Privacy Notice

Avanos collects personal data about you in a variety of ways.

We collect your personal data directly when you engage with us including when you: (i) visit our Sites; (ii) communicate with us, e.g. via email or telephone including via the email address on our Sites, (iii) register an account with us. We may also receive your personal data indirectly, for example through tracking technologies we use when you visit our Sites (see our Cookies Policy for more information).

The following are examples of the types of personal data that may be collected. The specific kinds of personal data collected will depend on the Site you use and who you are.

Site Visitors / Account Holders

• *Registration and Account Information:
• You can browse the Sites without providing us with direct identifiers like your name, email address, phone number, mobile telephone number, or mailing address.
• To register for an account or establish a profile on the Sites, you may need to give us personal data such as your:
• Contact information (such as name, title, email address, mailing address, and phone number)
• Payment information (including payment card numbers, billing/correspondence address, and bank account information), where relevant
• Account log-in credentials (e.g., username and password)

If you fail to provide this information, you may not be able to access our Sites or your use of our Sites may be limited.

• Information to Respond to Your Requests: You may also provide to us your personal data to sign up for our newsletters and other communications. This may include information such as your survey responses/preferences, profiles we have built about you, or information about enquiries you have submitted. You can exercise certain choices concerning how and when you will receive such newsletters and other communications by following instructions available on the Sites.
• Information from Other Sources: The information we collect may be combined with information from outside records (e.g., demographic information, marketing information, and/or additional contact information). We use and share anonymised information such as statistical demographic data which is not reasonably likely to reveal your identity. If we combine or connect anonymised data with other data so that it can directly or indirectly identify you, the combined data is personal data which will be used in accordance with this Privacy Notice.
• Information from chatbot services: We may collect personal data which is voluntarily provided when you visit our Sites and engage with our chatbot, such as: (i) personal contact information (e.g., phone number, email address, and postcode); (ii) the information within the free text facility within the chat; and (iii) the transcript of the chat.
• Information You Post on the Sites: You may provide us with information regarding your opinions and reviews of products.
• Mobile Information: We may collect additional information from you if you access the Sites through a mobile device (e.g., your unique device identifier, your device’s operating system, or the mobile carrier for your phone, location or GPS/geo-location, Domain, IP address, date, time and duration of your visit, browser type, page visits, internet traffic and other information about your computer or device).
• Geolocation Information: When you visit the Sites, we may collect geo-location information to provide certain location-based services that you request (e.g., maps).
• Technical Site Usage Information: When you visit the Sites, we collect usage information sent to us by your computer, mobile device, or other access device that tells us how you are using the Sites (“usage information”). We use tracking technologies – such as cookies (including cookies stored in HTML-5), web beacons/GIFs, embedded scripts, e-tags/cache browsers – to collect usage information, purchase history, and product use history. We may also collect password information from you when you log in, as well as computer and connection information. During some of your visits to the Sites, we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages, and page interaction information. For more information about the use of cookies and similar technologies on the Sites, please review our Cookies Policy.

Service Provider / Customer Representatives / Partners

• *Information You Share With Us: You may provide us with your name, email address and other contact information in the course of providing services to us / us providing services to you.
• *Information You Share with Us to Perform Background Checks: We may collect (and use, disclose and process) personal data of sub-contractors, contractors, business partners and our customers to perform background checks, prevent fraud, and comply with our legal obligations.
• Information to Respond to Complaints: You may give us your personal data when raising a complaint either directly or via one of our supplier’s / vendor’s representatives. We may collect (and use, disclose and process) this information, which may include health data (see below), in order to respond and investigate your complaint.

Health Data and Data of Minors

We collect (and use, share, and further process) health data in very limited circumstances:

• Where you provide to us your health data in connection with your employment by us, including for the purposes of documenting medical absences, evaluating any need for reasonable accommodations or workplace adjustments, and ensuring compliance with applicable employment, health and safety and equality laws;  
• Where you inform us of your allergies in connection with catering at, or any need for reasonable accommodations during one of our training courses or other Avanos-organized events;
• Where we conduct post-market surveillance and follow up (including investigation of adverse events and patient testimonials). We collect (and use, disclose and further process) health data in this context including which products were used and what failed, why the patient was using it, what happened to the patient, medical history of the patient, and their condition after the event. This information may be collected (and used, disclosed, and further processed) for the purposes of (i) advising healthcare professionals on the next steps; (ii) investigating and addressing product issues; (iii) communicating with regulators; and (iv) defence of claims.

Avanos does not intend that any portion of the Sites will be accessed or used by minors. We do not knowingly collect personal data via our Sites in this age group. If you are a parent or guardian of a minor and believe we have collected information from your child in error or have questions or concerns about our practices relating to children, please notify us at dataprotection@avanos.com.

We use the personal data that we collect for various purposes. We will generally use and process your personal data for the purposes outlined below, or for other purposes specified to you at the point of collecting your personal data. We will only use and process your personal data as necessary so that we can pursue these purposes. We use all personal data, collected directly or indirectly, to:

• Operate the Sites: We use personal data to: (i) respond to your requests; (ii) provide customer service (e.g., to resolve disputes, problems with your account/profile or the Sites); (iii) personalize your experience by providing content on the Sites, including targeted advertising that we believe may be of most interest to you; (iv) improve the Sites; (v) give you information about your account; and (vi) provide you with a safe, efficient, and customized experience.
• Provide Products and Services: We use personal data to: (i) provide you with our products, services, and resources; (ii) create and manage your account(s); (iii) allow you to order and purchase products and services; (iv) collect and process payments, complete transactions, and resolve disputes/problems with your orders; (v) handle product complaints; (vi) enroll you in programs that you or your healthcare provider request; and (vii) provide you with information on continuing education and credits for such education.
• Manage our relationship with You: We use information collected from you to: contact you;  maintain your account(s) with the Sites;  comply with your stated communication preferences;  provide you with other requested services (as described at the time when we collect the information from you); and to send you marketing, newsletters, and other communications that you have requested, to answer your questions or respond to your requests, or contact you for other purposes authorized by law.
• Personalised Content: We may also use your information to provide you with location-based services, such as advertising, search results, and other personalized content.
• Provide chatbot services: We use your personal data to provide you with the chatbot service, to learn from and improve the chatbot service, manage our relationship with you and meet our regulatory and legal requirements, as required. We may share the information with our third party chatbot supplier to facilitate improvement of services and wider development of service.
• Prevent Fraud: We use information collected from the Sites to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, enforce any applicable Terms and Conditions and otherwise manage our business.
• Comply with other relevant legal or regulatory obligations: We may also use your information, such as identity and contact information, educational grants, research and details regarding provision of hospitality to you during our events, to comply with other relevant legal or regulatory obligations where necessary.
• To enable or facilitate corporate transactions: We may use your personal data in connection with any merger, sale, integration, transfer of our assets, investment, acquisition, bankruptcy, or similar event or corporate transaction.

Generally, we may share your information to facilitate the provision of our products, services, and communications with customers, including the following. Where required by law, such sharing will only occur after we have obtained your consent:

Internally

We may share the information we collect about you with the Avanos corporate family and their and our affiliates and subsidiaries, as well as with third-party suppliers. The information may be disclosed to: (i) provide joint content and our services (e.g., registration, transactions, analytics, customer support); (ii) help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and (iii) guide decisions about our or a third- party’s products, Sites, applications, services, tools and communications. Members of our corporate family will use this information to send you marketing communications and you will have the opportunity to exercise certain choices regarding these email communications when we have consent if required by law.

Externally

• Service Providers and Other Third Parties: We will disclose personal data to service providers under contract to help with our business operations (such as, but not limited to, system administration service providers including IT and data storage providers, CRM providers and data management platform providers, software providers, data analysis providers, customer service and email delivery providers, payroll service providers, marketing and advertising agencies, providers that perform site analytics and operations, auditing and other similar services, travel agencies, hotels and airlines, caterers, third parties operating training sites (e.g. hospitals), healthcare professionals and organisations, event organisers, fraud investigators).
• Legal and Law Enforcement: We may share personal data with law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Avanos user to legal liability. In this regard, we may share your information with third parties in response to a subpoena, other legal process and/or as permitted by law and will take steps to minimise disclosure of data we may deem relevant to the investigation.
• Regulators, local authorities and government bodies, including the police and taxation authorities, to comply with any legal or regulatory requirements or formal/informal investigations.
• Professional advisers such as lawyers, accountants, auditors, facility management providers, insurance companies (including brokers) and insurance claims managers.
• Change of Control or Reorganization: If we decide to sell, buy, merge or otherwise reorganize businesses in some countries, such a transaction may involve the disclosure of personal data to prospective or actual purchasers, or the receipt of such information from sellers. It is our practice to seek appropriate protection for personal data in these types of transactions. We may also sell to any party who has a legal need to conduct due diligence, for example financial institutions, notified bodies or health authorities.
• Companies in the Mobile App Industry: If you access the Sites through a mobile device, we may also share your information with carriers, operating systems, and platforms.
• Other Entities with Your Consent: We will share personal data with other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service). On the Sites, you may have opportunities to express interest in or register for other services. If you do, we will provide information about you to those third parties, or parties working on their behalf, to implement your request.

Where required by law, we ensure that we have identified a legal basis (such as your consent) under which your data is lawfully collected, used, disclosed and processed.  

Avanos is headquartered in the United States, and we have operations, entities, and service providers in the United States and throughout the world.

The personal data that we collect pursuant to this Privacy Notice may be transferred to countries other than your own country for collection, use, disclosure, storage or processing, and these countries may offer different levels of privacy protection than apply in your own country. Where required under applicable data protection laws, we will ensure that the transferred personal information is subject to measures that provide a comparable level of privacy protection as provided by data privacy laws in your own country. 

Avanos will retain personal data collected pursuant to this Privacy Notice for as long as necessary to fulfil the purposes for which it is collected, used, disclosed or processed (as outlined in this Privacy Notice). We will also retain personal data collected pursuant to this Privacy Notice to comply with legal and regulatory obligations, handle disputes, and to establish, exercise or defend against legal claims in the countries where we do business.

If you have a question related to this Privacy Notice, please contact us by emailing us at Avanos single point of contact:  dataprotection@avanos.com. Your message will be forwarded to the appropriate member of the Avanos Data Privacy Team depending on the collection, use, disclosure or processing (i.e. it may be Avanos Medical Singapore Pte. Ltd. if you reside in Singapore).

Under data protection laws, you may have various rights. The rights available to you depend on our reason for collecting, using, disclosing or processing your personal data and where you are based. You can exercise these rights (including making these requests) by emailing us at our single point of contact: dataprotection@avanos.com. Please put the statement “Privacy Rights” in the body of your request, as well as your name, country or region, and enough information to allow us to respond to your request.

In general, you are not required to pay any charge for exercising your rights, although we may charge a reasonable fee if your request is unfounded, repetitive or excessive. We have one month (or a shorter period if required under applicable data protection law) to respond to you (unless you have made a number of requests or your request is complex, in which case we may take up to an extra two months to respond but we will inform you where this is the case) (“Response Time Limit”). Please note that, where we ask you for proof of identification, the Response Time Limit does not begin until we have received this. If we require any clarification and/or further information on the scope of the request, the Response Time Limit is paused until we receive that information.

Depending on the applicable data protection laws and subject to the conditions thereunder, you may have the following rights:

• Right of access. You can ask us for copies of your personal data, and for information about how we have used your personal data. There are some exemptions, which means you may not always receive all the information we collect, use, disclose or process. These exemptions include situations where the information requested also includes personal data about somebody else.
• Right to rectification. You can ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Right to withdraw consent. Where we are relying on consent to collect, use, disclose or process your personal data, you can withdraw it at any time. This will not affect the lawfulness of any collection, use, disclosure or processing carried out before you withdraw your consent. Where you withdraw consent, we will stop the collection, use, disclosure or processing activities based only on consent as a lawful basis. We may still collect, use, disclose or process personal data if we have another lawful basis for collecting, using, disclosing or processing (this will be for more limited purposes e.g. back-up storage).
• Right to data portability. This only applies to information you have given us. You can ask that we transfer the personal data you gave us from one organisation to another, or give it to you. The right only applies if we are collecting, using, disclosing or processing personal data based on performance of a contract and/or your consent.

In the event you consider our collection, use, disclosing and/or processing of your personal data not to be compliant with the applicable data protection laws, you can lodge a complaint by emailing us at dataprotection@avanos.com. If this is not satisfactory, you can complain to a supervisory authority. We would appreciate the chance to deal with your concerns before you approach a supervisory authority so, please contact us in the first instance.

If you reside in Singapore, the data protection supervisory authority will be the Personal Data Protection Commission, who can be contacted here: 10 Pasir Panjang Road, #03-01 Mapletree Business City Singapore 117438. Main line: +65 6377 3131 https://www.pdpc.gov.sg/.