EU-U.S. Privacy Shield Privacy Policy

Purpose

ZOLL Data Systems, Inc. (“ZOLL”) respects the privacy of its customers, employees, business partners, individuals whose personal information with which we are entrusted, and others. ZOLL collects and uses any collected personal health information in accordance with the laws and regulations of the countries in which the information is collected, and in which it does business.

ZOLL complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. ZOLL has certified that it adheres to the EU-U.S. Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability. If there is any conflict between the policies 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 page, please visit https://www.privacyshield.gov/.

Scope

ZOLL is committed to subject all personal data received from the European Union in reliance on the Privacy Shield to the Privacy Shield Principles. This policy applies to such data except for human resources data, which is addressed in a separate policy available to affected employees.

Types of Data

ZOLL provides online services that our customers use to operate aspects of their businesses. These services include tools for patient care, fleet management, records management and communications, among others. In providing these online services, ZOLL processes data our customers submit to our services or instruct us to process on their behalves. While ZOLL’s customers decide what data to submit, it typically includes information about their patients, customers, employees and users of our service, such as health, medication, demographic, billing and contact information.

Collection and Use

ZOLL processes data submitted by customers for the purpose of providing ZOLL’s online services to them. To fulfill this purpose, ZOLL may access the data to provide those services, to correct and address technical or service problems, to follow instructions of the ZOLL customer who submitted the data, to implement ZOLL’s software and hardware solutions or in response to contractual requirements.

Inquiries and Complaints

In compliance with the EU-US Privacy Shield Principles, ZOLL commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact ZOLL at: 

Attn: Justin Koan
11802 Ridge Parkway #400
Broomfield, CO 80021-5059
security@zoll.com

ZOLL has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. 

If neither ZOLL nor BBB EU PRIVACY SHIELD resolves your complaint, you may have the right to engage in binding arbitration through the Privacy Shield Panel.

Third Party Disclosures

ZOLL uses a limited number of third-party service providers to assist us in providing our services to customers. These third party providers offer customer support to our customers, assist with the transmission of data and provide data storage services. These third parties may access, process or store personal data in the course of providing their services. ZOLL maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our Privacy Shield obligations, and ZOLL may be liable if they fail to meet those obligations and we are responsible for the event giving rise to the damage.

Rights to Access Data and Limit Its Use and Disclosure

You have the right to access personal data about you, and to limit use and disclosure of your personal data. With our Privacy Shield certification, ZOLL has committed to respect those rights. Because ZOLL personnel have limited ability to access data our customers submit to our services, if you wish to request access, to limit use or to limit disclosure, please provide the name of the ZOLL customer who submitted your data to our services. We will refer your request to that customer, and will support that customer as needed in responding to your request.

Powers of Investigation and Enforcement

ZOLL is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission

Effective Date: August 31, 2016