ZOLL Patient Management Network Privacy Statement

Privacy is very important to ZOLL Services, LLC (“ZOLL”), and ZOLL understands that privacy is very important to you, too. This Privacy Statement tells you how ZOLL protects and uses information gathered in connection with the ZOLL Patient Management Network (the “Website”) and any other circumstances in which ZOLL makes this Privacy Statement available to you.

This Privacy Statement was last revised on 2025-03-13. ZOLL may change this Privacy Statement periodically (in particular if ZOLL’s processing activities change). The latest version will be published on this page. ZOLL encourages you to review this Privacy Statement each time you visit the Website.

Please read the Terms of Use to understand the general rules about your use of this Website.

For information about the use of cookies and similar tracking technologies, please see ZOLL’s Cookies Policy linked here.

INTRODUCTION

The information ZOLL receives, and how it is used, depends on what you do when visiting the Website. The Website is primarily intended for healthcare professionals serving patients wearing a ZOLL device, such as the ZOLL LifeVest® or another ZOLL device (each a “Device”).

If you are a patient reviewing this Privacy Statement and you are in the United States , you may also have received a Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) Notice of Privacy Practices from ZOLL or your healthcare provider. If that Notice of Privacy Practice conflicts with any provision in this Privacy Statement, the Notice of Privacy Practices will control.

This Privacy Statement also includes information relevant to individuals in certain U.S. states and the European Economic Area.

HOW TO CONTACT ZOLL

To ask questions or comments about this policy and ZOLL’s privacy practices, including requests to exercise rights you may have with respect to your personal data as detailed below, contact ZOLL as follows:

WHICH DATA CATEGORIES DOES ZOLL COLLECT?

The personal data ZOLL may collect about you through the Website includes:

• Product information
• Device performance information
• Information about the operation, function, and use of a Device
• Patient medical information, including recorded signals and treatment information, is collected by the Device, and made available to healthcare professionals. In addition, information may be entered by healthcare professionals about patients using the Device and collected by the ZOLL Patient Management Network system.
• Information related to your employment, and educational, and professional background as a healthcare professional
• The type of web browser software you use (for example, Netscape Navigator or Internet Explorer)
• The name of the domain from which you access the Internet
• The Internet address of the website from which you linked directly to the Website
• The date and time you access the Website
• Which pages you have visited on the Website
• Name
• Telephone number
• E-mail address
• Medical device serial number
• Date of birth
• Account registration information including your username and password

WHAT IS PERSONAL DATA?

Personal data is information directly or indirectly relating to an identified or identifiable natural person. In comparison, non-personal data cannot identify you or be tied to you in any way (e.g., fully anonymized personal data).

DOES ZOLL EVER SHARE PERSONAL DATA WITH THIRD PARTIES?

ZOLL will not share your personal data collected from this Website with an unrelated third party without your permission, except as otherwise provided in this Privacy Statement, and always in accordance with applicable data protection law. In the ordinary course of business, ZOLL will share some personal data with companies that perform services or functions on ZOLL’s behalf. For example, ZOLL may use different vendors or suppliers to ship products to you that you order on the Website. In these cases, ZOLL provides the vendor with information necessary to process your order, such as your name and mailing address. In all cases in which ZOLL shares your personal information with a third party, ZOLL will not authorize the third party to keep, disclose, or use your information with others except as necessary to provide the services ZOLL asked the third party to provide. In addition, ZOLL will conclude necessary data processing agreements where required by law. ZOLL may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law, or regulation. ZOLL may cooperate with law enforcement authorities in investigating and prosecuting Website visitors who violate the Terms of Use or engage in behavior that is harmful to other visitors or illegal. ZOLL may also disclose your personal information to third parties if ZOLL believes the disclosure is necessary to:

• enforce the Terms of Use and the other rules about your use of the Website;
• protect ZOLL’s rights or property;
• protect anyone's health, safety, or welfare; and
• comply with a law or regulation, court order, or other legal process.

In addition to the ways that ZOLL may keep, disclose, and use information described in this Privacy Statement, ZOLL also may keep, disclose, and use personal data that you provide through the Website in ways that ZOLL believes are consistent with HIPAA; U.S. Food and Drug Administration requirements; and other applicable governmental guidance, directions, regulations, and laws.

DATA RETENTION

ZOLL stores your data only as long as required to fulfill the purposes stated in this Privacy Statement or the Terms of Use. For example, ZOLL keeps the personal data as long as you keep an active account on the Website. After termination of the contract, ZOLL stores only the data that is required to fulfill statutory retention obligations.

SPECIAL TERMS FOR DATA SUBJECT TO THE GDPR

If you are an individual in the European Economic Area (the “EEA”), your personal data may be subject to the General Data Protection Regulation (the “GDPR”). The following provisions apply where the GDPR applies to ZOLL’s processing of personal data in connection with the Website.

ZOLL is the controller of this Website, the legal entity that determines the purposes and means of processing personal data on this Website.

Legal Basis for Processing Personal Data: ZOLL’s legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which it is collected. ZOLL collects personal data from you where needed to perform a contract with you—i.e., to provide you with services and to deal with any issues occurring related to these services. Furthermore, ZOLL processes your personal data if required to comply with statutory obligations or court or governmental orders or if you consent to the processing, such as certain types of marketing communication. ZOLL may also process personal data as necessary to protect your vital interests or those of another person, as well as for ZOLL’s legitimate interests not overridden by your interests or fundamental rights and freedoms.

International Data Transfers: As a US-based company, ZOLL will transfer your personal data to ZOLL in the US and to ZOLL’s business partners and service providers in territories outside of the EEA, including the US. If ZOLL processes your personal data outside the EEA, ZOLL has in place appropriate measures such as current Standard Contractual Clauses published by the European Commission and supplementary measures, where required, providing for an adequate level of protection.

Your EEA Data Protection Rights: If ZOLL processes your personal data that is subject to the GDPR and you wish to access, correct, update, or request deletion of your personal data, you can make a request at any time by contacting ZOLL using the contact details provided under the “How to Contact ZOLL” heading above.

You can object to processing of your personal data, ask ZOLL to restrict processing of your personal data, and request portability of your personal data. Again, you can exercise these rights by contacting ZOLL using the contact details provided under the “How to Contact ZOLL” heading above.

Similarly, if ZOLL has collected and processed your personal data pursuant to your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about ZOLL’s collection and use of your personal data. For more information, please contact ZOLL at the above e-mail address.

SPECIAL TERMS FOR CALIFORNIA RESIDENTS

If you are a California resident, your personal data may be covered by the California Consumer Privacy Act (the “CCPA”). The below disclosures apply to the extent the CCPA applies to ZOLL’s collection and processing of your data in connection with the Website, subject to any applicable exemptions. In particular, much of the information collected and used will be subject to HIPAA and therefore not subject to the CCPA.

“Personal Information” ZOLL Collects: The categories of “personal information,” as defined in the CCPA, that ZOLL collects include:

• Identifiers
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Characteristics of protected classifications under California or federal law
• Commercial information
• Internet or other electronic network activity information
• Educational information
• Professional or employment related information
• Inferences drawn from other personal information

ZOLL may obtain, use, and share these and other data categories as detailed in the above sections of this Privacy Statement regarding how ZOLL collects and uses personal data.

“Sales” of Personal Information: ZOLL does not “sell” your personal information as that term is defined in the CCPA.

Your California Privacy Rights: You may have the following rights with respect to your personal information under the CCPA:

(i) Right to Know About Personal Information Collected, Disclosed, or Sold: You may have the right to request that ZOLL provide certain information to you about its collection and use of your personal information over the past twelve (12) months. Specifically, you may have the right to request disclosure of:

• The specific pieces of personal information ZOLL collected about you;
• The categories of personal information ZOLL collected about you;
• The categories of sources from which ZOLL collected personal information;
• ZOLL’s business or commercial purpose for collecting or disclosing personal information; and
• The categories of third parties with whom ZOLL shared personal information.

(ii) Right to Request Deletion of Personal Information: You may also have the right to request that ZOLL delete any of your personal information that ZOLL collects or maintains about you, subject to certain exceptions.

(iii) Right to Correct Inaccurate Personal Information: You may also have the right to request that ZOLL correct inaccurate personal information ZOLL maintains.

(iv) Right to Non Discrimination for the Exercise of a Consumer’s Privacy Rights: ZOLL will not unlawfully discriminate against you for exercising any of your applicable privacy rights.

Exercising Your California Privacy Rights: To request to exercise your CCPA rights described above, please submit a verifiable consumer request to ZOLL by using the information in the “Contact Us” section above. Only you or your “authorized agent,” as defined in the CCPA, may make a verifiable consumer request related to your personal information.

Your verifiable consumer request must: (1) provide sufficient information that allows ZOLL to reasonably verify that you are the person about whom ZOLL collected personal information, or an authorized representative and (2) describe your request with sufficient detail that allows ZOLL to properly understand, evaluate, and respond to it. ZOLL cannot respond to your request or provide you with personal information if ZOLL cannot verify your identity or authority to make the request and confirm the personal information relates to you. ZOLL will use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format: ZOLL will make best efforts to respond to a verifiable consumer request within forty five (45) days of receipt. If ZOLL requires more time (up to ninety (90) days), ZOLL will inform you of the reason and extension period in writing. Within ten (10) business days of receiving the request, ZOLL will confirm receipt and provide information about its verification and processing of the request. ZOLL will maintain records of consumer requests made pursuant to the CCPA as well as ZOLL’s response to said requests for a period of at least twenty four (24) months.

WHAT HAPPENS IF THE PRIVACY STATEMENT CHANGES?

If ZOLL decides to make a significant change to this Privacy Statement, ZOLL will post a notice on the Website for a period of time after the change is made, and ZOLL will notify registered users of the change.

WHAT ABOUT PRIVACY ON OTHER WEBSITES?

The Website may contain links to other websites. Some of those websites may be operated by ZOLL, and some may be operated by third parties. The links are provided for your convenience, but ZOLL does not review, control, or monitor the privacy practices of websites operated by others. This Privacy Statement does not apply to any other website, including other ZOLL websites. ZOLL is not responsible for the performance of websites operated by third parties or for your business dealings with them. Therefore, whenever you leave this Website, you should review the privacy practices of those other websites and make your own conclusions regarding the adequacy of those practices.

DOES ZOLL EVER COMMUNICATE DIRECTLY WITH VISITORS TO THIS WEBSITE?

ZOLL may contact you periodically by e-mail, mail, or telephone to provide information regarding programs, products, services, and content that may be of interest to you (if you have given your prior consent to be contacted where required by applicable law). In addition, some of the features on the Website allow you to communicate with ZOLL using an online form. If your communication requests a response from ZOLL, ZOLL will send you any response via e-mail. The e-mail response or confirmation may include your personal data, including personal data about your health, your name, address, etc. ZOLL cannot guarantee that any e-mails to you will be secure from unauthorized interception.

WHAT ABOUT WEBSITE SECURITY?

ZOLL has implemented appropriate technical and organizational security measures designed to protect your personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, e-mail may not be secure, and you should therefore take special care in deciding what information you send to ZOLL via e-mail.