February 1, 2025

Vantive, the local Vantive operating company providing products and services in your market and their affiliates and subsidiaries (collectively “Vantive,” “us,” “we,” or “our”) are committed to protecting your privacy. This Privacy Notice (“Privacy Notice”) describes how we may collect and use information about you (“you,” “user”).   For information about the local Vantive operating company in your market, visit the Contact Us section of this Notice.

This Privacy Notice applies to the following (collectively referred to as the “Services”):

• Vantive websites, mobile or web applications, and other digital or online services or offerings that link, post, or reference this Privacy Notice.
• When you interact with us in the ordinary course of business (e.g., communications by phone, e-mail, or in person as part of a business relationship; or when we interact with companies or organizations you work for).

This Privacy Notice does not apply to the following:

• Services that link, post, or reference a different privacy Notice.
• Certain components of the Vantive.com website that hyperlink to a different privacy Notice.
• If our Services hyperlink to a third party site or service that has its own privacy Notice.

For purposes of this Privacy Notice, “Personal Information” means information that identifies you or may reasonably identify you that we collect or generate when you use or interact with our Services. Examples of Personal Information may include your name, your address, or an online identifier that could identify you (such as an IP address). Depending on the country, state, or province where you live, Personal Information may have a different definition according to the local privacy laws in your area. This Privacy Notice applies to all types of Personal Information as defined by the local privacy laws that apply to you.  

We collect and generate different types of Personal Information depending on how you use or interact with our Services. The following describe various categories and sources of Personal Information we may collect and generate. 

Demographic and Contact Information

Demographic and contact information that you provide to us. For example, we may collect information such as your name, mailing address, e-mail address, and telephone and fax number.

Online or Other Account Information

Username or email address and corresponding passwords, security questions, and other information needed to permit access to certain components of our Services which require registration and/or credentials. 

Webforms and Requests

Information you submit to us through online or interactive forms available within our Services. For example, you may “contact us,” submit feedback, request additional information about a product or Service, sign up for a mailing or other type of newsletter, or reach out to us regarding a question or concern. 

Websites

Information such as your username and password to enter certain sections of our websites or Services, unique identifiers, preference information (such as marketing preferences), browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site, operating system, date/time stamp, and clickstream data and other pieces of information further described in Tracking Technologies.

Mobile Apps

Some of our Services are available either as mobile applications or mobile sites that you can use on your mobile device. If you use a mobile device to access and use our Services, we may additionally collect mobile-specific information including your device ID, device type, hardware type, media access control (“MAC”) address, the version of your mobile operating system, the platform used to access or download the Services, location information and usage information about your device and your use of the Services. Please note that not all of our mobile services link to this Privacy Notice, so be sure to read the applicable privacy notice before using mobile services.

Device Information

Device-specific information including Internet Protocol ("IP") address, hardware model, operating system, unique device identifiers, and mobile network information. We may also associate the information we collect from your different devices, which helps us provide consistent Services across your devices.

Log Information

Usage details of our Services, including the address (or URL) where you came from before visiting us, which pages or features you visit or utilize, which browser you use, search terms you enter, and items you click on. We may also create usage statistics and monitor the traffic from your use or interaction with our Services. 

Internet Protocol (IP) Addresses

IP addresses are unique identifiers automatically assigned to each computer when logging onto the Internet. We generally collect IP address information from visitors using or interacting with the Services and we log them for system administration purposes. In some cases, as described below, we may also use IP addresses to serve you ads on third party websites regarding our Services that may be of interest to you based upon your use or interaction with the Services if you have opted-in to certain types of cookies. You can always adjust your Cookie Settings or your individual browser’s settings. 

Location Information

Your general location information may be collected in a variety of ways depending on how you use or interact with our Services. For example, location information can be derived from your IP address, location information associated with your use of a device, your country or location selection, or other location-based components and content of our Services. 

Health Information

If you use certain types of our Services, we may collect information about your health or medical condition, and your treatment (including the specific device or product that you are prescribed). To the extent that additional privacy laws apply to this type of information, additional or different privacy notices may govern our collection of this information. 

Business Interactions

Information derived from your business-related requests, communications, and dealings we have with you, or the company/organization you work(ed) for or are associated with. This may include your job title, business contact information (phone, email, fax, and address), information about products or services you expressed an interest in or purchased from us, or that we have purchased from you or your company/organization, and other information needed to verify your ability to conduct business with us.  

Financial Information

If you use a credit card to purchase a product or service from us, we may also collect information necessary to process the credit card transaction, such as the credit card type, number and expiration date.

Social Media

Our Services may link to our pages or accounts on third party social media networks (“social media”) but our Services do not use social media plug-ins. If you choose to interact with us on social media, we may collect the information you publish or submit. Note that this information is also governed by the privacy policies of the respective companies offering the social media service.    

Forums and Blogs

Some Services may link to blogs or forums (“forums”) that may or may not be owned or operated by Vantive. If you choose to participate in forums, we may collect the information you submit to the forums. Note that such information may also be governed by the privacy policies of the respective companies offering the forums.  

Our Services may incorporate tracking technologies to provide you with certain functionalities available within our Services. These tracking technologies, including those described below, may collect or generate Personal Information about you when you interact with us, but only if you decide to allow them in your Cookie Settings, or in you individual browser’s settings. 

You may adjust these preferences at any time, and you may be prompted to make your selections again if you navigate to a new part of our Services where different tracking technologies are used. Please review the Cookie Notice that is displayed at the time you use our Services to learn more, and feel free to contact us with any questions.     

Our Services may incorporate the following tracking technologies:

• Cookies: Small files that are transferred to your device’s hard drive for a period of time to store user preferences and other types of information to help us provide you with certain features. Read more about cookies in our Cookie Notice. 
• Web Beacons:  Electronic images placed in the code of a webpage, application, or email that allow us to monitor things such as user activity and site traffic.
• Tags: Pieces of code, or tags, which gather information about users. For example, tags are used on our websites to better understand online usage patterns and trends.  We may also use tags in our emails or newsletters to count how many of those messages are read. 
• Widgets: Small components embedded within our Services which enable you to use certain functionalities.  
• Google Analytics: Google Analytics uses cookies to collect data such as time of visit, website pages visited, time spent on each Vantive website page, IP address, URL, and type of operating system. To learn more about how Google Analytics collects and processes Personal Information, please visit www.google.com/policies/privacy/partners.

Depending on what Services you use and how you interact with us, we may use your Personal Information in the following ways. If you live in certain jurisdictions, we may not process your Personal Information for some of the below purposes unless you first provide us with your consent to do so. 

To administer and provide you with the Services

If you access a section of our Services requiring a username and password, we will use your Personal Information to create and/or administer your account, authenticate your credentials, remember your preferences, and allow you to access and use the Services. 

To manage business transactions

During certain business interactions, we may use your Personal Information to manage business transactions with you or the company or organization you work(ed) for. This may include making or responding to requests related to the Services or obtaining or making payments for such Services.

To respond to your inquiries and provide information about the Services

If you send us questions, make an inquiry or request, or ask for certain information, we may use your Personal Information to respond to you. 

To send you marketing information 

We may use your Personal Information to provide you with information about our Services, to send you marketing communications, or to enable you to participate in surveys or questionnaires.

To serve advertisements you may be interested in 

We may use your Personal Information to tailor and deliver relevant advertisements to you when you are using our Services, or when you are accessing a third party service. For example, you may receive online advertisements, emails, texts or social media notifications from us for promotional purposes. 

To improve the Services and user experience

We may use your Personal Information to gather and create statistics regarding your usage of our Services. For example, we may monitor how many users visit our Services in a given time, which components or pages are most popular, which domains you come from, which browsers you use, and how you navigate our Services. We use this information to better understand our users, personalize users’ experiences and interactions with us, and improve the content and performance of our Services.  

To comply with applicable laws and our legal obligations

We may use your Personal Information to comply with applicable laws, regulations, industry codes of conduct, and Vantive’s internal policies and procedures, including:

• For compliance with applicable retention obligations;
• For purposes of adverse event reporting, materiovigilance, pharmacovigilance, product safety, and other reporting obligations;
• To respond to lawful requests by public authorities (e.g., to investigate fraud or respond to a government request);
• To investigate potential breaches; and
• To protect our rights, property, safety, and those of our users.  

For treatment and/or quality control 

In certain cases, we may use your Personal Information to carry out your treatment, including treatment prescribed by a physician, and to provide you with general information about your treatment. We may also use your Personal Information to ensure high standards of quality and safety for our Services related to health care, medical products, and medical devices. 

Merger or Sale

If we are involved in a merger, acquisition, or sale of our assets (or a portion thereof), we may share your Personal Information with a corporate purchaser, succesor in interest, or prospect to the extent permitted by law. .  

Other uses

Where permitted by law, we may also enhance or combine information about you, including your Personal Information, with information about you that we obtain from third parties for the same purposes described in this Privacy Notice.

Links to Third-Party Websites

As a resource to our users, we may provide links to other unaffiliated websites or services within our Services. If you choose to visit such third-party websites or services, please note that any information you submit to them is not subject to this Privacy Notice. 

Vantive Affiliates and Subsidiaries

Vantive is a global company and it shares Personal Information with its affiliates and subsidiaries for the purposes described in this Privacy Notice. For more information about Vantive’s affiliates and subsidiaries in your market, please refer to the Contact Us section of this Notice.

Service Providers

We may share your Personal Information with third party service providers that we hire to help us administer and provide the Services to you. These third parties are required to treat your Personal Information in accordance with appropriate contractual and legal privacy and security requirements. 

Advertising

We may engage third party service providers who utilize tracking technologies to serve you advertisements that you may be interested in. Some of these advertisements may be personalized to you, meaning that the advertisements are intended to be relevant to you based on what we, or the third party service providers, know about you. Depending on where you live, we may be required to obtain your consent before we serve you with these types of advertisements. If you are unsure whether or not you provided your consent, you can always review and adjust your Cookie Settings or your individual browser’s settings. 

Embedded Videos

We may provide embedded videos on our Services that are hosted by third party video providers, such as YouTube (Google). If you click “play” on a video embedded within the Services, the third-party video provider may place tracking technologies on our Service, for example to remember where you left off in the video. Depending on where you live, we may be required to obtain your consent before this type of tracking technology is used. If you are unsure whether or not you provided your consent to such tracking technology, you can always review and adjust your Cookie Settings or your individual browser’s settings. 

 Joint Services

We may partner with other companies to provide you with Services that are jointly offered or “co-branded” or “co-promoted.” As such, you may see the logos of both Vantive and one or more of our partners. You should review the privacy notices of such partners before providing them with your Personal Information, as their privacy practices may differ from ours.

Vantive is a global company with global affiliates, and therefore we use global vendors, subcontractors, systems, and applications. As a result, the Personal Information that we collect and generate about you may be transferred, stored, or accessed in a destination outside of your country. Any transfers of Personal Information to Vantive affiliates or third parties outside your local country will be conducted in compliance with the international data transfer restrictions that apply under applicable data protection laws. Our service providers may process Personal Information in countries where our subsidiaries and affiliates are located.  Please refer to the Contact Us section of this Notice for the list of Vantive locations. 

• Jurisdiction-Specific Privacy Rights. Where required by applicable law you may have the right to obtain confirmation that we maintain certain Personal Information relating to you, to verify its content, origin, and accuracy, as well as the right to access your Personal Information, request their update, integration or completion, request deletion or portability of your Personal Information. You may also object to the processing of your Personal Information or request restriction of the processing, including for targeted advertising, as well as withdraw your consent to the processing of Personal Information (without affecting the lawfulness of processing based on consent before its withdrawal). Additionally, in certain jurisdictions you may have the right to opt-out of the “sale” of your Personal Information, as the term is defined under applicable law. You can exercise your rights by contacting us as detailed under the Contact Us heading below. 

In some jurisdictions, you can designate an authorized agent to make a request on your behalf. We will comply with your request as soon as reasonably practicable and as required by applicable law. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law. In any event, should you choose to exercise any of your rights as detailed above, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request. You may also have the right to lodge a complaint with the relevant data protection supervisory authority. You always have the right to object to the processing of your Personal Information for direct marketing purposes at any time.

In certain jurisdictions, if we refuse to take action on a request, you may appeal our decision within a reasonable period of time by contacting us as outlined below in the “Contact Us” section below and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the appropriate regulatory authority for your jurisdiction.

• Opt-Out of Sale, Sharing, and Targeted Advertising. You may have the right to opt-out of the sale or sharing (as those terms are defined by applicable law), or the processing of your Personal Information for targeted advertising purposes. To exercise these rights, you can access our cookie preference center for each of our websites and adjust your cookie settings, except for strictly necessary cookies, which cannot be adjusted. You can access the cookie preference center for each website via the Cookie banner or the Cookie Notice link available on each website. If you delete or reset your cookies, or use a different browser or device, you will need to reconfigure your cookie settings in the cookie preference center for each website you visited. We will address your request in accordance with applicable law.

Online components of our Services are not directed to children under the age of 13 or 14, depending on where you reside, and we do not knowingly collect Personal Information via online Services from children under the ages specified above. If you think that we have collected Personal Information via an online Service from a child under the ages specified above, please contact us as described below.

We have reasonable security measures in place to protect against the loss, misuse, and alteration of any Personal Information we receive about you. We maintain reasonable security standards to protect the Personal Information that we maintain. If you have any questions about the security of your Personal Information, please contact us.

Certain laws require us to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. As of the effective date of this Privacy Notice, an industry standard has not yet been established on how to respond to these signals, and therefore Vantive does not currently respond to such signals. Instead, we adhere to the standards set out in this Privacy Notice. If you have any questions, please contact us.

We will retain your Personal Information only for as long as we reasonably consider it necessary for achieving the purposes set out in this Privacy Notice, or for as long as we are legally required to retain it. If you have questions about applicable retention periods, please contact us.

If you reside in California, we are required by the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) (collectively, “California Privacy Law”) to provide you with information about how we use and disclose your Personal Information, and you may have certain rights with regard to your Personal Information. We have included this California-specific information below.

CA Personal Information. We may collect certain categories and specific pieces of information about individuals that are considered "Personal Information" in California ("CA Personal Information"). Specifically, we may collect the following categories of CA Personal Information: 

• Personal identifiers, such as name, mailing address, e-mail address, telephone number, fax number;
• Internet activity data, such as username and corresponding passwords and security questions, unique identifiers, browser type, device ID, internet service provider (ISP), referring/exit pages, the files viewed on our site, operating system, date/time stamp, and clickstream data and other pieces of information further described below under Tracking Technologies;
• Customer records, such as credit card type, number and expiration date;
• Geolocation data, such as Internet Protocol ("IP") address and general location information; and
• Inferences drawn from personal information that could be used to create a profile an individual.

Sources of CA Personal Information. We may collect this CA Personal Information directly from you, when you interact with our Services, or from companies or organizations you work for. 

Purposes of Collection. We collect and use CA Personal Information as follows: 

• Business Purposes
  1. To administer and provide you with the Services; 
  2. To manage business transactions; 
  3. To respond to your inquiries and provide information about the Services;
  4. To improve the Services and user experience; 
  5. To comply with applicable laws and our legal obligations; 
  6. For treatment or quality control purposes; 
  7. For a merger or sale. 
• Commercial Purposes 
  1. To provide you with marketing and advertising

Disclosure of CA Personal Information. We do not sell your CA Personal Information as that term is traditionally understood. However, some of our disclosures of CA Personal Information may be considered a “sale” or “share” as those terms are defined under California Privacy Law. Under California Privacy Law a “sale” is broadly defined to include a disclosure for something of value, and a “share” is broadly defined to include a disclosure for cross-context behavioral advertising. We disclose your CA Personal Information as follows: 

• Disclosing your CA Personal Information for Business Purposes. We may disclose the above categories of CA Personal Information to our subsidiaries and affiliates or to our service providers, as required by law, related to a merger or sale, to administer and provide the Services to you, or with your consent, for any of the Business Purposes described above.
• Disclosing your CA Personal Information for Commercial Purposes. We may share the above categories of CA Personal Information with service providers, third-party vendors, business partners, or to other third parties with your consent, for any of the Commercial Purposes described above.

We do not knowingly disclose the CA Personal Information of individuals under 16 years of age, in a manner that constitutes a "sale" under California law.

CA Sensitive Personal Information

Certain CA Personal Information that we collect about you may be considered sensitive personal information within the meaning of California Privacy Law, including: credit card information (for billing and transactional purposes in connection with providing our Services), health or medical condition, and your treatment (including the specific device or product that you are prescribed) (for purposes of providing our Services). We only use and disclose sensitive personal information as necessary in connection with the performance of services and the provision of goods, compliance with federal, state, or local laws, and as otherwise permitted by California Privacy Law.

Retention of CA Personal Information 

We retain your CA Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) as required by a legal obligation to which we are subject to; or (iii) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations). 

Your Rights under California Law

Subject to certain exceptions detailed in California Law and other applicable laws and regulations, as a California resident, you have the right to: (i) request to know/access your CA Personal Information, including the specific pieces and the categories of CA Personal Information we have collected or shared about you and the categories of sources from which we have collected the CA Personal Information; (ii) request deletion of your CA Personal Information; (iii) receive information about the CA Personal Information about you that we have "sold" to (as such term is defined under California Law) or “shared” with  third parties within the past 12 months, including the categories of third parties; and (iv) request correction of your CA Personal Information; and (iv) opt-out of the “Sale” or “sharing” of your CA Personal Information, as such terms are defined under California Privacy Law.

Exercising California Consumer Rights. 

If you are a California resident and wish to request the exercise of these rights as detailed above or have questions regarding the CA Personal Information collected or shared with third parties, please email us at [email protected] or call us at  844-787-0432 (U.S). To opt-out of the "sale" or "sharing" of your CA Personal Information, please email us at [email protected].  

1. You may be asked to provide additional proof of identification so that we can verify your identity and validate the request. 
2. Please note that you are limited by law in the number of requests you may submit per year. In some instances, we may decline to honor your request. For example, we may decline to honor your request if we cannot verify your identity or confirm that the CA Personal Information that we maintain relates to you. In other instances, we may decline to honor your request where an exception under California privacy laws applies, such as where the disclosure of California Personal Information would adversely affect the rights and freedoms of another consumer. 
3. In any case, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request.

Authorized Agents

To the extent that you elect to designate an authorized agent to make a request on your behalf, they must provide appropriate documentation including written signed permission from you, proof of your identity, and verification of their identity; or a valid, designated power of attorney as defined under the California Probate Code.

CA Shine the Light

We do not disclose personal information to third parties for such third parties to use for direct marketing purposes. Under California’s Shine the Light law, customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To make a request, please write us at the email or postal address set out in the “Contact Us” section below and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year. 

We may periodically update this Privacy Notice to describe new Services and how such Services may affect our collection and use of Personal Information. If we make material changes to this Privacy Notice, we will post a notice of the material changes on our website. In the event that we use your Personal Information for other purposes not specified in this Privacy Notice, we will notify you and obtain your consent, to the extent required by applicable law. We encourage you to periodically review this Privacy Notice for the latest information on our privacy practices.  

If you have questions or concerns about this Privacy Notice, our information practices, or any other aspect of the privacy and security of your Personal Information, please contact us using the information below. 

Email: [email protected]

Mail: Vantive US Healthcare LLC

ATTN: Global Privacy Office

1 Baxter Parkway, Deerfield, IL USA 60015

For information about your local Vantive operating company, please click on the applicable link below:

• Asia Pacific : https://www.vantive.asia/contact-support/get-touch
• Europe/Middle East/Africa: https://www.vantive.eu/contact-support/get-touch
• Latin America: https://www.vantive.lat/contact-support/get-touch
• North America: https://www.vantive.com/contact-support/get-touch