Micropump, Inc. Business Contact Privacy Notice

1. Introduction

This Privacy Notices to Business Contacts (“Notice”) describes the steps Micropump, Inc., 1402 NE 136th Avenue, Vancouver, Washington 98684, United States of America (“Company”), takes to protect the Personal Data that we Process about Business Contacts. The Company is commit-ted to the protection of the Personal Data that we process about you in line with the data pro-tection principles set out in the applicable Data Protection Law. This Notice informs you how we Process your Personal Data if you are one of our Business Contacts.

This Notice may be amended from time to time. The Company will post any change to this No-tice a reasonable period of time in advance of the effective date of the change.

2. Definitions

The following terms are used within this Notice and are defined as follows:

3. Identity and Contact Details of the Data Controller

The Company is responsible for Processing your Personal Data and is the Data Controller.
If you have any questions about this Notice, please contact us at Micropump, Inc.
1402 NE 136th Avenue, Vancouver, Washington 98684, United States of America mpvsales@micropump.com

4. Categories and Sources of Personal Data Processed

The Company Process different categories of Personal Data of our Business Contacts. These may include:

• Identity details, including name; information about your job title and hierarchical posi-tion; and educational level or work experience.
• Business contact details, including company address, business telephone number and e-mail address.
• Information you provide us during the course of our business relationship, including in response to corporate surveys or questionnaires; or other correspondence.
• Data from initiation, maintenance and execution of our business relationship, including performed and planned orders and related data such as delivery modalities or insurance coverages; user login and subscription data; use of our web services or newsletters; and data about your budget.
• Company data of our Corporate Partners, such as company name and company business registration number; information from our due-diligence or other onboarding proce-dures; or our Corporate Partner´s business needs.
• Data relating to the assertion or defense against legal claims, including the prevention of misconduct; compliance checks or investigations; and information regarding compli-ance violations or other infringements.

Most of the Personal Data we Process, you have provided directly to us. Other Personal Data may be provided by your employer, our Corporate Partners or other instances involved in the initiation of your business relationship and/or the execution of contracts with our Corporate Partners. In addition, we may process Personal Data which we permissibly obtain from publicly accessible sources (such as LinkedIn) or that are legitimately transmitted to us by third parties (such as credit agencies).

5. Purposes of Data Processing

The Company Processes Personal Data of Business Contacts for various business purposes in connection with your business relationship with the Company or our Corporate Partner:

• Partners, including to meet our contractual obligations; necessary due diligence and other onboarding requirements in regard to our Corporate Partners.
• For market analysis, including through surveys, to better understand the markets in which we do business; and for product and service development.
• For business communication and promotion of our products and services.
• For the fulfilment of legal obligations, including local tax and commercial law, as well as audits by governmental and regulatory authorities.
• For security control of the Micropump, Inc. physical premises or for IT security and data breach procedures.
• For asserting or the defense of legal claims or the prevention of misconduct, compli-ance violations or other infringements, such as routine inspections; internal investiga-tions; or dispute resolution cases.
• For customer services activities, such as responding to queries; or investigating and re-solving complaints.
• For customer relationship management, including listing important contacts for our business; connecting individuals with accounts of our Corporate Partners; listing im-portant stakeholders; and for customers surveys.
• For business process optimization, such as account management, including establishing and on-going management of business relationships; maintenance of a supplier or cus-tomer database; risk management; and activities geared toward preventing or detecting crime.

6. Legal Bases for Processing Personal Data

The Company Processes Personal Data relating to its Business Contacts based on multiple differ-ent legal bases:

• Once you have been informed about the intended Processing of your Personal Data and you have provided your consent. You may withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on your consent before the withdrawal. Article 6 GDPR.
• If the Processing of your Personal Data is necessary in order to carry out the con-tract concluded between you and us. Article 6 GDPR.
• If the Processing is necessary for the Company to comply with an applicable legal obligation. E.g., a court orders the release of certain information for legal proceed-ings). Article 6 GDPR.
• If the Processing is necessary for purposes of the legitimate interests pursued by the Company or by a third party except where overridden by Employee interests or fun-damental rights and freedoms of a Data Subject which require protection of Person-al Data. Article 6 GDPR. These legitimate interests can include:
• Management of our business relationships with our Corporate Partners, including meeting our contractual obligations; and corresponding com-munications in relation to our business relationship.
• The optimization of our business processes, including the implementa-tion of optimized customer service and/or customer management sys-tems, including with regard to you as an employee of our Corporate Partner.
• For the security of our property and infrastructure, such as IT Security and Data Breach Procedures; and measures to ensure operational, build-ing and plant safety and for business management;
• For the assertion and defence of legal claims and the prevention of compliance violations or other infringements;
• To grow the Company’s business by networking and market research and analysis of potential business opportunities as well as through direct marketing, including marketing activities and communications or in re-gard to product or service development processes.

7. Your Rights

The GDPR provides you with rights relating to the Processing of your Personal Data. These rights include:

• Request access to Personal Data about you (commonly known as a “data subject access request”). This enables you to receive information about the Personal Data we hold about you and to check that we are lawfully Processing it.
• Request rectification, correction, or updates to Personal Data that we hold about you. This enables you to correct any incomplete or inaccurate information.
• Request Personal Data to be transferred in machine-readable format (“data portability”) to the extent this right is relevant in the employment context.
• Request erasure of Personal Data. This enables you to request deletion or the removal of Personal Data where there is no legitimate reason for us to continue to Process it. You also have the right to ask us to delete or remove Personal Data where you have ex-ercised your right to object to Processing (see below).
• Request the restriction of Processing of your Personal Data. This enables you to ask us to suspend the Processing of Personal Data about you if you want us to establish its ac-curacy or the reason for Processing it.
• Withdraw consent you have given at any time without affecting the lawfulness of pro-cessing based on consent before its withdrawal.

Object to the Processing of your Personal Data in certain circumstances.

This right may apply where the Processing of your Personal Data is based on the le-gitimate interests of Company, as described in Annex 1, or where decisions about you are based solely on automated processing, including profiling.

Notwithstanding, you have the right to object at any time to Processing of your Per-sonal Data for direct marketing purposes.

These rights are not absolute and are subject to various conditions under Data Protection Law and any other applicable laws and regulations.

You may exercise these rights by contacting your Privacy Lead (see Section 3). You also have the right to lodge a complaint with a Supervisory Authority.

8. Data Sharing and International Data Transfers: External Third Parties

External Third Parties

The Company may share Personal Data with external vendors whom we engage to perform ser-vices or functions on our behalf and under our instructions. Where applicable, their Processing of your data will be subject to the GDPR requirements. The Company will also ensure that its contracts with these parties ensure they only Process Personal Data in accordance with our instructions and in order to provide the agreed services and protect the integrity and confiden-tiality of the Personal Data entrusted to them, in line with the GDPR requirements.

For the purposes set out in this Notice, we may also disclose your Personal Data to our IT ser-vice providers, auditors, lawyers, consultants, law enforcement, courts and tribunals and other public authorities, such as tax and social security bodies. Some of these recipients are them-selves responsible to determine the purposes and means of the Processing and for the lawful-ness of the Processing on their end. Where necessary, we will ensure that appropriate contrac-tual measures are in place to ensure the protection of your Personal Data.

The Company may share Personal Data with external vendors whom we engage to perform ser-vices or functions on our behalf and under our instructions. Where applicable, their Processing of your data will be subject to the GDPR requirements. The Company will also ensure that its contracts with these parties ensure they only Process Personal Data in accordance with our instructions and in order to provide the agreed services and protect the integrity and confiden-tiality of the Personal Data entrusted to them, in line with the GDPR requirements.

Some of the vendors we engage to Process your Personal Data are located outside the Europe-an Economic Area. We will ensure that these transfers are either:

• To countries, which fall under an adequacy decision by the EU-Commission and have been deemed to provide an adequate level of protection, currently includ-ing Switzerland, Uruguay, Argentina, Japan, Israel, Isle of Man, New Zealand, Guernsey, Canada, Andorra, Faroe Islands and Jersey; or are
• Governed by one of the following safeguards: EU Commission-approved Standard Contractual Clauses; GDPR-compliant Data Processor clauses where the US ven-dor is certified under the EU-US Privacy Shield Framework; or Binding Corporate Rules approved by an EU data protection authority. You may receive a copy of these data protection safeguards by contacting us at the contact details given in Section 3 above.

9. Retention of Personal Data

The Company will keep and Process your Personal Data only for as long as is necessary for the purposes for which it was collected or for legal obligations. Such legal obligations may arise particularly under tax and commercial law. If your data is no longer necessary for the fulfilment of contractual or legal obligations it will be deleted; unless they are needed to secure, assert or enforce legal claims. In this case, we will retain them in accordance with the regular limitation period. During this period, this data is blocked and is no longer available for any other use.

10. Statutory/Contractual Requirements

You may choose to not provide us with your Personal Data and/or provide incomplete Personal Data. However, please be aware that, in certain cases, we may not be able to engage in, or con-tinue a business relationship with you, as your Personal Data is required for administrative pur-poses and/or to fulfill statutory requirements.

11. Automated Decision-Making and Profiling

Your Personal Data will not be used for automated decision-making and/or profiling.