Privacy Notice

Kodak Alaris Rewards Program

Kodak Alaris Limited and its Affiliates (collectively and each individually “Kodak Alaris”) are committed to protecting your privacy online. Our pledge is to safeguard any personal information that you provide us, and to make certain we use this information only as you choose.

360insights (Canada) Ltd. And its affiliated companies, including 360insights (USA) Ltd., 360insights (Europe) Ltd., and 360insights (EEA) GmbH (collectively referred to as “360insights) provides the incentive program (“Incentive Program”) located at https://emeia.kodakalarisrewards.com on behalf of Kodak Alaris. Kodak Alaris and 360insights are herein referred to in the aggregate as “we”, “us”, or “our”.

This Privacy Notice is intended to inform you on how we handle the Personal Information of the visitors to this Kodak Alaris-branded website (the “Branded Site”) and participants in the Incentive Program (“you”). This Privacy Notice outlines the legal basis on which we process your Personal Information and provides other information as required by various privacy laws around the world, such as the EU GDPR, the UK Data Protection Act 2018, the Californian Consumer Privacy Act, the Canadian PIPEDA and the South African Protection of Personal Information Act 4 of 2013.

Please read through this Privacy Notice carefully so that you may decide to voluntarily consent, refuse to consent, or later withdraw your consent to the collection and use of your Personal Information.

THIS PRIVACY NOTICE IS EFFECTIVE SEPTEMBER 01, 2023.

1. Your Consent

(a) Providing Consent

Having reviewed this Privacy Notice, or having been given the opportunity to do so, and by confirming your consent, you expressly and voluntarily consent to all of the provisions of this Privacy Notice and to the Terms and Conditions governing the use of the Branded Site (the “Terms”).

(b) If you Elect Not to Provide Your Consent

You may choose not to consent to the processing of your Personal Information in accordance with our Privacy Notice or to withdraw your consent at any time after it is given. However, if you choose not to consent or you later withdraw your consent, then we may not be able to provide you the Incentive Programs on behalf of Kodak Alaris.
Specifically, you may not be able to create an account or participate on this Branded Site, and as a result you would be unable to apply for and receive any form of rebate or incentive offered by Kodak Alaris through the Incentive Program.

(c) Withdrawing Consent

Except as required or permitted by applicable data protection laws, we will not use, disclose or process your Personal Information for any purpose for which you refuse us consent or later withdraw your consent. You may at any time withdraw your consent.
If processing is based on consent, and you withdraw consent, we will immediately cease any processing of your Personal Information, however, this will not affect the lawfulness of any of your Personal Information formerly processed based on your previous consent.
If you withdraw consent, you agree that despite this withdrawal we may continue to process the Personal Information previously provided to us (i) to the extent that we are contractually obligated to do so, (ii) to the extent necessary to enforce any contractual obligations you may have to 360insights, and (iii) for any other legitimate purpose (including fraud prevention) permitted by applicable data protection laws. If you withdraw your consent to use and disclose this information, we may no longer be able to communicate with you or provide you the Incentive Programs.

2. What Is Personal Information?
“Personal Information” is broadly defined to include all information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. Personal Information could be as simple and direct as your name and e-mail address, but it could also be less explicit like how a certain individual interacted with a website or an advertisement.

3. Your Privacy Rights on this Branded Site
We believe in the fundamental right to privacy and that your rights should not differ based on where you live. Accordingly, no matter your residency, you have the following rights with respect to the Personal Information that we collect, use, or share:

To exercise your rights, you may contact Kodak Alaris directly via email at [email protected], or contact 360insights (as processor to Kodak Alaris) by email at [email protected], or if you live in California, you or your authorized agent can call 360insights’ toll-free at 1 (866) 684-2308.
You also have the right to approach the competent data protection authority with your request or complaint. If you live within:
• Canada, you may contact the Office of the Privacy Commissioner at Contact the OPC - Office of the Privacy Commissioner of Canada.
• California, you may contact the California Department of Justice’s Privacy Unit at State of California - Department of Justice - Office of the Attorney General.
• South Africa, you may contact the Information Regulator, South Africa at Contact the Information Regulator.
• the European Economic Area (EEA), a list and contact details of local data protection authorities is available here.
• the United Kingdom (UK), you may contact the UK Information Commissioner’s Office at Contact us | ICO.

4. Why We Collect Personal Information
We collect your Personal Information to enable and manage your participation in this Incentive Program, and for the other uses described herein.
Specifically, we collect your Personal Information:
(a) To facilitate our Incentives Programs on this Branded Site, which may include: Registering and managing your account, including qualifying purchases, claims, warranties, and nominations; and the fulfilment and provision of any prizes, rewards, events or payments.
(b) To communicate with you, regarding information concerning your account; the Incentive Program; or any updates to the terms of an agreement, including this Privacy Notice.
(c) To respond to you, after you have made initial contact with us regarding inquiries, comments, or concerns; requests for technical support, online services, information regarding your account; or any other communication.
(d) For analytics, such as to better understand, analyze, and respond to your needs and preferences, as well as to learn how visitors including you use the Site in order to improve it; subsequently develop, enhance, and/or provide products and services to meet those needs and preferences; or keep track of your product preferences and instructions and analyze that information.

5. How We Collect Personal Information
The Personal Information that we collect varies depending on the nature of and reason for your interaction with us. We collect Personal Information:
(a) when you register for an account or interact with our Branded Site and its respective Incentive Program;
(b) when you communicate with us or sign up to receive promotional materials or information via email, push notifications, or text messages;
(c) when you engage with our online communities or advertising, including when you click on advertisements, interact with our social media pages, submit content, leave reviews, or otherwise enter information into comment fields, blogs, message boards, events, and other community forums sponsored by or affiliated with 360insights; and,
(d) when we leverage and/or collect cookies, device IDs, location data from the environment, and other tracking technologies: We may collect certain Personal Information using cookies and other technologies such as web beacons, device IDs, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising. Our Cookie and Device Identifiers section contains more information and options to control or opt-out of certain data collection or uses.

6. Who is Your Data Controller?
Kodak Alaris is the Data Controller of this Incentive Program. Kodak Alaris is a UK company with offices located at Hemel One, Boundary Way Hemel Hempstead, HP2 7YU United Kingdom. Kodak Alaris’s global Data Protection Officer may be contacted directly by emailing [email protected].
360insights is a Data Processor for the processing activities described in this Privacy Notice. As noted below, we may share Personal Information with affiliated 360insights companies. 360insights companies are jointly responsible for the protection of your Personal Information.
(a) If you live within Canada, we have arranged for you to be able to centrally exercise all your rights through 360insights (Canada) Ltd.
(b) If you live within the EEA, we have arranged for you to be able to centrally exercise all your rights through 360insights (EEA) GmbH.
(c) If you live within the United Kingdom or South Africa, we have arranged for you to be able to centrally exercise all your rights through 360insights (Europe) Ltd.
(d) If you live within the United States, we have arranged for you to be able to centrally exercise all your rights through 360insights (USA) Ltd.

7. Legal Basis of Processing
We process your Personal Information because such processing is necessary for:
(a) exercising our rights and performing our obligations under any contract Kodak Alaris makes with you;
(b) the provision of additional services, such as marketing communications, where you have provided your consent;
(c) compliance with our legal obligations; and,
(d) legitimate interests pursued by Kodak Alaris, where such legitimate interests are the operation of the Incentive Program and the Branded Site.

8. What Personal Information Do We Collect?
We have collected the following categories of personal information from consumers:

(a) Marketing Communications

Where we are legally required to do so, we ask you for your prior consent before providing you with promotional materials or information (referred to as “Commercial Electronic Messages,” or “CEMs”). You may withdraw your consent to the receipt of CEMs at any time. This will not affect the processing of your Personal Information in relation to any rebate or incentive claim submitted to us on behalf of any of our manufacturer or distributor clients.

(b) Cookies and Device Identifiers

The Branded Site uses cookies to distinguish you from other users. This helps us to provide you with a good experience and also allows us to improve the Branded Site.
A cookie is a small file of letters and numbers that we store on your device, browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
When you first visit the Branded Site, we will ask for your consent to store certain non-essential cookies and other similar technologies on your device. We may ask you periodically to review your cookie settings.
Please note that, if you use your device or browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Branded Site.

We use the following cookies:

• Strictly necessary or essential cookies. These are cookies that are required for the operation of the Branded Site. They include, for example, cookies that enable you to log into secure areas, use a shopping cart or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around the Branded Site when they are using it. This helps us to improve the way the Branded Site works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to the Branded Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

You can find more information about the individual cookies we use on the Branded Site and the purposes for which we use them in the table below:

Except for essential cookies, cookies will expire within the times set out in the final column of the table above.

The Branded Site does not use any cross-site, targeting or advertising cookies, and we do not sell information collected by cookies on the Branded Site to any third parties or share such information with third parties for cross-context advertising purposes.

A device identifier is a unique label that can be used to identify a mobile device. Device identifiers may be used to track, analyze and improve the performance of the Branded Site and the Incentive Program.

(c) Branded Site Usage Information

Like most websites, this Branded Site gathers traffic patterns, usage information and other aggregated data in order to evaluate our visitors’ preferences and the effectiveness of our Branded Site. This aggregate usage data does not identify you individually. We may share anonymous, aggregated statistics about visitors to our Branded Site with others outside our company, or we may allow third parties to collect aggregate data through our Branded Site.

(d) California Do Not Track Requests

We do not track you over time and across third party websites to provide targeted advertising. Accordingly, we do not respond to Do Not Track (DNT) signals.

9. How we use and share your Personal Information
We do not sell Personal Information.
We will not share your Personal Information, except:
(a) to third parties performing clearly defined processing or subprocessing functions on behalf of us (such as reward fulfilment, service infrastructure, claim validation and processing, analyzing data, providing marketing assistance, and verification of data provided by you). Any processing of your Personal Information by these processors and subprocessors will be protected by an agreement regarding privacy and data security with substantially similar terms and conditions as contained herein;
(b) where we are required by law to disclose Personal Information i.e. in connection with any legal proceedings or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights;
(d) to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling. We will require any person or entity to whom we provide your Personal Information to agree to comply with our Privacy Notice. We will take reasonable commercial efforts to ensure that they comply with our Privacy Notice; and,
(e) in the event of a transfer of ownership or assets, or a bankruptcy, of 360insights or any of its affiliates.

We may also share your Personal Information with one or more of our respective subsidiary and parent companies, and other affiliated legal entities and businesses who are under common corporate control. However, all of the parent, subsidiary and affiliated legal entities and businesses of Kodak Alaris and 360insights that receive your Personal Information will comply with the terms of this Privacy Notice and all applicable data protection laws with respect to their use and disclosure of such Personal Information.

10. Anonymized Data
We may create de-identified or anonymized data from Personal Information that you provide to us by excluding data components (such as your name, email address or linkable tracking ID) that makes the data personally identifiable to you. Anonymized data is no longer considered Personal Information and is not subject to this Privacy Notice.

11. International Data Transfers
Kodak Alaris and 360insights are each global organizations. Sharing Personal Information cross-border may be required for us to fulfil the purposes for which you have disclosed that Personal Information to us.

Sharing data across borders is essential so that you receive the same high-quality service wherever you are in the world. As a result, we may, subject to applicable data protection laws, transfer Personal Information collected in connection with the Services, to entities in countries where data protection standards may differ from those in the country where you reside. By accessing the Branded Site and utilizing the Services, you understand and consent to our transfer of your Personal Information globally. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

In the event we transfer personal data to external recipients in foreign jurisdictions we will only do so if: (i) the recipient is in a jurisdiction deemed adequate by applicable data protection laws, or (ii) the recipient has entered into contract terms which afford personal data adequate protection in accordance with the requirements of applicable data protection laws, and where deemed necessary, has implemented additional measures to ensure that adequate protections are afforded to the personal data. (iii) .

12. How We Protect Your Information
To protect your Personal Information against accidental or unlawful destruction, loss, use, or alteration and against unauthorized disclosure or access, we and our processors and subprocessors use appropriate physical, technical and organizational security measures. However, please note that no method of transmission over the internet or method of electronic storage is 100 per cent secure, and therefore we cannot guarantee the absolute security of personal information. 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.

13. Your Rights to Access, Portability, and to be Forgotten

(a) Your Right to Access

You have the right to request us to confirm, free of charge, whether or not we hold Personal Information about you. You have a right to access the Personal Information we process about you. If you request access, we may levy a fee to cover our administrative expenses in providing a record of the Personal Information to you. In the event that we do levy a fee, we will first provide you with a written estimate of the fee, which you will need to agree to pay before the record may be provided to you.

We reserve the right to decline your request where the information requested:

• would disclose Personal Information of another individual or of a deceased individual;
• is subject to legal privilege;
• does not exist, is not held, or cannot be found by us; or,
• may harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions.

We also will not disclose the Personal Information where a law of your country, state, province, or other subnational entity would bar such disclosure.

(b) Updating or Correcting Your Information

You may in most cases correct or update your Personal Information by accessing your Account directly, or by instructing us to do so on your behalf.

(c) Your Right to Data Portability

If we provide you access to your Personal Information, we will provide it to you in a structured, commonly used, and machine-readable format. If you made your request electronically, we would provide access in electronic form unless you request otherwise. Your request may also be delivered by mail. This format will be, to the extent technically feasible, in a readily useable format that allows you to transmit this information to another entity without hindrance.

(d) Data Retention and the Right to be Forgotten

We do not hold onto your data forever. Instead, we shall retain your Personal Information:

• until it is no longer necessary for the purposes for which it was collected or otherwise processed;
• to comply with legal obligations (such as retention obligations under employment, tax or commercial laws); or,
• until you request that we delete it.

If you make a deletion request (see Exercising Access, Data Portability and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records as soon as is reasonably practicable, unless its retention by ourselves or our Service Providers:

• is required or authorised by law; or
• is necessary to provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise to perform our contract with you, including to enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; or
• constitutes the retention of de-identified or anonymized the data from your Personal Information so the data cannot be personally identifiable to you.

(e) Request restriction of processing of your personal data.

This enables you to ask for the suspension of the processing of your personal data in the following scenarios:

• To establish the data's accuracy.
• Where use of the data is unlawful but you do not want it erased.
• Where you need the data to be held even if no longer required, as you need it to establish, exercise or defend legal claims.
• You have objected to the use of your data but it is needed to verify whether there is an overriding legitimate grounds for it to be used.

14. We May Change this Privacy Notice
In order to maintain or enhance our Services it might be necessary to change this Privacy Notice from time to time. We therefore reserve the right to modify this Privacy Notice at any time, subject to applicable data protection laws. Please visit the Branded Site from time to time for information on updates to this Privacy Notice.

15. Other Sites
This Privacy Notice solely applies to the Personal Information collected by us in connection with the Branded Site. 360insights creates and maintains other branded websites on behalf of other partners for the provision of incentive programs to them and to their associates, customers, affiliates, and sales representatives. Each branded site is subject to its own separate privacy notice and this Privacy Notice does not apply to other branded sites. Please refer to the privacy policy on each branded site for information about how Personal Information is collected, used, and shared on those sites.

In addition, Kodak Alaris and 360insights each maintain certain corporate websites other than the Branded Site (“Corporate Sites”). This Privacy Notice does not apply to the Corporate Sites; Each Corporate Site is subject to the applicable separate privacy notice posted therein.

16. Data Privacy Contact
If you have any questions regarding this Privacy Notice or the privacy practices of Kodak Alaris, 360insights or their subprocessors, or if you require assistance to withdraw your consent to our processing of your Personal Information or wish to request that your Personal Information be deleted, please contact Kodak Alaris directly via email at [email protected] or by mail at Kodak Alaris, Attn: Data Protection Officer, 336 Initiative Drive, Rochester, NY 14624, or contact 360insights (as processor to Kodak Alaris) by sending an email to [email protected] or writing to 360insights, 300 King St., Whitby ON L1N 4Z4, Attention: Chief Privacy Officer. If you’re a resident of California, you may also call 360insights’ toll-free number at 1 (866) 684-2308.