The Privacy Policy explains how Aspen, as the controller of the personal data you provide to us, may collect, use, and disclose the personal information of users of this site, consumers of our goods or services, and others. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information. We do not consider personal information to include information that has been anonymized such that it does not allow a third party to easily identify a specific individual.

Register an account. The Site gives you the option of creating a user account via the customer login page (an “Account”). If you decide to create an Account, you will provide us with certain personal information, such as your user name and password. You are not required to register to use the Site. We collect this information to identify who you are, to provide you with the service or information you requested, and/or to facilitate your participation in an on-line forum or community. We may also use this information for other purposes, such as promotional and marketing purposes, in accordance with this Privacy Policy and not in violation of applicable law.

Purchase an Aspen product. When you purchase an Aspen product using the Site, you are given the option of logging into an Account or checking out as a guest. In either case, when you purchase an Aspen product, you will provide us with personal information, such as your name, email address, and shipping address. We use this information for purposes such as to process your orders, to better assist you when you visit or contact us in the future, as well as to improve our product offerings when we send you information about these in accordance with this Privacy Policy.

Make a payment. When you make a payment through the Site, you may need to provide personal information to our third-party payment processors. This may include your telephone number, credit card number, credit card security code and credit card expiration date. This information is used to process your payment, verify your identity, and prevent fraud. To learn more about the third-parties to whom we provide this information, please see the “Third Party Processors” section, below.

Submit information to the Site. We collect information you submit to the Site. For example, when you post a review of an Aspen product on the Site or refer a friend to Aspen using the Site, the Site will collect the information in your submission to the Site, including any personal information. If you choose to submit content to any public area of the Site, such content will be considered “public” and may be viewed, copied, shared, or otherwise disseminated without our knowledge.

Communicate with us. We may also collect personal information from you when you communicate with us. For example, you may send us personal information by writing an email to us, asking a question through the "Ask a question" button on the Site, subscribing to an Aspen newsletter or registering for an event hosted by Aspen. If you contact us, we may keep a record of that correspondence. We retain this information as necessary to assist you in the future, for instance with any further queries you may have. We also use your feedback, suggestions and comments to monitor and/or improve our publications, product offerings, and Services, among other things.

Take a survey. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include personal information. For example, you may be asked to provide contact information as well as information about your gender, date of birth, travel habits and travel preferences. Information obtained through surveys is aggregated and used internally. We may also share survey information with third-parties in an aggregated form that does not personally identify you. In the event personal information is requested as part of a survey, such personal information will only be provided to unaffiliated third parties after ensuring that depending on the circumstances you have either consented or not objected.

Passive collection. The Site collects and stores information that is generated automatically as you use it, including your preferences and anonymous usage statistics. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. We use this data to analyze trends in the aggregate and administer the site. Non-personal information that we passively collect may be combined with other information about you, including personal information.

Tracking technologies. Aspen and its partners use cookies, pixels (sometimes also referred to as "web beacons"), server logs, and other similar technology to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. Non-personal information that we collect using these technologies may be combined with other information about you, including personal information. Please see the section on “Cookies and Web Beacons” for more information.

Information provided by third parties. Aspen may collect information about you from third parties or supplement the information we collect from you with additional records received from third parties. We also collect information from third parties in order to enhance our ability to serve you, to customize our content to you, and to offer you information that we believe may be of interest to you.

Most browsers automatically accept cookies. You can set your browser option so that you will not receive cookies and you can also delete existing cookies from your browser. However, you may find that some parts of the site will not function properly if you have refused cookies or similar tracking technologies and you should be aware that disabling cookies or similar tracking technologies might prevent you from accessing some of our content. However, your viewing of editorial content may be hampered. If you wish to block cookies, go to http://www.allaboutcookies.org/ to find out how, or check your browser’s instructions.

Local Shared Objects: Local shared objects, such as Flash cookies, also may be stored on your computer or device. Local shared objects operate a lot like cookies, but cannot be managed in the same way. Depending on how local shared objects are enabled on your computer or device, you may be able to manage them using software settings. For information on managing Flash cookies, for example, see http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

HTML 5: HTML5, the language some Web sites are coded in, may be used to store information on your computer or device about your Site usage activities. This information may be retrieved by us to help us manage our Site, such as by giving us information about how our Site is being used by our visitors, how they can be improved, and to customize them for our users.

Cache Cookies: Cache cookies, such as eTags, may be used to identify your computer or device as the same computer or device that visited our Site in the past.

Web Beacons: Our website may also use small pieces of code called "web beacons" or "clear gifs" to collect advertising metrics, such as counting page views, promotion views, or advertising responses. A web beacon is an electronic image called a single-pixel or clear GIF. Web beacons can recognize certain types of information, such as a user's cookie number, time and date of a page view, and description of the page where the web beacon is placed. These web beacons may be used to deliver cookies that conform to our cookie policy above.

We use cookies, Local Shared Objects, HTML5, cache cookies, web beacons, and/or clear gifs to understand usage of the Services and to improve our content and offerings and to deliver advertisements that you might be interested in. For example, we use cookies to personalize your experience on our Site (e.g., to recognize you by name when you return to our site, to save your password in password-protected areas, to enable shopping carts, or to tailor content or product and service offerings).

Mobile Device IDs and Location-Based Information: Certain mobile devices, including smart phones and tablet devices, contain unique device IDs that can be used to identify their physical location. Some mobile device IDs are persistent, while others may be resettable by accessing the device’s privacy settings. Mobile devices also typically transmit caller ID data (which may include a phone number) when used to transmit a telephone call or text message. When you use mobile devices to access our Site, we may collect and transmit unique device IDs and collect caller ID data, as well as other information about your device, including without limitation, your wireless carrier, the make, model, operating system, capacity and settings of your device, the names, package IDs and versions of other software you have downloaded to your device and information about how you interact with and navigate within our Site. With your consent, we or our authorized service providers and partners also may use precise geolocation technology such as GPS or Wi-Fi triangulation or mobile Bluetooth beacon technology to collect information about the exact location of your mobile device. Precise location information may be collected both while you are using one of our mobile applications and continuously over time while our apps are not in use but are running in the background of your device. You can withdraw your consent to the further collection and use of your precise device location data through any of our mobile apps by accessing your device’s privacy settings as further explained below in "Your Choices” section, below. For information about how to reset your advertising identifier and your other opt-out choices relating to interest-based advertising in mobile applications, see "Your Choices” section, below.

These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf.

Internal and service-related usage. We use and retain information, including personal information, to improve and facilitate the Site and our services. We may also use such data to help us deliver targeted advertising to consumers that is displayed on both Aspen websites and unaffiliated websites, to analyze interactions with and performance of our Site, to measure the effectiveness of advertising on behalf of our advertising partners, and to identify the audience most likely to respond to an advertisement. We may also use data from third parties (such as data vendors) pursuant to their own privacy policies and enhance information (including personal information) that we have collected with such third-party data. We believe that the use of such information is helpful to providing users with better services. However, if you would like to opt-out of these interest-based advertisements, please follow the opt-out process described below under “Your Choices.”

Communications. We may send you emails to the email address you provide to us to verify your Account and for informational and operational purposes, such as account management, customer service, policy updates, or system maintenance.

Marketing. We may use information about you, including personal information, to send you information about Aspen’s products and services.

Non-Personal Information. We may use anonymized, aggregated or other data that is not personal information for any purpose, including marketing. These uses may include but are not limited to analyzing interactions with and performance of the Site, enabling us to improve our Site and services, and sharing such information with our business partners, affiliates, or any other third party. Similarly, we may enhance any such anonymized and aggregated data collected via our Site with other information collected from our business partners.

Internal business purposes. We may use your personal information to extrapolate trends.

Third Party Vendors and Service Providers. We may share personal information with our vendors and service providers who perform services on our behalf. These third parties are authorized to use your personal information only as necessary to provide these services to us. These entities may store and process personal information in countries other than the United States or your own country where privacy laws may not be as protective as those in your jurisdiction. For more information on international transfers, see the section "Location of Processing by Aspen" below. All of our service providers are required to maintain the confidentiality and security of your personal information and to use it only in compliance with applicable data privacy laws, and are prohibited from using or disclosing your personal information for any purpose other than providing the services on our behalf or as otherwise not prohibited by applicable law; although we may permit them to use aggregate information which does not identify you or de-identified information for other purposes. Third party vendors and service providers may receive your personal information to help facilitate the following:

Displaying to other users. The content you post to the Site may be displayed publicly on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review, along with your review. We are not responsible for privacy practices of the other users who will view and use the posted information.

As required by law and similar disclosures. We may access, preserve, and disclose your personal information, other account information, and content if we believe doing so is required or appropriate to comply with law enforcement requests and legal process, such as a court order, government request, or subpoena. We may also access, preserve, and disclose your personal information, other account information, and content if we believe in good faith that disclosure is necessary to protect yours’, ours’ or others’ rights, property, or safety, or investigate fraud.

Merger, sale, or other asset transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. The use of your personal information following any of the foregoing events should be governed by the provisions of the Privacy Policy in effect at the time such personal information was collected.

This might sound obvious, but we may also disclose your personal information with your consent.

We will try to comply with any opt-out requests as soon as reasonably practicable. Even if you opt out of receiving promotional correspondence from us, we may still send you non-promotional emails in connection with your relationship, activities, transactions, and communications with us. If you no longer want to receive third-party email offers, simply follow the advertiser's unsubscribe link or opt-out instructions that should be included in every commercial message you receive from them.

Analytics Cookies. As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. We engage third parties like Google Analytics and Crazy Egg to track and analyze usage and browsing patterns of our users, as described above. You can choose not to be included in Google Analytics go to https://tools.google.com/dlpage/gaoptout. You can choose not to be included in Crazy Egg analytics go to https://www.crazyegg.com/opt-out and to read about Crazy Egg’s data collection practices go to https://www.crazyegg.com/privacy.

Advertising Cookies. To manage our advertising on other sites, we engage third party advertising partners like Google DoubleClick. These third-party partners may use technologies such as cookies to gather information about your activities on the Site and other sites in order to provide you advertising based upon your browsing activities and interests. Certain of our third-party advertising partners participate in self-regulatory organizations, and those organizations operate websites that give you the ability to opt-out of receiving targeted ads from those partners. You can access these websites, and also learn more about targeted advertising and privacy, at Network Advertising or AboutAds. To be clear, whether you are opting out by adjusting your browser/device settings or by using a website established by a self-regulatory group, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device.

Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings. To exercise choice over the companies participating in the DAA’s separate choice tool for the collection of cross-app data on a mobile device, download the DAA’s AppChoices app. If you authorized us and/or our service providers to collect and/or share information about the precise location of your device through a mobile application, you can always withdraw your consent and prevent the further collection and sharing of your precise device location information by accessing your device’s location privacy settings. Each operating system, iOS for Apple devices, Android for Android devices and Windows for Microsoft devices, provides its own instructions on how to turn off precise location sharing. Access the privacy settings for your mobile device or contact your platform operator for more information.

The Site also contains links and interactive features with various social media platforms, such as Facebook, Twitter, Pinterest, Instagram, Snapchat, and Google+. These platforms are not owned or controlled by us. If you already use these platforms, their cookies may be set on your device when using our Site. You should be aware that personal information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes.

To file a request or take action on one of your rights, please contact us at the contact details provided. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

By choosing to visit the Site or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the State of California and the adjudication of any disputes arising in connection with Aspen or the Site will be in accordance with the Terms.

We will post any updates to the Privacy Policy on this web page, and the revised version will be effective when it is posted. If you are concerned about how your information is used, please bookmark this page and read this Privacy Policy periodically.

For EU Data Subjects
Aspen Medical Products GmbH
Im Leuschnerpark 4, 64347 Griesheim
Telephone: +49 (0) 6155 89791-0
Fax: +49 (0) 6155 89791-66
E-Mail: kontakt@aspenmp.de

To safeguard your rights, Aspen Medical Products GmbH has appointed a Data Protection Officer. You can reach the data protection team for inquiries concerning the protection of your personal data under: datenschutz@aspenmp.de.

Our regulatory authority for data protection is:
The Hessian Data Protection Officer
PO Box 31 63
65021 Wiesbaden

Effective Date: 08.01.2018