Guiding Principle:

The principles of integrity and trust are the fundamental basis of Teleflex Canada’s Privacy Policy. This Privacy Policy establishes our commitment to comply with the Personal Information Protection Act (B.C.) (“PIPA (BC)”) in our collection, storage, destruction, use and distribution of Personal Information.

Definitions:

Personal Information: “Personal Information” means any information about an identifiable individual. This information can include an individual’s identification cards*, passwords, medical information, family history, opinions or beliefs, as well as facts about or related to the individual. Business Contact Information and Publicly Available Information as defined in PIPA (BC) are not Personal Information.

Example: where an individual provides services to Teleflex Canada under contract or as an agent, his or her contact information provided to Teleflex Canada is Business Contact Information not Personal Information.

Employee: “Employee” means a candidate for employment with Teleflex Canada, an individual who is currently or was formerly employed by Teleflex Canada on a permanent, casual, part-time, short-term, and temporary or contract basis, and includes individuals who volunteer, intern or perform as a coop or apprentice student with Teleflex.

Privacy Investigation: for the purpose of this policy, a complaint that there has been a breach to this policy will result in an initial investigation by the Chief Privacy Officer who may select to outsource the investigation to an external third party who will report the findings to both the Chief Privacy Officer and the Executive.

Accountability:

Teleflex Canada is responsible for protecting the personal information in its custody and under its control. Teleflex Canada has appointed a Chief Privacy Officer who is responsible for ensuring Teleflex Canada’s compliance with its privacy obligations.

Teleflex Canada’s Chief Privacy Officer may be contacted at privacy@teleflex.bc.ca

Identified Purposes:

Individuals will be informed of the purposes for the collection, use or disclosure of their Personal Information at or before the time the information is collected. The purposes will be those that a reasonable person would consider appropriate in the circumstances.

Consent:

Teleflex Canada generally obtains prior consent to the collection, use or disclosure of Personal Information, except where otherwise required or permitted by law.

Consent may be express or implied, depending on the circumstances. When appropriate, the written consent of the individual will be obtained (i.e. by mail, email or fax). Sometimes, an individual's consent may be obtained verbally or implied through his or her conduct with Teleflex Canada.

Teleflex Canada does not require an individual to consent to collection, use or disclosure of Personal Information as a condition of the provision of a product or service, beyond that which is necessary to provide the product or service.
Teleflex Canada will collect, use or disclose Personal Information without notice or consent only where permitted or required by law.

Consent may be varied or withdrawn subject to legal limitations and reasonable notice. Teleflex Canada will advise the individual of any consequences of a variation or withdrawal.

The Personal Information We Collect:

Teleflex Canada collects only the Personal Information that is required to meet the purposes identified by Teleflex Canada. Teleflex Canada is committed to collecting Personal Information in a fair, open and lawful manner. For this reason, Teleflex Canada does not indiscriminately collect Personal Information.

The type of Personal Information we may collect includes contact information, such as name, postal address, email address, telephone or fax numbers, etc. and demographic information, (such as consumer product preferences, age, marital and family status, financial status, gender, etc.

How we Use Personal Information:

Teleflex Canada may use personal information to communicate with our consumers, customers, shareholders, and other individuals to share company information with them and to advise them of new products, and promotions.

Teleflex Canada also collects personal information from Employees, and uses and discloses it for reasonable purposes associated with establishing, managing or terminating the employment relationship between the individual and Teleflex Canada, including managing payroll and benefits, for employee performance evaluations, training and incentive purposes, making recruitment and selection decisions, and to meet legal, security or regulatory requirements.

If Personal Information is to be used or disclosed for a purpose not identified at the time of collection, individual consent will be obtained, where required.

Website / Cookies:

When you visit our web site, www.teleflexcanada.com, please note that cookies may be used on some pages of our site. "Cookies" are small text files placed on the visitor's hard drive that assists us in providing a more customized web site experience. Cookies cannot be used to obtain Personal Information about you or to access information on your computer. However, they do allow our web site to designate certain attributes to certain users and use this information to track a user's activities on our web site. For example, our web site may use cookies for various activities, including contests, games and tracking visits to our web pages. If you are concerned about cookies, most browsers permit you to decline cookies. However, some of the features on Teleflex Canada Canada’s web site may require that the cookie function in your browser be enabled in order for the feature to be fully functional.

Links to Third Party Web Sites:

There are several places throughout www.teleflexcanada.com that may link to other web sites that do not operate under Teleflex Canada’s Privacy Policy. When you link to other web sites, Teleflex Canada’s Privacy Policy no longer applies. We encourage you to review each site's Privacy Policy before disclosing any personally identifiable information.

Limiting Use, Disclosure and Retention:

Teleflex Canada limits its use or disclosure of Personal Information to the purposes for which it was originally collected, unless it has first obtained the consent of the person from whom such information was received, or as otherwise permitted or required by law. Teleflex Canada retains personal information only for as long as it is needed for the purposes for which it was collected or used, or as otherwise required by law.

Information that is used to make a decision about an individual is kept for at least one year from the date of the decision or the date of the decision is communicated to the individual, whichever is later.
From time to time Teleflex Canada may use a third party or a related entity to store or manage Personal Information on our behalf. In such circumstances, Teleflex Canada requires such service providers and related entities to protect, by contract or other means, the Personal Information transferred to them by Teleflex Canada. Such service providers or related entities may from time to time process or store Personal Information in countries other than Canada. In this event, such Personal Information would be subject to the laws of such countries, including those authorizing or requiring disclosure of information to government authorities.

Accuracy:

Personal Information is maintained in as accurate, complete and up-to-date form as necessary for the purpose, or where it is likely to be used to make a decision about an individual or is likely to be disclosed to another organization. Teleflex Canada does not routinely update Personal Information and relies on the individual to advise it when his or her Personal Information changes.
From time to time, in its sole discretion, and for a reasonable and legitimate purpose, Teleflex Canada may request written confirmation from an individual that the information collected and held by Teleflex Canada is up to date and accurate.

Safeguards:

Personal Information is protected, by security safeguards appropriate to its sensitivity, from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. Teleflex Canada's security safeguards include:
• premises security;
• locked file cabinets and secure faxes and photocopiers;
• restricted access to personal information;
• technological safeguards such as security software and authentication methods;
• secure destruction methods including cross-cut shredding and the use of attestations of destruction;
• organizational security measures.

If Teleflex Canada uses the services of any third parties to process Personal Information, Teleflex will enter into legal agreements that require the third party to protect the Personal Information in a manner acceptable to Teleflex Canada and consistent with the protection provided by Teleflex Canada.

Teleflex Canada also ensures that any of its Employees who deal with Personal Information are properly trained and are aware of the necessary and appropriate measures required to protect Personal Information.

Openness:

Teleflex Canada will make available information about Teleflex’s policies and practices in respect of management of Personal Information. This Teleflex Canada Privacy Policy is available on our web site at www.teleflexcanada.com and can be accessed at any time. A hard copy of this Privacy Policy is also available at 3831 No 6 Road, Richmond, British Columbia.

This Privacy Policy may be modified from time to time to ensure it remains current with this rapidly developing area, and any modifications shall be effective from the date it is posted on the Teleflex Canada website.

Individual Access:

Upon written request, Teleflex Canada will inform an individual about how his or her Personal Information in Teleflex Canada’s custody or control has been and is being used and disclosed, including the names of individuals and organizations to whom the information has been disclosed, and will give the individual access to the Personal Information, subject to any limitations as permitted or required by law. Teleflex Canada authenticates the identity of the person seeking access to Personal Information before providing access. In responding to an access request, Teleflex Canada may charge a reasonable fee but no fee shall be charged for access to Employee Personal Information.

Teleflex Canada may deny access to Personal Information when required or authorized by law. Possible reasons for denying access to Personal Information include but are not limited to:
• where the disclosure may reasonably be expected to threaten an individual’s safety or physical or mental health;
• where the information would reveal third party personal information;
• where the information is protected by solicitor-client privilege;
• where the information would reveal confidential commercial information; or
• other reasons as permitted or required by law.

Where the information can be severed and the remaining Personal Information can be provided, Teleflex Canada will do so. If Teleflex Canada is unable to provide access to all of the Personal Information it holds about an individual, then the reasons for the denial of access will be provided to the individual.

Requests for access to, or information about, Personal Information must be made in writing, either to the Chief Privacy Officer via email to privacy@teleflex.bc.ca or by postal mail at the address below. Upon receipt of a request, Teleflex Canada will advise the requester as to the steps required to carry out the access request, including the method of authenticating the individual’s identity and of any steps necessary to identify the records or information sought. The time to respond to a complete request is generally thirty (30) days, but may be extended in limited circumstances as permitted or required by law. If Teleflex Canada extends the time for response we will tell the requester the reason, the time when we expect to respond and his or her rights under the PIPA (B.C.). The Chief Privacy Officer's complete contact information is as follows:

Chief Privacy Officer
Teleflex Canada Inc.
3831 No 6 Road
Richmond, BC V6V 1P6

Requesting a Correction:

An individual may challenge the accuracy of the personal information under Teleflex Canada’s custody or control. Where an individual successfully demonstrates that an error in the accuracy or completeness of their Personal Information exists, Teleflex Canada will make any necessary amendments and if appropriate, advise any third parties to whom the information was disclosed in the year prior to the date the correction was made.

If the correction is not made, Teleflex will annotate the information to show the challenge. Teleflex Canada will correct Personal Information when advised to do so by an organization that disclosed the information to Teleflex Canada.

Challenging Compliance:

Should you have any questions about Teleflex Canada’s Privacy Policy or have reason to believe that Teleflex Canada may have failed to adhere to this Privacy Policy, you may contact our Chief Privacy Officer listed above. We will conduct an investigation without delay and work to resolve any issues or concerns expressed.