1. Our Commitment to Your Privacy
Key Surgical LLC (“Key Surgical”, “our”, “we” or “us”) recognizes the importance of data privacy. We believe that privacy is a matter of trust, and we are committed to managing personal data lawfully, fairly and transparently. We want our website visitors, customers, distributors, employees, and other business partners (collectively, "you" or "your") to understand the ways we collect and use personal data about you.
This Privacy Statement describes:
Ways we collect your personal data
Ways we use your personal data
Ways we share your personal data
Ways we retain and safeguard your personal data
Your rights and choices about how we collect, use and share your personal data
2. Statement Scope
This Privacy Statement applies to our business operations in Eden Prairie, Minnesota, and to the website keysurgical.com (hereafter, the “Site”), which is hosted in the United States.
3. Ways We Collect Your Personal Data
3.1 In General
We collect only personal data that you provide to us voluntarily and with your consent. Key Surgical takes measures to ensure that we collect personal data for specified, explicit and legitimate reasons only – namely, to provide products and services to you and meet our legal obligations. We also take steps to limit the personal data we collect to only the minimum necessary to carry out our mission.
We may collect your personal data when you:
Register for a Key Surgical event or interact with us at an event exhibit;
Communicate with us via e-mail or other channels, such as our Contact form.
In these instances, we may collect personal data such as: your name, e-mail address, postal address, phone and fax number, company name and job title.
If you apply for a job with Key Surgical and/or receive an offer of employment, we may collect special categories of personal data, such as: your birthdate, social security number, and other information necessary to facilitate the employment process.
3.2 Log Files
We may use log files to record data about each users’ visit to our Site. When you visit the Site, we collect the IP (Internet Protocol) address connected to your computer (or the proxy server you use to access the World Wide Web), your computer operating system, the type of browser you are using, mobile device operating system (if you are accessing the Site using a mobile device), as well as the name of your ISP ("Internet Service Provider") or your mobile carrier. We use this information to analyze overall trends to help improve the Site. We do not share log data with third-parties unless required by law to do so.
We use another type of cookie, called a "session" cookie, to identify your last visit to the Site. Session cookies used by the Site expire after you close your web browser.
We may also use web "beacons" to allow us to know if you visited a certain page, opened an email from us or to determine if ad banners on our Site were effective.
From time to time, we may collect information from you via an online survey. Participation in these surveys is completely voluntary. Information requested may include personal and demographic information. Key Surgical may use survey information for purposes of monitoring and improving the Site and/or Key Surgical products and services.
3.6 Your Consent to Our Collection and Subsequent Use
By using this Site or otherwise communicating with Key Surgical electronically, you consent to our collection and subsequent use of your personal data for our legitimate business uses. If you do not consent to such collection or subsequent use of your personal data, you may not be able to communicate electronically with Key Surgical.
4. Ways We Use Your Personal Data
4.1 In General
We may use your personal data to communicate with you and provide you our products and services. For example, we may use your personal data to:
Send you our blog and other newsworthy updates;
Send you invitations to events and conferences;
Answer questions you submit to us;
Administer our business processes; and
Comply with our legal and contractual obligations.
If you apply for a job Key Surgical, we may also use your personal data to process your employment application, conduct background screening, check references. Once hired, we may use your personal data to facilitate payroll and employee benefits administration .
4.2 Opting-Out of Uses of Your Personal Data
If you wish to request that Key Surgical refrains from using your personal data to communicate with you, please submit your request to Key Surgical by using the contact information below.
5. Ways We Share Your Personal Data
5.1 In General
We have not and will not sell or lease your personal data to third-parties. In the context of the uses of personal data mentioned in the Ways We Use Your Personal Data section above, we may share your personal data with third-parties we engage to help provide products and services to you. These third-parties include, but are not limited to, organizations that provide the following:
Payment processing system;
Customer relationship management (CRM) platform;
Business resilience and disaster recovery services;
User authentication tools and services;
Auditing platforms and accounting services;
E-mail and direct marketing tools and services; and
Recruitment tools, background checks, and other pre-employment related services.
5.2 Other Sharing Circumstances
We may also share your personal data in other circumstances, such as:
As required to by law or in response to a subpoena or other government information request;
If we believe that the disclosure is in the interest of your security or the security of Key Surgical (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction);
If we merge with or are acquired by another company, or;
If we go out of business, enter bankruptcy, or go through some other change of control.
5.3 Sharing Aggregate Information
When Key Surgical requests demographic information collected during an information request or registration, you have the option not to provide this information. We encourage you to do so that we may gain a better understanding of your needs, and so that we may serve you in a more personalized manner.
We may share aggregate non-personal information with strategic partners. For these circumstances, we do not disclose information that can uniquely identify you.
5.4 Opting-Out of Sharing Your Personal Data
You have choices regarding the ways we share your personal data with third-parties. If you wish to opt-out, please submit your request to Key Surgical by using the contact information below.
6. Personal Data Retention
We may retain your personal data for as long as you are a business contact to us or as needed to provide you products and services. For those individuals resident in the EU, you have the right to request that we delete your personal data under GDPR. However, Key Surgical may retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
7. Special Notice for Individuals in the European Economic Area (EEA)
If you are resident in the European Union (EU), please be aware that we operate the United States. As such, we may transfer your personal data from the European Economic Area (EEA) to the US to provide you products and services, or otherwise communicate with you. Key Surgical takes measures to ensure that your personal data is adequately safeguarded when transferred, processed, and stored in the United States or elsewhere. In doing so, we aim to comply with applicable EU data privacy laws and regulations.
By using Key Surgical’s Site or otherwise communicating with us electronically, you acknowledge that we may transfer, process or store your personal data outside the EEA, and that we may share your personal data as described in the How We Share Your Personal Data section above.
8. Individuals’ Rights Under the General Data Protection Regulation (GDPR)
Access: You have the right to access your personal data held by Key Surgical.
Correction, Amendment and Removal: You have the right to correct or amend your personal data held by Key Surgical. You also have a right to request that Key Surgical deletes certain personal data about you.
Restriction: You have the right to restrict processing of your personal data held by Key Surgical if you contest the accuracy of your personal data held by Key Surgical or the lawfulness of Key Surgical’s processing of your personal data.
Portability: You have the right to receive your personal data held by Key Surgical in a structured, commonly-used and machine-readable format. You also have the right to transmit your personal data to another organization without hindrance from Key Surgical.
Objection: You have the right to object, on grounds relating to your particular situation, to Key Surgical’s processing of personal data about you, unless Key Surgical demonstrates compelling legitimate grounds for continuing such processing. You also have the right to object to any automated decision-making (such as user profiling) used by Key Surgical.
Complaints: You have the right to lodge a complaint or concern about our data privacy practices with Key Surgical directly and/or with an appropriate supervisory authority, as defined by GDPR.
If you wish to exercise any of your rights under GDPR, as described above, please submit your request to Key Surgical by using the contact information below.
9, California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third-parties for their direct marketing purposes. If you wish to exercise your rights under California law, as described above, please submit your request to Key Surgical by using the contact information below.
10. Individuals Under the Age of 13
Key Surgical does not intend this Site for use by individuals under 13 years of age. Individuals under age 13 should avoid providing any personal data to the Site without verifiable parental consent.
11. Data Security
We constantly strive to align our data security practices with industry standards for securely handling, transmitting and storing personal data. To prevent unauthorized access, maintain data accuracy and the correct use of information, Key Surgical implements administrative, physical and technical measures to safeguard and secure the information we collect on this Site. We utilize industry-accepted encryption technologies and strengths to reduce the risk that others can view information passing between our Site and your browser.
Since the Internet is not a completely secure environment, we cannot ensure or warrant the security of any information you transmit to us. Key Surgical offers no guarantees that information cannot or will not be accessed, disclosed, altered, or destroyed by a breach of any of our administrative, physical or technical measures.
12. Notification in Event of Data Breach
International, federal and state laws and regulations require Key Surgical to notify individuals in the event of a breach of personal data. In such an unfortunate event, we will promptly notify data breach victims, in accordance with notification procedures defined in our internal policies, and as required by applicable law.
This Site may contain links to and from other third-party sites. Please be aware that Key Surgical is not responsible for the privacy practices of these third-party sites. We encourage you to be aware when you leave our Site, and to read the privacy statements of each website that collects your personal data.
14. How to Contact Us
You may contact us directly via post, phone or e-mail: Key Surgical LLC c/o Privacy Official 8101 Wallace Road Minneapolis, MN 55344 +1 800-541-7995 firstname.lastname@example.org
If you request to opt-out, there will be a 30-day period before such opt-out will take effect.
15. Updates to this Privacy Statement
Key Surgical reviewed and updated this Privacy Statement on August 9, 2019. We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Statement at any time. Your continued use of the Site following reasonable notice of such modifications constitutes your acceptance of any changes to this Privacy Statement.