The Site Collects Your Information
We collect personal information when you choose to provide it to us, including when you:
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.
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.
Cookies and Web Beacons
Cookies: To enhance your experience on the Site, we place "cookies" on your computer or device. Cookies are small text files that we place in your computer or device to store your preferences. Other information you provide to us may be linked to the data stored in the cookie. A cookie assigns a unique numerical identifier to your Web browser or device, and may enable us to recognize you as the same user who has used our Site, and relate your use of the Site to other information about 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.
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.
How Aspen Uses Your Information
We use personal information to facilitate and improve our services and communicate with you in the following ways.
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.
Aspen May Disclose Your Information
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:
- Providing customer services including fulfilling orders, delivering packages, and communicating with you about your order
- Payment processing
- Sending, evaluating, and improving marketing communications
- Conducting research and analysis
- Measuring and improving the performance of the Site
- Maintenance services
- Verifying your identity and preventing fraud
- Developing and improving Aspen products and services
- Registering your Account
- Data analytics
- Detecting, preventing and remediating fraud or other potentially prohibited or illegal activities.
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.
This might sound obvious, but we may also disclose your personal information with your consent.
Email. You can remove yourself from receiving our promotional e-mails by emailing us at email@example.com or by clicking the "unsubscribe" button that appears on our promotional e-mails. If you wish to disable web beacons in our email messages, turn images "off" in your email client (e.g., Outlook or Outlook Express) as available. Please refer to the settings or options menu in your email client for more information. If you would like to opt-out of Aspen sharing your information with third parties (such as data vendors) for non-Aspen related marketing purposes, send an email to firstname.lastname@example.org.
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.
Third Party Sites
The Site may contain links to other websites and other websites may reference or link to our Site. These other domains and third-party websites are not owned or controlled by us. We encourage our users to read the privacy policies of each and every website and application that they interact with. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk. We try to work only with Third Party Services that share our respect for your privacy, but we cannot take responsibility for their practices, content, or privacy policies.
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.
Security of Your Personal Information
Retention of Personal Information
We will retain your personal information for as long as necessary to fulfill the purpose for which it was collected. Please note that we may continue to retain personal information for purposes of our legitimate interests, including to comply with our legal obligations, resolve disputes, and enforce our agreements. Data subjects located in Europe have the right to request that we delete their personal information as set forth in the "International Users" section.
We do not knowingly collect, maintain, or use personal information from children under 16 years of age, and no part of the Site is directed to children under the age of 16. If you learn that your child has provided us with personal information without your consent, you may alert us at email@example.com. If we learn that we have collected any personal information from children under 16, we will promptly take steps to delete such information and terminate the child’s account.
EU data subjects have certain rights with respect to your personal information that we collect and process. We respond to all requests we receive from individuals in the EEA wishing to exercise their data protection rights in accordance with applicable data protection laws.
- Access, Correction or Deletion. You may request access to, correction of, or deletion of your personal information. Please note that even if you request for your personal information to be deleted, certain aspects may be retained for us to: meet our legal or regulatory compliance (e.g. maintaining records of transactions you have made with us); exercise, establish or defend legal claims; and to protect against fraudulent or abusive activity on our Service. Data retained for these purposes will be handled as described in “Data Retention” section, above.
- Objection. You may object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Restriction. You have the right to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Portability. You have the right to request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw Consent. If we have collected and processed your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- File a complaint. You have the right to file a complaint with a supervisory authority about our collection and processing of your personal information.
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.
Location of Processing by Aspen
California Privacy Rights
If you are a California resident, you also have the ability to ask us for a notice identifying the categories of personal information, as defined by California Civil Code Section 1798.83, we share with our affiliates and/or third parties for their direct marketing purposes and the contact information for such affiliates and/or third parties (under California Civil Code Sections 1798.83-1798.84). If you are a California resident and would like a copy of this notice, please submit a written request to firstname.lastname@example.org.
For Non-EU Data Subjects
Aspen Medical Products, LLC
6481 Oak Canyon, Irvine, California 92618
Aspen Medical Products, LLC
6481 Oak Canyon, Irvine, California 92618
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
Aspen Medical Products GmbH
Im Leuschnerpark 4, 64347 Griesheim
Telephone: +49 (0) 6155 89791-0
Fax: +49 (0) 6155 89791-66
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: email@example.com.
Our regulatory authority for data protection is:
The Hessian Data Protection Officer
PO Box 31 63
The Hessian Data Protection Officer
PO Box 31 63
Effective Date: 08.01.2018