Website Privacy Policy

Millar, Inc. Privacy Policy

Millar, Inc. (Millar, we or us) has prepared this privacy policy (the Privacy Policy) to explain how we use any personal data that can be used to identify you as an individual (Personal Data) we collect about you when you use this website and the choices you have concerning how the Personal Data is being collected and used.

Further notices highlighting certain uses we wish to make of your Personal Data together with the ability to opt in or out of selected uses may also be provided to you when we collect Personal Data from you.

The website is not intended for children and minors and we do not knowingly solicit or collect Personal Data from children and minors. As a parent or legal guardian, please do not allow your children to submit Personal Data without your permission. We will not intentionally collect any Personal Data from children under the age of 18. Please contact us if you think that we have collected Personal Data from a child under the age of 18.

This Privacy Policy contains general and technical details about the steps we take to respect your privacy concerns. We have organized the Privacy Policy by major processes and areas so that you can review the information of most interest to you. 

  1. Personal Data we collect
  2. How we use Personal Data
  3. How we share Personal Data
  4. How we transmit, protect and store Personal Data
  5. Your rights
  6. Contacting us
  7. Cookies
  8. Changes to the Privacy Policy
  9. Other Sites
  10. Careers

 

1. Personal Data we collect


1.1 We may collect and process the following Personal Data about you.

(a) Personal information about you ► personal information that you provide to us, such as when you create a user account, submit a quote request form, register for a webinar or to access our Knowledge Center, or request to download product or application literature, or submit a question, including your name, telephone number, e-mail address and street address;

(b) Your employment submission information ► for career-related purposes, you may submit certain Personal Data if you wish to be considered for potential employment – please see our Recruitment Data Protection Notice for further information about the Personal Data we collect for this purpose and how it is processed

(c) Your transactions with us ► for purchases of Millar products, we collect your itemized spending to prepare your invoice and purchasing history.  Because you cannot purchase Millar products directly from this website, many transactions are through our distributors:  ADInstruments for research pressure and pressure-volume systems, catheters and accessories, Kaha Sciences for life sciences telemetry products, and our authorized distributors listed here https://millar.com/sales-and-support/international-sales-support for all other Millar products;

(d) Our correspondence ► if you contact us such as when you make a general inquiry, request technical support, or request a quote, we may keep a record of that correspondence;

(e) Survey information ► we may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey;

(f) Your use of our website ► details of your visits to our website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access;

(g) Your viewing of videos on our website ► Millar uses a video hosting service called Wistia to allow the viewing of webinars and other informational videos on the website. Wistia uses cookies to track engagement of the videos to determine how long they were played and the number of views. For more information on Wistia cookies, visit https://wistia.com/privacy; and  

(h) Do-not-track ► Because there is not yet a consensus on how companies should respond to web browser-based “do-not-track” (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time.  If you would like additional information about online tracking and various opt-out mechanisms, please see https://www.eff.org/issues/do-not-track  

In addition, we use Google AdWords, so we are advertising the website online through a form of tracking called remarketing – third-party vendors, including Google, show our ads on various sites across the Internet, and use cookies to serve you ads based on your past visits to this website.  You can opt out of Google's use of cookies by visiting Google's Ads Settings https://support.google.com/ads/answer/7395996  Alternatively, you can opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page. http://optout.networkadvertising.org/

Please note that not all tracking will stop even if you delete cookies.

1.1 We do not collect Personal Data in the following circumstances:

(a) When you merely browse the website ► except as specified in Your use of our website above, we do not collect Personal Data when you are simply browsing the website unless you voluntarily and knowingly provide it to us, for example by accessing our website from a link in an e-mail that we send to you or where you have created a profile and you log-in to your user account.

1.2 We may collect your Personal Data from you directly.  We may also collect Personal Data from third parties including agents that place orders on your behalf.

1.3 If you provide us with Personal Data about other individuals, you must inform such individuals that you have provided us with their details and let them know where they can find a copy of this Privacy Policy.

2. How we use Personal Data

2.1 We may use your Personal Data in the following ways.

Please note that use of Personal Data under EU data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the grounds in respect of each use in this Privacy Policy. An explanation of the scope of the grounds available can be found here.

(a) To provide you with data, publications, videos, and webinars that you request ► to provide you with data and publications that we make available, to register you for webinars that you request, to enable you to see videos and previous webinars,  and to facilitate any special requests or assistance that you have asked for.

Use justification: contract performance, legitimate interests (to enable us to perform our obligations and provide services to you);

(b) To complete your purchase ►  to provide you a requested quotation and to deliver your orders when you purchase Millar products.

Use justification: contract performance, legitimate interests (to enable us to perform our obligations and provide services and products to you);

(c) To customize our services and products to you ►  to maintain our standard of customer service and give attention to your individual business needs, we collect and store specific information about you, such as your product purchases and other special requests. For example, if you are a repeat purchaser of catheters, we may store your Personal Data in our system to serve you better upon your return.

Use justification: legitimate interests (to allow us to provide customized services and products to you);

(d) To register you as a user ► to create your user account. You can set up, review or update your user account information (including your Personal Data) online at any time.

Use justification: contract performance, legitimate interests (to allow us to onboard you as a user);

(e) To provide marketing materials to you ► to provide you with updates and offers, where you have chosen to receive these. We may send you information about Millar products and the former Millar products now offered by Kaha Sciences by postal mail or e-mail and, where required by law, we will ask for your consent at the time we collect your Personal Data to conduct any of these types of marketing. Such marketing will consist of periodic contact via e-mail to provide you information about special offers and promotions that may be of interest to you. These communications will relate to offers relating to Millar products and former Millar products now offered by Kaha Sciences. We typically use third party e-mail service providers to send e-mails. These service providers are contractually prohibited from using your e-mail address for any purpose other than to send e-mails related to Millar’s operations. We provide you the ability to unsubscribe from all marketing communications. Every time you receive an e-mail, you will be provided with the choice to opt-out of future e-mails by following the instructions provided in the e-mail. You may also opt-out of receiving promotional materials by updating your Email Preferences, or contacting us as set out in section 6 below.

Use justification: consent (which can be withdrawn at any time - please see paragraph 5.1 below); for postal marketing, legitimate interest (to keep you updated with news in relation to our products and services);

(f) For recruitment purposes ► to enable us to review your employment application and conduct our recruitment efforts to fill open job positions - please see our Recruitment Data Protection Notice for further information about the Personal Data we collect for this purpose and how it is processed.   

Use justification: contract performance, legitimate interests (to enable us to perform our obligations and consider your employment application) – please see our Recruitment Data Protection Notice for further information;

(g) For analytics and profiling ► to tailor our marketing to you. In connection with our marketing activities, we analyze information that we collect from customers to determine what offers are most likely to be of interest to different categories of customers in different circumstances and at different times. We call this the creation of “segments”. For example,  we combine Personal Data that we have collected about a customer from an order with our authorized distributor in Japan with Personal Data that we have collected about the same customer from another authorized distributor. Such Personal Data include customer behavioral information such as transaction history, spending pattern, preferences, service requests and interactions with us. From time to time, we will assess the Personal Data that we hold about you in order to assign you to a particular segment. We may use the segment that you have been assigned to in order to tailor our marketing communications to include offers and content that are relevant to you. We may also use this method to avoid sending you offers that are inappropriate or unlikely to be of interest to you.  You have the right to opt out of such analysis of your Personal Data that we use to tailor the direct marketing that we send to you, at any time. You can exercise this right by contacting us as set out in section 6 below. 

Use justification: consent (which can be withdrawn at any time - please see section 5.2 below), legitimate interests (to enable us to tailor our marketing to you);

(h) To comply with our legal obligations ► to comply with our legal obligations such as financial reporting requirements imposed by our auditors and government authorities, and to cooperate with law enforcement agencies, government authorities, regulators and/or the court in connection with proceedings or investigations anywhere in the world where we are compelled to do so. 

Use justification: legal obligation, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities);

(i) To handle incidents and process any claims we receive ► to handle any accidents and incidents such as liaising with emergency services and to handle any claims made by customers such as personal injury claims;

Use justification: vital interest, legal claims, legitimate interests (to ensure that incidents and accidents are handled appropriately and to allow us to assist our customers);

(j) To improve our services and products ► to assist in developing new services and products and to improve our existing services and products.

Use justification: legitimate interests (to allow us to continuously improve and develop our services);

(k) To help our website functions correctly ► to help content from our website get presented in the most effective manner for you and for your computer

Use justification: contract performance, legitimate interests (to allow us to provide you with the content and services on the website);

(l) In connection with any reorganization of our business ► to analyze, enable the analysis of, or affect any proposed sale, merger, asset acquisition, or reorganization of our business.

Use justification: contract performance, legitimate interests (to allow us to continue providing services to you and to allow us to change our business).

3. How we share Personal Data

3.1 We may share your Personal Data in the following ways.

(a) Third party service providers who process Personal Data on our behalf to help us undertake the activities described in section 2  ► we may permit selected third parties such as ADInstruments, CD Leycom, Kaha Sciences, business partners, suppliers, service providers, agents, contractors and other Millar companies to use your Personal Data for the purposes set out in section 2, including mail houses and e-mail service providers that we engage to send and disseminate promotional materials for Millar products, data center providers that host our servers and third party agents that process mailing, orders, and purchases of on our behalf. These parties are contractually prohibited from using Personal Data for any purpose other than for the purpose specified in their respective contracts and will be subject to obligations to process Personal Data in compliance with the same safeguards that we deploy.  We also provide non-personally identifiable information to these parties for their use on an aggregated basis for the purpose of performing their contractual obligations to us. We do not permit the sale of Personal Data to entities outside of Millar for any use unrelated to our group operations or use of Personal Data by third-party for their own purposes.

Use justification: contract performance; legitimate interests (to enable us to perform our obligations and provide services to you and in respect of postal marketing to keep you updated with news in relation to our products and services); in respect of marketing, consent (which can be withdrawn at any time - please see paragraph 5.1 below);

(b) Law enforcement agencies, government authorities, regulators and the court in order to comply with our legal obligations or to handle incidents/ claims ► we may disclose your Personal Data when required by relevant law or court order, or as requested by other government or law enforcement authorities to assist with proceedings or investigations. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.  This also applies when we have reason to believe that disclosing the Personal Data is necessary to obtain legal advice, to identify, investigate, protect, contact, or bring legal action against someone who may be causing interference with our guests, visitors, associates, rights or properties, or to others, whether intentionally or otherwise, or when anyone else could be harmed by such activities.

Use justification: vital interest, legal obligation, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities and to ensure that incidents and accidents are handled appropriately and to allow us to assist our customers)

(c) Third parties who require such data in connection with a change in the structure of our business ►  in the event that we (or a part thereof) are (i) subject to negotiations for the sale of our business or (ii) sold to, merge with, or sell substantially all of our assets to a third party or (iii) undergo a reorganization, you agree that any of your Personal Data which we hold may be transferred to that reorganized entity or third party and used for the same purposes as set out in this Privacy Policy, or for the purpose of analyzing any proposed sale or re-organization. We will ensure that no more of your Personal Data is transferred than necessary.

Use justification: contract performance, legitimate interests (to allow us to continue providing services to you and to allow us to change our business)


3.2 This Privacy Policy does not apply to our processing of personal information on behalf of, or at the direction of, third-party providers (for example, ADInstruments) who may collect personal information from you and provide it to us. In this situation, we would merely act as a data processor and thus advise you to review applicable third party providers’ privacy policies before submitting your personal information.

Use justifications

We note the grounds we use to justify each use of your information next to the use in the How we use Personal Data and How we share Personal Data sections of this policy.

These are the principal legal grounds that justify our use of your Personal Data: 

Consent: where you have consented to our use of your Personal Data (you will have been presented with a consent form in relation to any such use)
Contract performance: where your Personal Data is necessary to enter into or perform our contract with you.
Legal obligation: where we need to use your Personal Data to comply with our legal obligations.
Legitimate interests: where we use your Personal Data to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
Legal claims: where your information is necessary for us to defend,  prosecute or make a claim against you, us or a third party.
Vital interest: where we need to process your Personal Data to protect the vital interest

 

4. How we transmit, protect and store Personal Data

Security over the internet

4.1 It is important to note that all e-mail communication is not secure. There is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by e-mail, for example, from the “Contact Us” section. We recommend that you do not include any sensitive information including credit card details when using e-mail or using any public computers/public WIFI. Our e-mail responses to you may not include any sensitive or confidential information. Please bear in mind that no security system or system of transmitting information over the Internet is guaranteed to be secure.

4.2 You should always close your browsers when you have finished completing a form. Although the session will automatically terminate after a short period of inactivity, it is easier for a third party to gain access to your profile whilst you are logged onto your account and accessing Millar data files.

4.3 We treat all Personal Data that you provide to us as confidential information. To prevent Personal Data from unauthorized access or leakage, we have adopted and regularly monitor our group’s security and data privacy policies and procedures. We use SSL protocol – an industry standard for encryption over the Internet, to protect sensitive Personal Data. This ensures that your sensitive Personal Data is encrypted as it travels over the Internet. You will know that you are in a secure mode when the security icon (such as a lock) appears on the computer screen.

Security controls

4.4 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

4.5 Millar trains its employees and staff on the importance of data privacy and protection. Our Privacy Policy is updated as required to reflect any changes in applicable laws and developments in best practice procedures. Further, we limit the number of individuals within the companies with access to Personal Data to those directly involved in the process of providing services to you.

4.6 We store certain customer information and purchase details in our Customer Information System. This system uses secured customer databases stored on a dedicated server located in a data center in the United States hosted by a third party service provider. Our onsite database is hosted on a local server only accessible by username and password. Our server resides behind firewalls to protect Personal Data collected from you against unauthorized or accidental access. Because laws applicable to personal information vary by country, our business operations may put in place additional measures that vary depending on the applicable legal requirements.

Data transmission across international borders

4.7 As a global company, we endeavor to provide you with the same outstanding service in the European Economic Area, as you would find in Houston or Auckland. To achieve this goal, we have established a global network comprised of properties, offices, global customer service centers, data centers, trusted service providers, and trained associates around the globe. The nature of our business and our operations require us to transfer your Personal Data to other authorized distributors, centers of operations, data centers, or service providers that may be located in countries outside of your own* for the purposes mentioned in this Privacy Policy. Although the data protection and other laws of these various countries may not be as comprehensive as those in your own country, Millar will take appropriate measures, including contractual clauses, to secure the transfer of your Data to recipients (which may be internal or external to Millar) located in a country with a level of protection different from the one existing in the country in which your Data is collected.

* Currently, Personal Data may be transferred to our headquarters in Houston, Texas as well as other countries where we are present, including Australia, China, Japan, New Zealand, the United Kingdom. We also use third-party service providers who are located in the United States of America and the United Kingdom to process shipping and business transactions.

4.8 Where your Personal Data may be transferred from inside the European Economic Area (EEA) to a country outside the EEA in which data protection laws may be of a lower standard than in the EEA, Millar will impose the same data protection safeguards that we deploy inside the EEA, including the following:

(a) Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions.

(b) In countries which have not had these approvals, (see the full list here https://ec.europa.eu/info/law/law-topic/data-protection_en), we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements. Please contact us as set out in section 6 below if you would like to see a copy of the specific safeguards applied to the export of your personal information.

Retention

4.9 Your Personal Data will be stored for the period of time required or permitted by law in the jurisdiction of the operation holding the information (for example certain transaction details and correspondence may be retained until the time limit for claims in respect of the transaction has expired or in order to comply with regulatory requirements regarding the retention of such data). So if information is used for two purposes we will retain it until the purpose with the latest period expires, but we will stop using it for the purpose with a shorter period once that period expires.

4.10 Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed. 

5. Your rights

Opt-out of marketing

5.1 You have the right to ask us not to process your Personal Data for marketing purposes. We will inform you if we intend to use, or disclose to third parties, your Personal Data for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the data collection forms. You can also exercise the right at any time by contacting us as set out in section 6 below.

Other rights

5.2 Subject to various exceptions and data protection laws in your country, you may have the following rights:

(a) Access: you can ask us to provide you with further details on the use we make of your Personal Data and a copy of the Personal Data we hold about you;

(b) Correction: you can ask us to correct any inaccuracies in the Personal Data we hold about you;

(c) Complaint: if you are not satisfied with our use of your Personal Data or our response to any exercise of these rights, you have the right to complain to the data protection authority in your country;

(d) Erasure: you can ask us to delete your Personal Data if we no longer have a lawful ground to use;

(e) Withdrawal of consent: where processing is based on consent (e.g. marketing), you can withdraw your consent to processing so that we stop that particular processing 

(f) Object to processing: you have the right to object to other types of processing (e.g. analytics and profiling activities carried out in relation to your Personal Data), unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;

(g) Restriction: you can restrict how we use your Personal data, for example, whilst we are verifying the accuracy of your Personal Data or where we are verifying the grounds that use as the basis of holding your Personal Data;

(h) Portability: where technically feasible, you have the right to ask us to transmit the Personal Data that you have provided to us to a third party in a structured, commonly used and machine-readable form.

Updating or modifying information

5.3 We will use reasonable endeavors to ensure that your Personal Data is accurate. In order to assist us with this, you should notify us of any changes to the Personal Data that you have provided to us by updating your details in your Email Preferences or by contacting us as set out in section 6 below.

Notifications in the event of breach

5.4 In the unlikely event of a data breach, we are prepared to follow any laws and regulations which would require us to notify you of the disclosure of private information.

California Privacy Rights

5.5 Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer data which we share with our group companies, affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this information, please submit a written request to the following address: info@millar.com

6. Contacting Us

6.1 If you have any questions about this Privacy Policy or our processing of your Personal Data, please contact us at :

Chief Privacy Officer
Millar Inc.
6001-A Gulf Freeway
Houston, Texas 77023
Phone: +1 832.667.7000
Fax: +1 713.714.8497
Email: info@millar.com

7. Cookies

7.1 Our website uses cookies to distinguish you from other users of the website. This helps us provide you with a good experience when you browse our website and also allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookies Policy.

Google Analytics

7.2    This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (but with an anonymized IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of this website. For details please visit http://www.google.com/intl/en/policies/privacy/

Pardot Cookies

7.3 Millar uses a marketing automation application called Pardot to analyze how visitors use this website. It uses javascript and cookies to identify website visitors, analyze email campaigns and track website forms. For more information on Pardot cookies, visit www.pardot.com/company/legal/privacy-policy/

Wistia Cookies

7.4 Millar uses a video hosting service called Wistia to allow the viewing of webinars and other informational videos on the website. Wistia uses cookies to track engagement of the videos to determine how long they were played and the number of views. For more information on Wistia cookies, visit https://wistia.com/privacy.

8.  Changes to the Privacy Policy

8.1 In the future, we may need to make additional changes. All additional changes will be included in the latest Privacy Policy published on this website or mobile application so that you will always understand our current practices with respect to the information we gather, how we might use that information and disclosures of that information to third parties. You can tell when this Privacy Policy was last updated by looking at the date at the bottom of the Privacy Policy. If the changes are material, we will indicate this clearly on the website. Any changes to our Privacy Policy will become effective upon posting of the revised Privacy Policy. We will seek your express consent to any changes to how we use or disclose your Personal Data if required by law but otherwise use of this website or our services following such changes constitutes your acknowledgment of the Privacy Policy then in effect.  Any changes will be effective only after the effective date of the change and will not affect any dispute arising prior to the effective date of the change.

9. Other Sites

9.1 The website or mobile application may contain links to other third-party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.

10. Millar Careers

10.1 Our Millar Careers page allows individuals who wish to be considered for potential employment to complete the required information and attach their resume for consideration. We will not use the information you provide for any purpose other than to determine your qualifications for potential employment at Millar.

11. Additional Rights

11.1 Applicable laws may give you additional rights that are not described in this Privacy Policy.

 

Last Updated: May 18, 2018