About Boston Scientific Cardiac Diagnostics
Boston Scientific Cardiac Diagnostics, Inc, is a United States-based corporation focused on
mobile health solutions and remote monitoring services that connect healthcare providers and
patients threatened by cardiac arrhythmias.
Our tech-enabled, service-based approach utilizes our cloud-based infrastructure, data analytics
and machine learning capabilities to facilitate the clinical decision-making of treating
providers. We listen closely to the needs of our customers to create revolutionary remote care
technologies and services that connect patients and providers in a way that redefines healthcare
– and works without interruption to daily life.
Boston Scientific Cardiac Diagnostics Services, LLC, and Boston Scientific Cardiac Diagnostics
Technologies, Inc. (collectively, “BSC CDx”) are the primary data controllers of
your personal data.
Please note this privacy notice is not addressed to patients.
About This Privacy Notice
At BSC CDx, your privacy is important to us. This Privacy Notice is intended to provide
information about how we process the personal data of individuals in the European Economic Area
(EEA), United Kingdom and Switzerland. We collect and process personal data in different
contexts, and we do so in compliance with applicable data protection laws, including the General
Data Protection Regulation (EU) 2016/679 also known as the “GDPR”, the Data
Protection Act 2018 (the “UKDPA”), and applicable local data protection laws.
This privacy notice applies to information collected by BSC CDx, as data controller, through our
website, our monitors and portals, or in the course of our business activities; including all
personal data in any format or medium, relating to all healthcare providers, vendors and others
who do business with BSC CDx.
Additional privacy notices may apply depending on the purposes of personal data processing. These
dedicated notices shall be available at the time of collection of personal data for that
specific purpose.
Information Collection and Use
Personal data is data that can be used to identify you, directly or indirectly. The main
categories of personal data BSC CDx may collect about you are described below along with the
main purposes for which they are processed and legal grounds for the processing:
- Business contact information. We collect business contact information
(such as names, email address, telephone number etc.) from current and potential customers,
and from marketing activities and events, in order to provide information regarding our
products and services, facilitate the provision of those products and services (for example,
when you create an account within our portal to utilize and access our services), deliver
monitoring services and supplies, and ensure quality, security and compliance. We also
collect such information from current and potential business partners and vendors to assess
and facilitate those business relationships set up and management. We will also collect your
contact details if you request information or submit questions to us via this website,
including other personal data that you decide to share with us.
- Job applicant and human resources related information. We may collect
certain employment-related data if you apply for and/or accept employment with BSC CDx .This
includes username and password, full name, email address, telephone number, mailing address,
driver’s license number, social security number or other unique personal identifier,
emergency contact information, educational and work experience information, certification
and licensure information, resume, language(s), job and salary preferences and expectations,
professional references, employment benefit and beneficiary information, financial
information, work performance, and training information. This information will mainly be
processed for evaluating and considering you for the position(s) which you have applied;
this may include communicating with you for job interviews and to update you on your status
and respond to your inquiries.
- Cardiac and health related information. We generally process, as data
processor, patient and study subject information related to arrhythmia monitoring, cardiac
event, digital holter, pacemaker monitoring and ambulatory blood pressure monitoring (such
as, patient electrocardiogram data, date of birth and/or age, relevant symptoms and
diagnoses). This information may also include contact information for the patient or study
subject, emergency contact information, mailing address, information about health insurance
and/or other information necessary for BSC CDx to provide the technology and/or monitoring
services. This information is owned by the physicians, healthcare practices, hospitals or
clinical research, which act as data controllers. BSC CDx will process these data as data
processor following the instructions of the healthcare providers. Please note the sections
of this website addressed to patients are only addressed to US patients. In the event that
BSC CDx acts as data controller of patient data, it will ensure that a dedicated privacy
notice is provided to patients.
- Cookies. BSC CDx only uses strictly necessary cookies for operating
this website and making it available to you. We do not perform any analytics or tracking
about your online behavior when you visit or navigate this website.
Legal Basis for Data Collection and Use
We may collect and process your personal data on the following legal grounds, depending on the
processing operation at hand:
- We have collected your prior consent;
- We have performed a contract with you or taken steps prior to entering into a contract with
you;
- We need to collect and process your personal data to comply with our legal obligations, for
example for vigilance obligations, transparency-related obligations, etc.;
- We rely on our legitimate interests, and we have balanced your interests or fundamental
rights and freedom in determining whether the processing is legitimate and lawful. For
example, to conduct our day-to-day business operations, to facilitate coordination and
communication with healthcare providers to process payments, etc.
Data Sharing and Transfers
BSC CDx may only share your personal data on a need-to-know basis to the recipients listed below,
in the context of the purposes described above and in compliance with applicable law. Such
access will be limited to the amount of information necessary to carry out the appropriate
purpose:
- Group of companies. BSC headquarters in the U.S., our affiliates and
subsidiaries for purposes consistent with this Notice. Please see a list of BSC
entities here;
- Service providers that perform various activities on behalf and
following the instructions of BSC CDx, such as those that provide services related to report
processing, billing, quality, security, compliance, legal, product development, information
technology and other such services. The agreement concluded between BSC CDx and these
service providers contain the appropriate safeguards, including but not limited to the
obligation to implement technical and organizational measures.
- Data Controllers: We may share patients’ personal data with
data controllers such as an ordering or treating healthcare provider, a study sponsor or
investigator, or other appropriate individuals at a hospital, clinic or other such facility
participating in your study, diagnosis or care, and insurance companies and other payers if
required to and only following their instructions.
- Government agencies, law enforcement personnel, authorities and other regulatory
bodies. We may only disclose your personal data to public authorities, if
permitted by law to meet national security requirements, or as part of a legal process, in
order to protect our property or legal rights to report adverse events, product
defects, problems or biologic product deviations, to track products in order to enable
product recalls, to make repairs or replacements, to conduct post-marketing surveillance, or
other such purposes as may be required by applicable law, regulation or guideline.
- Potential acquirers and other stakeholders in the event of a corporate
sale, merger, reorganization, dissolution or similar event of BSC CDx;
- Emergency Situations. In certain circumstances, where the health or
security of an individual may be endangered, we may share your personal data with an
emergency contact, healthcare worker, emergency responder or other such individual.
Some of our affiliates, subsidiaries and third parties to whom we transfer personal data are
located outside the European Economic Area (EEA), Switzerland or the United Kingdom. To ensure
your personal data will still be processed in compliance with our standard of data protection
and applicable law, BSC CDx has implemented EU Standard Contractual Clauses as adopted by the
European Commission between its entities as well as with third parties and has taken additional
safeguards such as encryption of the data in transfer. You can ask for more information on the
safeguards implemented by BSC as described in the Contact Section.
Your Rights
Where applicable, you have the following rights:
- Right of access: you have the right to obtain confirmation as to
whether or not your personal data is processed, and, if so, to request access to the
personal data held on you;
- Right to rectification: you have the right to have inaccurate personal
data about you rectified or completed if it is incomplete;
- Right to erasure: You have the right to have your personal data
delated.
- Right to restriction of processing: you have the right to request from
us that we limit the way we use your personal data.
- Right to withdraw consent: you have the right to withdraw your consent
at any time with future effect. Such a withdrawal will not affect the lawfulness of
the processing prior to withdrawal of the consent nor of continued processing activities
that are not based on consent.
- Right to object: you have the right to object, on grounds relating to
your particular situation, at any time, to the processing of your personal data; and we may
have to stop processing the data unless it demonstrates compelling legitimate grounds for
the processing which override your interests, rights and freedoms or for the establishment,
exercise or defence of legal claims; you also have the right to object to the processing for
direct marketing purposes. Each individual marketing email that we send out gives recipients
the chance to easily opt out of future marketing. The right to object for other processing
activities will be balanced to ensure that it is not incompatible with local regulations or
our legitimate interests.
If you have provided us with your consent, you can withdraw it at any time.
In some countries, you may have the rights to provide guidelines about the processing of your
personal data after your passing away.
You also have the right to lodge a complaint with a competent data protection authority where you
believe where you believe that your rights have been violated. List of EU data protection
authorities is available here.
You can exercise any of the above rights by contacting us using any of the methods in the Contact
Information section below.
BSC CDx will attend to your request in a timely manner within thirty (30) days after receiving
your request and appropriate identity-verifying information. If for any reason we need to extend
this time period, we will contact you.
Children’s Data Protection
BSC CDx does not knowingly solicit or collect personal information from or about children through
its services or technologies except as permitted under applicable law. Where consent may be
required for purposes of a cardiac study or clinical research, parents or legal guardians must
provide consent on behalf of any minors (with the age of minority as determined by the relevant
jurisdiction). This website is not intended for use by minors without the explicit consent of a
parent or legal guardian. If your child has submitted personal information and you would like to
request that such information be deleted from our records, you may do so by contacting us via
the contact options below.
Security
BSC CDx takes security seriously. We use reasonable and appropriate data protection measures,
such as robust technologies, security policies and procedures, to reduce the risk of misuse,
alteration, accidental destruction or loss, and unauthorized disclosure or access to our systems
and data. We follow industry standards and best practices to protect your personal data during
transmission and once we receive it.
Retention Periods
BSC CDx applies the storage limitation principle to retain personal data in our records only for
the length of time required to fulfill the purpose for which the data was collected. We will
only retain your personal data for as long as it is necessary to achieve the purposes listed
above, or alternatively, until you object to the processing of your data or withdraw the consent
which you have previously provided. However, where BSC CDx is required by law, regulation or
contractual obligation to retain your personal data longer, or where your personal data is
required for BSC CDx to assert or defend against legal claims, we will retain your personal data
until the end of the relevant retention period or until the claims in question have been
settled.
Changes to This Privacy Policy
We may modify this policy, and all modifications will be effective immediately upon our posting
of the modifications on this website. The time stamp you see on the policy will indicate the
last date it was revised. Changes to this notice will be available by accessing our website
www.cdx.bostonscientific.com (the “Website”) or by contacting us and requesting
that a revised copy be mailed to you. If BSC CDx makes a material change to this policy, we will
notify you prior to the changes, where required, via your account email address or by a Website
notice.
Other Websites
Our website contains links to other websites. This privacy policy only applies to this website,
so when you link to other websites, we recommend you to read their own privacy policies.
Contact Information
If you want to exercise your rights under the GDPR, please use the contact details below. You can
also direct any data protection-related issues, questions, comments or complaints to BSC CDx by
using the contact details below:
Email: EuropePrivacy@bsci.com or through our Data
Subject Request Form
Postal Mail:
Boston Scientific - DPO
c/Ribera del Loira, 46 Edificio 2
28042 Madrid (Spain)
Please note, when you contact us, you may be required to appropriately verify your identity.
Last Updated June 2023
BODYGUARDIAN: Indications, Safety and Warnings
