Privacy Policy

California Residents: For information relating to California residents, please click here.

Introduction 

Welcome to the Össur privacy policy.  

We understand that you are aware of and care about your personal privacy interests, and we take that seriously. This privacy policy describes Össur's policies and practices regarding its collection and use of your personal data and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies. 

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.  

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy. 

1. IMPORTANT INFORMATION AND WHO WE ARE 

2. THE DATA WE COLLECT ABOUT YOU 

3. HOW IS YOUR PERSONAL DATA COLLECTED?  

4. HOW WE USE YOUR PERSONAL DATA  

5. DISCLOSURES OF YOUR PERSONAL DATA  

6. DATA SECURITY 

7. DATA RETENTION  

8. YOUR LEGAL RIGHTS  

9. GLOSSARY  

1. Important information and who we are 

Purpose of this privacy policy 

This privacy policy aims to give you information on how Össur collects and processes your personal data through your use of our services and products, including any data you may provide when you purchase a product from us, use our services, programs and applications.  

It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.  

Controller 

Össur is made up of different legal entities. This privacy policy is issued on behalf of the Össur Group so when we mention “Össur”,"we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Össur Group responsible for processing your data. 

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.  

Contact details 

If you have any questions about this privacy policy or our privacy practices, please contact our DPO at: 

Össur hf. 
Grjótháls 5, 110 Reykjavík, Iceland 
[email protected] 

You have the right to make a complaint at any time to your country´s supervisory authority for data protection issues. Being that Össur´s headquarters are in Iceland the group’s main supervisory authority for data protections issues is the Icelandic Data Protection Authority Persónuvernd. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.  

Changes to the privacy policy and your duty to inform us of changes 

We keep our privacy policy under regular review. This version was last updated on 8 March 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 

Third-party links 

Our websites and applications may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit and application you use. 

2. The data we collect about you 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: 

• Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender. 
• Contact Data includes billing address, delivery address, email address and telephone numbers. 
• Financial Data includes bank information and payment card details. 
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. 
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites, applications and services.  
• Profile Data includes your username, purchases or orders made by you, your interests, preferences, feedback and survey responses.   
• Usage Data includes information about how you use our website, products, applications and services.  
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

Special Categories of Personal Data 

Being that Össur´s services and products are directly related to the health of many of our customers we might collect Special Categories of Personal Data about you (this includes information about your health and biometric data) if you provide us with such data when purchasing our products, using our services and/or applications and/or if such data is provided by a medical practitioner or other organization with whom you authorize to enter personal data on your behalf into our sites, systems or applications.  

If you fail to provide personal data 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a contract for a product or service you have with us, but we will notify you if this is the case.  

3. How is your personal data collected? 

We use different methods to collect data from and about you, including through: 

• Direct interactions. You may give us your Identity, Contact, Health and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  ·         apply for our products or services;
  ·         create an account on our websites;
  ·         subscribe to our service or publications;
  ·         use our applications;
  ·         request marketing to be sent to you;
  ·         enter a competition, promotion, seminar, or survey; or
  ·         give us feedback or contact us.
• Automated technologies or interactions. As you interact with our websites and applications, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. You can review or change your consent at any time by clicking our cookie banner in the bottom left corner of the page.
• Applications. As you interact with our applications, we will collect information about or related to your use, including information that directly or indirectly identifies you if you choose to share it. We receive information when you register and sign into our applications and collect information about how you use our applications. That is: 
• We collect your name and email address that helps secure and provide you with access to our applications. That also helps us to respond to your support requests and comments. 
• We collect information about your activity data, to provide you with applicable information of usage, that includes in some cases physical activity collected via our orthotic or prosthetic products. 
• We collect any pictures or other documents you choose to share with our applications. 
• We collect information from your device, which provide us with technical information when you access or use our applications. This technical information includes analytics information, client type and client operating system, affiliated product information such as serial number and specifications. 
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as analytics providers, advertising networks and/or search information providers.  
• Medical practitioners or other organisations. We may also receive information about you from a medical practitioner or other organisation with whom you authorize to enter personal data on your behalf into our sites and applications. 
• Contact, Financial and Transaction Data (if applicable) from providers of technical, payment and delivery services. 

4. How we use your personal data 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

• Where we need to perform a contract we are about to enter into or have entered into with you. 
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 
• Where we need to comply with a legal obligation. 
• Where we´ve received your consent. 

Click here to find out more about the types of lawful basis that we will rely on to process your personal data

Purposes for which we will use your personal data 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one basis has been set out in the table below.  

Marketing  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  

Promotional offers from us  

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).  

You will receive marketing communications from us if you have requested information from us or purchased from us and you have not opted out of receiving that marketing. 

Opting out 

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.  

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. 

Cookies 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. You can review or change your consent at any time by clicking our cookie banner in the bottom left corner of the page. 

5. Disclosures of your personal data 

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

• Entities within the Össur Group
• Service providers (usually acting as processors) relevant to the services that we provide. This may include, but is not limited to, professional service providers, regulators, authorities, and governmental institutions.
• Third party agents/suppliers/consultants or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers.
• Professional advisers who provide, for example, consultancy, banking, legal, insurance and accounting services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Data security 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.  

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

7. Data retention 

How long will you use my personal data for? 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. 

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.  

8. Your legal rights 

If you reside in the EU/EEA, you may exercise any of the rights described in this section by contacting us at [email protected]. Please note that we may ask you to verify your identity before taking further action on your request.

Please click here to find out more about the following rights:  

• Request access to your personal data. 
• Request correction of your personal data. 
• Request erasure of your personal data. 
• Object to processing of your personal data. 
• Request restriction of processing your personal data. 
• Request transfer of your personal data. 
• Right to withdraw consent. 

No fee usually required 

You will not have to pay a fee to access your personal data (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 could refuse to comply with your request in these circumstances. 

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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. 

Time limit to respond 

We try to respond to all legitimate requests within one month. Occasionally it could 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.  

9. Glossary 

LAWFUL BASIS 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. 

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. 

Consent means the informed, unambiguous and freely given permission you give to have data relating to you processed. 

YOUR LEGAL RIGHTS 

You have the right to: 

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.  

Object to processing of your personal data 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 data 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. 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:  

• If you want us to establish the data's accuracy. 
• Where our use of the data is unlawful, but you do not want us to erase it. 
• 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.  
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.  

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data 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 at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.