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Johnson & Johnson Medical Korea Ltd. cares about your privacy and wants you to be familiar with how we collect, use, and disclose information.  This Privacy Policy describes our practices in connection with information that we or our service providers collect through the website or application (hereinafter the “Service”) operated and controlled by us from which you are accessing this Privacy Policy.  By providing personal information to us or by using the Service, you acknowledge that you have read and understand this Privacy Policy.

USE BY MINORS

The Service is not directed to individuals under the age of 18, and we request that these individuals not provide personal information through the Service. If your child has submitted Personal Information and you would like to request that such Personal Information be removed, please contact us as explained below under Contacting Us.

INFORMATION COLLECTION

We may ask you to submit personal information in order for you to benefit from certain features (such as newsletter subscriptions, tips/pointers, or order processing) or to participate in a particular activity (such as sweepstakes or other promotions).  You will be informed what information is required and what information is optional.

We may combine the information you submit with other information we have collected from you, whether on‑ or offline, including, for example, your purchase history.  We may also combine it with information we receive about you from other sources, such as other Johnson & Johnson Affiliates, publicly available information sources (including information from your publicly available social media profiles), and other third-party information providers.If you submit any personal information relating to another individual to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

SENSITIVE INFORMATION

Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any sensitive personal information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, health, sex life or sexual orientation, criminal background, or trade union membership, or biometric or genetic data for the purpose of uniquely identifying an individual) on or through the Service or otherwise to us. 

AUTOMATIC INFORMATION COLLECTION AND USE

We and our service providers may automatically collect and use information in the following ways as you navigate around the Service:

Through your browser:  Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, and Internet browser type and version.  We may collect similar information, such as your device type and identifier, if you access the Service through a mobile device.  We use this information to ensure that the Service functions properly.

Using cookies:  Cookies are pieces of information stored directly on the computer you are using.  Cookies allow us to collect information such as browser type, time spent on the Service, pages visited, and language preferences.  We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Service.  We also use cookies to recognize your computer or device, which makes your use of the Service easier, such as to remember what is in your shopping cart.  In addition, we use cookies to gather statistical information about Service usage in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it.  Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Service.  We may also use cookies in online advertising to track consumer responses to our advertisements.

You can refuse to accept these cookies by following your browser’s instructions; however, if you do not accept them, you may experience some inconvenience in your use of the Service.  You may also not receive advertising or other offers from us that are relevant to your interests and needs.  To learn more about cookies, including how to refuse or block cookies, please visit http://www.allaboutcookies.org.

Using Flash cookies:  Our use of Adobe Flash technology (including Flash Local Stored Objects (“Flash LSOs”)) allows us to, among other things, serve you with more tailored information, facilitate your ongoing access to and use of the Service, and collect and store information about your use of the Service.  If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel.  You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions.  Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.

Using pixel tags, web beacons, clear GIFs, or other similar technologies:  These may be used in connection with some Service pages and HTML‑formatted e‑mail messages to, among other things, track the actions of users and e‑mail recipients, measure the success of our marketing campaigns, and compile statistics about Service usage.

Interest-based advertising:  We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Service and other online services, based on information relating to your access to and use of the Service and other online services on any of your devices.  To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags).  They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. 

If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.  You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.

IP address:  Your IP address is a number that is automatically assigned to your computer by your Internet Service Provider.  An IP address is identified and logged automatically in our server log files whenever a user visits the Service, along with the time of the visit and the pages visited.  Collecting IP addresses is standard practice and is done automatically by many online services.  We use IP addresses for purposes such as calculating Service usage levels, diagnosing server problems, and administering the Service.  We may also derive your approximate location from your IP address.

Device Information:  We may collect information about your mobile device, such as a unique device identifier, to understand how you use the Service.

HOW WE USE AND DISCLOSE INFORMATION

How We Use and Disclose Information

We use and disclose information you provide to us as described to you at the point of collection.  Please see the section entitled “Choices and Access,” below, to learn how you may opt out of certain of our uses and disclosures. 

Where required by applicable law, we will obtain your consent to our use of your personal information at the point of information collection.  We may also use information from or about you as necessary to perform a contract, to comply with a legal obligation (for example, due to our pharmacovigilance obligations), or for our legitimate business interests.  Our legitimate business interests may include any or all of the following:

  • to respond to your inquiries and fulfill your requests, such as to send you documents you request or e‑mail alerts;
  • to send you important information regarding our relationship with you or regarding the Service, changes to our terms, conditions, and policies and/or other administrative information; and
  • for other business purposes, such as data analysis, audits, developing new products, enhancing our website, improving our products and services, identifying Service usage trends, better understanding your interests so that we can serve you better, personalizing your experience on the Service by presenting products and offers tailored to you, and determining the effectiveness of our promotional campaigns.

We also disclose information collected through the Service:

  • to our affiliates for the purposes described in this Privacy Policy.  A list of our affiliates is available at http://www.investor.jnj.com/governance/sec‑filings.cfm (click on the link for Form 10K, Exhibit 21, under “SEC Filings”).  Johnson & Johnson Medical Korea Ltd. is the party responsible for the management of the jointly‑used Personal Information;
  • to our third party partners with whom we offer a co‑branded or co‑marketed promotion;
  • to our third party service provider, Acquia located in the United States, who provide services such as website hosting and moderating, mobile application hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, e‑mail and direct mail delivery services, auditing, and other services, in order to enable them to provide services; and
  • as permitted by applicable law, to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

In addition, we may use and disclose your information as we believe to be necessary or appropriate:  (a) to comply with legal process or applicable law, which may include laws outside your country of residence; (b) as permitted by applicable law to respond to requests from public and government authorities, which may include authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.  We may also use and disclose your information in other ways, after obtaining your consent to do so.

We may use and disclose information we collect automatically as described above, under “Automatic Information Collection and Use.” 

In addition, where allowed by applicable law, we may use and disclose information that is not in personally identifiable form for any purpose.  If we combine information that is not in personally identifiable form with information that is identifiable (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your personal information

We give you choices regarding our use and disclosure of your personal information for marketing purposes.  You may opt out from:

  • Receiving marketing communications from us:  If you no longer want to receive marketing communications from us on a going‑forward basis, you may opt out of receiving them by contacting us via email at [email protected].  In your request to us, please provide your name, identify the form(s) of marketing communications that you no longer wish to receive, and include the address(es) to which it/they are sent.  For example, if you no longer wish to receive marketing e‑mails or direct mail from us, tell us that, and provide your name and e‑mail or postal address.   In addition, you may opt out of receiving marketing e‑mails from us by following the unsubscribe instructions provided in any such message.
  • Receiving reminders from us:  If you no longer want to receive medical reminders from us on a going‑forward basis, you may opt out of receiving them by contacting us via email at [email protected].  In your response to us, please provide your name and the e‑mail address or phone number at which you receive reminders from us.
  • Our sharing of your personal information with affiliates and third‑party partners:  If you previously opted in to receiving marketing communications from our affiliates or third party partners, you may opt out of our sharing of your personal information with those parties for their direct marketing purposes on a going‑forward basis by contacting us via email at [email protected].  In your communication to us, please state that we should no longer share your personal information with our affiliates and/or third‑party partners for their marketing purposes, and include your name and e‑mail address.

We will seek to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt out as described above, we will not be able to remove your personal information from the databases of our affiliates with which we have already shared your information (i.e., as of the date that we implement your opt‑out request).  Please also note that if you opt out of receiving marketing‑related messages from us, we may still send you important transactional and administrative messages, from which you cannot opt out.

How you can access, change, or delete your personal information

If you would like to review, correct, update, restrict, or delete your personal information, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please contact us via this link.  We will respond to your request within the period required by law. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response. 

CROSS‑BORDER TRANSFER

Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Service or by providing consent to us (where required by law), you agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country.  Appropriate contractual and other measures are in place to protect personal information when it is transferred to our affiliates or third parties in other countries.

SECURITY

We seek to use reasonable organizational, technical, and administrative measures designed to protect personal information under our control.  Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.

RETENTION PERIOD

We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained.  The criteria used to determine our retention periods include:  (i) the length of time we have an ongoing relationship with you and provide the Service to you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

THIRD PARTY SITES AND SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or online service (including, without limitation, any application) that is available through this Service or to which this Service contains a link.  The availability of, or inclusion of a link to, any such site or property on the Service does not imply endorsement of it by us or by our affiliates.

CONTACTING US

If you have any questions about this Privacy Policy, please contact a chief privacy officer:

  • Name : Byung Jae Yoo
  • Tel : 02-2094-3500

Addendum applicable to users in South Korea

This addendum supplements this privacy policy and sets forth, in greater detail, the information related to how we process personal information of users in South Korea under the Personal Information Protection Act (“PIPA”) and other applicable privacy regulations in South Korea.

1.   Consent

Notwithstanding the foregoing, in accordance with the PIPA and other applicable privacy regulations, we will provide a separate information notice and obtain your consent accordingly in order to process your personal information, unless consent is not required per an applicable law.

2.   Transfer of Personal Information

Notwithstanding the foregoing, we provide personal information to or outsource the processing thereof to third parties as below.

Provision of Personal Information to Third Parties

Name of Recipient

Recipient’s Purpose of Use and Collection

Items of Personal Information Provided to Recipient

Periods of Retention by Recipient

Our Affiliates (list of which can be found through the website described in “How We Use and Disclose Information” section above

Information sharing and business exchange between affiliates

All information we collect as described in this Privacy Policy

As described in the “Retention” section above

Ministry of Health and Welfare

To review submitted report per applicable law

Name, name of the workplace

Period according to related laws

Korea Medical Devices Industry Association

To review submitted report per applicable rules and perform audit

Lecture: Date, place, title, purpose of the lecture, name and name of workplace of the lecturer, fees and theme of the lecture

Consulting: Date/period, title, purpose of the consultation, name and name of workplace of the consultant, fees and theme of the consulting

5 years after the January 1 of the following year of the date lecture/consulting took place

The Ministry of Food and Drug Safety, FDA of United States, and any corresponding authority of residing country of our affiliates

Reporting of Adverse events

Initial, gender, age, date of birth, height, weight of trial subject. Any personal information (including sensitive information) collected through the call center

Period according to related laws

Institutional Review Board and Clinical Trial Review Committee of relevant hospital

Processing clinical trials, reporting of adverse events, etc.

Names, title, contact information, name/address of the hospital of clinical trial researcher.

Date of birth, height, gender, weight, ethnicity, smoke/pregnant status, health information

Period according to related laws

 

Outsourcing of the Processing of Personal Information to Third Parties

Recipient

Outsourced Tasks

LG U+

Web service hosting

Ready Korea

Web service operation

GC Pharma

Distribution of medical device

Dalim Medical

Distribution of medical device

Medwin

Distribution of medical device

Gems Korea

Distribution of medical device

SuhHo MediCo

Distribution of medical device

Redcap

Management of marketing/training event and reservation process

Jinos Korea

Marketing

CS Techplus

Shipment and management of goods such as medical device

Medsoft

Operation of website related to conference/meeting

 

Cross-border Storage/Outsourcing of Personal Information to Third Parties

Name of Recipient

Items of the personal information to be transferred

Date, time, method of transfer

Outsourced tasks

Periods of retention by recipient

Johnson & Johnson Services, Inc. (United States, etc; +1-800-458-1653)

Items of which collection was consented to

Transferred when the consent is given or when needed

Development and management of website

As described in the “Retention” section above

Salseforce.com (Singapore; +65-800-1301-448)

Operation of customer DB

CVENT.com (United States; [email protected])

Operation of customer DB and system regarding training

6Connect (United States; [email protected])

Operation of customer DB and system regarding training

BBDO Worldwide Inc. (United States; +1 (212) 459 5000)

Operation of customer DB and system regarding training

Johnson & Johnson Global Services Finance (China; +1-800-458-1653)

Management and storage of vendor information

Axonify (United States; [email protected])

Training

Visible Patient (France; [email protected])

Operation of production of 3D patient image

CSATS Inc. (United States; [email protected])

Operation of CSAT device and related website

Hybris Managed Services (Germany; [email protected])

Web hosting, management and analyzing DB, announce notice, website operation, analyzing data for quality control

3.    Retention of Personal Data

Specifically, we will retain your personal information for the period necessary to fulfill the purposes outlined in the Privacy Statement unless a longer retention period is required or permitted by law, such as in the following cases:

  • Records on contracts and withdrawal of subscriptions: 5 years (as required under the Act on Consumer Protection in Electronic Commerce Transactions)
  • Records on payments and supply of goods: 5 years (as required under the Act on Consumer Protection in Electronic Commerce Transactions)
  • Records on consumer complaints and processing of disputes: 3 years (as required under the Act on Consumer Protection in Electronic Commerce Transactions)
  • Records on electronic financial transactions: 5 years (as required under the Electronic Financial Transactions Act)
  • Records of logins: 3 months (as required under the Protection of Communications Secrets Act)

4.   Procedures and Methods of Destruction of Personal Information

The process and method for destroying personal information are set forth below.

  • Destruction Process: We select certain items of personal information to be destroyed, and destroy them with the approval of the chief privacy officer.
  • Destruction Method: We destroy personal information recorded and stored in the form of electronic files by using a technical method (e.g., low level format) to ensure that the records may not be reproduced, while personal information recorded and stored in the form of paper documents would be shredded or incinerated.

5.   Technical and managerial Measures

We will implement and maintain at least the specific technical and managerial safeguards as stipulated under the applicable laws including, but not limited to, the PIPA.

 

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy.  Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Service.  Your use of the Service following these changes means that you accept the revised Privacy Policy.  We recommend that you regularly review the Privacy Policy when you visit the Service. This policy was last updated on September 20, 2021.