- How We Collect, Use and Retain Personal Information
- How We Share and Disclose Personal Information
- Information Security
- International Data Transfers
- Additional Policies
- Children’s Privacy
- Your Rights
- Links to Third Party Sites and Social Media
- User Generated Content
- Managing Communication Preferences
- Contact Us
The DJO subsidiary or affiliate who owns and operates the Service that you are visiting will be the data controller responsible for the collection and use of your Personal Information.
How We Collect, Use and Retain Personal Information
When we use the term “Personal Information,” we mean information that can be used to identify you as an individual person, relates to you, describes you, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. We do not consider Personal Information to include information that has been de-identified so that it does not allow a third party to easily identify a specific individual. We collect several categories of Personal Information through our Services, including information you provide, information collected automatically from your device, and information we obtain from third party sources. We use and share this Personal Information for the purposes described below, including as described under Additional Uses of Personal Information.
We rely on separate and overlapping bases to process your Personal Information lawfully. By way of example only, it may be necessary for us to process your Personal Information in certain ways in order to process a transaction you have requested or otherwise in accordance with a contract between us, or in certain cases we may process your Personal Information where necessary to further our legitimate interests, where those legitimate interests are not overridden by your rights and interests.
Information You Provide
We collect Personal Information you provide. For example, we collect Personal Information when you enter your full name, physical address, phone number, purchase information and account credentials, demographic information and information related to your preferences into form fields on our Services. The Personal Information we may collect includes, but is not limited to:
|Category of Personal Data|| Purposes of Processing
(see also Additional Uses of Personal Information below)
|Legal Bases for Processing|
|Contact Information including your name, home address, email address and phone number||To administer your account and the Services, authenticate you as a user, and communicate with you||To process transactions requested by you and meet our contractual obligations Legitimate interests Your consent, where applicable|
|Demographic Information including your age, information about your household, product preferences and other interests||To better understand and analyze our customer population, support our operations including inventory and product management, to deliver relevant offers and ads, to improve our products and services including the Services||Legitimate interests Your consent, where applicable|
|Online Purchase Information including payment card information, purchase details and other transaction information||To process purchases you make online, deliver purchased products and services, improve our e-commerce platform, personalize your customer experience and contribute to our marketing efforts, for example, by analyzing information about what products are viewed, when you browse items but do not make a purchase and other interactions you have with our e-commerce Services||To process transactions requested by you and meet our contractual obligations Legitimate interests Your consent, where applicable|
|Employment Application Information including your contact information, employment and education history, and other information you include in your CV/resume or application materials, as well as information collected for background checks where required||To process and evaluate job applications you submit through the Services and to communicate with you about your job applications and requests||Legitimate interests Your consent, where applicable|
For treatment, payment and health care operations purposes
To provide products and services to you and/or your Health Care Provider
For research, trending, analysis, and reporting, development and quality improvement of digital and physical products and services, enhancement of the quality of patient care and/or inclusion of information in an electronic data repository or domestic and international regulatory submissions
|Compliance with a legal obligation or law to which DJO is subject To meet our contractual obligations Your consent, where applicable|
Information Collected Automatically
As is true of most digital platforms, we gather certain information automatically when you use our Services. This information is gathered on our Services without you actively providing the information. This information may include browser, device, cookie and similar data that we collect as follows:
|Category of Personal Data||Purposes of Processing
(see also Additional Uses of Personal Information below)
|Legal Bases for Processing|
|Log Files including IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data||To maintain the security of our Services, for fraud detection, and to protect our rights||Legitimate interests|
|Cookies, Analytics and Related Technologies||To manage our Services and email messages and to collect and track information about you and your activities online over time and across different websites and online channels||Legitimate interests Your consent, where applicable|
|Location Information including latitude, longitude, date and time.||To offer you certain location-based services, and to conduct analytics to improve the Services. You may disable the collection of your location information in your device’s settings. Please be advised that we may not be able to provide location-based services to you if you choose to do so.||Legitimate interests Your consent, where applicable|
You may be able to change browser settings to block and delete cookies when you access our Services through a web browser. However, if you do that, the Service/site may not work properly. Our Services do not respond to Do Not Track requests.
Information We Obtain from Third Party Sources
We may obtain certain Personal Information about you from third party sources, which we may use to serve our legitimate interests, comply with legal obligations, perform a contract, or in some cases, in accordance with your consent.
Business Partners and Service Providers: We use business partners and service providers, such as payment processors and analytics providers, to perform services on our behalf. Some of these partners have access to Personal Information about you that we may not otherwise have (for example, where you sign up directly with that provider) and may share some or all this information with us. We use this information to administer the Services and conduct marketing and advertising campaigns as well as to process transactions that you request.
Supplemental Information: We may receive additional Personal Information from third-party sources, such as credit reference agencies and public databases, which we may append to existing consumer information, such as email address verification. We may use this supplemental information to process transactions that you request and to prevent fraud, deliver relevant offers and advertising to you and to improve our operations, Services and our advertising and marketing campaigns.
Additional Uses of Personal Information
In addition to the uses described above, we may use your Personal Information for the following purposes, which uses may under certain circumstances be based on your consent, may be necessary to fulfill our contractual commitments to you, and are necessary to serve our legitimate interest in the following business operations:
- Operating our business, administering the Services and managing your accounts;
- Contacting you to respond to your requests or inquiries;
- Processing and completing your transactions including, as applicable, order confirmation, enrollment in our loyalty or other programs, processing payments for online purchases and delivering products or services;
- Providing you with newsletters, articles, product or service alerts or announcements, savings awards, event invitations, and other information that we believe may be of interest to you;
- Providing you with promotional information, offers, and other information that are personally tailored to your interests and purchase behavior;
- Conducting market research, surveys, and similar inquiries to help us understand trends and customer needs;
- Administering our loyalty and rewards programs including allowing you to create and maintain customer profiles, analyzing your interactions with us, presenting customized offers, and improving our products, services, programs, and other offerings;
- Alerting you about a product safety announcement or recall or correction of an offer, promotion, or advertisement;
- Administering sweepstakes and promotions or contacting you regarding a contest prize;
- Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of Personal Information, our website or data systems; or to meet legal obligations;
- Enforcing our Terms and Conditions and other agreements; and
- Sending you text messages or push notifications when you sign up for one of our messaging programs. These messages may be sent by automated means. You may opt out of a text message program by following the instructions in the“Your Privacy Choices”section.
We rely on several legitimate interests in using and sharing your Personal Information. These interests include:
- Improving and customizing the Services for you;
- Understanding how the Services are being used;
- Obtaining insights into usage patterns of the Services;
- Exploring ways to develop and grow our business;
- Ensuring the safety and security of the Services; and
- Enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks.
- Where we are processing Personal Information based on our legitimate interests, we generally will retain such information for a reasonable period based on the particular interest, taking into account the fundamental interests and the rights and freedoms of data subjects.
- Where we are processing Personal Information based on your consent, we generally will retain the information for the period of time necessary to fulfill the underlying agreement with you, subject to your right, under certain circumstances, to have certain of your Personal Information erased (please see the Your Rights section below).
- Where we are processing Personal Information based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
- In addition, we may face threat of legal claim and in that case, we may need to apply a “legal hold” that retains information beyond our typical retention period. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.
How We Share and Disclose Personal Information
Service Providers: We share your Personal Information with third-party service providers who complete transactions or perform services on our behalf or for your benefit, such as for payment processing, marketing, analytics, processing employment applications and performing human resources administration or to verify customer data, such as mailing addresses.
Business Partners: With your consent, we may share your Personal Information with business partners, such as our distributors.
Third-Party Platforms: Certain Services may gather and transfer your location information, from and to other applications, functions and tools within your device to enable DJO to offer you certain location-based services, such as delivering advertisements that are relevant to your particular location, and to conduct analytics to improve the Services. You may disable the collection of your location information in your device’s settings. Please be advised that we may not be able to provide location-based services to you if you choose to do so.
Social Media Platforms: We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you on third party platforms. We may do this by providing a hashed version of your Personal Information to the third party for matching purposes.
Legal Process, Safety and Terms Enforcement: We may disclose your Personal Information to legal or government regulatory authorities as required by applicable law. We may also disclose your Personal Information to third parties as required by applicable law in connection with claims, disputes or litigation, when otherwise required by applicable law, or if we determine its disclosure is necessary to protect the health and safety of you or us, or to enforce our legal rights or contractual commitments that you have made.
Business Transfers: Your Personal Information may be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy or receivership. You will be notified via email or a prominent notice on any affected Service of any change in ownership or uses of Personal Information, as well as your choices regarding Personal Information about you.
DJO is committed to protecting the security of your Personal Information. We use technical and organizational measures designed to protect your information against unauthorized access, theft, and loss. However, due to the nature of the internet and information technology in general, we cannot guarantee the security of your information.
International Data Transfers
DJO may transfer your Personal Information within our family of companies and/or to the third parties discussed above. Your Personal Information may be transferred to, stored, and processed in a country other than the one in which it was collected. We may transfer your Personal Information outside the European Economic Area (“EEA”) and when we do so, we rely on appropriate or suitable safeguards recognized under data protection laws.
With your Consent: With respect to our Services operated from servers in the United States, if you are located outside of the United States, please be aware that the personal information we collect will be processed and stored in the United States, a jurisdiction in which the data protection and privacy laws may not offer the same level of protection as those in the country where you reside or are a citizen.
Adequacy Decision: With respect to our Services operated from servers in the EEA, we may transfer your Personal Information from the EEA to countries which the European Commission has approved as providing adequate protection to personal information.
Standard Contractual Clauses: The European Commission has adopted standard data protection clauses, which provide safeguards for personal information transferred outside of the EEA. With respect to our Services operated from servers in the EEA, we generally use Standard Contractual Clauses when transferring Personal Information from a country in the EEA to a country outside the EEA that does not have an adequacy decision. You can request a copy of our Standard Contractual Clauses by contacting us as set forth in the Contact Us section below.
In addition, we may transfer your Personal Information outside the EEA if the transfer is necessary to establish, exercise or defend legal claims.
Personalized Advertising Preferences
We personalize your experience on our site and on other sites and online services by showing you advertisements that are tailored to your interests. We may share your Personal Information with third-party marketing companies that use ad networks that rely on your browsing history on websites and mobile services, as well as other information to show you personalized advertisements on our site and on other websites. For example, if you view our products, you may see ads for our products as you continue to browse other websites on the Internet.
You can opt out of receiving personalized advertisements on your browser or device from advertisers or advertising networks who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out options of each of those organizations. Links to those websites are included here:
Network Advertising Initiative:
- Browser Opt-Out: http://www.networkadvertising.org/choices/
Digital Advertising Alliance:
- Browser Opt-Out: http://www.aboutads.info/choices/
We also work with Google and Facebook to provide advertising content. Links to information about their advertising preferences can be found at the following websites:
- Browser Opt-Out: https://adssettings.google.com/
- Browser Opt-Out: http://facebook.com/about/ads
When you opt out of personalized advertising, you may continue to see online advertising on our site and/or our ads on other website and online services.
You may also be able to opt out of advertisements in other ways, including:
- Opt out through website-specific mechanisms. Some websites and platforms, such as Facebook, offer their own opt-out methods. Please refer to the website that you are visiting for additional information.
- Browser-based opt outs. Some internet browsers (e.g., Internet Explorer, Firefox, Chrome) offer their own opt outs for personalized advertising. The ad networks and ad service providers we participate with may not recognize these opt outs.
- Mobile opt outs. Many mobile devices offer their own device-specific opt outs for personalized advertising. Please refer to your device settings and instructions for additional information.
We are committed to protecting the privacy of children. Our Services are not directed to, and we do not intend to or knowingly collect or solicit Personal Information online from children under the age of 13. If you are under the age of 13, do not provide us with any Personal Information.
If you learn that your child has provided us with Personal Information without your consent, you may alert us at the applicable Contact Us site listed below. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information.
We process all personal information in line with your rights, in each case to the extent required by and in accordance with applicable law (including in accordance with any applicable time limits and fee requirements).
Where required by applicable law, we will obtain your affirmative consent prior to using or sharing your Personal Information. To comply with other applicable laws, we will enable you to opt out of certain communications and uses of your Personal Information, including:
- Email and other communications from us, such as postal mail; and
- Our sharing of your Personal Information with third parties for their use in direct marketing, including for promotional purposes.
For other types of communication, we will comply with applicable laws that require us to request your consent before communicating with you. Where permissible, we may ask you to register in order to receive marketing-related phone calls or to send you newsletters.
You may opt out of email marketing by using the Unsubscribe link in a marketing email. You can also provide us with your marketing preferences by sending an email to firstname.lastname@example.org or by sending a letter to us at the address identified in the Contact Us section below. If you contact us by email, please be sure to include your full name, the types of communications you would like to receive or not receive, and your related contact information (e.g., mailing address if you would like to opt out of mail). Please allow sufficient time for your marketing preferences to be processed. You should also understand that, even if you opted out of receiving marketing communications from us, we may still contact you for transactional or other informational purposes.
Upon request, we will provide you with information about whether we hold any of your Personal Information along with any details required to be provided to you under applicable law. In certain cases, you may also have a right to:
- Rectify any of your Personal Information that is inaccurate;
- Restrict or limit the ways in which we use your Personal Information;
- Object to the processing of your Personal Information;
- Request the deletion of your Personal Information; and
- Obtain a copy of your Personal Information in an easily accessible format.
- To submit a request, please contact us as set forth in the Contact Us section below. We will respond to your request within a reasonable timeframe.
If you are accessing the Services from the European Union, you also have the right to lodge a complaint with your national or local data protection authority.
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact us as set forth in the Contact Us section below.
Links to Third Party Sites and Social Media
Managing Communication Preferences
If you have opted in to our marketing communications (or where permitted by law, if you have provided us with your contact information), we may send you email messages, direct mail offers, push notifications or other communications regarding products or services depending on the method of communication selected. You may ask us not to do so when you access our websites or mobile applications, or change your preferences by updating any accounts you have with us. At any time, you may elect to discontinue receiving commercial messages from us by submitting an opt-out request to the contact information below or by following the unsubscribe instructions in the form of the communication you received, as described below.
Printed Materials: To opt out of receiving printed marketing materials at your postal address, such as advertisements, flyers or postcards, please write to us at the address below. Please be sure to include your name and mailing address exactly as they appear on the printed marketing materials you received.
Emails: To opt out of receiving marketing communications via email, please send an unsubscribe request to the email address below or click on the unsubscribe link at the bottom of the email that was sent to you and follow the directions on the resulting web page. Please note that you may continue to receive certain transactional or account-related electronic messages from us.
Text Messages: If you have consented to receive text messages, you may opt out of receiving them by using the method provided in the text message or by contacting us as set forth in the Contact Us section below.
Push Notifications: To opt out of receiving push notifications, please set your preferences within your device setting menu.
DJO Global, Inc.
Att.: Privacy Compliance
1430 Decision Street
Vista, CA 92081