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Privacy and cookie policy

Privacy Statement

If you use our websites, platforms, applications, or other products and services, your personal data may be processed.

This Privacy Statement explains which personal data are processed by us, the type of processing that is conducted, and the purpose of the processing. Furthermore, reference is made to the rights of the data subject.

Our company has implemented numerous technical and organizational measures to ensure that protection of the personal data processed via our websites is as complete as possible. Nevertheless, absolute security cannot be guaranteed as there may be security gaps in the transmission of data and, in particular, in the online transmission of data.

The specific entity of Hamilton Medical that you have established a relationship with, for exampe, through website visits, service usage, event participation, or job applications, is responsible for managing processing of your personal data.

Responsible for this website is:

Hamilton Medical AG
Via Crusch 8
7402 Bonaduz

Phone: +41 58 610 10 20
Website: www.hamilton-medical.com

Your personal data may be processed in particular for the following legal grounds and purposes:

  • To communicate with you or process your request, as well as to respond to such a request ((pre)contractual or legitimate interest)
  • To process posts and comments (legitimate interest)
  • To register and send you newsletters to which you subscribe (consent)
  • For the purpose of marketing; for the purpose of delivering personalized information to you about our products and services, as well as to conduct market research and satisfaction surveys (consent or legitimate interest)
  • For the registering, authenticating and for the administration of user accounts (contractual)
  • To process your event registration, manage your attendance and accommodation, send you event-related communication, as well as to process your audiovisual content such as pictures, audio/video recordings, etc.) (consent, contractual or legitimate interest)
  • For purposes of analysis to improve our products and services (legitimate interest)
  • To adapt our website content and experience according to your interests (consent or legitimate interest)
  • For the security of our applications, platforms and websites, as well as securing other products and services (legitimate interest)
  • To process your application ((pre)contractual) 
  • To comply with any legal and regulatory requirements and requests, such as handling complaints and recalls, and to ensure our compliance with Medical Device Regulations (legal obligation)
  • To fulfill and execute your purchase of products and services (contractual or legitimate interest)
  • For corporate transactions purposes, (i.e., during a sale of a (part of) business, or any restructure, merger, joint venture, or other disposition of our business, assets, or stock or similar proceedings) (legitimate interest or legal obligation)
  • For the establishment, exercise and defence of legal claims (legitimate interest)

The relevant categories of personal data result from the relevant circumstances if they are not explicitly mentioned.

Our websites collect various general data and information whenever they are accessed by a data subject or automated system. Those general data and information are stored in the log files of the server. The following data may be collected:

  1. Browser types and versions used
  2. The operating system used
  3. The website from which a system accesses our website
  4. The subpages that the system accessing our website navigates to
  5. The date and time of access to the website
  6. The IP address
  7. The internet service provider of the system accessing the website 
  8. Other similar data and information that serve to protect our information technology systems in the case of attacks

The collection and use of the general data and information do not allow any conclusions to be drawn about the data subject. Instead, they serve the following purposes:

  1. Correct provision and display of the content of our website
  2. Optimization of the website content and advertising the website
  3. Ensuring the long term functionality of our website
  4. Provision of the necessary information to assist law enforcement authorities in the event of a cyber attack. The anonymous data stored in the log files are stored separately from any personal data

Our website provides users with the possibility of registering with their personal data to use our services and products such as:

  • The e-learning platform (currently named e-Academy)
  • Simulation software related to the Hamilton products
  • The Hamilton Medical e-Catalog of products
  • The Hamilton Connect App
  • VenTrainer

The data are entered using a data entry form on the website, which indicates the personal data that are transmitted to us. Other data might be provided by you or collected by us through the use of our services with your Hamilton Medical or MyHamilton account. When using our e-learning service, the user’s learning status and test results are also stored so that the user can be shown his/her learning progress.

Your personal data processed will first and foremost be processed in order to register and maintain a Hamilton Medical or MyHamilton account and to provide you with our services and products. The processing of personal data is therefore necessary in order to enable the services of the Hamilton Medical or MyHamilton account (performance of a contract); without the above, access to the account and its functionalities will not be granted.

The data may be used for occasional provision of information about our services and products, for optimizing and improving our services, for statistical purposes, as well as marketing, including personalized marketing messages via electronic message, post or phone (legitimate interest). Furthermore, we process certain data, such as the date and time of registration, in order to prevent abuse of our services and products, for security reasons, and, if required, disclosure of the data for the investigation of any criminal offenses.

Your data are not disclosed to third parties as a rule, unless there is a statutory obligation to disclose the data, disclosure of the data serves the purpose of law enforcement, you have asked us to or consented to such disclosure or it is in our interest to disclose the data for all the aforementioned purposes in this section to one of our contractually bound service providers.

You have the right to object to any processing for marketing purposes and receiving marketing communications. For further information regarding the exercise of your rights as data subject or matters not directly addressed within this section, please refer to the corresponding sections remaining in this Privacy Statement.

The personal data related to registration for the Hamilton Medical or MyHamilton account will be stored until you decide to delete your account or after a long time of inactivity with prior warning by Hamilton Medical, provided that there are no legal storage and documentation obligations that preclude deletion.

Our website offers users the possibility of subscribing to free newsletters. When registering for the newsletter(s), data such as the user’s surname, first name, email address, and country, are transmitted to us via the data entry form.

As a rule, our company’s newsletter(s) can only be received if (1) the data subject has a valid email address, and (2) the data subject registers for the newsletter.

For legal reasons, before the first newsletter is sent, a confirmation email is sent to the email address entered by the data subject as part of a double opt-in process. That confirmation email is intended to check whether the owner of the email address has authorized receipt of the newsletter.

When registering for the newsletter(s), the IP address, date, and time of the registration are also stored. The collection of that data is necessary in order to be able to trace (potential) abuse of the email address of a data subject in the future.

The personal data collected during registration for the newsletter(s) are used for:

  • Sending our newsletter(s)
  • Notifying the newsletter subscriber of changes to the newsletter service(s)
  • Technical changes to the newsletter service(s)

Users of the newsletter service(s) may cancel their subscription at any time, by contacting us under privacy.med.global@hamilton-medical.com. Each newsletter also contains a link under which consent may be withdrawn. Please be aware that if you have signed up for different newsletters, the respective unsubscribe link in each email is only unsubscribing you from that particular newsletter, not all lists. In case of doubt, please contact us.

Our newsletters may contain tracking technology so that we can target the content of our newsletters more closely to the information requirements of recipients. Such tracking technology includes, for example, miniature graphics embedded in an e mail sent in HTML format that enable analysis of whether and when the relevant email was opened, and which links contained in the email were followed.

The personal data collected using tracking pixels are stored by us and statistically analyzed to optimize the newsletter service(s) as described above. The user may withdraw his/her consent to newsletter tracking at any time.

Our website offers users the possibility to download white papers and other materials. We provide these materials in exchange for your data, which we use in order to inform you about our services and products, events, surveys and other marketing communication. The processing is based on your consent, and you can withdraw your consent at any time with effect for the future at the end of every email or by sending an email to privacy.med.global@hamilton-medical.com. Please be aware that the section “Newsletter tracking” applies for all marketing emails you receive from us as well.

Our website contains contact forms enabling users of the website to quickly contact our company directly and to request information. If a user contacts us using such a form, the personal data entered are automatically stored by us. The data entry form indicates which personal data are sent to us. The data are collected to enable an employee of our company or of a processor to contact or send further information to the person whose data were entered using the data entry form.

Alternatively, it is possible to contact us using the email address provided. In this case, the user's personal data that are sent by email are stored for the purpose of contacting the user.

Your personal data processed will first and foremost be processed in order to communicate with you and to respond to your request ((pre)contractual or legitimate interest). The data may - to the extent permitted by applicable data protection laws - be used for the occasional provision of information about our services and products, for optimizing and improving our services, and for statistical purposes, as well as marketing, including personalized marketing messages via electronic message, post or phone (legitimate interest). Finally, we may also process your data where required by law, for example, for complaint handling according to the Medical Device Regulations. 

You have the right to object to any processing for marketing purposes and to receiving marketing communications. For further information regarding the exercise of your rights as a data subject or for matters not directly addressed within this section, please refer to the corresponding sections remaining in this Privacy Statement.

We may use cookies and similar technologies (for simplicity reasons, hereinafter referred to collectively as cookies), when you use our websites, platforms, applications, or other products and services.

Our cookie banner and consent management system show you a list of the cookies we use, including their provider, purpose, description and other relevant information. In the default setting, only the essential cookies are enabled. Via the consent management system, you can determine whether you allow the setting of additional cookies or not. You can adjust your preferences at any time using the consent management system. 

Below we categorize our processing using cookies. You can find more details in our consent management system (fingerprint icon on the bottom-left corner of the page).


Web analysis

We conduct web analysis for the appropriate design of our websites, and in order to identify and count returning visitors. These tools may track your behavior on our website (including its subpages) and we use the information for optimization of our marketing activities.

We supplement the collected data with other data provided by third-party providers. This enables us to capture the demographic characteristics of our visitors, for example, information about their age, sex and place of residence.


(Conversion-) tracking and (re-) marketing 

We also use (cross-device) tracking technologies so that we can display targeted advertising outside of our website and determine how effective our advertising is.

When you visit or use our websites, platforms, applications, or other products and services, it is possible that the third-party providers listed in our consent management system use cookies (especially pixels of Facebook, Instagram, Linkedin, Twitter, Youtube, Oktopost).

The third-party providers may use the cookies and information collected to recognize your end device on other websites. We can instruct the respective third-party providers, especially on social media platforms such as Facebook, Instagram, Linkedin, Twitter, Oktopost, to display advertising that is based on the visit or use of our websites, platforms, applications or other products and services. If you register with the third-party provider using your own user data, the respective recognition characteristics of different browsers and end devices can be aligned with each other. If the third-party provider generated a separate characteristic for the laptop, desktop, smartphone or tablet you use, these individual characteristics can be associated with each other as soon as you use a service of the third-party provider with your login information. This way, the third-party provider can effectively manage our advertising campaigns across different end devices.

The Google AdWords advertising optimization service is integrated into our website.

The operator of the Google AdWords services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043 1351, USA.

Google AdWords is used to advertise our website by displaying relevant advertising on the websites of third-party companies and in Google search engine results.

If a data subject accesses our website via a Google ad, Google stores a conversion cookie (see the section "Cookies, web analysis, (conversion‑) tracking and (re‑) marketing") on the computer of the data subject. The conversion cookie expires after thirty days and does not serve to identify the data subject. The conversion cookie indicates whether specific subpages on our website have been visited. The conversion cookie enables both us and Google to track whether a data subject who has accessed our website via an AdWords ad has generated sales, i.e., has completed or canceled a purchase.

The data and information collected using the conversion cookie are used by Google to generate traffic statistics for our website. Neither our company, nor other Google AdWords advertising customers receive information from Google enabling identification of the data subject.

By storing the cookie, Google obtains knowledge of personal data, such as the IP address of the user, as such personal data are transmitted to Google in the USA. Those personal data are stored by Google in the USA. Google may share those personal data with third parties.

If you do not wish cookies to be stored, you can disable them by adjusting your browser settings accordingly. In addition, you can prevent data generated by the cookie referring to your use of the website (including your IP address) from being collected by Google and the processing of such data by Google by downloading and installing the following add-on: https://tools.google.com/dlpage/gaoptout?hl=en.

Opt-out cookies will prevent your data from being collected when you visit this website in future.

Furthermore, the data subject may disable personalized advertising by Google by opening this link https://adssettings.google.com from each internet browser used and adjusting the settings there accordingly.

For further information and the applicable Google privacy policy, please see https://policies.google.com/privacy?hl=en

We operate social media pages jointly with the respective social media provider and thereby process personal data for the interest of public relations and communication, based on legitimate interest, contract and/or consent. We may communicate with you through the social media platform, for example, by responding to comments or messages, and we may share your posted content and allow you to participate in contests and/or raffles. Furthermore, we analyze the statistics provided by the social media provider about your use of our social media pages.

On certain social media pages, we also accept job applications. The processing here is based on (pre-)contract. Please see the section “Privacy in job application processes” for more information. 

Please check the settings and privacy policy of the respective provider you have signed up to as well.

We also use the respective social media platforms to deliver advertising. For this purpose, we use target-group definitions that are provided to us by the social media provider. We only use anonymous target-group definitions - that is, we define characteristics based on, for example, general demographic information, behavior, interests and connections. The operator of the social media platform uses these to play advertisements to its users accordingly. The legal basis for this is the consent that the operator of the social media platform has obtained from its users. If you wish to revoke this consent, please use the revocation options provided by the social media platform provider, as the social media platform operator is responsible for this processing. Occasionally, we or the provider of the social media platform also use publicly available data for target-group definition. The legal basis for this processing is then the legitimate interest to define a target group that is as suitable as possible. 

Occasionally, we also use information about visits to or interaction with other sites (so-called remarketing) to define target groups. For this purpose, we also use cookies, see the section "Cookies, web analysis, (conversion-) tracking and (re-) marketing". In these cases, however, we obtain the consent of the user in advance through a consent banner on the other respective pages and provide information about the data processing at this point. You can revoke this consent at any time by calling up the consent banner of the relevant website again. 

If you wish to object to any of the described processing, please see the section “Your rights concerning the processing of personal data”.

The social media platforms use what are known as “web tracking methods” on their websites. Please be aware of the possibility that the social media platforms may use your profile data, for example, in order to evaluate your habits, personal relationships, preferences and the like. We have no influence on the processing of your data by the social media platforms. Further information on the data processing conducted by the platform provider, including information concerning your rights as a user, can be found in the provider's data protection policy and the joint controller addendum. Please contact us if you have further questions or require assistance in finding the respective information.

Applications shall be submitted via our career platform: 

Please see the relevant Privacy Policy on our career platform.

Your personal data may be disclosed to third parties in order to fulfil the purposes described in this statement.

Given Hamilton’s international organizational structure, specific departments and individuals may require your personal data on a need-to-know basis for adequate processing purposes. We comply with all applicable data protection requirements for all intragroup data access and transfers.

We may share your data to trusted third-party service providers contracted by us for the aforementioned purposes. These are, in particular; service providers that support us - amongst other things - with respect to order fulfillment, payment/billing, customer service, finance, auditing, fraud detection, IT services, communication, hosting, logistics, email delivery, marketing, sales, data analysis, event management, training, surveys, printing, archive, advisory and consulting services.

Your data may be disclosed to further recipients, such as private and public entities and institutions, including law enforcement, data protection authorities, tax authorities, credit agencies, debt collectors, banks, courts, hotels or other companies, insofar as there is a relevant legal basis for such disclosure.

We may transfer your personal data to other Hamilton entities globally and to other recipients, mainly in the EEA, UK, Switzerland, US, LATAM (e.g., Mexico, Brazil), South Africa and Asia Pacific (e.g., India, China, Australia) only and insofar as this is necessary or required for the fulfilment of the purposes described in this Privacy Statement, there is a legal basis for the data transfer, and appropriate standard contractual clauses are implemented, if no adequacy decision exists.

Personal data are stored for a duration corresponding to the respective statutory retention period. Following expiry of that period, the relevant data are routinely erased, provided they are no longer required for fulfillment of contractual obligations or for taking steps prior to entering into a contract.

If not already mentioned explicitly, depending on applicable data protection laws, you may have the right to:

  • Access your data as well as receive a copy of your data
  • Know about the personal data we collect about you and how it is used
  • Rectification and erasure
  • Restriction of processing
  • Data portability
  • Object, especially if the data is processed pursuant to our legitimate interests
  • Know whether and to whom your personal data is sold and/or disclosed
  • Not be discriminated for exercising your rights
  • Lodge a complaint with a supervisory authority if you believe that the processing of your personal data infringes applicable data protection regulations
  • Withdraw your consent at any time, with effect for the future. 

In tjhe case of questions related to data protection, the enforcement of your rights concerning the processing of personal data, or complaints, please contact us at: dpo@hamilton.ch. Please be aware that to the extent your request concerns one of your rights, we will retain that request up to three years in enable us to demonstrate our compliance to the respective authorities (legitimate interest). The aforementioned rights apply also to this processing of your personal data.

Our data protection officer within the EEA*, Switzerland and the UK is:
Naritaweg 127 137
1043 BS Amsterdam

*For medin Medical Innovation GmbH our data protection officer is:
rowidat GmbH
Lillweg 6
80939 Munich

In the case of questions related to the processing of your personal data, please contact Hamilton at dpo@hamilton.ch. However, if you wish to write to our data protection officer in confidentiality, please address you letter to FIRST PRIVACY BV or rowidat GmbH at the contact details specified above.

This privacy and cookie policy will be amended from time to time in order to comply with legal requirements or to implement changes to our services or products. We reserve the right to change these at any time. You will always find the current version here.

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