Global Privacy Policy on Personal Data
Overview
In the course of conducting our information services and technology business worldwide,
Zynex Medical collects and processes personally identifiable information of
our clients, shareholders, employees, suppliers, business partners, Web site visitors and
other persons (Personal Data). Maintaining the integrity and confidentiality of Personal Data
and handling it correctly is central to the way we conduct our business activities. This policy
describes how we handle Personal Data.
Personal Data is information that can be used directly or indirectly to identify a living individual.
Personal Data may include sensitive categories of information, such as information that reveals
racial or ethnic origin, political opinions, religious beliefs, trade union membership, health or
sexual orientation (Sensitive Personal Data).
This policy applies to Zynex Medical and its subsidiaries, and is effective as of
December, 2006. All employees will be required to abide by this policy.
This policy is designed to protect Personal Data under applicable law as it currently exists.
However, Zynex Medical realizes that this policy cannot address every potential
issue and circumstance. Therefore, we acknowledge that this policy is subject in all respects
to applicable local legal and regulatory requirements and existing agreements and confirm that
we will comply with such requirements and existing agreements.
Privacy Principles
We will observe the privacy principles described below of Notice, Choice/Fair Processing,
Access, Security/Integrity, Onward Transfer and Enforcement/Compliance in processing
Personal Data.
Notice
When we collect and process Personal Data about individuals, we will make certain information
available to those individuals on a reasonable and timely basis.
This information will include what
Personal Data is being collected, who is collecting it, how and for what purposes it is being
collected, how it is being used and to whom it will be disclosed.
Choice/Fair Processing
We will process Personal Data only with consent or when such processing is permitted by applicable
law. If we need to process Sensitive Personal Data, we will obtain explicit consent for such processing,
unless such processing is permitted by applicable law.
We will not process Personal Data in a manner incompatible with the purposes for which it was originally
collected unless later authorized by the affected individuals or allowed by law; we will take reasonable
steps to ensure that such data is accurate, adequate, relevant and not excessive in relation to such purposes;
and we will not keep such data longer than is necessary for such purposes.
We will enable individuals to choose whether their Personal Data can be disclosed to a third party for
direct marketing purposes.
Access
We will allow individuals reasonable access to their Personal Data to verify, correct or delete their data,
where inaccurate. We will also provide a means for individuals to exercise all other legal rights that they
may have in relation to their Personal Data.
Personal Data will be accessible and processed only by (i) Zynex Medical employees,
suppliers, business partners and others who require access for the performance of their obligations to
Zynex Medical; (ii) any person granted access by the individual to whom Personal Data
pertains; and (iii) those otherwise authorized by law or court order.
Security/Integrity
We will take reasonable security procedures through appropriate technical and organizational measures
to protect against unauthorized or unlawful access or processing, disclosure, alteration, destruction or
accidental loss of Personal Data.
We will utilize reasonable means to keep Personal Data accurate, complete and current in order to
protect the quality and integrity of Personal Data, however, we rely on individuals to provide all relevant
information and to advise us of any changes to their Personal Data to ensure that it remains accurate,
complete and current.
Onward Transfer
When we transfer Personal Data within Zynex Medical or to third parties (including our
suppliers and business partners), we will observe the privacy principles of Notice and Choice
(described above), and we will require all the recipients of such data to provide at least the same
level of protection for such data as specified by the standards stated in this policy.
Enforcement/Compliance
We will follow internal processes for handling complaints regarding our management of Personal Data.
We will demonstrate our compliance with this policy by:
- publishing this policy conspicuously so that it is accessible to all interested persons
- appointing and maintaining a Privacy Officer with responsibility for developing and implementing a privacy program
- implementing procedures to execute this policy in the conduct of our business, including training our employees in the
use of such procedures and disciplining employees for failure to comply with this policy and its procedures
- at least annually, reviewing this policy to ensure that it continues to comply with prevailing privacy standards, current
applicable law and regulations and existing agreements.
Zynex Medical Web Sites
In addition to all other Personal Data handled by Zynex Medical, this policy applies
to Personal Data collected through Zynex Medical Web sites.
As a convenience to our Web site visitors, we sometimes provide links to other Web sites.
These linked sites are not under the control of Zynex Medical, and as such, we
are not responsible for their content.
Updating the Policy
Changes in legislation and/or our business activities may require that this policy be updated from time to time.
Contact Us
If you have any questions or comments about this policy or our privacy practices, please contact us.
Phone: +1 (800) 845 1771
Street Address:
Zynex Medical, Inc.
8022 Southpark Circle
Littleton, CO 80120
USA
E-mail address: info@zynexmed.com
Web Address: www.neuromove.com
