GLOBAL DATA PRIVACY POLICY

1. About Henry Schein
2. Overview
3. Types of personal data we collect and use
4. Our Policy Towards Children
5. Sources of personal data
6. Uses and purposes of Personal Data
7. Legal basis for data collection and use
8. Retention periods
9. Disclosures to Third Parties and processing activities
10. Security
11. Your data protection rights and choices
12. International Transfers of Personal Data
13. Changes to this notice
14. Contact information
15. General Information

1. About Henry Schein

Henry Schein, Inc. (Nasdaq: HSIC) is the world’s largest provider of health care products and services to office-based dental, animal health and medical practitioners. The company also serves dental laboratories, government and institutional health care clinics, and other alternate care sites. Headquartered in Melville, N.Y., Henry Schein has operations or affiliates in 34 countries.

Henry Schein operates through a centralized and automated distribution network, with a large selection of branded products and Henry Schein private-brand products. The company also offers its customers innovative technology solutions, including practice management software and e-commerce solutions, as well as a broad range of financial services.

You can find our contact details at the last section of this policy.

2. Overview

At Henry Schein, Inc., your privacy is important to us. We process personal data in different contexts and we do so by fully respecting your privacy and your other rights and freedoms, as part of our unwavering commitment to ethical and responsible practices.

See below for more details.

3. Types of personal data we collect and use

We recognize personal data as any information related to an identified or identifiable individual. Depending on the context of your interactions with Henry Schein, we collect and use different types of personal data from employees, contractors, candidates, customers, prospect customers and vendors.

See below for more details.

4. Our Policy Towards Children

Our services are not directed to children. We do not knowingly collect personal data from children. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, please contact us. If we become aware that a child has registered for a service and has provided us with personal data, we will delete such information from our files.

5. Sources of personal data

Henry Schein receives and uses various types of personal data in order to conduct our day to day business activities. We apply the data minimization principle in the collection and use of personal data ensuring that we only collect information that is necessary and by fair means, and providing notice and requiring consent when necessary.

See below for more details.

6. Uses and purposes of Personal Data

The purposes for which we collect and use your personal data may vary depending on the type of relationship you have with us, such as if you are one of our employees, customers, or a website user. Henry Schein always collect and use personal data according to the purpose limitation principle. The use of personal data for new purposes should always guarantee consistency and your privacy expectations, otherwise we will request your authorization.

See below for more details.

7. Legal basis for data collection and use

Henry Schein only collects and uses personal data when there is a fair and legal basis for its collection and use, for instance, when the collection of personal data is necessary to enter into a contract, to meet our legitimate interests, to comply with legal obligations or when we have your authorization.

See below for more details.

8. Retention periods

Henry Schein applies the storage limitation principle in order to retain personal data in our records only for the length of time required to fulfill the purpose for which the data was collected. We do not keep personal data for longer than is necessary, and what is necessary depends on specific circumstances such as regulations requiring to retain information for a certain period of time and limitation periods of legal claims.

See below for more details.

9. Disclosures to Third Parties and processing activities

At times, Henry Schein engages third party contractors, service providers, and other vendors to help us accomplish our business objectives. There are other circumstances where we are required by law to disclose personal data to third parties such as public bodies or judicial authorities.

See below for more details.

10. Security

Henry Schein is committed to the security, confidentiality and integrity principle. We take commercially reasonable precautions to keep all information obtained from our online visitors secure against unauthorized access and use and we periodically review our security measures. We are committed to processing your data in a secure manner and have put in place specific technical and organizational measures to prevent the personal data we hold from being accidentally or deliberately compromised.

See below for more details.

11. Your data protection rights and choices

If you reside or otherwise find yourself in the territory of Europe, Henry Schein is committed to facilitate the exercise of your rights granted by the European data protection law. Otherwise you can contact us at any time to discuss your privacy concerns.

See below for more details.

12. International Transfers of Personal Data

If you are located outside the United States and you interact with our website or provide us personal data, then your personal data may be transferred to the United States. If you are based in the European Economic Area or Switzerland, please be informed that the United States is not in the list of countries that the European Commission considers adequate to the protection of personal data. However, we provide appropriate safeguards for your data in the US, as we elected to self-certify under the EU-US Privacy Shield and under the Swiss-US Privacy Shield.

13. Changes to this notice

We reserve the right to modify this Policy and related business practices at any time. We will duly inform you of any changes.

See below for more details.

14. Contact information

At Henry Schein we are committed to apply this Policy and the accountability principle. For this reason, if you have any concern or questions about how your personal data is used, please feel free to contact us.

See below for more details.

15. General Information

Policy Owner: Nancy Lanis, Vice President, Chief Compliance Officer
Policy Contact: Steve Tredwell, / Data Protection Officer
Published Date: 1st March 2018
Required Adoption Date: 25th May 2018
Date Last Revised: 1st March 2018
Approved By: Steve Tredwell / Data Protection Officer
[1] Published Date – The original published date the policy was approved by Senior Company Management
[2] Required Adoption Date – Date by which all subsidiaries of Henry Schein, Inc. need to comply with the policy
[3] Date Last Revised – Last date policy was updated

Additional Information

Overview

This Global Data Privacy Policy (“Policy”) sets forth the principles that govern our treatment of personal data across Henry Schein, Inc. and their subsidiaries and affiliates worldwide (hereafter, Henry Schein). All employees and those with whom we share personal data must adhere to this Policy.

Henry Schein is committed to protecting the information that our employees, customers, prospects, suppliers, and vendors have entrusted to us. We collect and use personal data in order to perform our business functions and provide quality health care products and services to our customers.

Consistent with our values, we treat any personal data that we obtain in accordance with the data privacy principles of transparency (including the right to information), purpose limitation, data minimization, data quality, integrity and confidentiality, accountability, and privacy by design.

This Policy applies to all personal data in any format or medium, relating to all employees, customers, vendors and others who do business with Henry Schein.

Types of personal data we collect from:

  • Employees, contractors and candidates: including contact and login information, employment details and history, benefits, compensation, performance, video images from security cameras, use of company resources for employees, contractors, and applicants all in connection with their role or potential role within Henry Schein.
  • Customers: including name, tax and financial information, contact information for key personnel, language, signature, communications and login information, segmentation and marketing attributes.
  • Prospect customers: including name and contact information.
  • Customers of our customers: we access personal data from customers of our customers, which may include sensitive information, only when it is necessary to provide the service. In this context, we act on behalf of our customers, and the service is governed by a data processing agreement.
  • Vendors and suppliers: including name, tax and financial information, contact information for key personnel, language, communications and segmentation.
  • Visitors of an office building: including name and contact information and video images from security cameras in some of our office buildings.
  • Website and social media users: In addition to the information visitors volunteer, we automatically collect the domain name, Internet Protocol (IP) address, browser type and version, operating system and platform, average time spent on our website, pages viewed, information searched for, access times and other relevant statistics. Our website also uses cookies (see below).

Use of cookies and other information gathering technologies

In addition to the personal data you volunteer, our Web server automatically collects such information as the domain name of the Website providing you with Internet access, the Internet protocol (IP) address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Web site, pages viewed, information searched for, access times and other relevant statistics. Henry Schein uses this information in order to ensure that unauthorized users do not access the information on its Web site, and in the aggregate to measure the use of its Web site and to administer and improve it.

Henry Schein also uses cookies to provide visitors a personalized experience on our Web site. Cookies are pieces of information that a Web site transfers to the memory or hard drive of a visitor’s computer for record-keeping purposes. Henry Schein uses cookies to allow access without re-entering the visitor’s User ID, to make improvements, and to better tailor its Web site to its visitors’ needs. Henry Schein also uses this information to verify that visitors meet the criteria required to process their requests.

Most browsers used by visitors have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent, but setting a browser to reject cookies will prevent access to our Web site. In addition, you can delete your Henry Schein cookies from your browser program at any time.

Sources of personal data additional information

Some of this data is collected directly from you in the following situations when:

  • You apply for a position with our company
  • We negotiate and/or establish a contractual relationship (e.g. on employment or commercial terms),
  • You provide us with any type of service, as a provider or vendor
  • When we provide you with any type of service, product or support.
  • When you browse, or use our website, e-commerce services, or social media pages

Sometimes we also obtain data from third parties including subsidiaries and affiliates of Henry Schein Inc. worldwide, in the following situations:

  • We may conduct analytics to determine additional product and services which may be of interest
  • We may share data between subsidiaries or affiliates for centralizing Customer Relationship Management systems
  • We may purchase data from external companies for marketing purposes

Uses and purposes of Personal Data additional information

  • Employees and candidates: if you apply for a job, we use your personal data to consider you for employment and to administer your application and/or account. If you have an employment or commercial relationship with Henry Schein, we use your personal data to develop our contractual relationship, to conduct performance evaluations and to comply with legal obligations, including tax and labor regulations.
  • Customers: we use our customers’ information to maintain our commercial relationship, to ensure the proper operation of the day-to-day business, to comply with tax and other regulations, and to administering sales, and marketing activities.
  • Customers of our customers: we provide support services to our customers that use our health care related products and services, when required.
  • Prospect customers: information from prospects customers is used to respond to their requests for information, products or services, and for marketing activities.
  • Vendors and suppliers: if you have a business or professional relationship with Henry Schein, we will use your information to develop our business relationship with you, and to comply with tax and other regulations.
  • Visitors of an office building: our buildings and premises generally have physical and technical access controls and some have video surveillance systems for security purposes.
  • Website and social media users: we collect personal data from visitors and users of our website and social media pages. We use the information to manage your account registration, to store your preferences and settings, to provide interest-based advertising, to conduct statistics and to analyze how you use our website and online services.
  • We also may use personal data of our employees, customers, prospects, vendors or suppliers for other purposes based on our legitimate interests, such as to conduct analytics for product development, to create statistics about product usage, to generate profiles for making promotional offers.

Legal Basis additional information

The information we collect when we enter into a contract or business relationship with you, except if we indicate otherwise, is mandatory to develop our contractual relationship and to comply with legal obligations. For instance, some tax laws, labor, anti-fraud or compliance laws require organizations to collect certain information that may vary depending on the local regulations. Without the required mandatory information, we would not be able to work with you.

Marketing activities are usually based on your consent or to an existing business relationship with us. However, you can opt-out of these communications anytime and free of charge.

When we use your personal data for our legitimate interests, we always conduct a balancing test in order to ensure that data subject rights are not overridden.

Finally, when we have access to personal data on behalf of our customers, in our role as data processors, there is always a written contract regulating the service, including specific instructions for the data processing and safeguards.

Retention period additional information

The retention period depends on the context in which we process data such as data from use of our website, data from prospective employees, or employee data after employee has left the company. The retention periods are established considering Henry Schein’s legitimate business purposes and according to local regulations.

Disclosures to Third Parties additional information

We engage with third party contractors, service providers and other vendors for the following services: Payroll processing, Warranty, waste disposal services, etc. If the engagement involves the transmission of personal data, Henry Schein requires the service provider to treat that data consistent with this Policy. A contract to protect the personal data will be executed before any data is disclosed.

In certain circumstances, Henry Schein may be required to disclose personal information when required by law, when required to protect our legal rights, or in an emergency situation where the health or security of an individual is endangered.

We may also disclose personal data in the context of any sale or transaction involving all or a portion of the business.

Security additional information

Henry Schein uses Let’s Encrypt for its sites security certificates. Please be aware that these protection tools do not protect information that is not collected through our Web site, such as information provided to us by e-mail.

We also conduct information risk assessments, we ensure that our staff understands the importance of protecting personal data, and we are responsibly managing access rights within the company. We include both physical security and IT security in our overall data security approach. We are diligent in selecting vendors that process personal data on our behalf so that they also ensure appropriate technical and organizational measures to protect the data.

Henry Schein makes reasonable efforts to notify individuals and regulatory authorities, as required by law, if we reasonably believe that personal information has been stolen, disclosed, altered or infringed by an unauthorized person. We create and maintain a breach notification and reporting protocol.

We also endorse the concept of privacy by design which is an approach to projects that promotes privacy and data protection compliance from the outset. This means considering the privacy and security implications for any new project or process throughout its lifecycle.

Your data protection rights additional information

Privacy rights under the European regulation:

Transparency and the right to information: we provide notice to our employees, customers, suppliers, vendors and others of how we use personal data in our day-to-day operations at the time of collecting personal data, or as soon thereafter as possible. We also publish this privacy notice for a greater transparency.

Right to access, rectification, restriction of processing, and erasure: we provide data subjects with access to their own personal data where required by applicable law. In addition, we will rectify their personal data when it is incorrect and inaccurate, and we will ensure the right to erasure and to restriction of processing when these rights are not compatible with local regulations.

Right to object and withdraw consent at any time: for all marketing materials, you can opt-out anytime, and free of charge. The right to object for other processing activities will be balanced in order to ensure that it is not incompatible with local regulations or the legitimate interests of Henry Schein.

Right to data portability: based on your specific situation, we provide data subjects with the right to obtain and reuse your data across different services and includes transferring of your data to you, another controller or a trusted third party.

Right to lodge a complaint with a supervisory authority

These requests should be submitted as follows:

  • Opt-out of marketing communications: you can opt-out anytime by following the opt-out instructions in our commercial e-mails using our customer preference web site or by communicating your wishes to a team member.
  • To exercise the rest of your rights: you should send a communication in writing to your local Henry Schein office using the contact information shown here and providing the following information in order to verify your identity your name address telephone number, email and account number if applicable. Henry Schein will attend to your request in a timely manner within 30 days after receiving your request. If for any reason we need to extend this period of time, we will contact you.
  • Right to lodge a complaint with a supervisory authority: you can have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of the alleged infringement.

Changes Additional Information

Changes in this Policy will be notified to you via an email communication. We will give you the opportunity to express your consent for processing your data for different and new purposes, or we will in any case inform you about the legal basis of such processing other than consent. The time stamp you see on the Policy will indicate the last date it was revised.

Contact additional information

If you have any concerns or questions about how your personal data is used, please contact us at:

Henry Schein UK Holdings Limited
Medcare House
Centurion Close
Gillingham Business Park
Gillingham ME8 0SB
England
Telephone: 0800 028 1533
Fax: 01634 877626
E-mail: customercare@henryschein.co.uk

You can also contact our Data Protection Officer at DPO@henryschein.co.uk. We will promptly respond and make everything possible to address your concern.

Last Updated: 22 May 2018