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BlueWind Medical is committed to maintaining the highest standards of Compliance and Ethics in our interactions with Healthcare Professionals, our patients, employees, consultants, and the communities in which we live and do business. Our Program’s foundation is built on honesty, trust, integrity, respect, communication, strong cross-functional partnerships, individual and shared responsibility, transparency, and accountability. We do the right thing. We help one another do the right thing.
BlueWind Medical is a member of AdvaMed and the Medical Device Manufacturing Association (MDMA). Our employees, contracted Healthcare Professionals, and other consultants and vendors are expected to know and follow laws and regulations applicable to the medical device industry, as well as our internal policies and procedures.
The Global Compliance Program is structured to meet the Seven Elements of an Effective Compliance Program as articulated by the Office of Inspector General, Department of Health and Human Services, and the Program is in alignment with updated Department of Justice (DOJ) Guidance on Effective Compliance Programs.
Should you have any questions or need additional information about the Global Compliance Program, or wish to report an issue, you may reach us through the Helpline. It is safe, secure and confidential-you may ask a question or report an issue anonymously. The Helpline is available 24 hours per day, 7 days a week, 365 days a year. There are two ways to contact the Helpline:
Phone: +1-844-946-0424 (Toll Free in the US)
Data protection on the BlueWind website
Welcome to the BlueWind Website. We appreciate your interest in our company.
Protection of the personal data you entrust to us is a priority for us, and we want you to
feel safe and secure when you visit our website or use our online offers.
It is important to us that you are fully informed about the personal data that we collect
when you use our online offers and services, and are familiar with how we use them.
Wherever BlueWind processes personal data, such processing is carried out for the
purposes defined in this data privacy statement.
Processing of personal data
Visiting our website
We record and save your computer’s IP address in order to send the contents of our
website visited by you to your computer (e.g. texts, pictures, and files provided for
downloading, etc.) (cf. Art. 6 (1) lit. b GDPR). We also process these data to identify and
pursue any misuse. Legal basis in this case is Art. 6 (1) lit. f GDPR. In this context, our
legitimate interest in data processing is to ensure the due functioning of our website and
the business transacted via the Website.
We also process personal data that you provide voluntarily, e.g. when you make an
inquiry or online appointment, or when you order information material or newsletters.
Legal basis in this case is Art. 6 (1) lit. b GDPR. The data processed by us in this context
include the data of customers, distributors, suppliers to the extent necessary for the
purposes specified within the scope of this data privacy statement.
In as far as we process your data as described above for the purpose of accepting and
processing your inquiry, appointment, or (newsletter) order, you are contractually
bound to make these data available to us. We are unable to process your request
without the data.
Where you have given your consent to the processing of personal data (cf. Art. 6 (1) lit. a
GDPR), you can withdraw your consent at any time. Withdrawal of consent will not
affect the lawfulness of processing based on consent up to the time of withdrawal of
Transfer to third parties
We may transfer your data to the relevant supplier or distributor where it is processed to
deliver the service and support you requested.
This means that information may also be processed by other entities. However, such
processing is limited to the extent required for the purposes defined in this data privacy
statement or to which the other legal entity acting as a service provider / processor has to
follow the instructions given by the controller.
These service providers / processors are bound by instructions. Given this, they are
subject to our requirements, which include processing of your data exclusively in line
with our instructions and in compliance with the applicable Data Protection Act. In
particular, they are contractually bound to treat your data with strict confidentiality, and
are not permitted to process data for other purposes than the ones agreed.
Data transfer to the data processor is effected on the basis of Art. 28 (1) GDPR.
We will not sell your data to third parties or otherwise share them for commercial purposes.
Beyond the above, we will transfer your personal data to prosecution authorities and, if
applicable, damaged third parties without your explicit consent where this is necessary
for clarifying illegal use of our services or for legal prosecution. However, such a transfer
will only take place if there is concrete evidence of illegal conduct or misuse. Transfer of
your data may also take place where this contributes to enforcing the conditions of use
or other agreements. We are also under legal obligation to provide information to certain
public bodies on request. These comprise prosecution authorities, authorities
prosecuting offences punishable by a fine, and financial authorities.
The transfer of these data is based on our legitimate interest in fighting misuse,
prosecuting criminal acts, and securing, asserting, and enforcing claims unless
our interests are overridden by your rights and interests in the protection of your
personal data, Art. 6 (1) lit. f GDPR.
Intended data transfer to third countries
At present, data transfer to third countries is not planned. Otherwise we will establish the
required legal conditions. In particular, you will be informed of the respective
recipients or categories of recipients of the personal data in line with the legal
BlueWind takes appropriate technical and organizational measures to protect any
personal data you provide to BlueWind from accidental or intentional manipulation,
loss, destruction, or access by unauthorized parties. This also applies to any external
services purchased. We verify the effectiveness of our data protection measures and
continuously improve them in line with technological development.
For a user-friendly website experience and to tailor the operations of our website to your
locally on your computer when you visit a website. When you revisit the website on the
same device, the cookie will indicate, for example, that you are a repeat visitor. Cookies
also allow us to analyze the use of our website. They do not include any personal data
and cannot identify you on third-party websites––including those of analytics providers.
We use the following types of cookies:
Standard periods for deletion of data:
Legislation has defined numerous data storage periods and obligations. At the end of
these periods, the relevant data will be routinely deleted. Data that are not affected by
the above storage periods and obligations are deleted or anonymized as soon as the
purposes defined in this data privacy statement no longer apply. Unless this data
privacy statement includes other deviating provisions for data storage, we will store
any data we collect for as long as they are required for the above purposes for which
they were collected.
Other data use and deletion of data
Any further processing or use of your personal data will generally only be carried out to
the extent permitted on the basis of a legal regulation or where you have consented to
data processing or data use. In the case of further processing for other purposes than
the ones for which the data were originally collected, we will inform you about these
other services and provide you with all other significant information before further
Rights concerning the processing of personal data.
Right of access
On request, you have the right to obtain information from us about the personal data
concerning you and processed by us, to the extent defined in Art. 15 GDPR. You can
send your request either by mail or email to the addresses given below.
Right to rectification
You have the right to require us to rectify any inaccurate personal data concerning
you without undue delay (Art. 16 GDPR). For this purpose, please contact the
address given below.
Right to deletion
Where the legal reasons defined in Art. 17 GDPR apply, you have the right to immediate
deletion (“right to be forgotten”) of personal data concerning you. These legal reasons
include: the personal data are no longer necessary for the purposes for which they were
processed, or you withdraw your consent, and there are no other legal grounds for
processing; the data subject objects to the processing (and there are no overriding
legitimate grounds for processing––does not apply to objections to direct advertising).
To assert your above right, please contact the contact address given below.
Right to restriction of processing
If the criteria defined in Art. 18 GDPR are fulfilled, you have the right to restriction of
processing as established in the above article of the GDPR. According to this article,
restriction of processing may be called for in particular if processing is unlawful and the
data subject opposes deletion of the personal data and requests the restriction of their
use instead, or if the data subject has objected to processing according to Art. 21 (1)
GDPR as long as it is unclear whether our legitimate interest overrides the interest of the
data subject. To assert your above right, please contact the contact address given
Right to data portability
You have the right to data portability as defined in Art. 20 GDPR. This means you
have the right to receive the personal data concerning you, which you have provided to
us, in a structured, commonly used, and machine-readable format, and have the
right to transmit those data to another controller, such as another service provider.
Prerequisite is that processing is based on consent or a contract, and is carried out
using automated means. To assert your above right, please contact the contact
address given below.
Right to object
You have the right to object at any time under Art. 21 GDPR to processing of personal
data concerning you which is based on Art 6 (1) lit. e or f GDPR, on grounds relating to
your particular situation. We will desist from processing your personal data unless we
can demonstrate compelling legitimate grounds for processing which override your
interests, rights, and freedoms, or unless processing is for the establishment, exercise,
or defense of legal claims. To assert your above right, please contact the contact
address given below.
Right to file a complaint with a supervisory authority
If you think that processing of personal data concerning you and carried out by us is
unlawful or impermissible, please contact us.
Please address any questions regarding the processing of your personal data,
requests for information, applications, or complaints directly to our data protection
officer, who will be happy to be of service
If you wish to make use of your right to information on the personal data we process on your behalf, you may contact us in the following contact details
PO Box 4101
4614002 Herzeliya, IL
For the purposes of the European data protection legislation (the GDPR and any successor or equivalent legislation in the UK) our EU and UK representatives are:
EU representative: DataRep, Place de L’Université 16, Louvain-La-Neuve, Waals Brabant, 1348, Belgium
UK representative: DataRep, BPM 335368, 372 Old Street, EC1V 9AU, London, United Kingdom
If you would like to raise a question or request to BlueWind’s representatives, you may do so by:
• Using the online webform at www.datarep.com/data-request, or
• Mailing your inquiry at the address listed above (when mailing, pleas address your inquiry or request to DataRap and clearly refer to BlueWind in your correspondence)
Amendment of this data privacy statement