Privacy Statement

Privacy Statement

Thank you for your interest in Miltenyi and our products and services. Your privacy is very important to us and Miltenyi takes the protection of your personal data very seriously. This Privacy Statement describes how we collect, use, share, and otherwise process personal information data when you use our products and services or when we interact with you. This Privacy Statement further informs you about your rights and choices regarding your personal information. 

As used in this Privacy Statement, “Personal Data” is data that identifies you as an individual or relates to an identifiable individual. A reference to “Miltenyi”, “we,” or “us” is a reference to Miltenyi Biotec B.V. & Co. KG and its relevant affiliates involved in the collection, use, sharing, or other processing of Personal Data.  You can find our address and our affiliates’ addresses here

This Privacy Statement applies to information collected by us, when you:

  • Use our services, devices and/or products, whether online or offline, that display a link or otherwise refer to this Privacy Statement;
  • Purchase or order services and/or products from Miltenyi, whether via email, phone, fax, web shop or other platforms;
  • Visit our websites, web shop, branded social media pages, computer or mobile applications;
  • Register, attend or participate in live or online events, webinars, contests, sweepstakes, trade shows, congresses, training courses or other activities hosted by or in connection with Miltenyi; or
  • Submit to our newsletter or respond to our marketing emails;
  • Seek help or assistance from us, e.g. by contacting our Customer Service;
  • Communicate or interact with us, including via email, telephone, texts or contact forms;
  • Visit our Miltenyi’s offices or otherwise interact with Miltenyi’s employees, staff members or representatives, e.g. business meetings.

These aforementioned forms of interactions shall collectively be referred to “Services”. This Privacy Statement applies regardless of the device or method used to access the Services (e.g., personal computer, mobile device, consumer electronics device, or any other technology or software known today or developed in the future). Some Services offered by or an Miltenyi affiliate may be governed by a separate privacy statement, and which will be provided to you at time of data collection. In those instances, the privacy statement of the relevant Miltenyi affiliate applies.

This Privacy Statement does not apply to any data processing when you:

  • participate as patient in any clinical trials or studies;
  • engage with Miltenyi in pharmaceutical matters;
  • engage with Miltenyi in employment related matters, e.g. as employee or job applicant for a position at Miltenyi

These activities will be governed by separate privacy statements which you will be provided to you before such data processing activities take place. 

Our Services may contain links to other websites, applications, and services maintained by third parties. Such third-party websites, application and services are subject to third party’s privacy statements, which you should review to better understand their privacy practices. 

A. Data Controller  

Unless specified otherwise, the Miltenyi affiliate you are engaging with is the data controller for your Personal Data. A list of Miltenyi affiliates is available here.

If you like to know what Personal Data we have stored about you or if you wish to exercise one of your rights, as described in Section L please forward your request to dataprivacyRfI@miltenyi.com

BName and address of the data protection officer 

Data Privacy Officer 
Sebastian Feik
legitimis GmbH
Ball 1 
51429 Bergisch Gladbach
+492202289410
E-mail: dataprivacy-MiltenyiBiotec@legitimis.com

CWhat Personal Data do we collect/How we collect  

The Personal Data we collect from you may depend on the Services you use or the medium you interact with. 

 

Personal Information we collect from you

When you interact with us, we may ask you to submit Personal Data in order to benefit from our Services. You will be transparently informed what information is required and what information is optional, and where required, we will ask for your explicit consent. This may include, without being limited to, the information you provide when:

  • registering or signing up for accounts, newsletters, events, webinars or contests. This may include your contact information, such as your name, job title, country, company name, department, professional interests, telephone number, email address or password;
  • participating in webinars and other online events, e.g. your name, profile image (optional), text, audio and video data (optional, when using webinar platform features for chat, recording or text); 
  • communicating with us on congress, events, fair trades or when visiting us on a congress booth, e.g. by filling out lead forms or other contact forms;
  • purchasing or submitting an order to purchase our products or Services, such as billing information, your name, payment card number, payment account details, and shipping address;
  • submitting information in Customer Service requests, contacts forms, or otherwise seek help from us, e.g. your contact details, device information, data files, communication transcripts, and records or screenshots of the issues your experience; 
  • in your responses to survey, emails, promotions and other feedback forms regarding our Services;
  • during personal or virtual business meetings, email and telephone calls with Miltenyi’s employees;
  • when visiting our offices, such as your name, email address, phone number, company name and time and date of arrival, CCTV recordings. Additionally, due to the COVID-19 pandemic, you may be required to provide information regarding your health status, including COVID-19-related symptoms, exposure to COVID-19 positive individuals, and recent travel history.

If you intend to provide us with any Personal Data about any individuals (e.g. your colleagues), please make sure to have their consent and please provide a copy of this Privacy Statement to these individuals. 

 

Sensitive Information and Personal Data of Children

Unless we specifically request or invite it, we ask you to not send or disclose any sensitive personal information (e.g. Social Security numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, health, sex life or sexual orientation, criminal background, or trade union membership, or biometric or genetic data for the purpose of uniquely identifying an individual) on or through the Service or otherwise to us.

Further, our Services are not directed at children and we do not market or promote our Services to minors, except in very limited circumstances as part of educational programs. We do not knowingly collect Personal Data from children under the age of 16 unless (a) we have obtained consent from a parent or guardian, (b) such collection is subject to a separate agreement with us or (c) the visit by a child under the age of 16 is unsolicited or incidental. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us at dataprivacyRfI@miltenyi.com and we will take steps to delete their Personal Data from our systems.

 

Personal Data we collect from Third Parties 

We may collect information about you from third party sources who may not have a direct relationship with you, e.g. data aggregators, data broker or medical agencies. Similarly, we may also collect information from trusted publicly available information, such as PubMed, Clinical Trials.gov, university and congress websites, social media platforms. Also, third parties who you have shared your Personal Data with, such as event or congress organizer, business or cooperation partners, may share your Personal Data with Miltenyi.

We may combine this information with Personal Data provided by you, helping us to update, expand, and analyze our records, identify new customers, and create more tailored offers that may be of interest to you. 

Personal Data we collect from these sources may include, but are not limited to: 

  • professional or employment-related information, such as title, position, name of the company;
  • education and biography information, such as first specialty, second specialty, year of graduation from medical school, publications, awards, links to universities, expertise and participation in/contribution to clinical trials;
  • commercial information and other business-related activities, such as purchase histories, participation in business or grant projects, congress activities, internet activity information;
  • and/or
  • information about professional preferences and behaviors. 

You will be informed about the data processing and the source of this information when we use Personal Data collected from third parties to interact or communicate with you. 

 

Device and Usage Data

We may automatically collect certain information as you navigate around our websites and applications, use our Services, participate in webinars or otherwise interact with us. This information may include:

  • IP address
  • Information about your device, hardware, and software, such as your hardware identifiers, mobile device identifiers, platform type, settings and components, and the presence of required plugins;
  • details of incoming and outgoing dial number, country names, start and end times when using a telephone;
  • Approximate geo-location data (derived from IP or device settings);
  • Browser information, including your browser type and the language preference;
  • Referring and exit pages, including pages viewed and other interactions with web content;
  • Details about Miltenyi devices, products or Services you have obtained, and your use of them, e.g. device identifiers, device category, installed Miltenyi software and updates; and/or
  • Miltenyi device event information, including error reports, request and referral URLs, logfiles, and system activity details

We also may collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5), and application data caches.
 

D. Additional Disclosures for Residents in California and Nevada: Categories of Personal Data sold or disclosed in the past 12 months  

According to privacy laws applicable in California and Nevada you have the right to know whether your Personal Data is sold to third parties. Under these laws, your Personal Data is considered to have been sold when it is shared with a third party for monetary or other valuable consideration for a purpose that is not “business purpose”. 

As a biotechnology company, Miltenyi does not sell Personal Data.

Depending on your use of the Services, we may have disclosed and shared the following categories of Personal Data with third parties as described in Section H.

  • Identifiers;
  • Commercial information;
  • Internet activity information;
  • Financial information;  
  • Professional and employment-related information;
  • Education information;
  • Sensitive information if requested; and
  • Inferences drawn from any of the above information categories. 

E. What Cookies or Similar Technologies do we use to collect information.  

When you use our websites, applications or other Services, we may use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons, pixels, and similar tools to automatically collect information that may contain Personal Data. 

The usage of these tools will help us to understand the usage of our Services, to provide a more user-friendly experience, to keep track of your shopping cart, to measure the effectiveness of our advertisement, to ensure the best possible and secure experience on our websites and to provide you tailored information on our products and services.  

The functionalities for which we use such technologies may include the following, without being limited to:

  • Assisting you in navigation,
  • Assisting in registering for an account, for events, login, your ability to provide feedback or to communicate with us,
  • Analyzing the use of our products, services or applications,
  • Assisting with our promotional and marketing efforts (including behavioral advertising),
  • Offering content of third parties (such as social media content).

We use essential but also non-essential cookies. We do not do this to track individual users or to identify them, but to gain useful knowledge about how Services are used so that we can keep improving them for our users. These tools use the technologies described below. 

 

Cookies and similar technologies 

Cookies are small text files that are stored in your internet browser or by your internet browser on your computer system. Whenever you visit our websites, applications or non-Miltenyi websites that host a Miltenyi plug-in or tag, a cookie may be stored. This cookie contains a characteristic string which allows the identification of an internet browser on a device connected to the internet. This helps us and our third-party partners to recognize you on your next visit. 

We use both session-based and persistent cookies on our websites. Session-based cookies exist only during a single session and disappear from your device when you close your browser or turn off the device. Persistent cookies remain on your device after you close your browser or turn your device off.

We classify these cookies and similar technologies in the following categories:

  • Technically required cookies
  • Statistics cookies
  • Comfort and Marketing cookies

We further may use tracking pixels or clear GIFS to collect information about your use of our Services, devices and products. We use internet log files (which contain Personal Data, such as your IP address) to monitor traffic on our Services, troubleshoot technical problems, detect and prevent fraud and enforce contractual obligations. We currently do not respond to Do Not Track (DNT) signals. 

Unless for technically required cookies and similar technologies, you can opt out of certain types of tracking, disable cookies, limit the categories of stored cookies by changing your browser settings. Alternately, you can set your internet browser to alert you when cookies are being sent. For more information, please review the setting description of your individual internet browser. In addition, in certain region, we offer cookie consent tools to help you to manage your cookies which you can find at the bottom of our websites. 

We also use internal or third-party analytics, or marketing technologies in our Services. These technologies may use the same cookies or similar mechanism, as described here. 

You can find a list of the cookies and similar technologies used by our Services, along with a list of relevant third-party companies, in our Cookie Statement.

 

Technically required cookies. Technically required cookies are necessary for basic website functionality. Some examples include session cookies needed to transmit the website, authentication cookies, and security cookies.

 

Statistics cookies. We further use internal and third-party analytics technologies that collect information about your use of our websites, products, devices and other Services.

Such technologies allow us to:

  • track and analyze aggregated data about usage of our Services, e.g. click-rate, viewing time;
  • monitor website traffic, e.g. which pages are viewed most often;
  • track and evaluate the performance of marketing campaigns;
  • share randomized identifiers with third party partners;
  • conduct A/B testing on our Services.

This information helps us to analyze the usage of our websites and Services, to provide a better user experience and enhanced interactions and more relevant communication. This information will be collected in aggregated form, which does not allow retracing of your personal usage of our Services. 

For example, we use Google Analytics (“Google Analytics”), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. You can learn about Google’s privacy practices by going to www.google.com/policies/privacy/‌partners/.

Google Analytics uses cookies to help us analyze how our websites are used, including the number of visitors, the websites from which visitors have navigated to our websites, and the pages on our websites to which visitors navigate. This information is used by us to improve our websites.  We use Google Analytics with restrictions on how Google can process our data enabled.  For information on Google’s Restricted Data Processing go to https://privacy.google.com/businesses/rdp/.

Such third-party analytics technologies integrated in our Services may combine the information they collect in connection with your use of our Services with information they have independently collected from different sources. A list of integrated third-party analytics technologies can be found in our Cookie Statement.

 

Comfort and Marketing cookies. We also use cookies to personalize our Services, store your preferences and settings when using our Services, and to enhance your user experiences by providing you more comfort. For instance, we use such cookies to save your preferences, e.g. your preferred language, or store the information you have submitted, e.g. items you have added to the shopping cart within the Miltenyi’s web shop or information that can be pre-populated in contact forms. This prevents you to repeatedly set the preference or submit the same information. 

Further, some cookies and similar technologies are set media services or special tools that we have added to Miltenyi websites to enable the display of media content and special tools, such as embedded videos, maps and Fluorofinder. Some of these cookies are necessary for the proper display of such content. Some media services or special tools may also place cookies or similar technologies for marketing purposes. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or see such services or tools.

Marketing cookies track activity across websites in order to understand a viewer’s interests, and to direct marketing to them. We sometimes use cookies delivered by us or by third parties to show you offers and advertisement for our Services that we think may interest you on devices you use and to track the performance of our advertisements. These offers and advertisement may be delivered to you on Miltenyi websites and application as well as on non-Miltenyi websites and third-party platforms with a Miltenyi plug-in or tag. For example, we use the conversion-tracking technology and retargeting functionality of “LinkedIn” on our website. This technology enables the display of personalized advertisements on LinkedIn after users have visited our website.

Such cookies and similar technologies do not store directly Personal Data but are based on uniquely identifiers of your browser or device.

Information collected through marketing technologies may include: 

  • Advertisement served and the located of the ad
  • Duration and Time of the visible ad
  • IP address
  • Your interaction with the ad, e.g. click-rate, response time

F. Purposes we use your Personal Data for  

We may use your Personal Information for the following business purposes: 

To comply with applicable laws and to operate our business, including to: 

  • Operate, improve and develop our products and other Services
  • Measure and analyze the performances of our Services
  • Assess and improve user experiences
  • Ensure compliance with our legal monitoring and reporting obligations, including those related to adverse events, product complaints and product safety.
  • Verify your eligibility to use certain products and other Services
  • Conduct training and quality assurance
  • Detect, prevent or investigate misconduct and resolve disputes
  • Comply with anti-corruption and transparency obligations.
  • Analyze or predict preferences of professionals to identify aggregate trends to develop, improve or modify our products, services and business activities
  • Manage the security of our offices, facilities, networks, systems and Services
  • Perform audits, transactions and other compliance activities

To engage in contractual relationship or business transactions, including to:

  • Provide our Services to you and fulfill our contractual or statutory obligations to you
  • Enforce contractual terms and conditions governing our relationship with you
  • Administer relevant transactions, such as purchase orders, contract negotiations, cost estimates
  • Manage payments
  • Manage and conduct events (e.g. webinars, trainings, congresses), including managing registration and attendance
  • Manage registration of office visitors and arrangement of business meetings

To communicate with you and to provide you support, including to:

  • Handle contacts and customer support requests
  • Help to identify and solve problems and issues you experience with our Services
  • Respond to your queries and requests
  • Manage and send confirmations and important information about your account, Services, transactions or purchases

To market and promote our product and other Services, including to:

  • Send marketing communications
  • Manage contests, promotions and marketing campaigns#
  • Identify customer opportunities
  • Display personalized advertisement and content
  • Manage subscriptions and newsletters

Miltenyi does not use algorithms or profiling to make any decision that would significantly affect you without the opportunity for human review.

G. On which legal basis do we rely  

Miltenyi processes your personal data only when we have a valid legal basis to do. Our legal basis for processing your Personal Data varies depending on the type of information we process and the context as well as on your country of residence. Such legal basis may include one the following: 

Consent. Where required by law, we will expressly obtain your consent to use and process your Personal Data for these purposes. You can withdraw your consent at any time, as described in Section L.

Performance of a contract with you. When you have entered a contractual relationship with us or when you take steps to initiate such a contractual relation, we may use your Personal Data to fulfill and perform our contractual obligations. For example, if you have purchased a product from Miltenyi, we need to use your contact details and billing data to process your order, deliver your product and send you the invoice.

Compliance with law: In some cases, we may have a legal obligation to use or process your Personal Data.

Our legitimate interests: We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations.
 

H. When do we share information with Third Parties  

We may share your Personal Data to third parties as follows:

Affiliates. As a global organization, we may share your Personal Data with affiliated companies if this is required to serve the applicable purpose as described in this Privacy Statement. You can find our address and our affiliates’ addresses here.

Service Providers. We employ and contract specialized third parties to provide services, such as IT and system administration and hosting, credit card processing, research and analytics, marketing, logistics, customer support, data enrichment and professional consulting, for the purposes and pursuant to the legal bases described above. We contractually require these third-party service providers to process any Personal Data for purposes consistent with this Privacy Statement and according to applicable data protection laws.

Webinar and other Online Platform Providers. If you participate in our webinars or other online events, we may share Personal data with contracted third parties operating the webinar and online event platforms (“Third-Party Providers”), such as Microsoft Teams, Zoom, Cisco Webex and Remo, in order to provide a webinar or online event to you. Like other Service Providers, we contractually require these Third-Party Providers to process any Personal Data for purposes consistent with this Privacy Statement and in accordance with data protection laws. In addition, you can control the scope of the shared data by deciding your use of the platform features when taking part in an online event. For instance, you may have the option of using the chat, question or survey functions of such online platform, in which case, the text inputted by you will be processed to be displayed in the online event. To enable the display of video and the reproduction of audio, the data from the microphone of your end device and from any video camera used will be processed while the meeting lasts. You can switch off the camera or microphone or turn off the sound using the online platform app at any time. Further, when we want to record online events, we will inform you in advance in a transparent manner and – if necessary – ask for your consent. The information that the meeting is being recorded will be also displayed in the respective app of the online platform.

Please note: If you visit the website of Third-Party Providers, such Third-Party Provider is responsible for data processing in accordance with the privacy policy of the respective Third-Party Provider published on their website. In general, you only have to visit the website to download the software required to use the online platform. Also, you may use the online platform if you directly type in the meeting ID and any other login details required for a meeting in the respective app of the online platform. If you do not wish to use the respective app of the online platform or are unable to use it, the basic functions will still be available on a web browser version which you may also find on the website of the respective Third-Party Provider. 

Business Partners. We may provide Personal Data to business partners with whom we offer joint Services or otherwise cooperate, such as event and contest sponsors, congress and conference organizers, collaboration partners, distributors and resellers. 

Merger, sale or other asset transfer. In the event of a merger, re-organization, dissolution, or other fundamental corporate change, sale or bankruptcy we may be required to transfer all information to the relevant acquiring third party. In accordance with applicable data protection laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.

Third party plug-ins. When you decide to interact with third party technologies, such as social media features, integrated in our Services, these third parties may collect information about the use of our Services. 

Legal Protection. We may share your Personal Data where we, in good faith, believe disclosure is required and appropriate. For example, this may the case where disclosure is required to protect the safety, the rights and property of Miltenyi and/or others, where we are required to comply with regulatory requirements, court orders or other form of governmental requests or to cooperate with public and government authorities.

With Your Consent. We may also share your Personal Data with third parties if you have expressly consented. In such case, you will be informed about the purpose and the recipient before you will be asked to give your consent. You may withdraw your consent at any time, including at a later stage. 

Anonymous Data. We may also share anonymous or de-identified usage data with third parties in the normal course of operating our business or for analytic purposes to improve our Services. Anonymous data cannot be traced back to your person. 

I. How do we protect your information

WMiltenyi implemented appropriate technical, physical and organizational measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data, including encryption of sensitive information.

Please note, however, that no security measure, no method of storage or transmission is 100% secure and hence, it cannot be guaranteed that your Personal Information is fully protected at all times. Your discretion is advised when you share Personal Data.

J. How long do we store your Information  

We will retain your Personal Data for as long as needed or permitted considering the purposes the Personal Data was collected for and as outlined in this Privacy Statement. The necessity to retain Personal Data and hence the respective retention period may can vary, depending on the different data category and the context of our interactions with you. 

The criteria we use to determine the appropriate retention periods may include, without being limited to, the following criteria: 

  • the length, intensity and the context of your contractual relationship, engagement or interaction with Miltenyi
  • the data category, e.g. shorter retention period for sensitive data;
  • any legal, contractual or similar obligation of Miltenyi to delete or to retain the data;
  • the necessity of data retention to achieve the agreed purpose;
  • your consent in certain data retention period. 

After expiry of the applicable retention periods, your Personal Data will be deleted, blocked or anonymized. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.

K. International Transfer of Personal Data 

Your Personal Data may be collected, processed and transferred in any country where (i) our affiliates are based or operate, or (ii) we engage services providers and business partners. This may include countries within but also outside of the EU, such as US and China 

Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. A list of these countries can be found here

For transfers from EEA to non-EEA countries that have not been recognized by the European Commission to have an adequate level of data protection, we have implemented appropriate safeguards to ensure, to the extent possible, that the recipient of your Personal Data offers an adequate level of protection and security, e.g. by ensuring that the recipient is bound by EU Standard Contractual Clauses, or an EU-approved code of conduct or certification, to protect your Personal Data. 

Otherwise, we will only share, transfer or store your Personal Data from EEA to such a non-EEA-country only with your prior consent. By consenting, you acknowledge that your Personal Data will be transferred to a recipient in a country that may not offer the same level of privacy protection as the laws in your country of residence. 

L. Your Choices and Control 

We give you meaningful choices to control your Personal Data collected and processed by us. The following rights are available to you based on applicable data protection laws. 

You have the right to:

  • Access your Personal Data we have stored about you;
  • Correct or complete your Personal Data;
  • Have your Personal Data deleted if there is no other legal ground for the processing;
  • Restrict the processing of your personal data;
  • Object to any data processing conducted by us when the data processing serves our legitimate interest, public interests, including profiling, unless we can demonstrate that our legitimate interests prevail or the data processing was necessary to assert, exercise or defend a legal claim. Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason;
  • Transfer your Personal Data to another data controller, if possible 
  • Complain to a supervisory authority;
  • Withdraw your consent at any time if and where the data processing is based on your consent. Please note that the withdrawal does not affect the compliance of any data processing that happen before your withdrawal;

Miltenyi respects your privacy and takes your wish to understand and control any processing of your Personal Data seriously. Hence, you have the right to and will not be treated in a discriminatory way nor will you receive a lesser degree of Service from Miltenyi when you exercise any of your rights above. 

To exercise any of the rights listed above, please send us an email to dataprivacyRfI@miltenyi.com or contact us through our Customer Support. We may need to verify your identity and place of residence before completing your rights request.  

Also, if you have registered for a Miltenyi Service, such an event or account, you may control the processing of your Personal Data by updating your account or registration settings logging into your accounts.

If you would like to opt out from receiving marketing communication, you may manage your receipt of marketing and non-transactional communications from Miltenyi by clicking on the “unsubscribe” link at the bottom of Miltenyi marketing emails. Please note, that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, product information or security information.

M. Changes to Privacy Statement 

We will update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “effective date” at the top. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you directly, or where required under applicable law and feasible, seek your consent to these changes.

We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing and sharing of your Personal Data.