Effective Date: June 2023
Policy Scope
This Privacy Policy (Policy) sets forth the Boston Scientific Corporation (BSC) privacy practices regarding the collection and use of personal data relating to event registration. BSC, acting as Data Controller, is dedicated to treating people with respect, transparency, and integrity; therefore, BSC does not sell or lease your personal data to a third party. This Policy also describes your rights regarding our use of your personal data and how you can exercise those rights related to your information. When we refer to BSC, we mean Boston Scientific Corporation, including but not limited to our affiliates and subsidiaries in EU/EEA and UK. BSC adheres to privacy best practices, including the Generally Accepted Privacy Principles (GAPP), and complies with international personal data transfer framework requirements.
Users who access BSC sites and applications or provide information to BSC in the context of event registration, understand and agree with BSC’s purposes related to collect, use, retain and transfer your personal data to the United States and other countries 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.
Table of Contents
- Personal Data Collected, Purposes and Legal Basis
- Data Sharing & Data Transfers
- Cookies & Similar Technologies
- Access & Choice
- Data Retention
- Security
- Links to Other Sites
- Minors
- California Privacy Rights & Do Not Track Disclosures
- Updates to Privacy Policy
- Contact, Questions, Comments, Complaints
Personal Data Collected, Purposes and Legal Basis
The personal data processed by BSC is limited to those strictly necessary to achieve the purposes set out in this Privacy Notice. Such personal data may include:
- Your name, email address, telephone number or similar contact information. We may also ask for any applicable dietary requirement to plan means at an event.
- Profession, specialist area, and role within your organization/hospital. Licensed medical professionals may need to provide additional personal data to register (e.g., profession, title, Medical ID and clinical affiliation).
- Your interactions with our Sites and applications (e.g., browsing behavior). Our Sites may 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
- Testimonials may be obtained via surveys requesting feedback following a program but in this case, we will provide you with a dedicated privacy notice.
We may use your personal data for the following purposes (you will also find a reference to our legal bases which are applicable to you if you are in the EU/EEA and UK):
- Manage the event and your attendance to the event including but not limited to granting you access to the event, engaging with third parties to facilitate flight bookings, airport transfers, accommodations, and other event logistics as needed, and recording the event. We will do this subject to your consent.
- Create a record of your attendance to the event which will be combined with other personal data we hold about you such as all the interactions that we have with you, including registration to marketing emails, newsletters, participation to medical events, trainings or webinars of or funded by Boston Scientific, with a view to provide you with more relevant content or propose better tailored services or products. To this extent, we may use profiling to optimize and personalize our relationship and information that we make available to you meaning that we may use automated processing tools in order to manage and adjust the type, content and frequency of specific communication for specific segmented groups. If you are a customer, the foregoing information will be registered in our customer database based on our legitimate interest in managing our customer relationship with you and your hospital in the most efficient way possible. Similarly, if you are not a customer but qualify as a BSC lead, we will record the information of your participation on our leads database subject to your consent.
- Communicate with you when necessary, including but not limited to sending you product updates, newsletters, marketing communications, invitations to events medical trainings, discussing your therapy awareness needs as well as your preferred medium of interaction. We may contact you by different means including but not limited to electronic means. If you are a customer, we rely on our legitimate interest in improving your experience with us and providing you with access to information according to your preferences. If you are a lead, we rely on your consent for the processing of your personal data for this activity.
- Learn more about how our websites and online resources are used and to otherwise improve and administer the site which in turn enables us to deliver information tailored to your interests and preferences, based on your use of the site. In most cases, this information is collected automatically, for our legitimate business interests. In some jurisdictions such as the EEA/EU and UK, 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).
- As necessary to comply with our legal and compliance obligations, respond to authorities’ requests, resolve disputes, and enforce our agreements based on our need to comply with legal obligations and fulfill our agreements.
- Specifically, regarding your event registration, Boston Scientific will share necessary information within Boston Scientific Group and affiliate entities and staff to ensure that the relevant team members are aware of your attendance at this event, to help with your travel arrangements etc. based on our legitimate interest of managing your attendance to the event.
Data Sharing & Data Transfers
Who Has Access to Your Personal Information?
Personal data that you provide during this registration process will be stored and retrieved from a 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
For individuals from EU/ EEA and UK, Cvent qualifies as a data processor and will process personal data on behalf of and following BSC instructions, as required by applicable data protection legislation.
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. Subject to applicable law, we and our third parties may disclose your personal data:
- To affiliates and subsidiaries for the purposes set out above in 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);
- BSC entities where this is necessary to manage event’s attendance and/or necessary to manage the business relationship with you and/or to provide you directly with information about products and services of the Boston Scientific Group, as described above. Please see a list of BSC entities here.
- External agencies to facilitate flight bookings, airport transfers, accommodations, and other event logistics as needed
- To third parties in the event of a corporate sale, merger, reorganization, dissolution or similar event; and
- 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 collect, store and process your personal data on servers located in the United States. To transfer personal data from the European Union to the United States, Boston Scientific has implemented EU Standard Contractual Clauses between its EU, Swiss and US entities and with the above service providers as well as additional safeguards such as encryption for data in transfer. If you would like more information, please reach out to our Data Protection Officer following the contact details set out below.
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. 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.
Cookies & Similar Technologies
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.
Please check our Cookie Policy. If you are in EEA, please visit this Cookies Notice.
Access & Choice
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, or 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 (1) object to having your personal data disclosed to third parties for promotional purposes, or (2) withdraw 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, UK ,Switzerland, or EEA zone or through our Data Subject Request Form. 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.
Any individual may request to exercise the rights listed below. However, our response to your request may vary based upon your location or the country, state or territory of your residence:
Right of access: You may have the right to request that we disclose to you the personal data we have collected about you.
Right to know: You may have the right to confirm that we have collected personal data about you, what personal data we have collected about you and other related information.
Right to rectification or correction: You may have the right to have inaccurate personal data about you rectified or completed if it is incomplete.
Right to erasure: You may have the right to have personal data that we have collected about you deleted.
Right to restriction of processing: You may have the right to request from us that we limit the way we use your personal data.
Right to withdraw consent: When you have provided your consent, you may have the right to withdraw it at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to withdrawal of the consent nor of continued processing activities that are not based on consent.
Right to object: You may have the right to object, on grounds relating to your particular situation, at any time, to the processing of your personal data; and we may have to stop processing the data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. You may also have the right to object to, or opt out of, the processing of your personal data for direct or targeted marketing purposes or the sale of your personal data.
Finally, if you are in the EU/EEA and UK, you have the right to lodge a complaint with the data protection authority of your country [see EU list] where you believe that your rights have been violated.
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 as long as required by locally country requirements. If you are a lead, we will keep your data as long as you remain active or you have not withdrawn your consent, without prejudice to the retention of your personal data during the statue of limitations. If you are not active in the system for 5 years, your personal data will be anonymized.
Security
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. Please email any Site or application security questions to cventsupport@bsci.com.
Links to Other Sites
This Policy applies only to BSC Sites created on the Cvent tool and applications that may 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.
Minors
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.
California Privacy Rights & Do Not Track Disclosures
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.
Updates to Privacy Policy
BSC may 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: July 2023
Contact, Questions, Comments, Complaints
You can exercise any of the above rights by sending a request to GlobalPrivacy@bsci.com or EuropePrivacy@bsci.com if you are located in the EU, UK ,Switzerland, or EEA zone or through our Data Subject Request Form. These rights will have to be enforced in line will the applicable law. Boston Scientific shall provide a response to your requests within 30 days of receiving such request.
Please direct privacy-related issues, questions, comments or complaints to one of the following:
EU/ UK/Switzerland/EEA countries:
Email: EuropePrivacy@bsci.com
Postal Mail: Boston Scientific c/Ribera del Loira, 46 Edificio 2 28042 Madrid (Spain)
Other Countries:
Email: GlobalPrivacy@bsci.com
Postal Mail: Boston Scientific Corporation Global Privacy Office/Legal 300 Boston Scientific Way Marlborough, MA 01752 (USA).