Our Commitment to Privacy
Intralink Spine™ adheres to the EU Safe Harbor Privacy Principles published by the U.S. Department of Commerce (“Safe Harbor”) with respect to certain personally identifiable information that it receives in the United States about European Union (“EU”) residents. Information about Intralink Spine™’ participation in Safe Harbor can be found in the section set out below entitled “Safe Harbor Participation.”
Intralink Spine™ operates in the business-to-business (B2B) medical equipment industry. Unlike many companies and websites, we do not focus on consumer users or the collection of consumer data. To the extent we collect information online, our purpose is to better serve our business customers.
The Information We Collect
We may collect the following types of information when you browse this Site, any other Intralink Spine™ website, or any affiliate site:
Information you provide directly when you register or make an online order, join an online community or other group, inquire about Intralink Spine™ products, or request Intralink Spine™ support or services at any Intralink Spine™ interactive message board, or via any e-mail messages you send us, including personally identifiable information such as your name, contact information (phone, fax and pager numbers, address, and email address), ordering information, and payment data.
Information you provide directly, including personally identifiable information you submit through this Site as part of the online job application process or in the process of registering for an Intralink Spine™ sponsored training, event, user group, or conference.
Passively collected information, including through the use of “cookies” described below, such as IP addresses, web browser and operating system information, date and time of visits, and the web pages your Internet browser visits when browsing this Site, any other Intralink Spine™ website or any affiliate site;
Click-through information related to Intralink Spine™ emails and related marketing activities; and
Aggregate, non-personally identifiable information, such as the number of hits per week or per web page.
“Cookies” are small text files that store information about your interactions with a particular website, either temporarily (known as a “temporary” or “session” cookie, and deleted once you close your browser window) or more permanently on the hard drive of your computer (known as a “permanent” or “persistent cookie”). Cookies can make it easier to use a website by allowing servers to access certain information quickly:
Session cookies can be used to help a user’s browser navigate a website more smoothly and may show up if the user comes from a website with which the subsequent website has some relationship (e.g., a website of an affiliated company) and can give helpful information.
Persistent cookies can be used to customize a website for a user, such as by storing passwords, preferences, and registration and account information so that users do not have to reenter this information each time they visit a website.
This Site may use both session/temporary cookies and persistent/permanent cookies to store information that allows us to offer you better customer service and to navigate through the Site with ease. To make the Site easier to use, we combine information collected via cookies with personally identifiable information. Note that if you configure your browser to reject cookies, you might not be able to access important functions or areas of the Site or enjoy certain conveniences at this Site.
Intralink Spine™ may use “web beacon” technology to gather metrics from anonymous web users and email recipients for the purpose of operating and improving Intralink Spine™ websites and email communications. A web beacon is an electronic image that is imbedded in a web page or email which allows Intralink Spine™ to track web page views/hits or the opening of an email containing a beacon. Intralink Spine™ may use web beacon in conjunction with cookies to track web site activity on and associated websites. Web beacon tracking by Intralink Spine™ does not identify the name or email address of the web user or mail recipient.
The Way We Use Information
Intralink Spine™ uses information collected online in the following ways:
For information you provide directly online, or through email messages, relating to inquiries about products, ordering products, requests for support or services, or downloading products, we use the information to engage in and process transactions with you, respond to your inquiries and requests, and provide customer support activities.
For information you provide online, including actions or clicks from hyperlinks and subscriptions, we use the information to customize future communications and web pages in accordance with communication preferences you have established with Intralink Spine™.
For some registration, email and use data you provide, we may direct you to particular web pages, customize the web pages you see, or otherwise increase the relevance of the information you receive.
For information about web pages visited, page hits per week, and the like, we use this information internally to improve the design of our web pages.
For information submitted using the online job application process, we may use and disseminate this information internally and among our affiliates as necessary to consider your application and to contact you regarding our decision.
For information submitted online for scheduling training or registering to attend a Intralink Spine™ sponsored conference or event, we may use and disseminate this information internally and among our affiliates to communicate with you and to facilitate your registration and participation.
When We Share Customer Information
Intralink-Spine Inc. shares information for business purposes only on a need-to-know basis and only with: (a) its own employees and affiliates; (b) the customer from which Intralink Spine™ received the information; (c) Intralink Spine™ subcontractors, consultants, and third-party service-provider companies, that have agreed to safeguard such information in a like manner to the way that Intralink-Spine™ safeguards such information and that have signed confidentiality agreements with Intralink-Spine™; and (d) other entities authorized to have access to such information under applicable law or regulation. Intralink Spine™ does not share non-public individually identifiable information with third party marketers.
Our Commitment to Data Integrity and Security
Intralink-Spine Inc. processes information only in ways compatible with the purpose for which it was collected. To the extent necessary for such purposes, we take reasonable steps to make sure that customer information is accurate, complete, current and otherwise reliable with regard to its intended use. However, Intralink Spine Inc. expects customers will update their personal information with Intralink Spine™ as necessary.
Intralink Spine Inc. takes reasonable and appropriate measures to maintain the confidentiality and integrity, and prevent the unauthorized use or disclosure, of information. This includes maintaining a system of appropriate administrative, physical and technical safeguards to secure such information.
Links to Unaffiliated Third Party Websites
This Site may contain links to unaffiliated third party websites. If you link to or otherwise visit any other websites managed by third parties, please review the privacy policies posted at those sites. Intralink Spine Inc. has no control over those websites and is not responsible or liable for the policies and practices followed by third parties.
How You Can Access or Correct Your Information
If you have created a profile with Intralink-Spine Inc. you can update your profile by emailing your updates to your local representative to update your Personal Information or by contacting Intralink Spine via the email identified on the site. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections.
We may keep information in an off-line form, for archival purposes or as otherwise required by law. Please note that if your information is removed from our databases, you may no longer be able to access certain areas of our website requiring registration or a subscription. Users may request to be removed from an Intralink Spine™ e-mail list, by following the “unsubscribe” instructions on e-mails from Intralink Spine™ or by sending a request via the email identified on the site.
Revisions and Contact Information
Safe Harbor Participation
We recognize that the EU has an “omnibus” data protection regime established pursuant to the European Data Protection Directive (95/46/EC) (the “Directive”). The Directive generally restricts the transfer of personally identifiable information about individuals in the EU to the United States, unless there is “adequate protection” for such information when it is received in the United States. To address this restriction, we adhere to Safe Harbor with respect to personally identifiable information about individual contacts for our customers, partners, suppliers and vendors in the EU (“EU Personal Information”) for the purposes described below, as well as for our employees and job applicants in the EU. Employees in the EU are provided with information regarding Intralink-Spine’ employee data privacy practices and Safe Harbor via a separate policy.
Collection, Use, and Disclosure of EU Personal Information
Intralink Spine collects, uses, and discloses EU Personal Information in the ordinary course of its business. In particular, Intralink Spine™ may obtain in the US the following types of EU Personal Information about individual contacts for customers, customer prospects, partners, suppliers, vendors, participants in Intralink Spine™ sponsored events, conferences and training, and online job applicants (“EU Data Subjects”), including: name; contact information (phone, fax and pager numbers, address, and email address); title; company name; sales, product and services purchase information; payment data; usernames and passwords; product skills; certifications; resume and application data; and other data necessary to register for Intralink Spine™ sponsored training, conferences and events.
We may use such EU Personal Information for the following purposes: fulfillment and tracking of orders; providing services and support; tracking of payments and otherwise ensuring payment; assessing performance and making assessments about future purchases; performing direct marketing activities and otherwise communicating information regarding Intralink Spine™ products or services (where permitted by law); providing registration for and participation in Intralink Spine™ sponsored training, events and conferences; and for facilitating the online employment application process.
Intralink Spine™ may disclose EU Personal Information to its affiliates, subsidiaries, business partners, and service providers for the purposes listed above. In situations where Intralink Spine™ discloses EU Personal Information to any third parties acting as service providers or “agents” on behalf of Intralink-Spine™, Intralink Spine™ will require the recipient to protect the disclosed EU Personal Information in accordance with the relevant Safe Harbor Principles, or otherwise take steps to ensure that EU Personal Information is appropriately protected. With respect to any sharing of EU Personal Information for purposes of marketing Intralink Spine™ products and services, Intralink Spine™ obtains promises from its affiliates, subsidiaries and business partners that such entities will use and disclose such EU Personal Information for purposes of marketing Intralink Spine™ products and services only. In certain situations, EU Data Subjects may seek to opt-out of disclosures of their EU Personal Information by following the opt-out instructions contained on marketing emails or by contacting Intralink Spine™ via the email provided at the site.
Data Processor Activities
In certain situations, Intralink Spine™ may obtain incidental access to information about its customers’ employees and other end users in the EU in connection with supporting its products or services (“EU Processor Information”). These customers act as the data controller for any EU Processor Information collected in the EU and subsequently transferred to Intralink Spine™ in the United States. Intralink Spine™ acts as a data processor on behalf of its customers with respect to such EU Processor Information and accordingly carries out their instructions with regard to the collection, processing, and protection of EU Processor Information.
Data Security, Integrity and Access
Intralink Spine™ takes reasonable precautions to protect EU Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Intralink Spine™ makes reasonable efforts to keep EU Personal Information reliable for its intended use, accurate, current and complete. Intralink Spine™ also provides EU Data Subjects with the opportunity to access, review and correct their own EU Personal Information, and otherwise provides such individual’s access to EU Personal Information in accordance with Safe Harbor. Individuals may contact the Intralink Spine™ Safe Harbor Privacy Contact identified below to review EU Personal Information about them. However, such individuals may first wish to contact their own company with questions regarding EU Personal Information shared with Intralink Spine™, as that might be the most efficient means of addressing such issues. Intralink Spine™ reserves the right to take reasonable steps to authenticate the identity of any such individual seeking access to EU Personal Information.
Intralink Spine™ may disclose EU Personal Information as necessary in connection with the sale or transfer of all or part of its business, where required or permitted by law, where Intralink Spine™ believes that such disclosures are appropriate in connection with a law enforcement request or otherwise permitted by Safe Harbor, or in order to investigate, prevent or take action regarding illegal activities or suspected fraud or enforce or apply INTRALINK-SPINE INC. agreements.