Edwards Lifesciences Privacy Statement
Last Updated January 2023
Who We Are
Edwards Lifesciences Corporation, Edwards Lifesciences LLC, and their affiliated companies (collectively “Edwards Lifesciences,” “our,” or “we”) are committed to respecting your privacy. This Privacy Statement describes our policies and practices on the collection, use, disclosure, and storage of Personal Information and the steps we take to protect it from unauthorized use or disclosure.
Purpose and Reach of This Privacy Statement
This Privacy Statement applies to all Edwards Lifesciences websites, online or digital services activities, and mobile applications, including, but not limited to www.edwards.com, in which this Privacy Statement is posted or linked (collectively our “Sites”) and, where applicable, will apply to Personal Information that we obtain and process other than through the Sites (for example, Personal Information about our customers, vendors, or service providers in the course of doing business).
Although this Site content is intended for a United States. audience, Edwards Lifesciences is a global company and any information that you provide or we collect, will be available to Edwards Lifesciences affiliates and vendors around the world. This means that your information may be transmitted to our affiliates and vendors located in a country other than the country in which you reside, including the United States, and the privacy and data protection laws in these countries may not be as protective as those of the country in which you reside and could be subject to access by governments in these countries. However, regardless of the country to which your Personal Information is transferred, it will be protected in a manner consistent with the protections described in this Privacy Statement.
By using this Site, you consent to the collection, use, storage, and processing of your Personal Information in the United States and in any country to which we may transfer your Personal Information in the course of our business operations.
In addition, where necessary and applicable, Edwards Lifesciences may transfer Personal Information relating to individuals in the European Economic Area, the United Kingdom, and Switzerland to other countries in reliance on the Standard Contractual Clauses.
If you are a resident of California interacting with us as an employee or former employee, or a dependent or beneficiary of an employee or former employee, this Privacy Statement does not apply to you. Please refer to our California Employee Privacy Notice for information regarding the processing of your personal information. Please email firstname.lastname@example.org to request a copy of this Notice.
Please note that our Sites might offer links to other websites that are owned or controlled by third parties. This Privacy Statement applies only to Edwards Lifesciences’ Sites. We do not control or endorse the content of any third-party sites and cannot accept responsibility for the privacy practices of any websites not controlled by us and we encourage you to review the privacy policies of any third-party sites prior to providing them with any of your personal information.
Please review this Statement carefully. To the extent permitted by applicable law, by providing us your Personal Information or otherwise interacting with us, you are agreeing to this Statement.
Click on any of the links below to visit the specific area of this Privacy Statement, or continue scrolling down to read this Privacy Statement in its entirety.
Information we collect on our Sites
Information we collect outside the Sites
How we use the information we collect
Disclosure of information to third parties
How we protect information
How long we retain personal information
Your privacy choices
If you have concerns about your personal information
Changes to our privacy statement
Information we collect on our sites
This section describes information that individuals might choose to provide to us, as well as our practices for the automatic collection and use of certain information related to the use and navigation of our Sites.
Information you provide
We define Personal Information as information that can (directly or indirectly) identify, locate, or be used to contact you or communicate with you, such as your name, address, telephone number, e-mail address, characteristics, or descriptions (such as gender and date of birth), and other similar and associated information (“Personal Information”). Personal Information includes certain subsets of Personal Information that are considered “sensitive” pursuant to applicable laws, such as information about health or medical status, and healthcare products used or services received (“Sensitive Personal Information”).
In most cases, we collect Personal Information directly from you. We will ask you for Personal Information, for example, when you interact with us, such as registering on our Sites, using any interactive features or applications, signing up to receive a newsletter, or, a patient who has received one of Edwards Lifesciences’ products may choose to share his or her experiences with us; a person seeking employment may choose to apply for a job online or request additional information about job opportunities; a health care professional might ask that we send information about one or more of our products. Before providing Sensitive Personal Information to us, we urge you to carefully consider whether to disclose it. If you do provide Sensitive Personal Information to us, you are consenting to its use and disclosure for the purposes and in the manner described at the time of collection and as set forth in this Privacy Statement.
Information we collect automatically
Additionally, through your use of the Sites, we collect information related to your use by automated means, such as the date and time of your website sessions, movements across our Sites, and the browser information and operating system you use and other system settings, as well as the language your system uses and the country, region, and time zone where your device is located (collectively, “Usage Data”). Usage Data also includes the IP Address of the device you use to connect to the Internet that is collected by our Site server logs. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. In certain circumstances, where we link Usage Data and Personal Information, Usage Data may be considered Personal Information. Usage Data may also allow us to identify the country you are visiting from, so that we may direct you automatically to the content that is appropriate for your country.
Digital Advertising, Cookies and Other Data Collection Technologies
When you use our Sites, we collect different types of Usage Data by automated means, using technologies such as APIs, web services, scripts, cookies, pixels, tags, web beacons, browser analysis tools, and server logs. Using these technologies, we may also collect data about the website you were visiting before you came to our Site, and the website you visit after you leave our Site. We may also use vendors, such as Adobe and Google, to place cookies and collect data to enable certain services we use, including advertising, visitor tracking, personalization, site analytics and security services, including reCAPTCHA, and the data may be disclosed to our vendors for these purposes.
Other data may be disclosed to vendors providing additional services integrated into our Sites, including performance monitoring, user experience components such as user interface frameworks, images and web fonts, maps, and ecommerce functionality. When we send email communications, we may place a web beacon or similar tracking technology in the email to know whether your device is capable of receiving HTML emails, or to collect data on whether the email or an attachment or link in the email has been opened or forwarded.
When you use our Sites, we may place cookies on your computer. Cookies are small text files that websites or mobile apps send to your computer or other Internet-connected device to uniquely identify your browser or to store data or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. Some of our Sites may use Web Storage instead of cookies.
You can also opt-out of receiving targeted advertising from Network Advertisers by clicking the “Ad Options” icon on the advertisements or by going to www.networkadvertising.org. In addition, the Digital Advertising Alliance maintains a web site where consumers can opt out from receiving interest-based advertising from some or all of the network advertising companies participating in the program (www.AboutAds.info/choices).
In many cases, the data we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Information. However, under some privacy and data protection laws, this data could be considered Personal Information. This Privacy Statement governs how we use this data when it is considered your Personal Information.
Information we collect outside the sites
We recognize that we might receive Personal Information in ways other than through our Sites. We collect information about our customers and potential customers for the purposes of providing our products and services – such as contact information, financial/billing information, and any other information that is provided to us during the course of doing business. For example, many physicians notify us when a specific valve has been implanted, so that we can maintain a database of the patient that received a valve with a specific serial number. Physicians also notify us of complaints or adverse events with our products. Job applicants may submit paper applications. We maintain records of purchases by our physician customers and their attendance at educational and other events we host.
We also collect information from our vendors, suppliers, consultants, professional advisors, and other third parties for the purposes of managing and operating our business. For example, we will collect business contact information, financial information, and other information necessary to engage our suppliers and other business partners and to evaluate their performance.
Personal Information is given the same protection by us, whether we receive it through a website or by other means. The descriptions below apply to Personal Information collected or received by us, no matter how the information was received.
How we use the information we collect
Edwards Lifesciences may use your Personal Information for its business, operational, and legal purposes, including:
- To respond to your specific inquiry or request, and to provide you with information and access to resources that you have requested from us;
- To provide, operate, and maintain the Sites;
- To improve the navigation and content of our Sites, system administration, and security;
- To provide you with general health information (such as information on certain health conditions) as well as information about our products and services;
- To provide you with marketing communications and offers for products and services and to deliver advertising (including targeted advertising) to you on this and other websites;
- To process and complete transactions;
- To manage our customer relationships, including to respond to inquiries and comments and providing customer service and support;
- To provide our products and services;
- To create anonymized or de-identified data so that it is no longer Personal Information;
- To carry out research and development to improve our products and services;
- To assess financial, credit or insurance risks arising from any relationship or prospective relationship with a customer, supplier, distributor, or business partner; or
- To carry out other legitimate business purposes, and other purposes about which we will notify our users and customers.
We will give you an opportunity to tell us whether we may use your Personal Information to send you other information about Edwards Lifesciences’ products, activities, or opportunities. In most circumstances, you will be able to “unsubscribe” from these communications by following the instructions provided at the time you sign up for the communications or that are included in such communications.
We may use the Usage Data we and our partners collect during your future visits. This information allows us to direct you to specific content on the Sites that may be of interest and to remember your computer/device the next time you visit. If you visit multiple Edwards Lifesciences Sites, we may aggregate the Usage Data from your visits to better understand usage of our Sites.
Disclosure of information to third parties
We may share your Personal Information with Edwards Lifesciences’ affiliates, with our business collaborators, and our product co-promotion and co-development partners, marketing and advertising agencies, and social media companies and platforms for the purposes set forth above and elsewhere in this Privacy Statement.
We may share Personal Information with our service providers, who are bound by law or contract to protect Personal Information and only use Personal Information in accordance with our instructions or the agreements we have signed. For example, we may share Personal Information with service providers who provide data processing or fulfilment services for us.
We may also disclose your Personal Information to a third party in connection with the sale, assignment, or other transfer of an Edwards Lifesciences’ asset(s), which may include associated Sites to which the information relates. We will try to assure that no Personal Information that is transferred will be used or shared in a manner inconsistent with this Privacy Statement without your consent. However, in the event of a sale or merger, your continued use of this Site signifies your agreement to be bound by the Privacy Statement and other applicable terms of the subsequent owner or operator.
Please note that we may also disclose data about you that is not personally identifiable. For example, we may publish reports that contain aggregate and statistical data about our customers.
How we protect information
Consistent with applicable laws and requirements, we have put in place reasonable physical, technical, and administrative safeguards designed to protect Personal Information from loss, misuse, alteration, theft, unauthorized access, and unauthorized disclosure consistent with legal obligations and industry practices. However, as is the case with all websites, applications, products, and services, we unfortunately are not able to guarantee security for data collected through our Products and Services.
We are not responsible for any interception or interruption of any communications or for changes to or losses of data through the internet. Users of the Sites are responsible for maintaining the security of any password, user ID, or other form of authentication involved in obtaining access to password protected or secure areas of the Sites. It is your responsibility to safeguard any passwords, ID numbers, or similar individual information associated with your use of the Products and Services. Any access to the Sites through your user ID and password will be treated as authorized by you. If we believe it is necessary or advisable to help protect your Personal Information and/or the integrity of the Sites, we may suspend your use of all or part of the Sites, without notice.
Unauthorized access to any of the Sites is prohibited and may lead to criminal prosecution.
How long we retain personal information
We retain information as long as it is necessary and relevant for our business, operational, and legal purposes. In addition, we retain Personal Information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, and other actions permitted by law. When your Personal Information is no longer needed for Edwards Lifesciences’ business, operational, and legal purposes, we dispose of it subject to applicable law. Whenever possible, we aim to de-identify the information or otherwise remove some or all information that may identify you from records that we may need to keep for periods beyond the specified retention period.
Your privacy choices
In your use of the Sites, you will be given opportunities to make choices about the data we receive and how we use it.
Do Not Track signals and Global Privacy Control. Certain web browsers and other programs may transmit “do-not-track” “opt-out” signals, also called a Global Privacy Control (or GPC) signal (we refer to these as “GPC Signals”), to websites with which the browser communicates. In most cases you will need to change your web browser’s settings or add an application to your web browser to enable your browser to send a GPC Signal. Our websites will recognize GPC Signals for website users differently, based on the location of the user when they access our websites. For users that access our websites from U.S. states that have laws requiring recognition of GPC Signals, we will recognize and apply the GPC Signal to inactivate all of the cookies for that website, except for cookies that are necessary for the website to operate (“Essential Cookies”). Additionally, if you are accessing our websites from one of these states, you can determine if your browser GPC Signal has been recognized by clicking on the “Do Not Sell or Share My Personal Information” link in the footer of the website and checking that appropriate cookies have been turned off. For users from states not currently requiring recognition of the GPC Signal, our website servers may recognize and apply the GPC Signal for only advertising and social media cookies, but will not apply the GPC Signal to functional or performance cookies. You can always check and adjust your cookie settings by going to the “Do Not Sell or Share My Personal Information” link in the footer of this website.
Some web browsers incorporate other "do-not-track" (“DNT”) or similar features that signals to websites with which the browser communicates that a visitor does not want to have their online activity tracked. As of the Effective Date, not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, Edwards Lifesciences Sites along with many other digital service operators do not respond to all DNT signals. We recognize GPC signals as required under certain state privacy laws, but we do not currently recognize other DNT signals. For more information about the Global Privacy Control, please visit https://globalprivacycontrol.org.
Opting out of communications. If you provide Personal Information to us, we may from time to time send you communications, including electronic communications about products or services. You may unsubscribe to such communications by following the instructions in any communication we send you or, in most cases, by completing this form.
Cookies. Your Web browser settings allow you to change your cookie settings. Please be aware that the Site functions may not work well if you choose to reject some cookies. You also have the options described above in the Digital Advertising, Cookies and Other Data Collection Technologies section of this Privacy Statement.
Edwards Lifesciences does not intend to collect Personal Information from children under age 13, without consent from the child’s parent or legal guardian. We do not share Personal Information of anyone under 13 years of age with anyone outside of Edwards (except where required by law, and to our agents who have committed to maintain data privacy).
Children under 13 years of age should not submit any Personal Information to us without the express permission of their parent or legal guardian. If you believe that your child has submitted Personal Information and you would like to request that their information be removed from our systems, please complete this form. We will make reasonable efforts to comply with your request.
Definition of Personal Information. “Personal Information” is any information—as electronically or otherwise recorded—that can be used to identify a person or that we can link to or associate with a specific individual. Personal Information may include information considered sensitive in some jurisdictions, such as biometric information, genetic information, health information, financial account information, specific geolocation, ethnic or racial origin, information concerning your sex life or your sexual orientation, social security number, driver’s license, state identification card, passport number, and other similar information. Data that could be considered Sensitive Personal Information is highlighted with an asterisk (*) in the dropdowns below.
We will process any Personal Information we collect in accordance with applicable law and as described in this Statement (unless, as explained above, a separate policy or notice governs). In some circumstances, if you do not provide us with your Personal Information, certain Products and Services may be unavailable to you.
This U.S. Policy provides the information required under applicable U.S. state laws and applies to both Edwards Lifesciences’ online and offline activities relative to our processing of your Personal Information. This U.S. Policy and the relevant U.S. state laws do not apply to information that has been de-identified or aggregated. Some of the Personal Information that we collect, use, and disclose may, pursuant to provisions in the relevant laws, be exempt because it is regulated by other federal and state laws that apply to us.
Notice on Collection of your Personal Information. The following table provides you with a notice of the Personal Information we may collect from or about you, and how we will use, maintain, and disclose it. Some of this will depend on the nature of our interaction with you but can include the following with respect to Personal Information categories that we may have collected in the preceding twelve (12) months:
CALIFORNIA PROFESSIONALS. The following table provides detail for residents of California who interact with us in a professional capacity, such as (i) health care providers and their staff, (ii) clinical investigators and their staff, (iii) employees of companies with whom we conduct business, including employees of service providers, with respect to the category of Personal Information collected, the source of that information, the purposes for collection and sharing/disclosure, and the categories of third parties to whom the category of Personal Information is shared.
CALIFORNIA JOB APPLICANTS. The following table provides detail for residents of California who interact with us applicants for jobs, with respect to the category of Personal Information collected, the source of that information, the purposes for collection and sharing/disclosure, and the categories of third parties to whom the category of Personal Information is shared.
Other Uses of Personal Information
Mergers and Acquisitions. In addition to the uses set forth above, in certain circumstances, we will use and disclose your Personal Information to facilitate a merger, consolidation, transfer of control or other corporate reorganization in which Edwards Lifesciences participates, or pursuant to a financial arrangement undertaken by Edwards Lifesciences and your Personal Information will be disclosed to the buyer, assignee, or transferee.
Data Retention. We will retain your Personal Information for as long as needed or permitted to fulfill the purpose(s) for which it was collected or obtained, and as outlined in this Privacy Statement. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject that affects the Personal Information; and (iii) whether retention is determined to be necessary or advisable for Edwards Lifesciences due to applicable statutes of limitations, litigation, or other legal or regulatory obligations. We take reasonable steps to dispose of Personal Information upon the expiration of retention periods taking into consideration these litigation, legal, or regulatory obligations.
De-Identification. We may de-identify your Personal Information, which means it will remove certain data from your Personal Information, such as Contact Information, such that the resulting data would not be able to identify you or anyone else as the subject of the data. The de-identified data will no longer be Personal Information and may no longer be subject to data protection laws. We will not attempt to re-identify you or anyone else from this de-identified data and if we disclose it to third parties, we will require that they commit to not attempting to re-identify you or anyone else from the de-identified data. We will use de-identified data for our business purposes.
Third Party Advertising: We disclose Personal Information about you (as set forth in the table above) to third-party advertising network companies. We use third-party advertising network companies to place ads on other websites, including network advertising companies with whom we work who place their own cookies on your browser when you visit our Site. This enables these third-party advertising network companies to collect and use data from their cookie on your browser, which may include information about your visits to this and other websites. These advertising companies use and further disclose this information in order to deliver advertisements about our goods and services to you when you are on other websites. These advertisements will often be tailored to you. These advertisers may in turn disclose the information about you collected from their cookies to other advertisers to allow those advertisers to display ads to you as well. You may opt-out of our disclosure of your Personal Information for these purposes as set forth below.
Service Providers: Service providers acting on our behalf must execute agreements requiring them to maintain confidentiality and to process Personal Information as necessary to perform their functions in a manner consistent with this Statement, other applicable privacy notices, and as explicitly permitted or required by applicable laws, rules, and regulations.
Combination of Data with Data Received from Third Parties: We may combine information we collect, including Personal Information, with Personal Information that we may obtain from third parties.
Links to Other Websites: Our Products and Services may contain links to other websites, applications, products, or services that are not owned or operated by Edwards Lifesciences, such as social media websites and applications like Facebook and Twitter. You should carefully review the privacy policies and practices of other websites, products, and services as we cannot control and are not responsible for privacy policies, notices, or practices of third-party websites, applications, products, and services.
Your Data Privacy Rights Regarding Your Personal Information
Please note that in many circumstances, we cannot effectively do business with you without processing some Personal Information about you (e.g., your contact information). For example, when you contact our customer service representatives, we may require you to provide information to authenticate your identity to assist you with your request. If you are unable to provide this information, we may be unable to process your request.
To the extent that the state in which you live has a data protection law that requires us to offer some or all of the following rights to you, we will provide the following rights to you based on your state’s law:
- To opt-out of sharing your Personal Information for cross-context behavioral advertising or, in other states, to opt-out of targeted advertising;
- To request access to and a copy of your Personal Information, including to provide your Personal Information directly to another organization, i.e., a right to data portability;
- To request to know about the Personal Information we process about you or, in other states, to request to acknowledge our processing of your Personal Information;
- To request that we correct your Personal Information;
- To request that we delete your Personal Information;
- To opt-out of processing of Sensitive Personal Information;
- To appeal the denial of a request; and
- To lodge a complaint with the data protection authority in your jurisdiction.
To opt-out of sharing Personal Information or opt-out of targeted advertising, click here: “Do Not Sell or Share My Personal Information”. To learn if you have the other above rights in the state in which you live and to exercise any of these rights with respect to your Personal Information, please see the following section on How to Submit a Data Privacy Rights Request. We will not discriminate against you for exercising any of the rights described above, although we may not be able to continue to provide you Products and Services, or it may otherwise affect the way we are able to interact with you.
How to Submit a Data Privacy Rights Request
To submit a request pursuant to your data privacy rights under state privacy laws, we have designated the following two options for you to use: you can submit a data privacy rights request
- by completing and submitting this form, or
- by contacting us at (888) 570-4014.
We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. We may, after receiving your request, require additional information from you to honor your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.
You may designate an authorized agent to assist you in exercising any of your rights stated above. When you use an authorized agent to submit a request to exercise your rights, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.
In the event you wish to make a complaint about how we process your Personal Information, please contact us at email@example.com and we will handle your request as soon as possible. Even if you make a complaint to us, you may always lodge a complaint with the relevant authority in your location.
When we receive your Personal Information from our customers and process your Personal Information on their behalf, we do so at their request and subject to their instructions. We do not have control over our customers’ privacy and security practices and processes. If your Personal Information has been submitted to us by an Edwards Lifesciences customer and you wish to exercise any of the above-mentioned rights, please contact the relevant customer directly.
Right of non-discrimination for exercise of your privacy rights
We or Edwards Lifesciences will not discriminate against any person exercising his or her rights under applicable state data protection laws, as described above. Discrimination, in this context, includes that, as a result of exercising any of your data privacy rights, you are denied goods or services, charged different prices for goods or services, or provided a different level of quality.
Edwards Lifesciences’ does not sell Covered Information as defined under Nevada law. If you would like to make a further inquiry regarding the selling of your Covered Information as defined under Nevada law, please send an email to the Privacy Office at the email address provided below.
If you have concerns about your personal information
If you have any questions about this Privacy Statement or about your personal information, you may contact us as follows:
Privacy Office Edwards Lifesciences
One Edwards Way
Irvine, California 92614
If you wish to receive a response by email, please be sure to include your name, postal address, and email address. If we do not receive an email address, we will respond by postal mail.
Changes to our privacy statement
We may update this Privacy Statement from time to time. When we do update it, for your convenience, we will make the updated statement available on this page. Our intention is to use personal information in accordance with the Privacy Statement in place at the time the information was collected.
Revised January 1, 2023, to address changes related to U.S. state privacy laws