This Privacy Notice (the “Notice”) sets out how OSI Systems, Inc. and our subsidiaries (including American Science and Engineering, Inc., AS&E Global, Inc., Locker LLC, OSI Electronics, Inc., OSI Laser Diode, Inc., OSI Laserscan, Inc., OSI Optoelectronics, Inc., OSI Solutions, Inc., Rapiscan Government Services, Inc., Rapiscan Holdings, Inc., Rapiscan Laboratories, Inc., Rapiscan Systems, Inc., Rapiscan Systems Ltd, S2 Global Inc., Spacelabs Healthcare Inc., Spacelabs Healthcare Ltd., Spacelabs Holding, Inc.) (each an “OSI group entity”) collects and processes information about you when you visit any website operated by that entity (“Website”) or when you otherwise provide your personal information to that entity, as described in this Notice.
References in this Notice to “we”, “us” or “our” are references to the OSI group entity that is operating the relevant Website that you visit or to which you otherwise provide personal information as described in this Notice.
If you have any questions or concerns about our use of your personal information then please contact us using the contact details provided at the bottom of this Notice.
1. Information collected
The personal information that we may collect about you broadly falls into the following categories:
Information that you provide voluntarily
Certain parts of our Websites may ask you to provide personal information voluntarily. Further examples of this are set out below; however as a general point, the personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
- General: You may give us information, including information that can identify you (“personal information”), when you make enquiries about a Website, our products or services or about career opportunities with us or when you otherwise communicate with us (whether via a Website or otherwise). For example, we may ask you to provide specific information set out in an online inquiry form. You may choose to provide additional information to us when you communicate with us or otherwise interact with us, including in any free text box contained in an online inquiry form.
- Joining our talent network: In order to stay up-to-date with the latest jobs and career-related information, you will need to register with the talent network operated by OSI Systems, Inc via a Website. In order to do so, we collect information necessary for us to contact you by various means and to assess whether you are likely to be interested in a particular role. When you refer someone who you think you would like to join our team, we ask for your name, email address and phone number. We also ask for your friend’s name, phone number and email address.
- Personal Information that we collect when you do business with us:
We may process your personal information when you conduct business with us (whether through the Website or otherwise) as, or on behalf of, a customer or prospective customer, or as, or on behalf of, a vendor, supplier, consultant, professional adviser or other third party. In this context, we process:
- business contact information that is necessary to understand your role within your organization and to communicate with you;
- financial information that is necessary to take payment or fulfil contractual obligations or for related purposes;
- personal opinions/insights included in any feedback necessary to evaluate our performance and that of our suppliers or other business partners; and
- personal information necessary to conduct business effectively with you or the organization that you represent.
- Access to online resources: For access to certain resources on a Website (e.g. eLearning modules and Product Manuals) we may ask you to register as a customer/customer representative in order to create an online account. If so, as well as the business contact information referred to above, we will ask you to create a username and password.
- Providing feedback: Customers may also have the option of providing online feedback via a Website (e.g. in relation to OSI group company products, services or distributors) and we may request certain personal information via any online feedback form, such as name and contact details of the relevant customer representative. Customer representatives may choose to provide additional information in the context of such feedback, e.g. via free text boxes.
- Supplier change requests: Suppliers may make a change request via a Website. In such circumstances, we may request via the relevant online form personal information that is necessary to process such change request.
- Personal Information that you provide about another person: If you provide us with information about another person, for example, if you refer someone to us via the Website who you think would be interested in joining our team, you confirm that you have informed them of our identity and the purposes (as set out in this Notice) for which their personal information will be processed and that you have obtained any necessary consents to the processing of their personal data. When we first contact them, we may tell them where we got the information from.
Information we collect automatically
When you visit our Websites, we may also collect certain information by automated means from your device. In some countries, including countries in the European Economic Area (EEA), this information may be considered personal information under applicable data protection laws.
Specifically, the type of information we collect automatically may include information such as your IP address, device type, unique device identification numbers, browser type, broad geographic location (e.g. country or city-level location) and operating system, referring URLs, information about your visit including the URL clickstream to, through and from our Websites, download errors, number of Website visits, average time spent on the Website, length of visits to certain pages and page interaction. We collect this information automatically through the use of various technologies including through “cookies”.
A cookie is a data file containing small amounts of information that a website can send to your browser (and many websites do), which may then be stored on your computer as a tag that distinguishes your computer but does not name you. For further information about the types of cookies we use, why and how you can control cookies, please see our Cookies Notice at https://www.osi-systems.com/cookies.
Information that we obtain from third party sources
From time to time, we may receive personal information about you from third party sources, including our group companies, business partners and other third party sources and add it to the information we already hold about you. We will only do so where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. The types of information we collect from third parties include:
- updated business address information;
- purchase history;
- demographic information;
- credit information from credit reference agencies about customers or business partners;
- information obtained from employment and recruitment agencies to whom you provide your information in connection with a career opportunity with us.
Personal Information for which we act as a data processor: We may process personal information on behalf of our customers in the context of supporting our products. We do so in accordance with the instructions of our customers. While our customers are in control of what personal information is processed by our products it will typically include personal information about individuals who are involved with the sale or support of our products. For further information about how such information is handled by our customers, please refer to the privacy policies of those customers.
2. Use of personal information
We process your personal information for the following purposes:
- To deal with your inquiries and requests;
- To create and administer records about any online account that you register with us, or to allow you to register an account with us;
- To maintain and improve the accuracy of the records that we hold about you;
- To provide you with information, and access to resources that you have requested from us;
- To provide our products and services;
- To otherwise maintain our relationship with you, including requesting/processing your feedback;
- Research and development and to improve our products and services (subject to your prior consent, which will be obtained separately from this Notice);
- Website and system administration and security;
- For internal analytics, in particular too better understand the visitors who come to our Websites, where they come from and what content on our Website is of interest to them and to improve the navigation and content of the Website (please see our Cookies Notice (https://www.osi-systems.com/cookies/) for information about opting out of the cookies that are used for this purpose);
- To assess financial, credit or insurance risks arising from any relationship or prospective relationship with a customer, supplier, distributor or other business partner;
- To alert you to updates to the Websites, and any to any news and events in which we think you may be interested (should you opt in to receiving such updates) and/or to allow you to submit enquiries to us;
- (In the case of your job application information): For recruitment purposes – if you have given your prior consent by means other than this Notice, any resume submitted by you (whether on your own behalf of or on behalf of a third party) whether in connection in with a particular job or otherwise, may be kept for a period of 6 month’s to assess suitability for jobs which become available from time to time.
3. Information we share
We will only disclose personal information to other companies within our group of companies (the OSI group entities, please see above) for the purposes outlined in this Notice. We may also share your information with third parties when:
4. Your choices in relation to direct marketing
We may use the information that you give to us to contact you by mail, telephone, fax email or electronic messaging service to alert you to updates to the Websites, and any news and events in which we think you may be interested (should you opt in to receiving such updates). We will also offer you the opportunity to unsubscribe in every communication sent.
5. Legal basis for processing personal information (if EEA data protection law applies)
If EEA data protection law applies, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Website(s) and to communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Website(s), undertaking marketing, or for the purposes of detecting or preventing illegal activities.
Given the business-to-business context in which we undertake the processing of your personal information, and the safeguards we take to protect your personal information, our legitimate interests are not outweighed by an prejudice to your individual rights and freedoms. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
You can choose not to provide personal information to us. However, unless otherwise indicated, the information that we request is necessary for the purposes of entering into and performing a contract with you or your organization and/or providing services/website facilities to you or your organization and failure to provide it will impede the contracting process and/or the provision of the relevant services or facilities.
Links to Other Websites and social media
Websites may contain links to other websites which are outside our control and are not covered by this Notice. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security or privacy practices employed by other websites. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy notice, which may differ from ours.
On some Website pages, third parties that provide content, applications or plug-ins through our Websites may track your use of content, applications and plug-ins or customize content, applications and plug-ins for you. For example, when you share a webpage using a social media sharing button on our Websites (e.g., Facebook, Twitter, or Google Plus), the social network that has created the button will record that you have done this. For more information on social media plug-ins on our Websites, see our Cookies Notice.
6. Data Retention
We retain personal information that we collect from you where we have an ongoing legitimate business need to do so. If you are a client or vendor (or a representative of a client for vendor, your personal information will be retained for a period of time to allow us to provide or receive the relevant services (as the case may be) and to comply with applicable legal, tax or accounting requirements. We will not retain your information for longer than is necessary for our business purposes or for legal requirements.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it form any further processing until deletion is possible.
We maintain reasonable and appropriate technical and organizational security measures to protect the personal information you provide to us through a Website against unauthorized disclosure, use, alteration, or destruction. These measures are designed to provide a level of security appropriate to the risk of processing your personal information. Please note, however, that perfect security does not exist on the Internet. Therefore, while we endeavor to protect your personal information, when data is transferred over the Internet it may potentially be accessed and used by unauthorized parties.
Where you have a password, which enables you to access a Website, you are responsible for keeping this password secure and confidential.
8. Your rights
If you are from certain territories (such as Switzerland or the EEA), you may have the right to access the personal information that we hold about you, or to correct, amend or delete such information pursuant to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks (as applicable). If EEA data protection law applies to the processing of your personal information, you have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “Who to contact” heading below.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Who to contact” heading below.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “Who to contact” heading below.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
If you wish to make such a request, please contact us at the address below. Before responding to your request, we may ask you to verify your identity and to provide further details about your request. We will endeavor to respond within an appropriate timeframe and, in any event, within any timescales required by law or, where applicable, within the timescales required by the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.
9. International transfers
We belong to an international group of companies. Consequently, we may transfer your personal information outside your country of residence to countries or jurisdictions where we have facilities or engage third parties to provide services to us for the purposes outlined in this Notice. The countries to which we may transfer your personal information are in the following regions: USA, Europe, or Asia. Such countries may not have the same level of data protection as within your country. If we do make such a transfer, we will, take steps in accordance with applicable laws to protect your personal information and will obtain your prior consent separately from this Notice, if required to do so by applicable law. For example, as described below, we have certified (pursuant to Article 45 of the EU General Data Protection Regulation 2016) to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks for international transfers of personal information from our group companies within the EEA and Switzerland to our group companies in the US. We have also implemented the EU Commission’s Standard Contractual Clauses (pursuant to Article 46.2 of the General Data Protection Regulation 2016) for international transfers of personal information from within the EU to our service providers and our non-US group companies located outside the EEA. Further details can be provided upon request using the contact details provided under the “Who to contact” heading below.
10. EU-U.S. and Swiss-U.S. Privacy Shield
OSI Systems Inc. and its controlled U.S. subsidiaries (including American Science and Engineering, Inc., AS&E Global, Inc., Locker LLC, OSI Electronics, Inc., OSI Laser Diode, Inc., OSI Laserscan, Inc., OSI Optoelectronics, Inc., OSI Solutions, Inc., Rapiscan Government Services, Inc., Rapiscan Holdings, Inc., Rapiscan Laboratories, Inc., Rapiscan Systems, Inc., S2 Global Inc., Spacelabs Healthcare Inc., Spacelabs Holding, Inc.) (together “OSI US”) comply with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EEA or Switzerland to the United States. In doing so, OSI US has certified that, in respect of all personal information it receives from the EEA or Switzerland, it will adhere to the Privacy Shield Principles of: Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity and Purpose Limitation, Access and Recourse, Enforcement and Liability. If there is any conflict between the terms in this Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To access the Privacy Shield Program, and to find details of OSI US’s certification, please visit www.privacyshield.gov.
OSI US’s participation in the Privacy Shield applies to all personal information that is subject to this Notice and is received from the EEA or Switzerland. OSI US will comply with the Privacy Shield Principles in respect of such personal information.
Where OSI US transfers personal information from the EEA or Switzerland to its third party agents and service providers, it will require such third parties to process the information only for the purposes described this Notice and to provide the same level of protection for the information as required by the Privacy Shield Principles. OSI US remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal information on its behalf do so in a manner inconsistent with the Principles, unless OSI US proves that it is not responsible for the event giving rise to the damage.
If you believe that OSI US is processing your personal information within the scope of its Privacy Shield certification, you may direct any inquiries or complaints concerning its Privacy Shield compliance in the following ways:
(1) In the first instance, please send your inquiry or complaint to firstname.lastname@example.org or by writing to:
OSI Systems, Inc.
Attention: Data Privacy Officer
Corporate Compliance Department
12525 Chadron Avenue
Hawthorne, California 90250
United States of America
OSI US will respond within 40 days.
(2) If you are not satisfied with OSI US’s response, or for complaints that cannot be resolved with OSI US directly, OSI US has chosen to cooperate with EU and Swiss data protection authorities (DPAs) and comply with the information and advice provided to it by an informal panel of DPAs in relation to such unresolved complaints EU DPAs are available here: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. Swiss individuals may contact the Swiss Federal Data Protection and Information Commissioner’s (FDPIC) office. Under certain circumstances, you may be eligible to invoke binding arbitration.
(3) Further, the European and Swiss DPAs may refer your complaint to the US Department of Commerce or the Federal Trade Commission for further investigation.
OSI US’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
11. Updates to this Notice
From time to time we may update this Notice in response to changing legal, technical or business developments. If material changes are made to this Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make (for example we may notify you by e-mail or place a pop-up notice on our Websites for a period of 30 days). We will obtain your consent to any material Notice changes if and where this is required by applicable data protection laws.
You can see when this Notice was last updated by checking the “last updated” date displayed at the top of this Notice.
12. Who to contact
If you have any questions or comments in relation to this Notice, or our privacy practices or use of your personal information, please contact us via email at email@example.com or write to:
OSI Systems, Inc.
Attention: Data Privacy Officer
Corporate Compliance Department
12525 Chadron Avenue
Hawthorne, California 90250
United States of America