categories of data:

  • Newsletter technology

    • Meta Data (e.g., Device-ID, IP-Address)

    • Usage Data (e.g., access time, interests)

  • Contact information

    • Email address

    • Professional position (job title)/company affiliation (company name)

  • Interest-specific information

    • Selection of the product section you would like to receive information on (e.g., Prosthetics, Orthotics and Human Mobility)

    • Your relationship with Ottobock (interested party, user, medical supply store, etc.)

    • Raffles

    • Surveys

    • Invitations to exhibitions

    • Clinical studies/evaluations/testing probation

Purposes:

We use this data to check the accuracy of your email address and to ensure that the promotional material is correctly tailored with the information that is appropriate for you.

Legal basis:

The data will be processed exclusively on the basis of your consent.

Withdrawal of your consent:

You may revoke the receipt of newsletters directly by contacting NAPrivacy@ottobock.com. Please note that this does not affect the permissible data processing that took place up to the point of withdrawal.

Storage periods or criteria for determination:

As soon as the data is no longer required for the purposes we pursue or you have withdrawn your consent and there is no other legal basis, the data will be deleted. If the latter is the case, we will delete the data where the other legal basis has ceased to apply.

When, How, and to Whom we share information

In our usual course of business, we will share some personal information with unrelated companies that we hire to perform services or functions for us. Specifically, we share personal information with our vendors, contractors, business and service partners, or other third parties with whom we contract (collectively, “Service Providers”). Examples of Service Providers include analysis firms, advertisers, payment processing companies, customer service and support providers, email, IT services and SMS vendors, web hosting and development companies and fulfillment companies. For example, we may use different vendors to create content for the websites or to deliver the information you requested. Service Providers also include our co-promotion partners for products that we jointly develop and/or market with other companies. Some Service Providers may collect personal data on behalf of Ottobock. These Service Providers may be provided with access to personal data needed to perform their functions. In these cases, we may provide the vendor with personal information to process your order such as your name and mailing address. In all cases in which we share your personal information with a third party, we require them to sign and adhere to a confidentiality agreement. We will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.

We may also disclose your personal information to our financial, insurance, legal, accounting and other advisors that provide professional services to us. We may disclosure your personal information in the event that we are (i) subject to negotiations for the sale of our business or part thereof to a third party, (ii) are sold to a third party or (iii) undergo a re-organization. We may also need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process or for the purpose of analyzing any proposed sale or re-organization. In addition, we may transfer your personal information to a third party, such as a re-organized entity or third-party purchaser, or an acquirer or licensee of an existing marketed product or investigational unapproved compound or asset, to be used for the same purposes as set forth in this Privacy Notice.

Ottobock may also share your information with its subsidiaries and affiliates.

We do not sell your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition. If Ottobock sells all or part of one of its product lines or divisions, your information may be transferred to the buyer.

There may be times when Ottobock may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law or regulation. Ottobock may also disclose your personal information to third parties when needed to: enforce this Privacy Notice and the other rules about your use of the Ottobock Shop; protect the rights or property of our customers, the public, Ottobock or others, and to exercise, establish or defend Ottobock’s legal rights; protect someone's health, safety or welfare; comply with laws, regulations, court orders or other legal processes.

Information on the use of cookies and other technologies

To ensure that our website works securely and properly and to offer you relevant products and services, we and our service providers use cookies and other technologies on our websites. When we use cookies, we may use “session” cookies (that last until you close your browser) or “persistent” cookies (that last until you and/or your browser delete them). For example, we may use cookies to remember your personal preferences, such as sections of the website that you visit frequently, your user ID, or other settings so you do not have to set them up every time you visit, and we may use cookies to serve you relevant advertising tailored to your interests. Some of the cookies we use are associated with your Ottobock account (including personal information about you, such as the email address you gave us), and other cookies are not.

We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of Ottobock services and report on activities and trends. This service may also collect information regarding the use of other websites, Mobile Apps and online resources. You can learn about Google’s practices by going to https://policies.google.com/privacy/google-partners, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout

Certain Services may have additional cookies and we will provide you with additional information in the specific terms, privacy notices and/or consent forms for those services.

Hyperlinks to third party websites

This website may contain links to other Ottobock or non-Ottobock websites. The links are provided to you for your convenience, but Ottobock does not review, control, or monitor the privacy practices of websites operated by others. This Privacy Notice does not apply to other websites, including other Ottobock websites not operated by our North American region. We are not responsible for the performance of websites operated by third parties or for your business dealings with them. We recommend that you review each website's privacy practices and make your own conclusions regarding the adequacy of these practices.

Your Rights

You may have certain rights and choices regarding our processing of your personal data. Depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right (with certain limitations and exceptions) to:

  • Know the categories and/or specific pieces of personal information collected about you, including whether your personal information is disclosed, and with whom your personal information was shared

  • Access a copy of the personal information we retain about you

  • Request deletion of your personal information

We reserve the right to verify your identity in connection with any requests regarding personal information to help ensure that we provide the information we maintain to the individuals to whom it pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If you are an authorized agent making a request on behalf of a consumer, we may require and request additional information to verify that you are authorized to make that request.

We reserve the right to deny your request if we cannot verify your identify. Where we deny your request in whole or in part, we will endeavor to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

If you have an account with Ottobock, we reserve the right to collect, retain, and use your personal information in accordance with the terms of the relationships until such time as the relationship is terminated or expired.

We will not restrict or deny you access to our Shop because of choices and requests you make in connection with your personal information.

You may exercise any of your rights in relation to your personal information by contacting us using the details provided under the “Data Protection Officer" section.

Transfer of personal data to countries outside the US and Canada

If you provide personal information through the Ottobock Shop, you acknowledge and agree that such personal information (1) may be stored and processed, transferred between and accessed from the European Union, where Ottobock is headquartered, (2) may be transferred from your current location to the United States offices and servers of Ottobock and the authorized third parties referred to herein located in the United States, Canada, and other countries which may not guarantee the same level of protection of personal data as the one in which you reside, and (3) may be accessed by the national security or law enforcement agencies of those countries. Without limiting any of the foregoing, we have the right to cooperate fully with any law enforcement authorities or court orders requesting or directing us to disclose the identity or other information of anyone posting any materials on or through the Ottobock Shop. However, Ottobock will handle your personal information in accordance with this Privacy Notice, regardless of where your personal information is stored/accessed.

To the extent permitted by applicable law, we may retain information for as long as the account of the customer for whom we collected the information is active, for at least six (6) months thereafter, or as long as is reasonably necessary to provide the Ottobock Shop services or as needed for other lawful purposes. We may retain cached or archived copies of information. We may retain anonymized or pseudonymized, aggregated data indefinitely, to the extent permitted under applicable law. We may be required to retain some data for a longer period of time because of various laws and regulations or because of contractual obligations. We also will retain information as long as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

Changes to this privacy notice

We will revise this privacy notice whenever changes are made to this website or other reasons that require it. You will always find the current version on this website.

State of declaration: February 10, 2022

Further privacy notices

The Children's Online Privacy Protection Act

Ottobock cares about protecting the online privacy of children. Absent appropriate consent, we will not intentionally collect any personal information (such as a child's name or e-mail address) from children under the age of 13.

California Consumer Privacy Act

The California Consumer Privacy Act “CCPA” provides California residents with the following rights. To exercise your rights in relation to your personal information as allowed for under the California Consumer Privacy Act, click here

Right to Access: If you are a California consumer, you have the right to ask us to send you the following information up to two times in a twelve-month period:

  • The categories of personal data we have collected about you

  • The categories of sources from which we collected the personal data

  • Our business or commercial purpose for collecting personal data

  • The categories of third parties with whom we share personal data

  • What categories of personal data we disclose about you for business purposes

  • What categories of personal data we sell or exchange for consideration about you

  • The specific pieces of personal information we have collected about you

Right to Delete: If you are a California consumer, you have the right to ask us to delete the personal data about you we have collected. We may deny the request if the information is necessary to:

  • complete a transaction, including providing a requested or reasonably anticipated good or service, or fulfill a contract between the consumer and Ottobock

  • detect and protect against security incidents, malicious, deceptive, fraudulent, or illegal activity, or take against those responsible for such activity

  • debug to identify and repair errors impairing intended functionality

  • exercise free speech or another right provided for by law

  • comply with the California Electronic Communications Privacy Act

  • engage in research in the public interest adhering to applicable ethics and privacy laws where the consumer has provided informed consent

  • enable solely internal uses reasonably aligned with the consumer’s expectations based on the consumer’s relationship with Ottobock

  • comply with a legal obligation; or

  • otherwise use the information internally in a lawful manner compatible with the context in which the consumer provided the information

Right to Opt-out of the sale of Personal Information: If a business sells personal information to third parties, California consumers have the right, at any time, to opt out of the sale or disclosure of their personal information to third parties. Ottobock does not sell personal information to third parties, except in conjunction with a corporate sale, merger, dissolution, or acquisition.

Right to designate an authorized agent: You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us.

Right to non-discrimination: The CCPA grants California consumers the right not to be discriminated against for exercising your privacy rights. If you exercise your privacy rights, we will not discriminate against you, for example, by denying you access to our Ottobock Shop or charging you different rates or prices for the same Ottobock Services, unless that difference is reasonably related to the value provided by your data.

Colorado

The Colorado Privacy Act provides Colorado residents with the following rights:

Right to opt out: A consumer has the right to opt out of the processing of personal data concerning the consumer.

Right of access: A consumer has the right to confirm whether a controller is processing personal data concerning the consumer and to access the consumer's personal data.

Right to correction: A consumer has the right to correct inaccurate personal data collected from the consumer.

Right to deletion: A consumer has the right to delete personal data concerning the consumer.

Right to data portability: When exercising the right to access personal data, a consumer has the right to obtain the personal data in a portable, and to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another entity without hinderance. A consumer may exercise this right no more than two times per calendar year.

Virginia

The Consumer Data Protection Act provides Virginia residents with the following rights:

Right to access: A consumer has the right to confirm whether or not a controller is processing the consumer's personal data and to access such personal data. 

Right to correct: A consumer has the right to correct inaccuracies in the consumer's personal data, taking into account the nature of the personal data and the purposes of the processing of the consumer's personal data.

Right to deletion: A consumer has the right to delete personal data provided by or obtained about the consumer.

Right to data portability: A consumer has the right to obtain a copy of the consumer's personal data that the consumer previously provided to the controller in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance, where the processing is carried 4 of 8 out by automated means; and

Right to opt out: A consumer has the right to opt out of the processing of the personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.