Effective May 2020
Types of Information We Collect
The types of Personal Data that we may collect while you use the Leica Microsystems Sites are described in this section and include both information that you provide to us and information that we collect automatically when you use the Leica Microsystems Sites.
Information You Provide
You do not have to register for a service or program to receive much of the information available through Leica Microsystems Sites. However, some of our content is available only to registered or identified users and will require you to set up a profile or provide specific information about yourself in order to provide you the service.
Personal Data You Provide When Visiting Leica Microsystems Sites
Leica Microsystems collects Personal Data that you provide on Leica Microsystems Sites.You may do this when purchasing a product, to receive marketing products and information, contact Leica Microsystems customer service, or respond to Leica Microsystems questionnaires or surveys. This could include:
- Contact Information such as your name, address, phone number, or email address
- Registration Information such as your username and password
- Remuneration information when you provide a service to Leica Microsystems
- Employment, education and other background information when you inquire about employment with Leica Microsystems
- Content you may provide (for example, when you complete our Online Contact Form or submit other information).
Personal Data You Share During Other Interactions with Leica Microsystems
You may contact Leica Microsystems to ask questions, discuss your concerns, or report issues regarding our products. If you communicate with or request information from Leica Microsystems, you may be prompted to provide your contact information as well as any Personal Data that is relevant to your request. This information includes contact information such as your name, address, phone number or email address and username.
Information That May Be Collected Automatically
When you use the Leica Microsystems Sites, we also may collect certain usage and device information automatically as described below. Your IP address and non-identifying information about your use of Leica Microsystems Sites may be collected automatically using tracking technologies, such as cookies. This information can include: device and advertising identifiers, browser type, operating system, Internet service provider, pages you visit before and after using the Site, the date and time of your visit, information about the links you click and pages you view within the Site, and other standard server log information. Your website browser software can be set to reject all cookies; however, cookies can allow you to take advantage of some of the site’s essential features, so they may not work if you reject cookies.
We may record the Internet Protocol (“IP”) address of your computer or other electronic device when you visit the Leica Microsystems Sites. An IP address identifies the electronic device you use to access the Sites, which allows us to maintain communication with your computer as you move about Leica Microsystems Sites and to customize content.
Cookies and Other Tracking Technologies
We also collect information about your use of Leica Microsystems Sites through tracking technologies such as cookies and web beacons. A “cookie” is a unique numeric code that is transferred to your computer to track your interests and preferences and to recognize you as a return visitor. A “Web beacon” is a transparent graphic image placed on a Web site, e-mail or advertisement that enables the monitoring of things such as user activity and site traffic. These technologies help remember your preferences and allow us to bring you the content and features that are likely to be of greatest interest to you on the basis of “clickstream” data that shows your previous activities on Leica Microsystems Sites. Leica Microsystems Sites utilize both Google Analytics and Adobe Analytics for tracking purposes.
We may share information about your use of Leica Microsystems Sites with third parties for certain business purposes, including personalizing and delivering online marketing and advertising. We utilize Google Display Advertising (such as Retargeting with Google Analytics, Google Display Network Impression Reporting, DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting) to (1) show you our ads on other websites based on your prior visits to Leica Microsystems Sites, and (2) better understand our ad impressions and use of ad services. In connection with the Google Analytics Demographics and Interest Reporting service, we may use data from Google's interest-based advertising or third-party audience data (such as age, gender and interests) with Google Analytics to understand and improve our marketing campaigns and Site content.
Some of our online advertising takes place through Google Display Advertising. As part of this program, we use Google Analytics features such as Retargeting. In connection with that feature and others offered by ad networks, we and the operators of ad networks, including Google, may use third-party cookies (such as the DoubleClick cookie) – and in some cases first-party cookies (such as the Google Analytics cookie) – to inform, optimize and serve ads across the Internet, based on a user's past visits to Leica Microsystems Sites. We also may show you ads from some of our affiliated companies when you visit Leica Microsystems Sites.
When we disclose data for business purposes as discussed above, we disclose the categories of data listed above in Types of Information We Collect.
You can opt out of Google Ads by visiting http://www.google.com/ads/preferences. If you do not want your data used by Google Analytics, you can install the Google Analytics opt-out browser add-on at the Google Analytics opt-out page.
To learn more about cookies and other tracking technologies, including how to disable them, please visit http://www.allaboutcookies.org/. Please note that some cookies are essential to the functioning of our Sites and deleting or disabling them will reduce the site’s functionality.
Some Leica Microsystems Sites are available either as mobile applications or mobile sites that you can use on your mobile device. If you use a mobile device to access and use the Leica Microsystems Sites, we may collect the following mobile-specific information in addition to the other information described above: device or advertising ID, device type, hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the version of your mobile operating system, the platform used to access or download the Leica Microsystems Site (e.g., Apple, Google, Amazon, Windows), location information and usage information about your device and your use of the Leica Microsystems Sites.
Information Collected from Other Sources
We may combine information about you from Leica Microsystems Sites with information that you provide offline, for the purposes specified in this notice. Any Personal Data that we obtain offline from you or others will be processed in compliance with notice requirements and other applicable law.
How We Use Your Information
We use your Personal Data to provide you the product and services you request, communicate with you, improve your experience on the Leica Microsystems Sites, generally improve our products and services and for other internal business purposes, including detecting security incidents, debugging to identify and repair errors that impair existing functionality, performing services on our behalf or that you request (such as serving online marketing and advertising), and fulfilling transactions. These uses may also include the recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data. The Personal Data we collect about you will be retained only for so long as reasonably necessary for the purposes set out above and in accordance with applicable laws.
Providing Product and Services You Request
If you choose to purchase a product or receive our services, we use the Personal Data that you provide through Leica Microsystems Sites to manage your orders and invoices, to process payments, to respond to your questions, provide you the services you request and offer an optimal customer experience.
You may also receive marketing information from Leica Microsystems and related affiliates, such as offers regarding Leica Microsystems related products or services, invitations to participate in surveys about our products, or notifications about special promotions. In such cases, we will use your contact and other Personal Data to send you marketing information.
Customized User Experiences
Business and Product Improvement
In order to discover new facts that could help Leica Microsystems better understand customer needs and help improve, develop, and evaluate product, services, materials, and programs, Leica Microsystems analyzes the information that you have provided. For these purposes Leica Microsystems does not use information that can directly identify you.
Site Analytics and Improvement
We may use the information that you provide and the information we collect automatically about your use of the Leica Microsystems Sites to monitor user traffic patterns and preferences for site improvement, analytics and optimization.
Legal Basis for Processing
Consistent with applicable law, Leica Microsystems must have a legal basis to process your Personal Data. The legal basis that applies in an instance will depend on for which of the specific purposes described above Leica Microsystems is processing your Personal Data:
- In certain cases, and where required by applicable law, Leica Microsystems may ask for your consent to collect and process your Personal Data. Should you choose to provide your consent, you may later withdraw your consent by contacting us as described in the “Your Privacy Choices” section. Please note that the withdrawal of consent will not affect processing which has already occurred.
- In other instances, the processing of your Personal Data may be necessary in order to comply with an applicable law or regulation or for the performance of a contract to which you are subject. You may not be able to opt-out of this processing, or your choice to opt-out may impact our ability to perform a contractual obligation otherwise owed to you.
- In still other instances, Leica Microsystems may process your Personal Data based on Leica Microsystems’s legitimate interests in communicating with you about our products and services, and about scientific research and educational opportunities. You have the right to opt-out of all such processing of your Personal Data. You may do so by contacting us as described in the “Your Privacy Choices” section.
Information We Share
We may share information about your use of Leica Microsystems Sites with third parties for certain business purposes, as follows:
Third-Party Advertising and Online Behavioral Advertising
You may be provided with online advertisements of Leica Microsystems products and services on third-party websites and mobile services that are tailored to you, for example, on the basis of information that you provide to Leica Microsystems or a third-party website you are visiting, or of your browsing activity, purchases, or interests. These types of tailored online advertisements may come through several sources, such as the following:
- We may share with our advertising service providers your non-identifying information that we have obtained from cookies and other tracking technologies on our Leica Microsystems Sites.
Affiliates, Vendors and Suppliers
We have relationships with suppliers and affiliated companies, who help us operate our business and for whom it may be necessary to have access to your Personal Data in the course of providing services to Leica Microsystems. We require these parties to use your Personal Data in accordance with applicable law and reasonable privacy protections, and we do not share Personal Data from countries that require consent, unless consent has been obtained in advance to sharing with related affiliates.
During the last 12 months:
We have shared with affiliates the following categories of Personal Data specified in the California Consumer Privacy Act (CCPA): personal identifiers, characteristics of protected classifications, commercial information, and professional or employment-related information.
We have shared Personal Data (which may be in any CCPA category) with service providers for business purposes.
We have sold the following categories of Personal Data to distributors for business or commercial purposes: contact details including name of company, phone and email address of contacts.
You can find all related affiliates here: https://www.danaher.com/our-businesses/business-directory
We may partner with other companies to provide you with content or services on a joint or “co-branded” basis. At a co branded site, you will see both the Leica Microsystems logo and the logo of the co-branding partner displayed on your screen. You should read the individual privacy policies of our co-branding partners, as they may differ in some respects from ours. Reading these policies will help you to make an informed decision about whether to provide your information to a given site.
If you contact Leica Microsystems regarding your experience in using one of our products, we may use the information that you provide in submitting reports to the designated government regulatory authority, as required of us by law.
Legal Rights and Obligations
In certain limited circumstances, Leica Microsystems may need to disclose your Personal Data in order to comply with a legal obligation or demand, such as to comply with reporting obligations to our governing regulatory authorities regarding the safety of our products, or in connection with the sale or transfer of one of our product lines or divisions, which includes the services provided through one or more of the Leica Microsystems Sites. In such instances, we will take measures to protect your Personal Data to the extent possible. We also reserve the right to use Personal Data to investigate and prosecute users who violate our rules or who engage in behavior that is illegal or harmful to others or to others’ property.
Change in Organization
In the event Leica Microsystems decides to reorganize or divest our business through sale, merger, or acquisition, Leica Microsystems may share Personal Data about you with actual or prospective purchasers. We will require any actual or prospective purchasers to treat this Personal Data in a manner consistent with this policy.
Leica Microsystems does not knowingly collect or use any Personal Data directly from children on Leica Microsystems Sites (Danaher defines as “children” as minors younger than 18). We do not knowingly allow children to order our products, to communicate with us, or to use any of our online services. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below, and we will work with you to address this issue.
Your Privacy Choices
You have the right to be informed about our data practices, as well as about entities with which we have shared your Personal Data and the possibility of denying consent and the consequences of such denial. You also have the right to see and get a copy of Personal Data about you that we maintain as well as to ask us to make corrections to inaccurate or incomplete Personal Data about you. You have the right to receive data you have provided to us in a machine-readable format and to transmit that data to another controller. You may also request the erasure of your Personal Data or the restriction of its processing, or object to the processing of Personal Data about you. We will comply with any other rights you may have under applicable law in addition to those listed above.
Consistent with applicable law, you also may request access to information about the categories of Personal Data we collect, the sources from which we obtain that Personal Data; why we collected it; and with whom we share it.
To seek access to Personal Data about you, exercise any other rights, to file a concern, complaint, or request for correction, or to opt-out of particular programs, please contact our Privacy Office by clicking on the “Contact Us” link on the Leica Microsystems Site you are using, by using the Leica Microsystems contact information on the Leica Microsystems mobile application you are using, or by emailing us at firstname.lastname@example.org. You may also send a letter to the following address:
Leica Microsystems GmbH
Attn: Legal department
Ernst Leitz Strasse 17-37
Many countries have a data protection authority to ensure that data protection law is followed. For more information about your privacy rights, or if you are not able to resolve a problem directly with us and wish to make a complaint, contact your local authority.
In all communications to Leica Microsystems, please include your email address, the Web site address, mobile application, and/or the specific Leica Microsystems product to which you provided Personal Data (e.g., Leica-Microsystems.com), and a detailed explanation of your request. If you would like to delete, amend, or correct your Personal Data and are contacting us by email, please put “Deletion Request” or “Amendment/Correction Request” in the subject line of the email. We will respond to all reasonable requests in a timely manner and may need to further confirm your identity in order to process certain requests.
Once we receive your request, we may need to contact you to further verify relevant details. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise your rights and choices on your behalf, please provide sufficient proof of assignment of authority.
Additional Notice to California Residents
Subject to certain limits under California Civil Code § 1798.83, California residents may ask us to provide them with (i) a list of certain categories of Personal Data that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. To make this request, California residents may contact us at email@example.com.
In addition to the Privacy Choices listed above, in accordance with applicable law, California residents may also opt-out of the sale of their information by clicking the “Do Not Sell My Personal Information” link on the Leica Microsystems site web page or by calling toll free (844) 842-6676. We will not discriminate against you for exercising your rights, and any difference in services as a result of your decision not to provide us with Personal Data is reasonably related to the value of such data.
Leica Microsystems maintains reasonable technical, administrative and physical controls to secure any Personal Data collected through the Leica Microsystems Sites. However, there is always some risk that an unauthorized third party could intercept an Internet transmission, or that someone will find a way to thwart our security systems. We urge you to exercise caution when transmitting Personal Data over the Internet, especially your financial-related information. Leica Microsystems cannot guarantee that unauthorized third parties will not gain access to your Personal Data; therefore, when submitting Personal Data to Leica Microsystems Sites, you must weigh both the benefits and the risks.
Third Party Sites and Social Media Plug-ins
Accessing Our Sites Globally
Leica Microsystems may transmit Personal Data about you to related affiliates worldwide. These affiliates may in turn transmit Personal Data about you to other related affiliates. Some affiliates may be in countries that do not ensure an adequate level of data protection. Nevertheless, all of Leica Microsystems’s related affiliates are required to treat Personal Data in a manner consistent with this policy. We only transfer your Personal Data internationally or to a third party when we are satisfied that adequate levels of protection are in place to protect the integrity and security of your Personal Data being processed, in compliance with applicable data protection laws. Where necessary, including for transfers to affiliates, we use Standard Contractual Clauses approved by the European Union to provide such protection. To obtain additional information regarding the safeguards we have in place for cross-border transfers of Personal Data, please contact us using the information provided in the “Your Privacy Choices” section.
Russian Residents Only
We will carry out the following operations on your Personal Data with and without use of automated means: collection, recording, systematization, accumulation, storage, specification (update, modification), retrieval, use, transfer (provision, access), including cross-border transfers, depersonalization, deletion and destruction.
We share information about your use of Leica Microsystems Site with third parties and transfer your information outside of Russia for certain business purposes. If you would like to get more information on these third parties and the countries to which we transfer your Personal Data, please contact us as described in the “Your Privacy Choices” section and we will provide you with the information on names, locations of those third parties as well as their roles in processing your Personal Data.
Leica Microsystems implements necessary legal, organizational and technical measures to secure any Personal Data collected through the Leica Microsystems Sites, including:
- Restriction of access to the Personal Data on a need-to-know basis, i.e. only to individuals who require such data to perform their respective duties;
- Ensuring physical security of premises where our information systems are located;
- Use of hardware and software information security tools, such as state-of-the-art malware protection and firewalls; and
- Appointment of a Data Protection Officer.
Integrity and Compliance Program
Please go to www.danaherintegrity.com for
- a copy of our Standards of Conduct or
- to make a report on the Danaher Integrity and Compliance Helpline.
UK Modern Slavery Act 2015
Leica Microsystems (the "Company") is committed to improving our practices to combat slavery and human trafficking and is taking steps to ensure that this is not taking place in our supply chains or in any part of our business –please go to http://investors.danaher.com/corporate-governance under Policies & Reports for details regarding the Company’s compliance with the Modern Slavery Act 2015.
UK Leica Pension Scheme: Statement of Investment Principles
By law the Trustees of the Leica Pension scheme are required to oversee the scheme’s assets on behalf of scheme members to ensure that benefits will be paid when they fall due. The Pension Regulator (TPR) monitors Trustee activity and requires that the Trustees produce a Statement of Investment Principles (“SIP”) which is agreed with the employer. This SIP is updated from time to time to take account of changing investment conditions and an increase in governance. In the spirit of transparency TPR has requested that the current SIP is made available to members on a publicly available website from the 1 October 2020 and so the SIP is provided here courtesy of the employer.
The Trustees of the Leica Pension Scheme.
Leica California Comprehensive Compliance Program and Compliance Declaration
NOTICE: Leica is providing this information pursuant to the requirements of California Health and Safety Codes §§119400-119402 (the “Statute”), which requires certain medical device companies doing business in California to make available their Compliance Program and annual written Declaration of compliance with the Compliance Program.
The Description and Declaration below cover all members of the Leica Microsystems and Leica Biosystems family of companies.
Leica is committed to doing business in accordance with the highest standards of business conduct and ethics, and we consider our reputation for ethical and compliant behavior to be a valuable corporate asset. Accordingly, Leica has established a Compliance Program (“CP”) in accordance with California Health and Safety Code, Division 104, Part 15, Chapter 8, Sections 119400‐119402 (the “Statute”), based on our good faith understanding of the requirements of the Statute as it may apply to a medical device manufacturer, and the Compliance Program Guidance for Pharmaceutical Manufacturers (“OIG Guidance”) published by the Office of Inspector General, U.S. Department of Health and Human Services.
Our Compliance Program, applied in conjunction with our MedTech Healthcare Professional Engagement Policy (“MedTech Policy”), is tailored to Leica’s size, organizational structure, available resources, and the nature of our business as a medical device manufacturer. The medical device industry has established, and Leica’s Compliance Program is designed in accordance with, the AdvaMed Code of Ethics on Interactions with Health Care Professionals (the “AdvaMed Code”). The AdvaMed Code is a voluntary ethical code substantially similar to the Pharmaceutical Research and Manufacturers of America Code on Interactions with Healthcare Professionals (the “PhRMA Code”) but was developed with a primary focus on the unique interactions between medical device manufacturers and healthcare professionals and is thus more uniquely suited to Leica’s compliance needs.
This is a description of Leica’s Compliance Program. It reflects the plan and policies we have implemented, but Leica’s Compliance network is a dynamic and continuously developing entity requiring coordination between multiple policies and programs as well as the commitment of our management team and associates. While adoption and implementation of appropriate policies cannot guarantee complete elimination of improper conduct, it is Leica’s expectation that all associates will comply with our Compliance Program and all applicable laws, rules, and regulations. To our knowledge, we are, in all material respects, in compliance with our Compliance Program and applicable law. Leica’s passion for continuous improvement in all areas of our business dictates that we regularly review and enhance our Compliance Program to adapt to our evolving compliance needs.
II. DESCRIPTION OF COMPLIANCE PROGRAM
A. Leadership and Structure
Our Compliance Program has been developed by Leica’s Compliance leadership and is managed by Katrin Hoenig, Global Senior Compliance Manager, and James Kim, Legal & Compliance Counsel for the Americas. Company Management works with the Compliance team to ensure Leica effectively prevents, detects, and reacts to instances of non-compliance.
B. Policies and Procedures
Leica has adopted written policies and procedures such as our MedTech Policy to implement our high ethical standards and meet our healthcare compliance obligations under applicable laws, regulations, and industry codes of conduct. These policies apply to all Leica associates and compliance with those policies is a condition of employment.
Leica, in accordance with California law, has established an annual limit on promotional spending of USD $5000 per individual California medical and health professional, which includes persons licensed by California to prescribe prescription products, medical students, and members of drug formulary committees. This limit covers gifts, promotional materials, or items or activities that Leica may give or otherwise provide to an individual medical or healthcare professional in California. This limit represents a spending cap and not an average or target, and in most instances the amount spent per physician will be substantially less than this annual limit.
The annual limit excludes non-promotional spending such as: drug samples or demonstration units; financial support for continuing medical education forums or health education scholarships if provided in accordance with Leica policy; fair market value compensation for bona fide professional services, and any meals or other expenses related to the provision of such services; training programs necessary for the safe and effective use of Leica products; items of nominal value with a retail value of less than $10.
C. Training and Education
We provide training on ethics as well as Leica’s Compliance Program and MedTech Policy to all sales, marketing and research and development associates, both as a part of a regular training program and ad hoc as needed.
D. Compliance Communications
Our Company is committed to maintaining a work environment where all individuals encourage and embrace open discussion across both geographical and operational boundaries. Employees are encouraged to seek guidance in resolving ethics and compliance questions. They are required to report suspected or actual unethical or non-compliant conduct, violations of law or regulation, and violations of internal company policies. Leica associates are encouraged to use our reporting hotline which allows anonymous reporting of suspected or actual noncompliance without retaliation.
E. Auditing and Monitoring
Our Company performs compliance gap analyses, process reviews and data analysis to identify and address potential issues and opportunities to enhance its processes and practices. These are collaborative efforts between the Compliance Department and the business which has generated the development of new and revised policies, new training and communications initiatives and corrective action.
F. Investigating and Responding to Potential Violations
Our Compliance Department monitors company functions and activities for potential violations of law, regulation, industry codes, the Code of Conduct and company policies. Potential violations are promptly and thoroughly investigated and appropriate corrective action taken.
G. Corrective Action
In determining the appropriate response to an established violation, our Company considers various options for corrective action. These options include remediation to evaluate current practices and close any gaps in policies, practices or training that may have led or contributed to the violation, as well as the imposition of disciplinary action up to and including termination. In situations that call for it, Leica will not hesitate to notify appropriate law enforcement agencies of criminal or otherwise illegal activity.
A copy of this description of Leica’s Compliance Program and Declaration may be obtained by calling (800) 248-0123 and speaking with a Customer Service representative.
Leica Turkey Personal Data Processing Policy-Kisisel Veri Isleme Politikasi
Dear Turkish Customers, Suppliers, Employees, Employee Candidates, Business Partners, Potential Customers, Visitors; as Leica Teknoloji Çözümleri Dağıtım Ltd. Sti (“Leica” or “Company”), we attach great importance to the protection of your personal data. With Leica Turkey Personal Data Processing Policy-Kisisel Veri Isleme Politikasi, we would like to inform you about your personal data and their processing operations in the capacity of “data controller” in accordance with the Turkish Law No. 6698 on Personal Data Protection ("LPDP").