Privacy Policy
Privacy Policy of BIOTRONIK Vertriebs GmbH & Co. KG (“BIOTRONIK”)
Protecting your personal data is a very important concern for BIOTRONIK. We would like to inform you about which personal data we collect and use, what rights you have, and what options are available to you. We process your data in accordance with applicable data protection laws, in particular the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).
This privacy policy provides you with an overview of the key processes in which we process your data.
Controller and Contact for Data Processing
The controller pursuant to Art. 4 No. 7 GDPR is:
BIOTRONIK Vertriebs GmbH & Co. KG
Woermannkehre 1, 12359 Berlin
privacy@biotronik.com
If you have general questions about data protection at BIOTRONIK, you can contact our Data Protection Officer. You can reach them at datenschutz@biotronik.com or by mail at our postal address with the addition “Data Protection Officer.”
Your Rights
You have the right at any time to:
Request information about the categories of data processed, processing purposes, any recipients, and planned storage duration (Art. 15 GDPR)
Withdraw consent at any time with effect for the future (Art. 7(3) GDPR)
Object to data processing based on legitimate interests for reasons arising from your particular situation (Art. 21 GDPR)
Request the correction or completion of inaccurate or incomplete data (Art. 16 GDPR)
Request the deletion of data in certain cases — in particular if the data is no longer necessary for the intended purpose, is unlawfully processed, or if you withdraw your consent under Art. 7(3) GDPR or have objected under Art. 21 GDPR (Art. 17 GDPR)
Request the restriction of data processing under certain conditions if deletion is not possible or the obligation to delete is disputed (Art. 18 GDPR)
Receive the data you have provided to us in a commonly used, machine-readable format and, if applicable, request its transfer to another controller (Right to data portability under Art. 20 GDPR)
In addition, you have the right to lodge a complaint with a data protection supervisory authority pursuant to Art. 77 GDPR. The supervisory authority responsible for us is:
Berlin Commissioner for Data Protection and Freedom of Information
Alt-Moabit 59-61, 10555 Berlin, Germany
Tel.: +49 (0)30 13889-0
Fax: +49 (0)30 2155050
E-Mail: mailbox@datenschutz-berlin.de
1. Data Processing When Using BIOTRONIK Websites
(www.biotronik.com, incarenet.com) as well as additional subdomains such as manuals.biotronik.com, patients.biotronik.com, media.biotronik.com
a. Browser Data
When you visit BIOTRONIK websites, we collect the data transmitted by your browser to our server. Depending on the browser and its settings, this typically includes:
IP address
Date and time of the request
Information about the time zone used by your browser
Address of the requested page (URL)
Amount of data transferred
Operating system
Name, language, and version of the browser software
Manufacturer and type of device on which the browser is used
We generally use this data only to the extent necessary to provide a functional website and to display our content and services.
We use this data for the following purposes:
To enable access to and visits of BIOTRONIK websites
To detect, correct, and prevent errors, disruptions, and potential misuse
The legal basis for processing this data is Section 25 (2) No. 2 TDDDG (Telecommunications-Telemedia Data Protection Act) and our legitimate interest pursuant to Art. 6 (1) sentence 1 lit. f GDPR.
No data is shared with third parties.
The data is deleted as soon as it is no longer required for the above-mentioned purposes within the legal framework, usually at the end of the browser session, but no later than one month.
b. Cookies
We use cookies on BIOTRONIK websites. Cookies are small text files or similar storage technologies placed on your device by your browser, enabling recognition of your browser.
We use both session cookies (temporary cookies) and persistent cookies.
Session cookies are stored only for the duration of your use of our websites. These cookies are required for transactions (such as logging into a user account) and are valid until the end of the browser session. Depending on your browser type and settings, these cookies are automatically removed after the session ends or when the tab/browser is closed, unless you have configured your browser otherwise. The session cookies we use contain only a session ID.
Persistent cookies are stored on your computer for future sessions to recognize returning visitors even after a long time and to provide tailored product or service offerings. Persistent cookies remain stored on your device and are not deleted when you leave the website or close the browser. If you want to remove persistent cookies, this must be done manually.
Why are cookies used?
Essential Cookies
Essential cookies make a website usable by enabling basic functions such as page navigation and access to secure areas (e.g., shopping cart cookies, login cookies, cookies for country or language selection, consent tool cookies for cookie consent). The website cannot function properly without these cookies. These cookies cannot be disabled.
You can configure your browser to block these cookies or notify you about them. However, some areas of the website may not function properly.
Functional Cookies
Functional cookies enable enhanced functionality and personalization, such as videos and live chat.
If you do not allow these cookies, some or all of these features may not work properly.
Analytics Cookies
Analytics cookies are used by us or third parties for tracking and analyzing user behavior, delivering user-based content, or marketing activities. This allows us to tailor website content to target groups and improve website content and functionality.
If you do not allow these cookies, you will not experience user-based content or targeted offers on other websites.
The legal basis for storing cookies, device identifiers, and similar tracking technologies—or for storing information on the end user’s device and accessing this information—is the European ePrivacy Directive in conjunction with the TDDDG.
Please note that the legal basis for processing personal data collected in this context is derived from the GDPR (Art. 6 (1) sentence 1 GDPR). The specific legal basis applicable in each case can be found in the table below regarding the cookies and tracking technologies we use.
The primary legal basis for storing information on the end user’s device—particularly for storing cookies—is your consent, Section 25 (1) sentence 1 TDDDG. Consent is given when visiting our website (although it is not mandatory) and can be withdrawn at any time in the cookie settings.
According to Section 25 (2) No. 2 TDDDG, consent is not required if storing information on the end user’s device or accessing information already stored is absolutely necessary for the provider of a telemedia service to provide a telemedia service explicitly requested by the user. The cookie settings indicate which cookies are classified as strictly necessary (often referred to as “technically necessary cookies”), thus falling under the exemption of Section 25 (2) TDDDG and not requiring consent.
You can view and manage which cookies are set or accessed at any time in the “Used Services and Cookies” section. However, disabling cookies may limit website functionality (e.g., login for certain areas).
If you opt out (for example, by disabling a previously accepted cookie), we will set a persistent cookie to recognize and respect the opt-out during future visits to our websites.
Opt-out cookies prevent future data collection when visiting these websites with a specific device/browser and domain. To prevent data collection across multiple devices, the opt-out must be performed on all devices/browsers used.
We use the following service provider:
Google Analytics
For the purpose of tailoring and continuously optimizing our website, BIOTRONIK uses “Google Analytics” based on your consent. Google Analytics is a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google Analytics uses, among other things, so-called “cookies” (text files) and similar technologies that are stored on your device and enable an analysis of your use of the website. This information is used to evaluate your use of the website, compile reports on website activity, and optimize the delivery of advertising.
The processing of data after its transmission by BIOTRONIK to Google Ireland Limited is carried out by Google as the sole data controller under data protection law. In this context, Google Ireland Limited, as the sole data controller, may store data about you in the USA. The European Court of Justice has determined that the USA does not provide an adequate level of data protection. In particular, there is a risk that your data may be processed by U.S. institutions/authorities for monitoring and surveillance purposes without sufficient legal remedies available to you.
However, on July 10, 2023, the EU Commission adopted the adequacy decision for the EU-U.S. Data Privacy Framework. This means that the EU Commission considers the level of data protection in the USA to be comparable to that in the EU and therefore safe for transfers based on this agreement. Google is certified under this framework and relies on it for any data transfers to the USA.
The legal basis for this data processing is Article 6(1)(a) GDPR (consent). Further information on Google Analytics and Google’s privacy policy can be found here. You can withdraw your consent for the use of Google Analytics at any time here [A1] [A2].
2. Data Processing at Events
As part of events or your participation in programs, workshops, or similar activities, we process the following personal data in particular:
Contact information, especially first and last name, title (if applicable), address, phone number (if applicable), email address
Information about the company or institution you work for
Details about your professional position
Date and place of birth (if applicable)
We generally collect this data directly from you. In some cases, we receive personal data about you from the company or institution you work for so that we can invite you to one of our events.
We use your contact details (name, postal address, email address) to send invitations to our events that match your interests and, prior to the event, to send relevant materials (e.g., program) by post or email. The legal basis is Art. 6(1)(f) GDPR, based on our legitimate interest in adequate communication of our corporate strategy and activities, which also includes public events and the involvement of reporters.
If you no longer wish to receive invitations to our events, you can object to the use of your data for these purposes at any time by sending an email with your objection to privacy@biotronik.com. In this case, we will immediately stop sending invitations to our events.
If you attend an event organized by us, we process your above-mentioned data to conduct the event and enable your participation. This also includes, where applicable, listing your name, company/institution details, and current professional position in a participant directory that may be made available to other participants (including in electronic form), or providing your data (name, company/institution details) to event moderators for the purpose of conducting the event. Furthermore, we use this data to send you event-related materials (e.g., training documents) after the event. We may also share your data with cooperating institutions or affiliated companies if necessary to conduct the event and enable your participation (e.g., external guest management). The legal basis for these data processing activities is Art. 6(1)(b) GDPR.
We store your contact details for sending invitations until you object, in order to fulfill the legitimate mutual interest in communication and information. We will retain your objection for evidence purposes for a period of 3 years.
3. Photo, Audio, and Video Recordings at Events
We process image, video, and audio recordings to provide them as live streams or “video-on-demand” for training purposes or for individuals who cannot attend the event.
The legal basis for processing your personal data by BIOTRONIK is your consent to data processing pursuant to Art. 6(1)(a) GDPR.
In addition, photos and/or videos are regularly taken at our events, some of which may be published on our website, on our social media channels, as part of external and internal reporting, or in BIOTRONIK newsletters. Alongside photo and video recordings, metadata such as location and time of recording and geolocation are automatically stored in digital cameras. The legal basis for publishing photo and video recordings is generally Sections 22 and 23 of the German Art Copyright Act (KUG) and your consent under Art. 6(1)(a) GDPR.
The legal basis for creating and storing photo and video recordings may, in certain cases, also be Art. 6(1)(f) GDPR, based on our legitimate interest in reporting on the event.
If we process your data based on legitimate interest, you have the right under Art. 21(1) GDPR to object at any time, for reasons arising from your particular situation, to the creation and storage of your photo and video recordings with future effect by sending an email with your objection to privacy@biotronik.com.
If we use this data based on your consent, you may withdraw your consent at any time with future effect by sending an email with your withdrawal to privacy@biotronik.com.
Please note that external reporters may also be present at events and take photos and videos. Since we have no influence over the photos and videos taken by external reporters or their use, we cannot provide information about the purpose and scope of their data processing.
Photo and video recordings, including metadata, stored on the basis of Art. 6(1)(a) GDPR will be retained until you withdraw your consent.
Photo and video recordings, including metadata, stored on the basis of Art. 6(1)(f) GDPR will be retained until you have lawfully objected to storage under Art. 21(1) GDPR, unless there are overriding legitimate grounds for processing under Art. 21(1) sentence 2 GDPR.
If data is shared with processors bound by instructions or affiliated companies, this will only occur to the extent and for the duration necessary to provide the respective services.
4. Data Processing for Inquiries
If you contact us (e.g., by email, phone, or contact form), we use the data you provide to process your inquiry.
To provide you with the appropriate information or verify your authorization, we generally require the following details:
Email address
Name
For medical professionals: Practice / Clinic
Country
Address (if applicable)
Phone number (if applicable)
Any additional data you provide
Depending on the nature of your inquiry, your data will be processed based on different legal grounds:
For contractual matters: Art. 6(1)(b) GDPR
For legal obligations: Art. 6(1)(c) GDPR or Art. 9(2)(i) GDPR (e.g., provision of operating instructions or product information)
For legitimate interest: Art. 6(1)(f) GDPR
Based on consent: Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR
If necessary to process your inquiry, we share your data with GETEMED Medizin- und Informationstechnik AG and Semdatex GmbH. Otherwise, data is not shared with third parties, except where we use service providers acting on our behalf or share your data with affiliated companies responsible for your inquiry.
Your transmitted data will be deleted as soon as it is no longer needed for the above-mentioned purposes and provided there are no statutory retention obligations, at the latest after 3 years.
5. Additional Data Processing
If we process data for purposes other than those listed in this privacy policy, you will find more specific privacy notices under the respective sections or products.
Location of Data Processing
Your data is generally processed in Germany. If your data is processed outside the European Union (so-called third countries), this will only occur if you have expressly consented, if it is necessary for providing our services to you, or if legally required (Art. 49 GDPR). Furthermore, data processing in third countries will only occur if specific measures ensure an adequate level of data protection (Art. 44 et seq. GDPR).
Encryption of Data Transmission
To ensure the confidentiality of your data during transmission, we use encryption methods corresponding to the current state of technology, such as HTTPS/TLS.