Effective Date:  July 07, 2020

This Privacy Policy (Policy) sets forth the Boston Scientific Corporation (BSC) privacy practices regarding the collection and use of personal data relating to BSC websites (Sites) addressing Europe and Switzerland, including mobile sites and our applications. BSC is dedicated to treating people with respect, transparency, and integrity; therefore, we don’t sell or lease your personal data to a third party. This Policy also describes your choices regarding our use of your personal data and how you can access and update your information. When we refer to BSC, we mean Boston Scientific Corporation, including our affiliates and subsidiaries. BSC adheres to privacy best practices, including the Generally Accepted Privacy Principles (GAPP), and complies with international personal data transfer framework requirements.

International users who access our international, EU and Swiss Sites and applications or provide information to BSC, understand and agree with BSC’s legitimate interest  to collect, use, disclose, retain and transfer your personal data to the United States and other countries and territories for the purposes stated in this Policy. This includes, but is not limited to, the transfer of personal data between BSC's third parties, affiliates and subsidiaries located in the United States and globally. 

BSC complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Boston Scientific has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

BSC remains accountable for onward transfers of EU and Swiss personal data to third party agents acting on BSC’s behalf, where those parties have processed personal data in a manner inconsistent with the Principles, unless BSC proves it is not responsible for the event. The U.S. Federal Trade Commission has jurisdiction over BSC’s compliance with Privacy Shield. If you have an unresolved privacy or data use concern that BSC has not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider, JAMS Privacy Shield Program, (free of charge). 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.

BSC protects any EU and Swiss information transferred to other third countries by introducing privacy provisions to our contracts with online providers or by ensuring the providers adopt the EU standard model clause of the European Commission to ensure information are protected in an adequate manner.

Personal data is data that can be used to identify or contact you, such as your name, email address, telephone number or similar information. 

When registering for this event you will be asked to provide contact information and other details needed to provide services and necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We may also collect information about your profession, specialist area, and role within your organization.

How we use the information we collect:

· We will use the data you provide for event logistics and services

· We will create a record of your attendance at this event which will be stored as a record within our database.

· We use your information as necessary to comply with our legal and compliance obligations, resolve disputes, and enforce our agreements.

· Specifically, regarding your event registration, Boston Scientific will share necessary information within Boston Scientific group and affiliate staff to ensure that the relevant team members are aware of your attendance at this event, to help with your travel arrangements etc. 

· Boston Scientific will also share some of this data: (name, date of birth, passport number, address, email address and telephone number) with our external service providers to facilitate flight bookings, airport transfers, accommodations, and other event logistics as needed.

· Where mandated to do so by law (e.g. due to legal enquiries or subject to subpoena) Boston Scientific may have to disclose data to competent authorities.

We provide interactive digital health tools through which information is collected from users. We also collect information about your interactions with our Sites and applications (e.g., browsing behavior). Our Sites automatically track certain behavior (Usage Data) during visits, such as, referring/exit URLs and we also collect other basic information about you which does not directly identify you but which may correspond with you or a particular device. We use this information to learn more about how our websites and online resources are used and to otherwise improve and administer the site. We also use this information to enable us to deliver information tailored to your interests and preferences, based on your use of the site. For example, we may collect the Internet Protocol Address assigned to your computer by your internet service provider. This address may change each time you connect to the internet (a “dynamic” IP address), or it may remain the same (a “static” IP address). In most cases, this information is collected automatically, for our legitimate business interests. In some jurisdictions, we are required to ask for your consent before collecting this information, in which case you will be presented with a choice as to whether you wish to allow the collection and use of this type of information, generally this will present itself in the form of a consent banner (providing you with a choice to accept or reject such collection). If you are a registered user, we may use your Usage Data with or without your personal data, in order to measure the Site's performance and improve the Site's design and functionality.

We may also collect the following voluntarily from you:

Information about your business such as company name, company size, business type or your position in the company

Medical condition

Demographic information such as age, education, gender, interests and location

Contact information such as email address and phone number

Testimonials

Site survey responses

Transaction history. 

We use this information to:

Send you product updates, newsletters, marketing communications, requested product or service information, fulfil services you have requested, and to understand your interests and preferences.

Respond to your questions

Administer your account

Conduct surveys or other research and analysis

Improve our Site and marketing efforts

Optimize user experience

Display personalized content

Deliver promotional material where allowed by law

Notify you of Policy updates

Identify you as a possible future event attendee

We may also collect from you the following personal data about your contacts:

Email Address, in order to share information or messages

When you provide us with personal data about your contacts we will only use it for the specific reason for which it is provided. If you believe one of your contacts has provided us with your personal data and you want to submit a removal request, please contact us at Globalprivacy@bsci.com or at EuropePrivacy@bsci.com if you are located in the EU, Swiss, or EEA zone. 

Licensed medical professionals may need to provide additional personal data to register (e.g., profession, title, Medical ID and clinical affiliation) . In addition to the uses mentioned above, we use this data to review and verify your registration.

We may use your personal data to support the activities of unaffiliated third parties that are under contract to perform services for or on behalf of BSC (including to maintain computer database, perform marketing activities when allowed by law, or conduct surveys). For example, personal data collected through interactive digital health tools we provide may be used to improve these tools and determine payment amounts for vendors who assist us in making these tools available. 

Who Has Access to Your Personal Information?

Data that you provide during this registration process will be stored and retrieved from database provided by Cvent (http://Cvent.com).  Cvent is a provider of meeting management software, which is widely used by Scientific Societies, companies and professional Congress Organizers, utilizing secure cloud-based storage for its data. Cvent’s data privacy policy statement can be accessed at the following website: 

https://www.cvent.com/en/privacy-policy

BSC won’t sell or lease your personal data to a third party; however, there are certain circumstances where we may share your personal data without additional notice to you. In addition to the disclosures described throughout this Policy, and subject to applicable law, we and our third parties may disclose your personal data:

To affiliates and subsidiaries for purposes consistent with this Policy;

To unaffiliated third parties that are under contract to perform services for or on behalf of BSC (e.g., to maintain computer database, perform marketing activities, or conduct surveys);

In the event of a corporate sale, merger, reorganization, dissolution or similar event;

To other persons as permitted by applicable law or regulation; and

To law enforcement personnel and agencies, including to meet national security requirements, or as part of a legal process, in order to protect our property or in furtherance of an investigation regarding a breach of the Site rules and policies, unauthorized access to or use of the Site or any other illegal activities.

We may share aggregate data with selected third parties. For example, BSC may disclose aggregate Usage Data to third parties to understand how the Site is used or for marketing purposes. See also "Cookies", below. Aggregate data does not identify individuals.

The access granted to our affiliates, subsidiaries, and third parties is limited solely to the purpose for which such information was provided. Furthermore, we require our affiliates, subsidiaries and third parties to uphold and maintain BSC’s policies with respect to privacy and the treatment of your personal data. Regardless of their locations or the laws of the countries they are based in, they are contractually required to provide at least the same level of protection as required by the Privacy Shield Principles.

BSC and our partners use a variety of technologies to facilitate the delivery of services to you via our Sites and applications and to understand and preserve your personal preferences. Use of these is governed by our Policy or the privacy policy of the third party providing the service.

Registered users and those who have provided BSC with personal data may request to review, change or delete information by logging in and modifying their profile, by e-mailing cventsupport@bsci.com. Deletion or change requests should be made by you directly. We will respond to all access requests within 30 days. 

To "opt-out" of (1) having your Site provided personal data disclosed to third parties for promotional purposes, or (2) any other consent previously granted for a specific purpose concerning your personal data on this Site, send an e-mail to BSC at cventsupport@bsci.com, contact us at Globalprivacy@bsci.com or at EuropePrivacy@bsci.com if you are located in the EU, Swiss, or EEA zone. To "opt-out" of receiving a particular marketing or promotional communication, follow the unsubscribe instructions included in the specific communication.

Every email related to your event registration contains instructions on how to opt-out of receiving further similar emails from us. 

If you wish to update or delete a testimonial you submitted, please contact us at cventsupport@bsci.com.

At any time, you are entitled to:

· Be informed about and access the information we hold

· Request that inaccuracies be corrected

· Object to the processing of your information for profiling you

· Request that some or all of your information be erased when no longer necessary; and,

· In some circumstances you can ask for restriction of access to your information. 

Data Retention

We retain your information while your account is active or as needed to provide you services. We also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. This includes creating a record of training that Boston Scientific has provided to you in relation to our products for a period of 5 years or as long as required by locally country requirements.

BSC takes security seriously. We use reasonable and appropriate data protection measures, such as robust technologies, security policies, and procedures, to reduce the risk of misuse, alteration, accidental destruction or loss, and unauthorized disclosure or access to our systems and data. For example, we encrypt the transmission of sensitive information using secure socket layer technology (SSL). We follow industry standards and best practices to protect your personal data during transmission and once we receive it. Unfortunately, no security method is 100% secure; therefore, we cannot guarantee absolute security. Please email any Site or application security questions to cventsupport@bsci.com.

This Policy applies only to BSC Sites and applications that link to this Policy. Our Sites include links to both our affiliated sites and to non-BSC web sites, including access to content, products and services of such affiliated and non-affiliated sites (Other Sites). BSC is not responsible for the privacy practices of Other Sites. You should directly contact these Other Sites to read their privacy policies and for more information about their practices.

Our Sites and applications are not intended for use by individuals under the age of 18, and BSC does not knowingly collect personal data from those in this age group. If you are under 18, please discontinue the use of our Sites and applications. If we become aware that someone under the age of 18 has registered, we will expunge any related personal data from our records.

Under the California “Shine the Light Act,” California residents have the right to request 1.) The identity of any third parties to whom BSC has disclosed personal data for the third parties’ direct marketing purposes, and 2.) The type of personal data disclosed. Not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response. To make a request, please send your full name, street address, city, state and zip code to Globalprivacy@bsci.com.

Please be aware BSC does not respond to your browser’s Do Not Track signals.

BSC may, in its sole discretion, update this Policy by posting the amended Policy on this Site. We will notify you prior to the changes, where required, of material Policy changes via your account email address or by a Site notice

This Policy was previously updated on June 20, 2018.