Secure Start℠

Terms of Use

Terms and Conditions of Use

1. Contact Information

   The person who determines the purpose for which your personal data is processed is Hollister Incorporated, 2000 Hollister Drive, Libertyville, IL 60048, U.S.A. (“Hollister”)

   If you have any questions, comments, or concerns about or in connection with this Privacy Notice, or would like to make a complaint about our handling of your personal data or exercise any of your rights regarding your personal data, please contact us by using one of the following methods:

   • by sending an email to support@us.securestart.app
   • by sending a letter to Hollister Incorporated, Secure Start Service, 2000 Hollister Drive, Libertyville, Illinois, USA, 60048, U.S.A.
   
   

2. What data do we process?

   We may process various categories of data about you. The main categories of data are the following:

   Contact and communication Information: When you are in contact with us via the contact form, by e-mail, telephone or by letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. If we record or listen in on telephone conversations or video conferences, for example for training and quality assurance purposes, we will tell you specifically. Such recordings may only be made and used in accordance with our internal policies. If we have to determine your identity, for example in relation to a request for information, we may collect data to identify you (for example a copy of an ID document).

   Contact and communication Information may include, depending on the purpose(s) of data collection, data such as name, address, e-mail address, telephone number and other contact details, gender, date of birth, data about related persons, websites, social media profiles, photos and videos, copies of ID cards; moreover, details of your relationship with us (customer, end-user, supplier, visitor, service recipient, etc.), details of our interactions with you (if applicable, a history thereof with corresponding entries) that concern you. As payment information, we may collect, for example, your bank details, account number. Declarations of consent and opt-out information are also part of the Contact and communication Information, as well as information about third parties, for example contact persons, caregivers, relatives or representatives, the means, place and time of communication and usually also its content (i.e. the content of e-mails, letters, chats, etc.). This data may also include information about third parties. For identification purposes, we – or our third party providers- may also process your ID document number or a password set by you. In relation to contact persons and representatives of our customers, suppliers and partners, Contact and communication data includes, for example, the role or function in the company, qualifications and (where applicable) information about superiors, co-workers and subordinates and information about interactions with these persons.

   Registration data: Certain online offerings and services (such as login areas of our application) can only be used with a user account or registration, which can happen directly with us or through our third-party service providers. In this regard you must provide us with certain data, and we collect data about the use of the application.

   Registration data includes the information you provide when you create an account on our application and/or website(s) (for example username, password).

   Technical data: When you access the Service, our servers automatically record certain information. These server logs may include information such as your information request, your interaction with the functions available through the Service, the date and time of your request and one or more unique identifiers so we can identify your device, including device type, operating system and device ID. We do not share your personal information as linked with your IP address or device ID with third parties.

   Health Data: during the registration process, you have consented to share information about your Stoma Marking Appointment, Surgery date, procedure, facility name. You could share other health information in order to provide you with the correct sample product you would like to use.

   Health Data is mobility, type of surgery, duration of hospitalization, pharmacovigilance, information about treatment for documentation of adverse reactions.

   Other data: We also collect data from you in other situations. For example, data that may relate to you is processed in relation to administrative or judicial proceedings..

   
   

3. Purpose(s) of processing

   Please note that Ostomy Journey Companion App and the Secure Start Services are for informational purposes only. The Ostomy Journey Companion App and the Services are not a substitute for assessment, diagnosis, and/or treatment by qualified healthcare professionals. If you have or suspect that you have health problems, you should always contact a licensed healthcare professional. The content provided in the App is designed for you to use in conjunction with appropriate professional health care. Information provided by use of the Ostomy Journey Companion App is meant to be interpreted by a properly qualified healthcare professional. Your use of the Ostomy Journey Companion App and/or the Services does not create or imply any type of patient-physician relationship between you and Hollister.

   Hollister may collect your Personal Data for the following purposes:

   • To join Hollister’s customer Secure Start Services program, create your Ostomy Journey Companion App Account and to allow you to use the Ostomy Journey Companion App;
   • to access, complete and/or correct personal information of a Secure Start End-User personal information account, on their behalf;
   • To send you samples and related product guide;
   • To inform you about Hollister’s products and services which may be of interest to you (direct marketing);
   • To participate in Hollister feedback programs, such as surveys, product or service evaluations, and/or clinical trial activities;

   • to carry out Hollister business operations; carry out marketing ( direct marketing) as well as education and insight about Hollister product use; respond to data subject requests; to keep track of data subject interactions and meetings, such as when data subject contact Hollister for information and support;

     All this processing is important to us not only to promote our services and product as effectively as possible, but also to make our relationships with end-users, customers and other third parties more personal and positive, to focus on the most important relationships, and to use our resources as efficiently as possible.

   • to comply with legal or regulatory obligations that apply to Hollister as a manufacturer of medical devices; to provide further required information;

     This may includes receiving and processing complaints and other reports, monitoring communications, conducting internal investigations or disclosing documents to an authority if we have sufficient reasons to do so or are legally obliged to do so. The legal obligations may arise under your local law but also under foreign regulations to which we are subject, as well as self-regulations, industry standards, our own “corporate governance” and instructions and requests from authorities.

   • for the conclusion, administration and performance of contractual relationships. We conclude various contracts with end-user, customers, healthcare professionals, suppliers, subcontractors and other parties. As part of performing contractual relationships, we process data for the administration of the customer relationship, to provide and claim contractual services (which includes involving third parties, such as logistics companies, security or technical service providers), for consulting and for end-user support.
   • for security and access control purposes.
     We continuously review and improve the appropriate security of our IT and other infrastructure (for example buildings). Like all companies, we cannot exclude data security breaches with absolute certainty, but we do our best to reduce the risks. Access controls include electronic system access controls (for example logging into user accounts), as well as physical access controls (for example building access). For security purposes (to prevent and investigate incidents), we also keep access protocols and visitor lists and use surveillance systems (for example security cameras). We will inform you about surveillance systems at the relevant locations through appropriate signage.
   • to conduct research and development; carry out studies; manage and validate the recruitment and participation of individuals to studies; analyze demographic data; offer special programs, activities, events or promotions via our services; carry out market or consumer studies;
   • to improve and develop the application, products and services (by collecting application performance data and application error data); identify usage trends and develop new products and services; understand how you and your device interacts with our services/application; track and respond to application security questions; determine the effectiveness of our promotional campaigns, conduct surveys;
   • We strive to continuously improve our products and services (including our website or online application). We, therefore, analyze, for example, how you navigate through our website or which products are used by which groups of people in which way. This helps us understand the market acceptance of existing products and services and the market potential of new products and services. This may lead us to aggregate your personal data. This help us to tailor our services and products to the needs of our customers.
   
   

4. With whom do we share your data?

   Your personal data can be disclosed:

   • To Group companies: Hollister companies in our corporate group (a list of such companies can be found on the last page of this document).
   • To Third party service providers who process data on our behalf as necessary for the provision of products and services (if you are an end-user, in some cases this may include your nurse, doctor, healthcare product supplier, or other healthcare professional to help them address your condition), including our IT service providers or freight forwarders for the purpose of delivering products and other materials which you have ordered; The Application and Service is provided by an IT service providers, Higgs Boson Incorporated;
   • To authorize your caregivers and family members ("Authorized Individual-Representative") to access and view your Ostomy Journey Companion App account. These Authorized Individual-Representative will be able to view, modify, provide and manage your information in the Ostomy Journey Companion App. You are responsible for designating your Authorized Individuals-Representative and terminating access by such Authorized Individuals-Representative.
   • If you have consented access to your Ostomy Journey Companion App account to an Authorized Individual-Representative, you can withdraw the access at any time by deleting the caregiver account in Account Settings.
     As an Authorized Individual-Representative, you agree to share your First Name*, Last Name*, Mobile Number*, Email Address, Relation to the Secure Start End-User with the end-user, Hollister or third-party acting on its behalf. You agree that your access can be withdrawn at any time by the end-user;
   • To Governmental authorities, courts, external advisors, and similar third parties as required or permitted by applicable law;

   
   

   Hollister does not seek to collect or request personal information from children under the age of 18. Consent to provide us with personal information of a child under the age of 18 must be provided to us by the parent or legal guardian of that child.

   Unless as described in this policy, Hollister will not sell or lease your personal information to third parties. Any access to your personal data at Hollister is restricted to those individuals who have a need to know it in order to fulfill their job responsibilities.

   You are registering for the Service for your own personal use as a patient and not in connection with a covered entity (e.g., a hospital or physician/physician practice), you understand and agree that Hollister is not a healthcare provider or other "covered entity" for the purposes of the Health Privacy Laws and that Personal Information provided by you to Hollister or through the Service, even if it is health information will not be subject to HIPAA requirements or deemed Protected Health Information for such purposes.

   
   

5. How long do we process your data?

   Your personal data is stored by Hollister and/or Dansac to the extent necessary for the performance of our obligations and for the time necessary to achieve the purposes for which the personal data is collected, in accordance with applicable data protection laws. When Hollister no longer needs to process your personal data, we will delete it from our systems and/or records and/or take steps to properly anonymize it so that you can no longer be identified from it, unless we need to keep your personal data to comply with legal or regulatory obligations to which Hollister is subject.

   
   

6. How do we protect your data?

   We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.

   Technical and organizational security measures may include encryption and pseudonymization of data, logging, access restrictions, keeping backup copies, giving instructions to our employees, entering confidentiality agreements, and monitoring

   
   

7. What are your rights?

   Depending on your state of residence, you may also have rights, subject to the conditions set forth in applicable law:

   • Right of access: You have the right to obtain from us confirmation as to whether or not your personal data is being processed, and, where that is the case, to request access to the personal data. This right of access includes, inter alia, the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. You also have the right to receive a copy of your personal data which we process about you. For additional copies requested by you, we may charge a reasonable fee based on administrative costs.
   • Right to rectification: You have the right to have your personal data corrected where it is incomplete or inaccurate.
   • Right to erasure (right to be forgotten): You have the right to ask us to delete your personal data, including (i) where your personal data is no longer necessary for the purpose(s) for which it was processed; (ii) if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal data; (iii) if you object to the use of your personal data (as set out below); (iv) if we have used your personal data unlawfully; or (v) if your personal data needs to be erased to comply with a legal obligation.
   • Right to restriction of processing: You have the right to restrict our processing of your personal data in certain circumstances, such as (i) where you think your personal data is inaccurate and only for such period to enable us to verify the accuracy of your personal data; (ii) the use of your personal data is unlawful and you oppose the erasure of your personal data and request that it is suspended instead; (iii) we no longer need your personal data but your personal data is required by you for the establishment, exercise or defense of legal claims; or (iv) you have objected to the use of your personal data and for such period to enable us to verify whether our grounds for the use of your personal data override your objection.
   • Right to data portability: You have the right to obtain your personal data in a structured, commonly used and machine-readable format, and for it to be transferred to another organization where it is technically feasible. The right only applies where the use of your personal data is based on your consent or for the performance of a contract, and when the use of your personal data is carried out by automated means.
   • Right to object: You have the right to object on grounds relating to your particular situation, or where personal data are processed for direct marketing purposes at any time to the processing of your personal data by us and we can be required to no longer process your personal data. Such a right to object may not exist, in particular, if the processing of your personal data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

   If you wish to exercise the above-mentioned rights in relation to us (or with one of our Group Companies), please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 1. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).

   Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.

   
   

8. Can we update this Privacy Notice?

   We can change this Privacy Notice at any time. The version published on this website is the current version.

   
   Last updated: [09/20/2022]
   Hollister Privacy Team