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1. Thermo Fisher Scientific Privacy Notice
THERMO FISHER SCIENTIFIC PRIVACY NOTICE
Last Updated June 2022
Privacy principles
Purpose and reach
Information collected
Marketing, cookies, and tracking
Third parties
Your rights regarding your personal data
Transfer of personal data across national borders
Safeguarding information
How long your personal data will be retained
Special note to patients in the United States
Changes to this privacy notice
Contact us
PRIVACY POLICY
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WHO WE ARE
Thermo Fisher Scientific values your privacy and the protection of your Personal
Data. This Thermo Fisher Scientific Privacy Notice (“Notice”) explains how we
collect, store, use, share, transfer, delete, and process information collected
from or about you (“Personal Data”) by Thermo Fisher Scientific Inc., and any
directly or indirectly controlled affiliate or subsidiary thereof (collectively,
“Thermo Fisher Scientific,” “we,” “our,” or “us”). As an international company,
Thermo Fisher Scientific has multiple legal entities in different jurisdictions
that are responsible for the Personal Data they process, and we process Personal
Data in accordance with these applicable laws and regulations.
--------------------------------------------------------------------------------
THERMO FISHER SCIENTIFIC’S PRIVACY PRINCIPLES
Across all of our business activities we seek to base our privacy practices on
accepted principles of privacy and data protection. These principles include:
* Transparent: To be open about privacy practices, policies, developments, and
the details of any processing that takes place and to specify the purposes
for which Personal Data is collected and processed before such collection
takes place.
* Fair in Processing: To obtain Personal Data in good faith by legitimate,
lawful, and fair means and to process Personal Data only in accordance with
the purposes for which it was collected.
* Engage in Privacy by Design: To ensure we create solutions and process data
with privacy at the forefront and in accordance with these principles.
* Accountable: To be accountable for complying with measures that give effect
to these principles, including by ensuring accountability of third parties
with whom we interact through appropriate contracts.
* Responsive to Privacy Requests: To be responsive to individual’s privacy
rights afforded by law.
* Protective: To protect Personal Data using reasonable security safeguards, to
ensure data accuracy, and to limit use to that which is necessary for the
processing purpose.
--------------------------------------------------------------------------------
THE PURPOSE AND REACH OF THIS PRIVACY NOTICE
This Notice describes the types of Personal Data that Thermo Fisher Scientific
may collect or process, how we may use and disclose that Personal Data, and how
you may exercise any rights you may have regarding our processing of your
Personal Data.
This Notice applies to Personal Data collected or processed by us online
(through websites, applications, email, and otherwise) (“Online Services”); when
we process your Personal Data for your potential participation as a research
subject in clinical trials; when we process Personal Data for your potential
participation in clinical trials as an investigator or a member of the
investigator team; when we process medical information and in connection with
post-approval pharmacovigilance and adverse events, complaints, and reports;
when we provide products or services to you, your doctor, hospital, medical
treatment or scanning facility, or other healthcare provider (collectively,
“Healthcare Provider,” which refers both to the Healthcare Provider institution,
organization, or company, and individuals employed by or working for or with
such organization), or your patients; and in other situations where you interact
with us, including but not limited to interacting with or visiting our sites and
offices or our events (e.g., tradeshows and conferences) (such products,
services, Online Services, and other systems collectively, the “Products and
Services”); when we process your data as an employee of a company for which we
provide Products or Services; or anywhere this Notice is posted or referenced.
This Notice also applies to Personal Data that is collected or processed when
you interact with us in person, by telephone, or by mail.
* Thermo Fisher Scientific may have other unique privacy notices that apply to
certain specific situations, including informed consent forms for use in
interventional and observational medical research. To the extent you were
provided with a different privacy notice or policy and those policies or
notices apply, those policies or notices will govern our interactions with
you, not this one.
* If you provide us with Personal Data of anyone other than yourself (such as a
patient or family member), please note that you are responsible for complying
with all applicable privacy and data protection laws prior to providing that
information to Thermo Fisher Scientific (including obtaining consent, if
required).
* Please review this Notice carefully. To the extent permitted by applicable
law, by providing us your Personal Data or otherwise interacting with us, you
are agreeing to this Notice.
* The Thermo Fisher Scientific subsidiary or affiliate with whom you, your
employer, your Healthcare Provider, or your patient is interacting or who
owns and operates the Product or Service is, where applicable, the entity
responsible for the collection and use of your Personal Data (known in some
jurisdictions as the “data controller”). A list of the data controllers can
be found here, and contact details can be found in the Contact Us section at
the end of this Notice and in the list of data controllers.
--------------------------------------------------------------------------------
INFORMATION COLLECTED
What is Personal Data?
* “Personal Data” is any information—as electronically or otherwise
recorded—that can be used to identify a person or that we can link directly
to an individual, such as name, address, email address, telephone number, or
credit card number, as applicable. Personal Data in some jurisdictions can
include information that indirectly identifies a person, such as a unique
number assigned to a patient by a Healthcare Provider or a clinical trial
participant, even absent other identifying information.
* Personal Data may include information considered sensitive in some
jurisdictions, such as biometric information, genetic information, medical
and health information, financial account information, geolocation, ethnic or
racial origin, information concerning your sex life or your sexual
orientation, and other information. Please note that, for patients, as
described below, we may receive information about you from your Healthcare
Provider or others, when legally permitted.
* We will process any Personal Data we collect in accordance with applicable
law and as described in this Notice (unless, as explained above, a separate
policy or notice governs). In some circumstances, if you do not provide us
with your Personal Data, certain Products and Services may be unavailable to
you.
Below is a high-level summary of the types of Personal Data we may collect from
you. Following that high-level summary is additional detail and information on
how we collect, process, and use Personal Data and the potential recipients of
your Personal Data, and how we have done so in the preceding 12 months. Some
jurisdictions require us to state the legal bases for processing your Personal
Data, which are included below, but please note that not all jurisdictions may
recognize all legal bases.
×
USERS OF ONLINE SERVICES, VISITORS TO OUR WEBSITES AND PHYSICAL LOCATIONS, AND
SENDERS OF INQUIRIES
We may process your Personal Data when you: (1) visit our websites and our
physical locations; (2) submit inquiries to us both online (e.g., via email) or
offline (e.g., by written letters); (3) sign up for our newsletters or other
informational or marketing materials; and/or (4) register for, visit, or use our
online Products and Services.
EXAMPLES OF THE TYPES OF DATA WE PROCESS
Identity and contact information, such as:
• first and last name
• email address
• postal address
• phone number
• username and password
Other personal information, such as:
• age
• gender
• marital status
• disability
• date of birth
Visual and audio information, such as:
• still images
• video (including via CCTV)
• recordings of your calls with our customer service representatives
Technical Information, such as:
• Internet Protocol (IP) addresses (which may identify your general geographic
location or company)
• browser type and browser language
• device type
• advertising IDs associated with your device (such as Apple’s Identifier for
Advertising (IDFA) or Android’s Advertising ID (AAID))
• date and time you use our Products and Services
• Uniform Resource Locators, or URLs (i.e., website addresses) visited prior
to arriving and after leaving our Products and Services
• activity on our Products and Services and referring websites or applications
• data collected from cookies or other similar technologies***
• geolocation information
Anonymized / De‑identified Data:
• Anonymized data is data for which your individual personal characteristics
have been removed such that you are not identified and the information is no
longer considered Personal Data under data protection laws****
WHERE DO WE GET THE DATA?
* you directly
* your devices
* our security systems (including CCTV)
* third parties
WHY WE PROCESS THE DATA?
* to provide you with our Products and Services
* to communicate with you (about your inquiry)
* to administer our relationship with your organization
* to send you updates
* to identify and authenticate you
* to customize content for you
* to detect security incidents
* to protect against malicious or illegal activity
* to ensure the appropriate use of our Products and Services
* to improve our Products and Services
* for short-term, transient use
* for administrative purposes
* for marketing, internal research, and development
* for quality assurance and to assist in training and development of our
representatives
THE LEGAL BASES FOR PROCESSING:
* for the purposes of our legitimate interests
* in preparation for or to perform a contract with you
* in circumstances where we have requested and received consent and for other
purposes that may be required or allowed by law*
WHO RECEIVES THE DATA?
* Thermo Fisher, our affiliates, subsidiaries, and related companies
* partners that assist us in providing the Products or Services or help us
improve our marketing or administration**
PATIENTS AND USERS OF MEDICAL PRODUCTS
We may process your Personal Data when you are the existing or prospective
patient of a Healthcare Provider who is a Thermo Fisher customer and/or when you
receive or use Thermo Fisher medical products (including, where applicable,
mobile apps).
EXAMPLES OF THE TYPES OF DATA WE PROCESS
Identity and contact information, such as:
• first and last name
• email address
• postal address
• phone number
• username and password
Other personal information, such as:
• age
• gender
• marital status
• disability
• date of birth
Visual and audio information, such as:
• pictures and videos of treatment activities
Technical Information, such as:
• Internet Protocol (IP) addresses (which may identify your general geographic
location or company)
• browser type and browser language
• device type
• advertising IDs associated with your device (such as Apple’s Identifier for
Advertising (IDFA) or Android’s Advertising ID (AAID))
• date and time you use our Products and Services
• Uniform Resource Locators, or URLs (i.e., website addresses) visited prior
to arriving and after leaving our Products and Services
• activity on our Products and Services and referring websites or applications
• data collected from cookies or other similar technologies***
• geolocation information
Information regarding your treatment, such as:
• date of birth
• sex/gender
• genetic information
• blood and tissue samples
• identification of pathologies/diseases
• areas of interest in medical research
• treatment dates
• medical history and treatment information
• patient-reported outcome measures (e.g., responses to questionnaires and
surveys)
• X-rays, magnetic resonance imaging, and medical scans
• user activity
• therapy completion and use details
• communications with your Healthcare Provider, including audio and/or video
from telehealth sessions
Commercial and financial information, such as:
• Products and Services purchased, obtained, or considered
• request documentation
• customer service records
• financial transaction history
• financial account number
Anonymized / De‑identified Data:
• Anonymized data is data for which your individual personal characteristics
have been removed such that you are not identified and the information is no
longer considered Personal Data under data protection laws****
WHERE DO WE GET THE DATA?
* you directly
* your Healthcare Provider
* your devices
* our business partners and other third parties
WHY WE PROCESS THE DATA?
* to provide you with our Products and Services
* to communicate with you (about your inquiry)
* to administer our relationship with you
* to send you updates
* to communicate with you
* to identify and authenticate you
* to detect security incidents
* to protect against malicious or illegal activity
* to ensure the appropriate use of our Products and Services
* to improve our Products and Services
* for short-term, transient use
* for administrative purposes
THE LEGAL BASES FOR PROCESSING:
* for the purposes of our legitimate interests
* for medical diagnosis and the provision of healthcare and treatment
* in the public interest
* to comply with a legal obligation
* in preparation for or to perform a contract
* to protect vital interests
* to ensure high standards of quality and safety of healthcare and medical
devices
* in circumstances where we have requested and received consent and for other
purposes that may be required or allowed by law*
WHO RECEIVES THE DATA?
* Thermo Fisher, our affiliates, subsidiaries, and related companies
* Healthcare Providers
* partners that assist us in providing the Products or Services or help us
improve our marketing or administration**
CLINICAL STUDY PARTICIPANTS AND CANDIDATES
Clinical Study Participants: We may process your Personal Data when you
participate in a clinical study sponsored by us or conducted by us on behalf of
a third party.
If you are a participant in a clinical study, clinical trial, or other
health-related research, you should receive a separate privacy notice regarding
the Personal Data we process for those purposes. That privacy notice—and not
this Notice— governs our used of such Personal Data.
Clinical Study Candidates: we may process your Personal Data when you have been
identified as a potential candidate for clinical studies sponsored by us or
conducted by us on behalf of a third party.
If you are a participant in a clinical study, clinical trial, or other
health-related research, you should receive a separate privacy notice regarding
the Personal Data we process for those purposes. That privacy notice—and not
this Notice— governs our used of such Personal Data.
EXAMPLES OF THE TYPES OF DATA WE PROCESS
Identity and contact information, such as:
• first and last name
• email address
• postal address
• phone number
Other personal information, such as:
• age
• gender
• marital status
• disability
• date of birth
Technical Information, such as:
• Internet Protocol (IP) addresses (which may identify your general geographic
location or company)
• browser type and browser language
• device type
• advertising IDs associated with your device (such as Apple’s Identifier for
Advertising (IDFA) or Android’s Advertising ID (AAID))
• date and time you use our Products and Services
• Uniform Resource Locators, or URLs (i.e., website addresses) visited prior
to arriving and after leaving our Products and Services
• activity on our Products and Services and referring websites or applications
• data collected from cookies or other similar technologies***
• geolocation information
Information regarding your treatment, such as:
• date of birth
• sex/gender
• genetic information
• identification of pathologies/diseases
• areas of interest in medical research
• treatment dates
• medical history and treatment information
• X-rays, magnetic resonance imaging, and medical scans
• user activity
• therapy completion and use details
Anonymized / De‑identified Data:
• Anonymized data is data for which your individual personal characteristics
have been removed such that you are not identified and the information is no
longer considered Personal Data under data protection laws****
WHERE DO WE GET THE DATA?
* you directly
* your Healthcare Provider
* your devices
* our business partners and other third parties
* your friends or family
WHY WE PROCESS THE DATA?
* to communicate with you (about your inquiry)
* to administer our relationship with you
* to send you updates
* to determine your eligibility in one or more clinical studies
* to identify and authenticate you
* to detect security incidents
* to protect against malicious or illegal activity
* to ensure the appropriate use of our Products and Services
* to improve our Products and Services
* for short-term, transient use
* for administrative purposes
* for quality assurance
THE LEGAL BASES FOR PROCESSING:
* for the purposes of our legitimate interests
* in the public interest
* to comply with a legal obligation
* in preparation for or to perform a contract
* to protect vital interests
* in circumstances where we have requested and received consent and for other
purposes that may be required or allowed by law*
WHO RECEIVES THE DATA?
* Thermo Fisher, our affiliates, subsidiaries, and related companies
* our customers
* Healthcare Providers
* clinical investigators and/or members of investigator teams
* partners that assist us in providing the Products or Services or help us
improve our marketing or administration**
HEALTHCARE PROVIDERS
We may process your Personal Data when you are a Healthcare Provider who is a
current or prospective Thermo Fisher customer, uses Thermo Fisher Products and
Services, or treats patients with Thermo Fisher Products and Services, including
use of Thermo Fisher’s online portals.
EXAMPLES OF THE TYPES OF DATA WE PROCESS
Identity and contact information, such as:
• first and last name
• company/employer
• email address
• postal address
• phone number
• username and password
Other personal information, such as:
• age
• gender
• marital status
• disability
• date of birth
Technical Information, such as:
• Internet Protocol (IP) addresses (which may identify your general geographic
location or company)
• browser type and browser language
• device type
• advertising IDs associated with your device (such as Apple’s Identifier for
Advertising (IDFA) or Android’s Advertising ID (AAID))
• date and time you use our Products and Services
• Uniform Resource Locators, or URLs (i.e., website addresses) visited prior
to arriving and after leaving our Products and Services
• activity on our Products and Services and referring websites or applications
• data collected from cookies or other similar technologies***
• geolocation information
Commercial and financial information, such as:
• Products and Services purchased, obtained, or considered
• request documentation
• customer service records
• financial transaction history
• financial account number
Professional and educational information, such as:
• job title or position
• employer
• National Provider Identifier number
• state medical license number
• work skills
• employment history
• graduate degrees
• certifications
• specialized training
• responses to surveys and questionnaires
• enrolment history for our education and training events
Anonymized / De‑identified Data:
• Anonymized data is data for which your individual personal characteristics
have been removed such that you are not identified and the information is no
longer considered Personal Data under data protection laws****
WHERE DO WE GET THE DATA?
* you directly
* your devices
* our business partners and other third parties
* your employer or principal
* your patients
* other Healthcare Providers
WHY WE PROCESS THE DATA?
* to provide you with our Products and Services
* to communicate with you (about your inquiry)
* to administer our relationship with your organization
* to send you updates
* to communicate with you
* to identify and authenticate you
* to detect security incidents
* to protect against malicious or illegal activity
* to ensure the appropriate use of our Products and Services
* to improve our Products and Services
* for short-term, transient use
* for administrative purposes
* for quality assurance
* for marketing, internal research, and development
* for quality assurance
* to customize content for you
THE LEGAL BASES FOR PROCESSING:
* for the purposes of medical diagnosis and the provision of healthcare and
treatment
* for scientific or historical research or statistical purposes
* to ensure high standards of quality and safety of healthcare and medical
devices
* for the purposes of our legitimate interests
* to comply with a legal obligation
* in preparation for or to perform a contract
* to protect vital interests
* in circumstances where we have requested and received consent and for other
purposes that may be required or allowed by law*
WHO RECEIVES THE DATA?
* Thermo Fisher, our affiliates, subsidiaries, and related companies
* other Healthcare Providers
* your patients
* partners that assist us in providing the Products or Services or help us
improve our marketing or administration**
CLINICAL INVESTIGATORS AND MEMBERS OF INVESTIGATOR TEAMS
We may process your Personal Data if you are an existing or prospective clinical
investigator or a member of an investigation team for a clinical study that
Thermo Fisher manages on behalf of a customer.
EXAMPLES OF THE TYPES OF DATA WE PROCESS
Identity and contact information, such as:
• first and last name
• company/employer
• email address
• postal address
• phone number
• username and password
Other personal information, such as:
• age
• gender
• marital status
• disability
• date of birth
Technical Information, such as:
• Internet Protocol (IP) addresses (which may identify your general geographic
location or company)
• browser type and browser language
• device type
• advertising IDs associated with your device (such as Apple’s Identifier for
Advertising (IDFA) or Android’s Advertising ID (AAID))
• date and time you use our Products and Services
• Uniform Resource Locators, or URLs (i.e., website addresses) visited prior
to arriving and after leaving our Products and Services
• activity on our Products and Services and referring websites or applications
• data collected from cookies or other similar technologies***
• geolocation information
Professional and educational information, such as:
• job title or position
• employer
• National Provider Identifier number
• state medical license number
• work skills
• employment history
• graduate degrees
• certifications
• specialized training
• responses to surveys and questionnaires
• enrolment history for our education and
Commercial and financial information, such as:
• Products and Services purchased, obtained, or considered
• request documentation
• customer service records
• financial transaction history
• financial account number
Anonymized / De‑identified Data:
• Anonymized data is data for which your individual personal characteristics
have been removed such that you are not identified and the information is no
longer considered Personal Data under data protection laws****
WHERE DO WE GET THE DATA?
* you directly
* your devices
* our business partners and other third parties
* our customers
* your employer or principal
WHY WE PROCESS THE DATA?
* to provide you with our Products and Services
* to communicate with you (about your inquiry)
* to administer our relationship with your organization
* to send you updates
* to communicate with you
* to identify and authenticate you
* to detect security incidents
* to protect against malicious or illegal activity
* to ensure the appropriate use of our Products and Services
* to improve our Products and Services
* for short-term, transient use
* for administrative purposes
* for quality assurance
* for marketing, internal research, and development
* for quality assurance
* to customize content for you
THE LEGAL BASES FOR PROCESSING:
* for the purposes of medical diagnosis and the provision of healthcare and
treatment
* for scientific or historical research or statistical purposes
* to ensure high standards of quality and safety of healthcare and medical
devices
* for the purposes of our legitimate interests
* to comply with a legal obligation
* in preparation for or to perform a contract
* to protect vital interests
* in circumstances where we have requested and received consent and for other
purposes that may be required or allowed by law*
WHO RECEIVES THE DATA?
* Thermo Fisher, our affiliates, subsidiaries, and related companies
* our customers
* other clinical investigators and/or members of investigator teams
* partners that assist us in providing the Products or Services or help us
improve our marketing or administration**
EMPLOYMENT AND APPRENTICESHIP CANDIDATES
We may process your Personal Data when you apply or are a candidate for
employment or apprenticeship at Thermo Fisher.
EXAMPLES OF THE TYPES OF DATA WE PROCESS
Identity and contact information, such as:
• first and last name
• company/employer
• email address
• postal address
• phone number
• username and password
Other personal information, such as:
• age
• gender
• marital status
• disability
• date of birth
Technical Information, such as:
• Internet Protocol (IP) addresses (which may identify your general geographic
location or company)
• browser type and browser language
• device type
• advertising IDs associated with your device (such as Apple’s Identifier for
Advertising (IDFA) or Android’s Advertising ID (AAID))
• date and time you use our Products and Services
• Uniform Resource Locators, or URLs (i.e., website addresses) visited prior
to arriving and after leaving our Products and Services
• activity on our Products and Services and referring websites or applications
• data collected from cookies or other similar technologies***
• geolocation information
Professional and educational information, such as:
• job title or position
• employer
• work skills
• employment history
• graduate degrees
• certifications
• specialized training
• responses to surveys and questionnaires
Anonymized / De‑identified Data:
• Anonymized data is data for which your individual personal characteristics
have been removed such that you are not identified and the information is no
longer considered Personal Data under data protection laws****
WHERE DO WE GET THE DATA?
* you directly
* your employer or principal
* your devices
* our business partners and other third parties
WHY WE PROCESS THE DATA?
* to communicate with you
* to identify and authenticate you
* to detect security incidents
* to protect against malicious or illegal activity
* for short-term, transient use
* for administrative purposes
* for marketing, internal research, and development
THE LEGAL BASES FOR PROCESSING:
* for the purposes of our legitimate interests
* in preparation for or to perform a contract
* to comply with a legal obligation
* in circumstances where we have requested and received consent and for other
purposes that may be required or allowed by law*
WHO RECEIVES THE DATA?
* Thermo Fisher, our affiliates, subsidiaries, and related companies
* partners that assist us in providing the Products or Services or help us
improve our marketing or administration**
BUSINESS PARTNERS AND THEIR EMPLOYEES, AGENTS, AND CONTRACTORS
We may process your Personal Data when you act as a business partner such as
vendor, supplier, distributor, retailer, or service provider.
EXAMPLES OF THE TYPES OF DATA WE PROCESS
Identity and contact information, such as:
• first and last name
• company/employer
• email address
• postal address
• phone number
• username and password
Other personal information, such as:
• age
• gender
• disability
• date of birth
Technical Information, such as:
• Internet Protocol (IP) addresses (which may identify your general geographic
location or company)
• browser type and browser language
• device type
• advertising IDs associated with your device (such as Apple’s Identifier for
Advertising (IDFA) or Android’s Advertising ID (AAID))
• date and time you use our Products and Services
• Uniform Resource Locators, or URLs (i.e., website addresses) visited prior
to arriving and after leaving our Products and Services
• activity on our Products and Services and referring websites or applications
• data collected from cookies or other similar technologies***
• geolocation information
Commercial and financial information, such as:
• Products and Services purchased, obtained, or considered
• request documentation
• customer service records
• financial transaction history
• financial account number
Anonymized / De‑identified Data:
• Anonymized data is data for which your individual personal characteristics
have been removed such that you are not identified and the information is no
longer considered Personal Data under data protection laws****
WHERE DO WE GET THE DATA?
* you directly
* our business partners and other third parties
* your employer or principal
* your devices
WHY WE PROCESS THE DATA?
* to communicate with you (about your inquiry)
* to administer our relationship with your organization
* to send you updates
* to identify and authenticate you
* to detect security incidents
* to protect against malicious or illegal activity
* for short-term, transient use
* for administrative purposes
* for marketing, internal research, and development
* to provide you with our Products and Services
* to communicate with you
* to identify and authenticate you
THE LEGAL BASES FOR PROCESSING:
* for the purposes of our legitimate interests
* for medical diagnosis and the provision of healthcare and treatment
* in the public interest
* to comply with a legal obligation
* in preparation for or to perform a contract
* to protect vital interests
* to ensure high standards of quality and safety of healthcare and medical
devices
* in circumstances where we have requested and received consent and for other
purposes that may be required or allowed by law*
WHO RECEIVES THE DATA?
* Thermo Fisher, our affiliates, subsidiaries, and related companies
* our customers
* Healthcare Providers
* patients
* partners that assist us in providing the Products or Services or help us
improve our marketing or administration**
ATTENDEES AND PARTICIPANTS AT EVENTS
We may process your Personal Data when you attend or participate in professional
and educational events we sponsor or hold.
EXAMPLES OF THE TYPES OF DATA WE PROCESS
Identity and contact information, such as:
• first and last name
• company/employer
• email address
• postal address
• phone number
• username and password
Other personal information, such as:
• age
• gender
• marital status
• disability
• date of birth
Visual and audio information, such as:
• still images
• video (including via CCTV)
Technical Information, such as:
• Internet Protocol (IP) addresses (which may identify your general geographic
location or company)
• browser type and browser language
• device type
• advertising IDs associated with your device (such as Apple’s Identifier for
Advertising (IDFA) or Android’s Advertising ID (AAID))
• date and time you use our Products and Services
• Uniform Resource Locators, or URLs (i.e., website addresses) visited prior
to arriving and after leaving our Products and Services
• activity on our Products and Services and referring websites or applications
• data collected from cookies or other similar technologies***
• geolocation information
Professional and educational information, such as:
• job title or position
• employer
• work skills
• employment history
• graduate degrees
• certifications
• specialized training
• responses to surveys and questionnaires
Anonymized / De‑identified Data:
• Anonymized data is data for which your individual personal characteristics
have been removed such that you are not identified and the information is no
longer considered Personal Data under data protection laws****
WHERE DO WE GET THE DATA?
* you directly
* your employer or principal
* your devices
* our business partners
WHY WE PROCESS THE DATA?
* to communicate with you (about your inquiry)
* to communicate with you (about your inquiry)
* to administer our relationship with your organization
* to send you update
* to communicate with you
* to identify and authenticate you
* to detect security incidents
* to protect against malicious or illegal activity
* for short-term, transient use
* for administrative purposes
THE LEGAL BASES FOR PROCESSING:
* for the purposes of our legitimate interests
* in preparation for or to perform a contract
* to comply with a legal obligation
* in circumstances where we have requested and received consent and for other
purposes that may be required or allowed by law*
WHO RECEIVES THE DATA?
* Thermo Fisher, our affiliates, subsidiaries, and related companies
* other event attendees and participants
* partners that assist us in providing the Products or Services or help us
improve our marketing or administration**
CHILDREN
Thermo Fisher Scientific does not knowingly collect, maintain, disclose, or
otherwise process Personal Data from minors below the age of 16 without the
permission of such minor’s parents or legal guardians.
*The legal bases relied upon by Thermo Fisher Scientific include those
enumerated in Articles 6 and 9 of the European Union’s General Data Protection
Regulation (“GDPR”), depending on the type of Personal Data.
**In limited circumstances, recipients may include, (1) in the event of a sale,
assignment, or transfer, to the buyer, assignee, or transferee; and, (2)
government or regulatory officials, law enforcement, courts, public authorities,
or others when permitted by this Notice or required by law.
***Please see our Notice on Cookies for more information on how we use cookies
and similar technologies.
****This includes in the United States the removal of identifiers from protected
health information required under the Health Insurance Portability and
Accountability Act (“HIPAA”), 45 CFR § 164.514(b)(2), for such data to be
considered deidentified. In the course of research, study doctors and authorized
personnel may still have access to named subject records collected for such
research.
--------------------------------------------------------------------------------
MARKETING, COOKIES, AND TRACKING
Marketing Uses, Cookies, and Other Activities
To the extent permitted by applicable law, including in accordance with your
consent where required by applicable law, we may engage in the following
activities:
* We may use your contact details to contact you to determine whether you would
like to initiate a business relationship with us or to send you marketing
emails. If you do not wish to receive such marketing emails, you may opt out
by declining to receive such emails when registering or in our subsequent
communications by following opt-out instructions included in the email or at
other information collection points on the Online Services.
* We may display advertisements to you regarding Products and Services that we
believe are relevant to you based on your activities on the Online Services
or on other web or digital properties. Such advertisements may be shown on
our Online Services or the online services of others. We achieve this by
using, and allowing third parties (e.g., Facebook, LinkedIn) to use certain
cookies, eTags, pixels, web beacons, and other tracking technologies to track
your activities on our Online Services and other online services. For more
information about these activities and how to manage or opt out of them,
please see our Notice on Cookies.
* We may make customer offers to you based on your activities across different
Online Services, including activities on other web or digital properties or
your other interactions with Thermo Fisher Scientific that are not via the
Online Services (e.g., regional offers based on the location of your office
listed on order forms).
* We also perform statistical analyses of the users of our Online Services to
improve the functionality, content, design, and navigation of the Online
Services.
Processing Using Website Tracking
On certain of our websites, we use Google Analytics, to help us understand how
users engage with this and other of our websites. Google Analytics may track
your activity on our sites (i.e., the pages you have seen and the links you have
clicked on) and helps us measure how you interact with the content that we
provide. This information is used to compile reports and to help us improve the
sites. The reports we receive disclose website trends without identifying
individual visitors. You can learn about Google’s practices by going to
www.google.com/policies/privacy/partners/, and exercise the opt-out provided by
Google by downloading the Google Analytics opt-out browser add-on, available at
https://tools.google.com/dlpage/gaoptout or as described in our Notice on
Cookies.
Interactive Features of our Websites
To the extent we offer any public or group forums on our Products or Services,
such as newsfeeds, blogs, message boards, or similar tools (“Interactive
Features”), the posts or comments you make may be public and viewed by others.
You should use care before posting information about yourself, including
Personal Data. You acknowledge and understand that you have no expectation of
privacy or confidentiality in the content you submit to Interactive Features
over the Products and Services. Except when required to do so by applicable law,
we assume no obligation to remove Personal Data you post on our Products and
Services, and your disclosure of any Personal Data through the Interactive
Features is at your own risk.
--------------------------------------------------------------------------------
THIRD PARTIES
Third-Party Service Providers
Third-party service providers acting on our behalf must execute agreements
including confidentiality requirements and will only process Personal Data as
necessary to perform their functions in a manner consistent with this Notice,
other applicable privacy notices, and as explicitly permitted or required by
applicable laws, rules, and regulations. Our third-party service providers may
be located in the United States and other jurisdictions.
Combination of Data With Data Received from Third Parties
We may combine information we collect, whether Personal Data or not, with
Personal Data that we may obtain from third parties.
Links to Other Websites
Our Products or Services may contain links to other websites, applications,
products, or services that are not owned or operated by Thermo Fisher
Scientific, such as social media websites and applications like Facebook and
Twitter. You should carefully review the privacy policies and practices of other
websites, products, and services as we cannot control and are not responsible
for privacy policies, notices, or practices of third-party websites,
applications, products, and services.
--------------------------------------------------------------------------------
YOUR RIGHTS REGARDING YOUR PERSONAL DATA
Please note that in many circumstances, we cannot effectively do business with
you without processing some Personal Data about you (e.g., your contact
information). For example, when you contact customer service representatives, we
may require you to provide information to authenticate your identity to assist
you with your request. If you are unable to provide this information, we may be
unable to process your request.
You may have a right under your area’s data protection law to the following
rights with respect to some or all of your Personal Data:
* To request access to your Personal Data (including under GDPR Article 15);
* To request that we rectify or erase your Personal Data (including under GDPR
Articles 16 and 17);
* To request that we restrict or block the processing of your Personal Data
(including under GDPR Articles 18, 21 and 22 and to object to the sale or
sharing of your Personal Data under other relevant laws);
* This includes the right to opt-out of solicitations;
* To provide your Personal Data directly to another organization, i.e., a right
to data portability (including under GDPR Article 20);
* When we previously obtained your consent, to withdraw consent to processing
(including under GDPR Article 21); and
* To lodge a complaint with the data protection authority in your area.
You can make a request with respect to your Personal Data by clicking below and
submitting the form.
We will make reasonable efforts to respond promptly to your requests in
accordance with applicable laws. We may, after receiving your request, require
additional information from you to honor the request and verify your identity.
Please be aware that we may be unable to afford these rights to you under
certain circumstances, such as if we are legally prevented from doing so. You
may also find additional contact information in the list of data controllers
here.
When we receive your Personal Data from our customers and process your Personal
Data on their behalf, we do so in the capacity of a data processor. We do not
have control over our customers’ privacy and security practices and processes.
If your Personal Data has been submitted to us by a Thermo Fisher Scientific
customer and you wish to exercise any of the above-mentioned rights, please
contact the relevant customer directly, or provide us with the name of the
customer so that we can appropriately refer your request to them.
--------------------------------------------------------------------------------
TRANSFER OF PERSONAL DATA ACROSS NATIONAL BORDERS
Please be aware that Personal Data we collect and process may be transferred and
maintained outside your state, province, country, or other jurisdiction where
the privacy laws may not be as protective as those in your location, including
the United States. Thermo Fisher Scientific has put in place lawful transfer
mechanisms and adequate safeguards, in accordance with applicable legal
requirements, to protect your Personal Data.
--------------------------------------------------------------------------------
SAFEGUARDING INFORMATION
Consistent with applicable laws and requirements, Thermo Fisher Scientific has
put in place physical, technical, and administrative safeguards to protect
Personal Data from loss, misuse, alteration, theft, unauthorized access, and
unauthorized disclosure consistent with legal obligations and industry
practices. However, as is the case with all websites, applications, products,
and services, we unfortunately are not able to guarantee security for data
collected through our Products and Services. In addition, it is your
responsibility to safeguard any passwords, ID numbers, or similar individual
information associated with your use of the Products and Services.
--------------------------------------------------------------------------------
HOW LONG YOUR PERSONAL DATA WILL BE RETAINED
We generally retain Personal Data for as long as needed for the specific
business purpose or purposes for which it was collected. In some cases, we may
be required to retain Personal Data for a longer period of time by law or for
other necessary business purposes. Whenever possible, we aim to anonymize the
information or remove unnecessary identifiers from records that we may need to
keep for periods beyond the specified retention period.
--------------------------------------------------------------------------------
SPECIAL NOTE TO PATIENTS IN THE UNITED STATES
If you are a U.S. patient, please note that this Notice is distinct from your
Healthcare Provider’s HIPAA Notice of Privacy Practices, which describes how
your Healthcare Provider uses and discloses individually identifiable
information about your health that it collects, as well as any other privacy
practices it applies. Thermo Fisher Scientific collects, uses, and discloses
Personal Data it receives on behalf of your Healthcare Provider in accordance
with its HIPAA-required agreements with your Healthcare Provider.
--------------------------------------------------------------------------------
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to change this Notice from time to time. We will alert you
when changes have been made by indicating the date this Notice was last updated
as the date the Notice became effective or as otherwise may be required by law.
It is recommended that you periodically revisit this Notice to learn of any
changes.
--------------------------------------------------------------------------------
CONTACT US
If you have questions or comments about this Notice or about how your Personal
Data is processed, please contact the Thermo Fisher Privacy Office by submitting
a privacy inquiry here or call us at +1 888-386-0779. We will make reasonable
efforts to respond promptly to your requests in accordance with applicable laws.
We may, after receiving your request, require additional information from you to
honor the request and verify your identity. Please be aware that we may be
unable to afford these rights to you under certain circumstances, such as if we
are legally prevented from doing so. You may also find additional contact
information in the list of data controllers here.
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