Privacy & Cookies Policy 

We take your privacy very seriously.  Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information.  It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you.  When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.

1.  Key Terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our :  

LHM Medical Technology (America) Inc.

Personal information :

Any information relating to an identified or identifiable individual

Special category personal information: 

Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation

2.  Personal Information We Collect About You

We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

  • Personal identifiers, such as your name, alias, social security number, driver’s license number, passport number, or postal address

  • Device and online identifiers and related information, such as telephone number and email address

  • Internet, application, and network activity, such as cookie IDs and browser visits

  • Government identifiers, such as national identification numbers and driver’s license numbers

  • Demographic information, such as age and date of birth

  • Financial information, such as credit and debit card numbers and claims information

  • Health and health insurance information, such as prescription numbers and health insurance identification numbers

  • Characteristics of protected classifications under state or federal law, such as Gender, race, religious creed, colour, national origin, ancestry, physical disability, mental disability, medical condition, marital status, sex, age, sexual orientation or nationality

  • Purchase history information, such as products and/or services you have bought, rented, and returned

  • Biometric information, such as imagery of the iris, retina, and fingerprints

  • Location information, such as geo-location information

  • Audio, visual, and other sensory information, such as audio and video recordings

  • Employment information, such as occupation, title, licenses and professional memberships

  • Background and criminal information, such as background checks and criminal convictions

  • Education information, such as degree and schooling information including information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)

  • Individual preferences and characteristics, such as inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

We do not collect any special category personal information from you.  The personal information that we collected from you is required to provide our products and/or services to you.  If you do not provide us the personal information we ask for, it may delay or prevent us from providing the products and/or services to you.

3.  How Your Information is Collected

We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website.  However, we may also collect information:

  • From publicly accessible sources (e.g., property records);

  • Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);

  • From a third party with your consent (e.g., your bank);

  • From cookies on our website; and

  • Via our IT systems, including:

    • Door entry systems and reception logs;

    • Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.

4.  Why We Use Your Personal Information

We use your personal information for the following reasons:

  • To comply with our legal and regulatory obligations;

  • For the performance of our contract with you or to take steps at your request before entering into a contract;

  • For our legitimate interests or those of a third party; or

  • Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

5.  Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”).  This means we do not usually need your consent to send you promotional communications.  However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organizations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

6.  Who We Share Your Personal Information With

We routinely share personal information with:

  • Our affiliates, including companies within LHM Holding Limited, a conglomerate with more than 40 years of history with operations in United States of America, Hong Kong, China, United Kingdom, Europe and Mexico

  • Service providers we use to help deliver our products and/or services to you, such as payment service providers, warehouses and delivery companies;

  • Other third parties we use to help us run our business, such as marketing agencies or website hosts;

  • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;

  • Credit reporting agencies;

  • Our insurers and brokers;

  • Our bank[s];

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.  We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.  We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring.  We will typically anonymize information, but this may not always be possible.  The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

7.  Personal Information We Disclosed for a Business Purpose

We will not sell or rent your personal information for money.  We may share your personal information other companies, including those within our corporate family, for a business purpose or with your consent.

In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

  • Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);

  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;

  • Characteristics of protected classifications under California or federal law;

  • Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);

  • Biometric information;

  • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);

  • Geolocation data;

  • Audio, electronic, visual, thermal, olfactory, or similar information;

  • Professional or employment-related information;

  • Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and

  • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

8.  Where Your Personal Information is Held

Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

9.  How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or while we are providing products and/or services to you.  Thereafter, we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf;

  • To show that we treated you fairly; or

  • To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy.  When it is no longer necessary to retain your personal information, we will delete or anonymize it.

10.  Transferring Your Personal Information Out of the EEA

To deliver services to you, we may share your personal information outside the European Economic Area (EEA), e.g.:

  • With our offices outside the EEA;

  • With your and our service providers located outside the EEA;

  • If you are based outside the EEA; or

  • Where there is an international dimension to the services we are providing to you.

11.  Your Rights Under the CCPA

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

(a) Disclosure of Personal Information We Collect About You

You have the right to know:

  • The categories of personal information we have collected about you;

  • The categories of sources from which the personal information is collected;

  • Our business or commercial purpose for collecting or selling personal information;

  • The categories of third parties with whom we share personal information, if any; and

  • The specific pieces of personal information we have collected about you.

Please note that we are not required to:

  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or

  • Provide the personal information to you more than twice in a 12-month period.

(b) Disclosure of Personal Information Sold or Used for a Business Purpose

In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:

  • The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and

  • The categories of personal information that we disclosed about you for a business purpose.

(c) Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records; and

  • Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

  • Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

  • Debug to identify and repair errors that impair existing intended functionality;

  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

  • Comply with the California Electronic Communications Privacy Act;

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

  • Enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us;

  • Comply with an existing legal obligation; or

  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

(d) Stop Selling Your Personal Information

You have the right to request a business stop selling your personal information.  According to the CCPA, selling is defined as follows:

“selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.”

We do not sell your personal information for money.  We do share your personal information within our affiliated companies and with certain third parties, which may be considered a “sale” under California law even if we don’t receive money in exchange for the information.  If you are a California resident, you have a right to opt-out of the sale of your personal information. To do so, click “Do Not Sell My Personal Information” at the bottom of this page.

(e) Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

  • Deny goods or services to you;

  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

  • Provide a different level or quality of goods or services to you; or

  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate, or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to us by your personal information.

12. Keeping Your Personal Information Secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way.  We limit access to your personal information to those who have a genuine business need to access it.  Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach.  We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

13.  How to Exercise Your Rights

If you are a California resident, you may ask us to disclose what personal information we have about you and what we do with that information, to delete your personal information and not to sell your personal information.  To exercise any of your rights as described in this Privacy Policy, please:

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly by website/email/phone/in writing, you will need to provide us with:

  • Enough information to identify you (e.g., your full name, address and customer or matter reference number);

  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and

  • A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

14.  Changes to This Privacy Notice

This privacy notice was published on June 1, 2021 and last updated on June 1, 2021.

We may change this privacy notice from time to time–when we do, we will inform you via mechanism for informing the data subject of changes to the notice, e.g., our website or other means of contact such as email.

15.  How to Contact Us

Please contact us [and/or our Data Protection Officer] by post, email or telephone if you have any questions about this privacy policy or the information, we hold about you.

Our contact details are shown below:

Address: 738 Phillips Drive, City of Industry, CA 91748

Email: us-sales@lhm-medical.com

Telephone: (888) LHM-0012

16.  Do You Need Extra Help

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).

contact us.png

LHM Medical Technology (America) Inc.

City of Industry, California, USA

Email: us-sales@lhm-medical.com

Phone: +1 (888) LHM-0012         

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