Edwards Lifesciences privacy statement
(Effective June 01, 2022 – Thailand)
Edwards Lifesciences Corporation, Edwards Lifesciences LLC, and their affiliated group companies, including Edwards Lifesciences (Thailand) Ltd. (collectively "Edwards Lifesciences," "our,", "we" or "us") recognize the importance of online privacy and are committed to protecting the privacy and privacy choices of our online visitors and others whose personal information we receive. This Privacy Statement describes our policies and practices on the collection, use, storage, disclosure and security of information on "www.edwards.com" or any website owned, operated or controlled by us ("Sites"), and also applies to personal information which we obtain from any individual and process other than through the Sites (for example, including but not limited to personal information about our employees, customers, end-users, vendors and service providers or any other individual having any association with us in the course of our business activities).
Please note that our websites might offer links to other websites that are owned or controlled by third parties. This Privacy Statement applies only to Edwards Lifesciences. 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. We encourage you to review the privacy policies of any third-party sites you visit.
This Privacy Statement hereinafter deals with the following aspects:
Information We Collect on Our Sites
Information Provided to Us Outside the Sites
How we use the information we collect
International Processing in the U.S. and Elsewhere
Disclosure of information to third parties
Your privacy choices
Our commitment to data security and protection
How is the personal information store?
If you have concerns about your personal information
Changes to our privacy statement
Information we collect on our sites
We have designed our Sites so that visitors can navigate and view Site content without having to provide any personal contact details to us, such as their name, address, e-mail or telephone number.
This section describes information that visitors might choose to provide voluntarily, as well as our practices for the automatic collection and use of visitors' device-related information and analytics information, such as visitors' IP addresses and information about how visitors navigate through the Sites.
Information you provide
Through your use of the Sites, you may choose to provide us with personal information that identifies you or your family members. This personal information may include a person's name, surname, postal or email address, phone number, national identifying number, age, date of birth, gender, information about your health or medical condition, or any other information that would allow Edwards Lifesciences to identify or contact you including any sensitive personal information prescribed by the applicable data privacy laws. For example, 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 register to attend an event we are hosting, might ask that we send information about one or more of our products, or they might report information about a specific patient. A charitable organization might request a donation.
Edwards Lifesciences may require you to provide from time to time, the personal information of other individuals such as your family members, next of kin or dependents, for administering and/or managing employment relationship with Edwards Lifesciences, such as but not limited to contacting such individuals for emergency purposes; declaration of conflict of interest or processing any corporate group insurance scheme.
If you provide the personal information of any third party (including but not limited to your family members) to us, you represent and warrant that you have notified the third party of the details under this Privacy Statement, have obtained consent from the third party (if required by applicable laws), and complied with other legal requirements according to applicable laws, to ensure that we can collect, use and/or disclose personal information of such third party according to applicable laws, before submitting personal information about such third party to us.
In addition, some aspects of our Sites may be restricted to use only by licensed health care professionals, and access to those portions of the Sites may require personal information to facilitate registration and verification.
In these instances, in order to fulfil your request to use the features of our Sites, we may ask for personal information such as your name, surname, postal or email address, phone number, age, date of birth, gender, and perhaps a medical license number or other information to verify eligibility to view certain restricted content or to allow you to register for an event. In limited circumstances, such as an adverse event with one of our products, we may also be required to obtain personal information about your medical condition to enable required reporting to government regulatory agencies. Health care professionals represent and warrant that they have notified their patient of the details under this Privacy Statement, have obtained their patient's consent (where legally required by applicable laws) and have complied with other legal requirements according to applicable laws, to ensure that we can collect, use and/or disclose personal information of such patient according to applicable laws, before submitting personal or medical information about their patients to us.
Information we collect automatically
In order to improve the online experience, we routinely collect certain device-related and analytics information about our visitors and their use of our Sites. For example, we record the IP address of each computer that logs onto our Sites. This IP address does not enable us to identify you by name or contact details, but it does allow us to maintain communication with your device during your visit. It also allows us to identify the location and country you are visiting from, so that we may direct you automatically to the content that is appropriate for your country.
We also use "cookies" and similar tracking technologies. These are small data files that are placed on your computer which enable us and our third party partners to identify your navigation of the Sites and any specific pages or information that you visit. You can set your browser to reject certain cookies, but the Sites may not function properly without them.
We may also place advertisements on third parties' websites. These third parties may track website usage information, as well as information on "click throughs" from an advertisement to our Sites. This helps us understand the effectiveness of our advertising.
Certain other information may also be collected from your device automatically if so permitted by you through your internet browser settings, which would be used to display the Sites correctly on your device.
Information provided to us outside the sites
We recognize that we might receive personal information in ways other than through our websites in cases where the individual chooses to provide such information to us or otherwise provides us with their consent to collect such information from them directly or through another source, either by reason of having some form of contractual arrangement or association with us or by reason of an applicable law. We, for example, 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, and may inadvertently include information about the patient's health. 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
If you choose to provide personal information to us, we will collect, use and disclose that information for a range of 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 process and complete transactions, including event registration;
- To manage our customer or business partner relationships, including to respond to inquiries and comments and providing customer service and support including the investigation, review, assessment and settlement of claims;
- To provide our products and services;
- 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;
- For activities associated with mergers and acquisitions, subsidiary maintenance, and legal advice;
- To comply with all legal and regulatory requirements under applicable laws and disclosures to judicial, regulatory, governmental authorities and industry entities applicable to Edwards Lifesciences;
- To carry out other legitimate business purposes, and other purposes about which we will notify our users and customers;
- For exercising any rights that Edwards Lifesciences may have in connection with products and/or provided to you;
- For marketing products and/or services offered by Edwards Lifesciences.
Additional purposes for Employees, Directors, Workers, Contractors:
- facilitating, supporting processing, dealing with, administering, managing, maintaining and/or terminating your employment relationship with Edwards Lifesciences , including but not limited to secondments with or transfer to affiliated companies, secondments with third party organisations who are/may be Edwards Lifesciences ’ business partners, suppliers or customers;
- payroll administration, performance appraisal, personal and career development; monitoring, analyzing and/or managing your performance, dealing with and/or recording your achievements or progress, performance targets and/or transactions carried out for Edwards Lifesciences , administering programs and plans with respect to training and development, attendance at seminars and events, job assessment, compensation, planning and organisation, determining your suitability for promotion, awards or any other benefits that may be provided by Edwards Lifesciences ;
- supporting, dealing with and/or administering your health needs, medical needs, safety and welfare requirements (all of which may or may not be provided by Edwards Lifesciences at Edwards Lifesciences’ absolute discretion), medical and/or insurance benefits and/or claims (whether for yourself or for your family members depending on what Edwards Lifesciences provides);
- facilitating communication with you or your nominated contacts in an emergency;
- facilitating, administering, processing, dealing with and/or managing your application(s) for loans, any benefits or schemes, financial aid or bursaries (if any), whether for yourself or for your family member(s) and if successful, administering and/or managing such financial aid grants or bursaries;
- dealing with, administering and/or managing your use of infrastructure or facilities that may be provided by Edwards Lifesciences including but not limited to provision of information technology equipment and services, recreation facilities and benefits as well as administering and managing any social or sports related club;
- managing Edwards Lifesciences’ infrastructure and business operations, including storage, hosting, back-up and/or disaster recovery, application for corporate loans, contractual requirements, AML (anti money laundering checks), IT outsourcing;
- dealing with, monitoring, preventing, investigating any fraud, unlawful activity or omission, misconduct, complaints and discipline related matters;
- complying with or as required by any applicable law, regulations, guidelines or governmental requirements of any relevant jurisdiction, whether in Thailand or elsewhere, and/or complying with Edwards Lifesciences’ internal policies,
- dealing with, handling and/or conducting disciplinary, security and quality assurance processes, matters and/or arrangements;
- complying with or as required by any request or direction of any governmental authority, including dealing with tax related requirements, claims, deductions or matters and immigration related matters (where you are a non-Thailand);
- recording and collecting personal information by the surveillance cameras installed throughout the premises of Edwards Lifesciences for security reasons;
- responding to legal process, pursuing legal rights and remedies, defending litigation and managing any complaints or claims;
- dealing with and/or administering CSR (corporate social responsibility) activities such as recycling, care for the environment, community involvement including visits to old folks homes or participating in events held by charities;
- conducting research, analysis and development activities to improve Edwards Lifesciences’ infrastructure, welfare, benefits and facilities in order to enhance your employment relationship with Edwards Lifesciences or for your benefit, or for benchmarking or assessing the competitiveness of your remuneration package;
- record-keeping purposes, reporting purposes, and producing statistics and research for internal and/or statutory reporting and/or record-keeping requirements, reporting on salary, performance reviews and achievements;
- carrying out and/or performing Edwards Lifesciences’ obligations in its contracts with current / potential project partners and/or customers, including that it may require provision of your personal information to such project partners and/or customers; and
- publicity and promotion with a view to marketing the business of Edwards Lifesciences and/or to acquiring customers.
Additional purposes for Candidates:
- For recruiting and candidate interviews;
- To enable candidates to submit applications and create candidate profiles;
- To conduct legally permitted background screenings, reference checks;
- For any other related activities that may be communicated or posted publicly from time to time, and with your consent where appropriate;
We will also 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 including any marketing products and/or services offered by Edwards Lifesciences. If at any time you wish to "unsubscribe" from these communications, you may reach out to us at the contact information provided below. Edwards Lifesciences does not sell or otherwise provide personal information to third parties for the third parties' marketing purposes.
We may also aggregate this device-related and analytics information we collect from all visitors, which helps us to improve our Sites by monitoring interest in the various Site content and understanding how our visitors navigate the Sites. This information may also help us diagnose any problems with our Sites.
If you choose to provide personal information to us, we may combine that information with the non-personal information collected through IP address recognition and cookies, to help us understand your specific interests and to deliver pertinent information to you.
Subject to applicable laws, you may be required to provide your personal information in order to comply with law or contracts or there exists a need to provide your personal information for the purpose of entering into a contract. Please be informed that if you do not provide your personal information, decisions by Edwards Lifesciences may be prevented or delayed, Edwards Lifesciences may be unable to carry out the actions for the purposes outlined in this Privacy Statement and/or Edwards Lifesciences may not be able to establish, administer or maintain any contractual relationship and/or the agreement or arrangement with you.
Subject to applicable laws and to the extent permitted by applicable laws, Edwards Lifesciences may collect, use, and/or disclose your personal information for any of the following purposes without your consent:
- if it is in order to comply with laws of Edwards Lifesciences;
- if it is in order to prevent or suspend danger to life, body or health of a person;
- if it is in order to comply with the contract to which you are a party or in order to comply with your request prior to execution of the contract;
- if it is in order for Edwards Lifesciences to comply with the duty to take actions for public benefit or to comply with the duty to exercise state power conferred on Edwards Lifesciences;
- if it is in order to achieve legitimate interests of Edwards Lifesciences, Edwards Lifesciences affiliates or other persons unless such interest has less weight than your basis right in the personal information;
- if it is in order to achieve the objective related to the preparation of historical documents or annals for public benefit or in relation to research or statistics for which there is in place appropriate protective measure to safeguard the right and freedom of you; or
- if it is permitted by or falls under any circumstances prescribed by any applicable laws including the applicable data privacy laws.
International processing in the U.S. and elsewhere
Any information that you provide or we collect, may be disclosed to Edwards Lifesciences affiliates and to our third party service providers around the world for purposes that are consistent with this Privacy Statement. This includes transfers to the United States, where much of our electronic data are stored. If you choose to provide your personal information to us via the Sites, this provision of information constitutes your acknowledgement of and consent to such transfers.
This means that your information may be communicated to a country other than your country of residence for processing or storage, and it may also be communicated to any third parties including third parties hired by us to provide services such as website hosting, database management, analytics services, travel and event registration, suppliers, advisors, consultants, governmental authorities and courts. Some of these countries may not have data protection laws that are equivalent to the laws of the country where you reside, but we have taken measures to ensure your personal information remains protected to the standards described in this Privacy Statement, wherever it is processed.
Disclosure of information to third parties
In general, we may need to disclose your personal information to any third parties located in your country of residence and/or other countries (such as Edwards Lifesciences affiliates, our business partners, service providers, suppliers, advisors, consultants including governmental authorities and courts), for the purposes outlined in this Privacy Statement and/or in connection with the operation of our business and/or to comply with applicable laws or orders of the relevant governmental regulators and courts.
Edwards Lifesciences uses third parties that perform services for us, including data processing services, and those third parties have agreed to maintain the privacy and security of any personal information they receive from us.
In some instances, we may be required by law, subpoena, or court order to disclose information. For example, if you use a Site to report an adverse product experience, we may be required to report that information to the U.S. Food and Drug Administration (FDA) or to similar regulatory agencies in other countries. We may also disclose information where we believe necessary in order to protect the vital interests of any person, or exercise, establish or defend our legal rights.
If a third party buys any of our group members or their assets, then we may disclose information to that third party in connection with the sale. We will make clear to the third party purchaser that it may only use personal information it receives from us for the purposes for which it was originally obtained.
Please note that under certain circumstances, we may be required to disclose your personal information in response to lawful requests by public authorities and/or courts, including to meet national security or law enforcement requirements.
Finally, we may request your consent to share your personal information with some third parties. In those circumstances, we will only share your personal information with your consent.
Your privacy choices
In your use of the Sites, you will be given opportunities to make choices about the personal information we receive and how we use it.
Receive information about Edwards. If you provide personal information to us, you may be asked to confirm whether you would like to receive future communications, including e-mail communications. If you confirm, we may from time to time send you information about products or services. Even if you confirm that Edwards to send you additional information, you may change your mind at any time by following the instructions in any email communications we send you or by reaching out to us at the contact information provided below.
Accessing, Correcting or Changing Your Personal Information. If you wish to access, update or correct, amend or delete the personal information you have previously given us, please reach out to us at the contact information provided below. We will consider your request in accordance with any applicable laws.
Do Not Track Signals/Online Tracking. Some Web browsers may be set to send a "Do Not Track" (DNT) signal to the websites you visit. This signal instructs the website to not collect information about your activities across different websites. We currently do not respond to DNT signals.
However, Edwards Lifesciences does not track your activities on any third-party websites or applications (except for monitoring of your interactions with any of our advertisements on third-party sites), and we do not select content based on your activities on third-party sites or applications. If you visit more than one Edwards Site, we do track your activities on all Edwards-run websites, so that we can improve your overall experience with Edwards.
Removing your personal information. You may request that Edwards Lifesciences delete your personal information by reaching out to us at the contact information provided below.
Edwards Lifesciences does not intend to collect personal information from children under age 20, without consent from the child's parent or legal guardian. We do not share personal information of anyone under 20 years of age with anyone outside of Edwards Lifesciences (except where required by law, and to our agents who have committed to maintain data privacy).
If you are under 20 years of age, you represent and warrant that you shall not submit any personal information to us without the express permission of your parent or legal guardian (if required by applicable laws), and that you have complied with other legal requirements according to applicable laws, to ensure that we can collect, use and/or disclose your personal information according to applicable laws, before submitting your personal information to us. 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 reach out to us at the contact information provided below. We will make reasonable efforts to comply with your request.
Our commitment to data security and protection
Edwards Lifesciences understands that the security of your personal information is of the utmost importance, and we work to maintain your trust. We have implemented appropriate security measures and use industry-standard technological and organizational measures to protect the security of the information that we collect and that which you provide to us from risk of loss, misuse, unauthorized access, disclosure, alternation and destruction.
Despite these reasonable efforts to safeguard personal information from loss, theft, alteration, or other types of misuse, we cannot guarantee that such loss will never occur. There is always a risk that a third party, without our authorization, might unlawfully access our systems or otherwise access personal information.
How is the personal information stored?
Edwards Lifesciences store your personal information for the duration of legal relationship between you and us, or for as long as is necessary to fulfil the original or directly related purposes outlined in this Privacy Statement or comply with any legal and regulatory requirements or a retention period required by applicable laws, or as per legal prescription for an establishment of legal claims, legal compliance or exercise of legal claims, or defense of legal claims, whichever is longer.
Subject to provisions, conditions and exceptions under the applicable laws, you have the following rights in respect of your personal data that we hold, depending on your jurisdiction:
- Rights to withdraw the consent. Where you have given us consent to collect, use or disclose your personal data in a certain way, you may withdraw your consent at any time unless there exist limitation on the right to withdraw the consent imposed by applicable laws or contract which confers benefits on you. The withdrawal shall not affect the collection, use, or disclosure of personal data for which you has already given consent.
- Right of access. The right to access to and to receive copy of personal information related to you or request for the disclosure of the acquisition of your personal information for which you has not given consent.
- Right to rectification. The right to obtain rectification of your personal information where that personal information is inaccurate or incomplete and proceed as appropriate in order to ensure that your personal information is correct, up-to-date, complete and not misleading.
- Right to erasure. The right to delete or destroy your personal information or cause your personal data to be unable to identify you as the data owner in certain circumstances such as your personal information is no longer necessary in relation to the purposes for which it was collected, used or disclosed.
- Right to restriction. The right to obtain the restriction of the processing and using undertaken by us on your personal information in certain circumstances such as the case where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
- Right to portability. The right to request to send or transfer your personal data to other data controller or to you when possible through automatic method and to receive your personal data that Edwards Lifesciences sends or transfers directly in automatic method to other data controller unless it is technically impossible.
- Right to object to processing. The right to object to the collection, use or disclosure of your personal data at any time.
- Right to lodge complaint. If you are of the opinion that your personal data is not being processed in accordance with the applicable data privacy laws, you also have the right to lodge a complaint to the relevant competent authorities in accordance with criteria set out under the applicable data privacy laws.
If you have concerns about your personal information
If you have any questions about this Privacy Statement or about your personal information, you may reach out to us at the contact information provided below:
Edwards Lifesciences LLC
One Edwards Way
Irvine, California 92614
Edwards Lifesciences (Thailand) Ltd.
Attn: Sr Spec, Country HR, Thailand
191 Silom Complex Building,
15th Floor, Unit C
Silom Road, Silom, Bangrak
Bangkok 10500 Thailand
Tel: +66 2494 8060
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.
This Privacy Statement is governed by the laws of Thailand. Any action, suit, or other legal proceeding, which is commenced to resolve any matter arising under or relating to this Policy, shall be subject to the exclusive jurisdiction of the courts of Thailand.
Changes to our privacy statement
From time to time, we may revise our Privacy Statement. When we do so, we will post the updated policy and change the "last revised" date below. You are encouraged to check back on this page on occasion in order to remain up to date with our practices.
Our intention is to use personal information in accordance with the Privacy Statement in place at the time the information was collected. If we intend to materially change the way in which we use or share personal information, we will inform you in advance and you will be given an opportunity to choose whether to allow us to use your information in those new or different ways.
Last revised June 01, 2022