Nonin Medical Privacy Policy

Welcome to Nonin Medical, Inc. (“Nonin,” “us,” “we,” or “our”). We design, manufacture and bring to market noninvasive devices which measure and report various physiological parameters of patients for medical use, as well as of individuals for general health and wellbeing.

This Privacy Policy describes how we collect, use, and share your Personal Information in the United States when you use any of our products, visit our websites and apps, connect with us on social media, and interact with us online and offline (individually and collectively, the “Service”).  Other policies may be applicable for Services in other countries or in certain States.

Privacy Policy, “Personal Information” is information that could reasonably be used to identify you as an individual.  Examples of Personal Information include, but are not limited to, your name, your email address, your home address, your telephone number, your date of birth, your individual computer or mobile device information, your health information, and individual data collected and reported by our devices, apps and websites used by you.  Personal Information does not include information that is publicly available, de-identified or aggregated.

By accessing or using our Service, you agree to this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Service. We also encourage you to review our Terms of Use to understand other requirements and limitations related to your use of the Service, and the Terms and Conditions of Sale (at https://www.nonin.com/terms/) to understand requirements and limitations related to the purchase of products on Service.

How Does Nonin Collect My Personal Information?

Website and App Information

If you visit our websites or apps to read or download information, such as information about a health condition or about one of our products, we may collect certain information about you from your computer or mobile device.  Examples of this information include, but are not limited to, the name of the domain from which you access the Internet, the Internet Protocol address of the device you are using, the browser type and browser version you are using, the date and time you use our websites and apps, the webpages you visited, the Internet addresses from which you link to our websites and apps, the links you click within our websites and apps, and the search terms you use.

Cookies

We may use cookies and similar tracking technologies, such as web beacons and pixels, to track the activity on our websites and apps and hold certain information.  Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies.We use Session Cookies to operate our Service.
  • Preference Cookies.We use Preference Cookies to remember your preferences, navigation history and various settings.
  • Security Cookies.We use Security Cookies for security purposes and block unauthorized data inputs and intrusions.

What Does Nonin Do With My Personal Information?

Website and App Functionality

We may use your Personal Information to provide and maintain the Service.  Examples of such uses include, but are not limited to, detecting, preventing and addressing technical issues, enabling website and app functions, improving website and app functionality, providing website and app maintenance and diagnostics, collecting statistical data, and analyzing system performance.

Customer Communications About the Service

We may use your Personal Information to engage with you about the Services.  Examples of such uses include, but are not limited to, notifications to you about changes to our Service, providing you customer support, and responding to inquiries regarding our products and services.

Location Data

We may use your Personal Information to identify and store your location if you give us permission to do so. We use this data to provide features of our Service, to improve and customize our Service, and to comply with privacy and other legal requirements for the geography in which you are located. You can enable or disable location services when you use our Service at any time, through your device settings.

Individual Device Data

We may use your Personal Information to collect, keep and use information submitted to us by individuals to register and track purchased devices. We are required to track these devices in accordance with the US Federal Food, Drug and Cosmetic Act and various US Federal Drug Administration regulations. In the United States, no patient consent or authorization is required to disclose information to medical device manufacturers for tracking purposes, in accordance with the Health Insurance Portability and Accountability Act (“HIPAA”), as amended.

Testing Results Data

When you use the Services, you may generate individual testing data through a device.  We do not have access to this data unless you or your agents provide it to us.  In the event we are authorized to collect or receive certain personal data and other data about you (“Protected Health Information” or “PHI”) on behalf of the health care providers who use our platform, such information will be governed in accordance with HIPAA. Please consult your health care providers’ privacy policies for further information about their privacy policies regarding PHI.

Customer Communications Regarding the Service

We may use your Personal Information to engage with you about the Services.  Examples of such uses include, but are not limited to, notifications to you about changes to our Service, providing you customer support, and responding to inquiries regarding our products and services.

Advertising

We may use your Personal Information to contact you regarding information which may be of interest to you.  Examples of such information include, but are not limited to, newsletters, marketing or promotional materials, special offers, and general information about other goods, services and events which we offer that are similar to those that you have already purchased or about which you may have enquired. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

How Long Does Nonin Retain My Personal Information?

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will also retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Where Does Nonin Store My Personal Information?

Generally, the Personal Information that we collect from you will be transferred to and stored in the United States. If you reside in another country, the United States may have different levels of data and privacy protection than those which apply in your country. Your Personal Information may also be processed by staff, in the United States, working for us or for one of our related companies or third-party service suppliers. Such staff may be engaged in, among other things, the provision of support services. By submitting your Personal Information via use of our Services, you agree to any such transfers, storage or other processing.

We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Information.

When Is Nonin Required to Disclose My Personal Information?

In addition to disclosures which may be authorized or required by privacy laws and HIPAA, we may disclose your Personal Information in the good faith belief that such action is necessary to comply with a legal obligation, to protect and defend our rights or property, to prevent or investigate possible wrongdoing in connection with the Service, to protect the personal safety of users of the Service or the public, or to protect against legal liability.

Does Nonin Use Third-Party Service Providers?

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use Service Providers to monitor and analyze the use of our websites and apps.

Google Analytics. We may use Google Analytics as one such analytics Service Provider. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

Behavioral Remarketing

We may use remarketing services to advertise on third-party websites to you after you visited our websites and apps. These Service Providers use cookies to inform, optimize and serve ads based on your past visits to our websites and apps.

Google AdWords. We may use Google AdWords as one such remarketing Service Provider. Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

Facebook. We may also use Facebook remarketing service as one such remarketing Service Provider.  Facebook remarketing service is provided by Facebook Inc.

To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

Does Nonin Include Links to Other Internet Sites?

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

What Does Nonin Do to Protect the Security of My Personal Information?

Nonin takes reasonable steps in accordance with industry standard security safeguards to protect your Personal Information from loss and unauthorized access, modification, disclosure, inappropriate alteration or misuse.  Nonin maintains physical, electronic, and procedural safeguards in compliance with industry standards and applicable laws to protect your Personal Information.

Electronic files containing Personal Information are kept in a secure environment with restricted access. Paper-based files are stored in locking filing cabinets. Access is restricted to authorized employees who have a legitimate business purpose and reason for accessing your Personal Information.

We manage our server environment appropriately and strictly adhere to our firewall infrastructure. Our security practices are reviewed on a regular basis and we routinely employ current technologies to protect the confidentiality and privacy of your Personal Information.

For those areas of our websites and apps collecting Personal Information, our websites uses industry standard Secure Socket Layer (SSL) and encryption technologies to enhance security when you visit the secured areas of these websites. When you access your accounts or send information from secured sites, encryption will scramble your data into an unreadable format to protect it from interception by others. To safeguard against unauthorized access to your accounts, you are required to “sign-on” using a user id and a password to certain secured areas of our websites and apps. Both user identification and password are encrypted when sent over the Internet. If you are unable to provide the correct password, you will not be able to access these sections.

You are required to keep your password and user identification secure and not provide that information to third parties. If you suspect that someone is using your user id or password, please report it immediately to us.

You have an active role in protecting your own Personal Information. Please safeguard your environment and use reasonable steps to ensure that others do not access your information through your computer. Always logout to keep your information secure. We will not be liable for disclosures of your Personal Information due to errors in transmission or unauthorized acts of third parties.

When you call one of our customer service centers for patient and product questions, you will be required to verify your identity by providing Personal Information. We will only use this information in order to identify you.

While we take reasonable steps to protect Personal Information as outlined in this Privacy Policy, we cannot ensure or warrant our ability to do so because no internet transmission is 100% secure. Please consider this when sending information to us by e-mail.

Does Nonin Use “Do Not Track” Signals?

We do not currently support Do Not Track. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

What are My Data Protection Rights Outside the United States?

If you are a resident of the European Economic Area or the United Kingdom, you may have certain data protection rights. If you are a resident of certain US states, you may also have certain data protection rights.

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information as required by law. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please use our Contact Information.

If you are from the European Economic Area or the United Kingdom, our legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.  We may process your Personal Information because we need to perform a contract with you, you have given us permission to do so, the processing is in our legitimate interests and it’s not overridden by your rights, or to comply with the law.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you using the Contact Information below.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Information.

The right of restriction. You have the right to request that we restrict the processing of your Personal Information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where we have relied on your consent to process your Personal Information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA) or the UK.

Does Nonin Collect Children’s Personal Information?

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Information, please contact us using our Contact Information. If we become aware that we have collected Personal Information from children without verification of parental consent, we take steps to remove that information from our servers.

How Do I Find Changes to This Privacy Policy?

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.  We may also let you know via email and/or a prominent notice on our Service, where feasible, prior to the change becoming effective and update the date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

What Are My State Privacy Rights?

This notice is provided to residents in states with applicable privacy laws, such as California.  The information below serves as a “Notice at Collection” under California law.  As described above, we may collect certain categories of Personal Information and we may have collected any of these categories of Personal Information in the past 12 months, including:

  • Identifiers such as your real name, alias, postal address, username, Internet Protocol address, email address, or other similar identifiers.
  • Personal Records such as telephone number.
  • Commercial Information, including records of products or services purchased, obtained, or considered.
  • Internet or Other Electronic Network Activity Information, including, but not limited to, browsing history, search history, and information regarding your interaction with an internet website application, or advertisement.
  • General Geolocation Data.

We do not process Personal Information that would be considered “sensitive” under applicable privacy laws.  When individuals use our devices, they may generate biometric data, but we do not have access to data which can be used to identify an individual unless authorized in accordance with law.

The collection and uses of your Personal Information are described above, as well as your options for opting out of certain uses.

Certain US state residents may have certain privacy rights, including:

  • The right to confirm whether we process your Personal Information;
  • The right to request access to or delete certain Personal Information (subject to certain exceptions);
  • The right to request correction of inaccuracies in your Personal Information;
  • The right to request your Personal Information in a portable format; and
  • The right to limit or opt out of certain forms of Personal Information processing.

To exercise any of these rights, please contact us (or contact us through an authorized agent) using our Contact Information.  We review, verify, and process all requests in accordance with applicable law.

We will not retaliate against you or otherwise discriminate against you for exercising any of your privacy rights.

How Do I Contact Nonin Regarding this Privacy Policy?

If you have any questions about this Privacy Policy, please contact us:

  • By email: info@nonin.com
  • By visiting this page on our website: www.nonin.com/contactus
  • By phone number: +1 763.553.9968
  • By mail: Nonin Medical Corporate Communications, 13700 1st Avenue North Plymouth, Minnesota 55441

Last Updated: July 30, 2024.