This Privacy Notice ("Notice") describes how Stericycle Inc. and its affiliates (collectively referred to as "Stericycle", "we", "us" or "our") collects, uses and shares personal data collected in the context of our websites, business contacts, suppliers, current and prospective customers who use Stericycle services or products or users affected by our services (together referred to as "you" or "your"). This Notice also explains your ability to edit, update, correct, or delete your personal data and the security procedures that we have implemented to protect personal data.
In this Notice, you can find out more about:
The Stericycle entity responsible for your personal data will be the member of Stericycle that originally collects information from or about you. This will be explained in separate privacy notices made available when your personal data are first collected by that Stericycle entity, for example where you or the business you work for engages us to provide a service.
You can find out more about Stericycle at www.stericycle.com or by contacting us using the information in the Contact us section.
In this section, you can find out more about:
We may collect personal data about you if you:
You may use our websites as an unregistered user without (actively) providing any personal data about you. In this case, Stericycle collects the following metadata that result from your usage of our websites: referral page, date and time of access, type of web browser, IP-address, geographic location as determined by your IP address, operating system and interface, language and version of browser software, session information (such as download errors and page response times).
Your IP-address will be used to enable your access to our websites. The metadata will be used to improve the quality and services of our websites by analyzing the usage behavior of our users.
If you commence direct communications via our websites enquiry form, by telephone or writing to us, the nature of the enquiry (e.g., as tick box selection from service type/careers/other) and your message will also be collected and processed to respond to it and improve our services.
If you are a registered user or choose to register on a Stericycle website, you may be asked to provide the following personal data about you: first and last name, work phone number, company name, email address, personal telephone number, Stericycle Customer No. or Shred-It Ship to ID, postal address and primary usage. Further, Stericycle will collect user access content.
Stericycle will process such personal data in order to provide you in particular with the services for registered users, verify the legitimacy of your account, to avoid fraudulent accounts being opened, provide you with our products, customer support, compliance trainings, business communications solutions (e.g., answering services, appointment reminders, follow-up services, virtual receptionists), contact form, marketing materials as selected by you, inform you about system issues, comply with legal obligations, and defend, establish and exercise legal claims.
The personal data collected from Website Users is also used to personalize your experience of our websites. We may use such information in the aggregate to understand how you use our services and the resources provided on our websites. We may also use the feedback you provide to improve our services.
If you purchase products from Stericycle, either via a Stericycle website or offline, you may be asked to provide, among other, the following personal data about you, your representative and/or your contact person: first and last name, suffix, credentials, work phone number, personal phone number, facsimile, email address, job title, mailing address, tax identification number, credit card information, billing address, types and amount of products ordered, reseller/promo code, auto-delivery selection, marketing preferences, job information, academy of general dentistry and license.
To provide certain services we may have to process, depending on the services provided, the following personal data about you: professional data; data relating to your physical characteristics; dosimetry monitoring data; health information such as, as applicable, the dose of radiation to which you were exposed, any relevant medical imaging results, pregnancy status and data relating to the fetus, data relating with accidents at work and disabilities; data relating with professional training.
Stericycle will use such personal data to process your order, deliver the products or services ordered, provide customer care services, provide you with marketing materials as selected by you, provide you with Stericycle updates and/or newsletters, to maintain our client relationship management systems, to detect, investigate, report and seek to prevent fraud and anti-money laundering, for example through know-your- customer checks, AML screening and other identity checks, comply with other legal obligations, defend, establish and exercise legal claims. We may also need to conduct credit and fraud checks on business customers and certain officers of your business, such as your directors.
When providing certain services to a Customer to which you are related to (e.g., if you are an employee, a contractor, an apprentice, a trainee, a patient, etc., of our Customer), Stericycle may have to process the following personal data about you (as applicable, depending on the specific service provided): identification data; contact data; professional data; data relating to your physical characteristics; dosimetry monitoring data; health information such as, as applicable, the dose of radiation to which you were exposed, any relevant medical imaging results, pregnancy status and data relating to the fetus, data relating with accidents at work and disabilities; data relating with professional training. Most of the personal data is obtained from our Customer.
We process such personal data in the context of the provision of a service to a Customer and for purposes of providing the services to said Customer. However, we need to process your personal data either because the services provided have an impact on you (e.g., the dosimetry services are intended to measure the radiation to which you were exposed, or the professional training services are provided to you) and/or because we have to comply with legal obligations that imply the processing of your personal data (e.g., we have a legal obligation of reporting the dosimetry results).
If you work with us as a Business Partner or a service provider, we will collect personal data from you, your representative and/or your contact person such as your full name, job title, email address, phone number.
Most of the personal data is obtained directly from you. In addition, we will collect personal data from other public sources such as credit reference agencies.
We use this information to review/assess your suitability as a Business Partner or service provider, to comply with our legal obligations, to detect investigate, report, and seek to prevent fraud and anti-money laundering, for example through know- your-customer checks, AML screening and other identity checks and to meet our obligations under any contracts we have with you, we may also need to conduct credit and fraud checks on your business and certain officers of your business, such as directors.
If you send to, or receive emails from us, we may monitor their content to ensure compliance with our internal policies and to protect our business.
We will only collect, use and share your personal data where we are satisfied that we have an appropriate legal basis to do this. We carry out the processing of your personal data on the following legal bases:
In most of the cases, the provision of your personal data is not required by a statutory or contractual obligation. However, where applicable, the provision of your personal data will be necessary to enter into a contract with Stericycle or to receive our services and products as requested by you. In such situations, not providing your personal data may likely result in disadvantages for you, e.g. you may not be able to use the full functionalities of our websites or to receive the products and services requested by you. However, unless otherwise specified, not providing your personal data will not result in legal consequences for you.
In some cases, where the processing of personal data is necessary for purposes of legal reporting (e.g., dosimetry services or professional training services), the provision of your personal data is a statutory requirement. In other cases, the provision of your personal data is a contractual requirement (e.g., for the provision of professional training services when the contract is executed directly with you).
If you would like to find out more about the legal basis for which we process personal data, please contact us at firstname.lastname@example.org
How we use personal data to keep you up to date with our products and services
We may use personal data to let you know about our products services that we believe will be of interest to you and/or provide you with our newsletter. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.
As a rule, we will obtain your consent prior to sending you marketing materials. We will only contact you with marketing materials without your prior consent if this is permitted by law.
How you can manage your marketing preferences
To protect privacy rights and to ensure you have control over how we manage marketing with you:
We share your personal data in the manner and for the purposes described below:
The personal data that we collect or receive about you may be transferred to and processed by recipients who are located within and outside your location (such as the US), where the level of data protection may not be equivalent to the level of protection applicable at your location.
Where we are legally required to do so, transfers of personal data to parties located in countries outside the EU/EEA will be made pursuant to the European Commission-approved Standard Contractual Clauses or other legally acceptable mechanisms that ensure an adequate level of protection. Please contact email@example.com for more details on the third countries to which the data will be transferred.
Where applicable, you are entitled to receive a copy of the relevant agreements (such as Standard Contractual Clauses or Binding Corporate Rules) showing that appropriate safeguards have been taken to protect your personal data during such transfer. You can obtain a copy by contacting us at firstname.lastname@example.org. However, please note that we are not required to share details of safeguards where sharing such details would affect or commercial position, or create a security risk.
Some recipients located outside of the EEA are located in countries for which the European Commission has issued adequacy decisions (currently this includes Canada ((for non-public organizations subject to the Canadian Personal Information Protection and Electronic Documents Act)). The transfer is thereby recognized as providing an adequate level of data protection for personal data.
Contact email@example.com for additional information regarding the identity, industry, sector and location of the relevant data recipients.
How long does Stericycle keep your personal data?
Your Personal Data will be retained as long as it is required for the purposes for which the data is collected e.g. as necessary to provide you with the services and products requested. Once you have terminated the contractual relationship with us and/or you have deleted your account, or, in case you are a User, following the termination of the contractual relationship in the scope of which your personal data was processed, we will permanently remove your personal data unless statutory retention requirements apply (such as for taxation purposes, dosimetry purposes or professional training purposes) or in order to fulfill regulatory requirements. We retain your contact details and interests in our products or services for a longer period of time if Stericycle is allowed to send you marketing materials. We also retain your personal data if needed to establish, exercise or defend a legal claim, on a need to know basis only. Personal data security
As technology continues to enhance, we are committed to using our technological resources in an effort to ensure that our customers and users receive the kind of privacy protection that will make them confident and secure. We are not responsible, however, for harm that you or any person may suffer as a result of a breach of confidentiality due to your use of the Internet.
We have adopted appropriate data collection, storage and processing practices, technical, organisational and security measures designed to protect against unauthorized access, alteration, disclosure or destruction of the personal data that you share with us. For example, such measures include:
As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.
We will take steps in accordance with applicable legislation to keep your personal data accurate, complete and up-to-date. Depending on the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement. You also have the right to request access to your personal data as well as additional information about the processing and to request us to erase the personal data we hold about you.
You can object to the use of your personal data which has our legitimate interests as its legal basis, including for the purposes of marketing, without incurring any costs other than the transmission costs (see also below).
The following rights apply, to European residents:
You have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and where that is the case, to request access to the personal data. The accessed information includes – among others - the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom the personal data have been or will be disclosed.
You have the right to obtain a copy of the personal data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
You can request the rectification of inaccurate data and the completion of incomplete data. We will inform relevant third parties to whom we have transferred your data about the rectification and completion if we are legally obliged to do so.
You have the right to obtain from us the erasure of personal data concerning you in limited circumstances where:
We are not required to comply with your request to erase personal data if the processing of your personal data is necessary for:
You have the right to obtain from us restriction of processing your personal data. In this case, the respective data will be marked and only be processed by us for certain purposes. This right can only be exercised where:
We can continue to use your personal data following a request for restriction, where:
You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another entity without hindrance from us, but in each case only where:
You have the right to object at any time to any processing of your personal data which has our legitimate interests as its legal basis. You may exercise this right without incurring any costs.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
The right to object does not exist, in particular, if the processing of your personal data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
You can request that we change the manner in which we contact you for marketing purposes. You can request that we not transfer your personal data to unaffiliated third parties for the purposes of direct marketing or any other purposes.
If you have given us your consent for the processing of your personal data, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal
You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside the EU/EEA. We may redact data transfer agreements to protect commercial terms.
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal data.
We ask that you please attempt to resolve any issue with us first, although you have a right to contact your supervisory authority at any time.
Please note that the aforementioned rights might be limited under the applicable national data protection law.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
To exercise your rights please Contact us using the contact information below. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfill your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Stericycle reserves the right to change this Notice at any time. Any changes to this Notice will be effective immediately upon notice, by posting the latest version on our websites.
The primary points of contact for all issues arising from this Notice can be contacted in the following way:
If you have any questions, concerns or complaints regarding our compliance with this Notice, the information we hold about you or if you wish to exercise your rights, we encourage you to first contact firstname.lastname@example.org. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.
EU residents have a right to lodge a complaint with their local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement). We ask that you please attempt to resolve any issues with us before your local supervisory authority.
Last updated: 20/8/20