1. Purpose and scope of application of the Policy
SPARINGVISION attaches great importance and care to the protection of privacy and Personal Data, as well as to compliance with the provisions of the Applicable Legislation.
2. Update of the Policy
This Policy may be regularly updated to take into account changes in the Personal Data Regulations.
Date of last update 14/09/2022.
3. Data Controller
In the context of your activity on the https://sparingvision.com/ website, we collect and use Personal Data relating to you, as a natural person (“Data Subject”).
For all the Processing, SPARINGVISION, SAS listed in the Paris Trade Register under the number 821 148 327 R.C.S Paris, with a capital of 161 426,00 EUROS having its head office 5 avenue Percier, 75008 Paris, France, determines the means and purposes of the Processing. Thus, we act as a Data Controller, within the meaning of the Regulation on Personal Data, and in particular Regulation (EU) 2016/679 on the protection of individuals with regard to the Processing of Personal Data and on the free movement of such Data.
4. What Personal Data do we collect and how?
By using our website, or by contacting us you provide us information about yourself, some of which may identify you (“Personal Information”). This is the case when you browse our site, when you fill in online forms, or simply when you sent us emails.
The nature and quality of the Personal Data collected about you varies according to the relationship you have with SPARINGVISION, the main ones being:
- Identification data: this includes all information that would allow us to identify you, such as your name, first name, telephone number. We may also collect your e-mail address and your postal address.
- Documents of different natures (PDF, Office format, Image) with titles, contents, folder names, or information linked to a document, such as comments written in the documents, alert and reminder dates.
- Navigational information: As you browse our website, you interact with it. As a result, some browsing information is collected.
- Data collected from Third Parties: Personal Data that you have agreed to share with us or on publicly available social networks and/or that we may collect from other publicly available databases.
- Health data: this includes all the medical information that you willingly share with us.
5. Why do we collect your Personal Data and how?
We collect your Personal Data for specific purposes and on different legal grounds.
On the basis of the execution of the contract or pre-contractual measures, your Data is processed for the following purposes:
- Management of contracts.
On the basis of your consent, your Data is processed for the following purposes:
- Management of the sending of press releases;
- Management of cookies requiring your consent.
On the basis of SPARINGVISION’s legitimate interests, your Data is processed for the following purposes:
- Establishment of statistics for the improvement of products and services;
- Management of users’ requests;
- Reception of patients’ health data and conduct of clinical trials
6. Do we share your Personal Data?
Your Data is intended for use by SPARINGVISION’s authorised employees in charge of the management and execution of contracts and legal obligations, according to the purposes of the collection and within the limits of their respective attributions.
It may be transmitted for certain activities related to the purposes, and within the limits of their respective missions and authorisations, to the following recipients:
- Service providers and Data Processor that we call upon to carry out a series of operations and tasks on our behalf, in particular:
- Duly authorised public authorities (judicial, supervisory, etc.), as part of our legal and regulatory obligations;
- Regulated professions (lawyers, bailiffs, etc.) who may be involved in the implementation of guarantees, collection or litigation;
When your Data is communicated to our service providers and Data Processor, they are also required not to use the Data for purposes other than those initially intended. We make every effort to ensure that these Third Parties maintain the confidentiality and security of your Data.
In all cases, only the necessary Data is provided. We make every effort to ensure that your Data is communicated or transmitted securely.
We do not sell your Data.
7. How long do we keep your Personal Data?
We keep your Personal Data only for as long as is necessary to fulfil the purpose for which we collect the Data and to meet your needs or our legal obligations.
Retention periods vary depending on several factors, such as:
- SPARINGVISION business needs;
- Contractual requirements;
- Legal obligations;
- Recommendations from supervisory authorities.
The retention periods for your Data are as follows:
Management of contracts
5 years starting from the end of the contract
Management of recruitment operations
2 years after the last contact with the rejected candidate
Management of the sending of press releases
3 years starting from the last contact with the data subject
Management of cookies requiring your consent
Establishment of statistics for the improvement of products and services
Management of users’ requests
Reception of patients’ information.
8. How do we guarantee Personal Data security?
SPARINGVISION is committed to protecting the Personal Data we collect or process from loss, destruction, alteration, unauthorised access or disclosure.
Therefore, we implement all appropriate technical and organisational measures, depending on the nature of the Data and the risks involved in processing it. These measures must preserve the security and confidentiality of your Personal Data. These measures may include practices such as restricted access to Personal Data by persons authorised by virtue of their functions, pseudonymisation or encryption.
In addition, our practices and policies and/or physical and/or logical security measures (secure access, authentication process, back-up, software, etc.) are regularly reviewed and updated as necessary.
9. What are your rights?
SPARINGVISION undertakes to guarantee the effective exercise of the Data Subjects’ rights granted to them by the Applicable legislation. Subject to the Applicable legislation Data Subject have the following rights:
- Right to information: the right to have clear, precise and complete information about SPARINGVISION’s use of their Personal Data.
- Right of access: the right to obtain a copy of the Personal Data that the Controller holds on the requester.
- Right of rectification: the right to have their Personal Data rectified if they are inaccurate or obsolete and/or to complete them if they are incomplete.
- Right to erasure / right to be forgotten: the right, under certain conditions, to have the Data erased or deleted, unless SPARINGVISION has a legitimate interest in keeping them.
- Right to object: the right to object to the Processing of Personal Data by SPARINGVISION for reasons related to the particular situation of the requester (under conditions).
- Right to withdraw Consent: the right at any time to withdraw Consent when the Processing is based on Consent.
- Right to restriction of Processing: the right, subject to specific conditions, to request that the Processing of Personal Data be temporarily suspended.
- Right to Data portability: subject to specific conditions, right to receive from the Controller Personal Data concerning the Data Subject, which he or she has provided to the Controller, in a structured, commonly used and machine-readable format.
- Right not to be the subject to an automated decision: subject to specific conditions, right not to be subject to a decision based solely on an automated Data Processing activity, including profiling, which produces legal effects concerning the Data Subject or similarly significantly affects him or her.
- Right to define post-mortem instructions: the right for the Data Subject to leave instructions regarding the fate of his/her Personal Data after death.
Additional rights may be granted by the Local Regulations to the Persons concerned.
To this end, SPARINGVISION defines and implements a procedure for the management of Data Subjects’ rights in accordance with the requirements of the Applicable legislation. This procedure establishes:
- The standards to be respected to ensure the transparent information of Data Subjects;
- The legal requirements that must be respected;
- The authorised means of submitting an application for each right, according to the category of Data Subjects;
- The business processes to manage these requests in accordance with the above requirements;
- The parties involved in these processes, their roles and responsibilities.
Requests submitted by Data Subjects pursuant to their rights are recorded in a register for the purpose of demonstrating compliance. The procedure for managing the rights of persons referred to above defines the content and procedures for keeping this register.
To exercise your rights, you can contact the Data Protection Officer (DPO): 5 avenue Percier, 75008 Paris or by email at firstname.lastname@example.org.
When you send us a request to exercise a Right, you are asked to specify as far as possible the scope of the request, the type of right exercised, the Personal Data Processing concerned, and any other useful element, in order to facilitate the examination of your request. In addition, in case of reasonable doubt, you may be asked to prove your identity.
You also have the right to complain to the Commission Nationale de l’Informatique et des Libertés (CNIL), 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07, about the way in which SPARINGVISION collects and processes your data.
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