SPINE INNOVATIONS is fully aware of the importance of privacy and the protection of personal data and is committed to ensuring adequate protection of personal data with regard to all persons with whom it has relations.
What you will find in this document
This global Privacy and Personal Data Protection Policy (the « Policy ») describes the general measures implemented by SPINE INNOVATIONS to ensure adequate protection of personal data, that is to say of any information relating to an identified or identifiable natural person, and this for the major data processing carried out within the framework of its business relations and its activities (“Personal Data”). What processing activities are covered by this Policy? This Policy applies to the processing activities carried out by SPINE INNOVATIONS with respect to the persons with whom it maintains relations in the course of its activities and business relations.
Collection of your Personal Data for explicit and legitimate purposes
SPINE INNOVATIONS may collect your Personal Data for the following purposes:
- to carry out operations related to our activities;
- comply with the legal and regulatory obligations applicable to SPINE INNOVATIONS;
- provide assistance to patients;
- manage our research and development activities;
- provide you with access to our online services, platforms and tools;
- allow us to identify and authenticate you;
- develop and improve our products and services;
- personalize your experience when you use our services;
- allow us to communicate with you;
- make payments that we may have to issue in specific situations;
- make donations and carry out sponsorship operations;
- respond to requests from administrative or judicial authorities in accordance with applicable law;
- protect our rights and interests.
Processing of Personal Data
Depending on the data processing in question, SPINE INNOVATIONS will process your personal data on the basis of one or the other of these legal grounds:
- your prior consent when you have clearly expressed your agreement for SPINE INNOVATIONS to process your Personal Data.
- a contractual relationship between you and SPINE INNOVATIONS: in such a case, the processing of your Personal Data is generally necessary for the signing or performance of the obligations of the contract; therefore, if you do not want SPINE INNOVATIONS to process your Personal Data under these conditions, SPINE INNOVATIONS may or must refuse to enter into a contractual relationship with you or will not be able to provide you with the products or services covered by this contract. .
- legal, regulatory and ethical obligations applicable to the activities of SPINE INNOVATIONS; such as our publication obligations relating to « link transparency » in accordance with the Bertrand Law of December 29, 2011.
- a “legitimate interest” of SPINE INNOVATIONS within the meaning of the applicable legislation on the protection of Personal Data. In such a case, SPINE INNOVATIONS will take into account your interests and fundamental rights in determining whether the processing is legitimate and lawful.
Collecting data from reliable sources
SPINE INNOVATIONS may collect your Personal Data from different sources:
- Data that you communicate to us through various media, during registration, or use of the application and any other direct or indirect interaction with SPINE INNOVATIONS.
- Data that we collect automatically, for example, when we monitor your interactions with our websites, platforms, tools and services, in particular by means of cookies.
- Data that we collect in compliance with applicable law from public sources, including data published by you in various media.
with Edge: tool tab (pictogram in the shape of a cog at the top right) / internet options. Click on Privacy and choose Block all cookies. Validate on Ok
with Firefox: at the top of the browser window, click on the Firefox button, then go to the Options tab. Click on the Privacy tab. Configure the retention rules on: use personalized settings for history. Finally, uncheck it to disable cookies.
with Safari: Click at the top right of the browser on the menu pictogram (symbolized by a cog). Select Settings. Click Show advanced settings. In the « Confidentiality » section, click on Content settings. In the « Cookies » section, you can block cookies.
with Chrome: Click on the menu pictogram at the top right of the browser (symbolized by three horizontal lines). Select Settings. Click Show advanced settings. In the « Confidentiality » section, click on preferences. In the « Confidentiality » tab, you can block cookies.
Recipients of your Personal Data
For the purposes described above, SPINE INNOVATIONS may have to share your Personal Data with the parties authorized below:
- SPINE INNOVATIONS and its affiliated companies;
- our selected partners and suppliers;
- any administrative or judicial authority, when required under applicable law, including under provisions of foreign law;
- any potential purchaser and other stakeholder;
In all cases, SPINE INNOVATIONS ensures that these third parties:
- undertake to comply with applicable data protection legislation and the principles of this Policy;
- process Personal Data exclusively for the purposes described in this Policy; and implement the appropriate technical and organizational security measures to protect the integrity and confidentiality of your Personal Data.
Transfers of your Personal Data outside the UE
SPINE INNOVATIONS may need to transfer your Personal Data (including by giving access to it, allowing it to be viewed, or storing it) to subsidiaries, subcontractors and partners of the group in other jurisdictions, including included from the European Economic Area and outside the European Economic Area.
Implementation of security measures to protect your Personal Data
SPINE INNOVATIONS implements all the necessary and appropriate control measures so that your Personal Data is kept on secure servers, and is kept strictly confidential.
Retention of your Personal Data
SPINE INNOVATIONS will keep your Personal Data only for the time necessary to achieve the purposes described in this Policy
Exercise of your rights relating to your Personal Data
You have the possibility to exercise the rights which are granted under the terms of the applicable data protection legislation.
To this end, SPINE INNOVATIONS informs you that you have the right:
- access your Personal Data on request, in which case you will receive a copy, unless these data are made available to you directly;
- obtain rectification of your Personal Data in the event that they are inaccurate, incomplete or obsolete;
- to obtain the deletion of your Personal Data in the situations provided for by applicable data protection legislation (« right to be forgotten »);
- withdraw your consent to the processing of your Personal Data (without this affecting the lawfulness of the processing) when your Personal Data has been processed and collected on the basis of your consent;
- to oppose the processing of your Personal Data, when they have been collected and processed on the basis of the legitimate interests of SPINE INNOVATIONS, in which case it will be up to you to justify your request by explaining your particular situation to us;
- request a restriction of processing in the situations covered by applicable law;
If you wish to exercise any of these rights, please contact us as indicated in the « Contact Us » section. We will take the necessary steps to respond to you as quickly as possible.
SPINE INNOVATIONS will be happy to hear your comments and answer your questions regarding this Policy or its implementation. If you wish to contact us about the use of your Personal Data, or object to the processing of your Personal Data, please send an email to the personal data manager at : firstname.lastname@example.org
When making this request, we thank you for indicating specifically the information you wish to correct, modify, delete, and attach your identity document (for example, identity card, passport).
Validity and evolution of this Policy
This Policy may be modified by SPINE INNOVATIONS over time, in particular to adapt it to developments or changes in applicable law or internal SPINE INNOVATIONS practices. The changes will appear on this page. We invite you to consult this Policy regularly.
Date of last update: August 2020