Terumo Global Privacy Policy | Privacy Policy | Terumo

PRIVACY STATEMENT

1. Privacy Statement.This Website is operated by MicroVention, Inc. (“MicroVention”). This Data Privacy and Cookies Policy sets forth the policies that govern our collection, use, and disclosure of the information that you may provide via our Websites. Before using or submitting information to this Website, please read this entire Data Privacy and Cookies Policy. This Website is governed solely by applicable Federal and State laws and governmental regulations in the United States of America. Use of this Website constitutes your consent to application of such laws and regulations and to this Data Privacy and Cookies Policy. Whenever you submit information via this Website, you consent to the collection, use, and disclosure of that information in accordance with this Data Privacy and Cookies Policy.

2. Information We Collect:

a. Personal Information.This Website may collect personal information from its visitors both by asking them specific questions and by facilitating direct communications with us via email, feedback forms, etc. Some of the information that visitors submit may be personally identifiable information (that is, information that can be uniquely identified with an individual, such as full name, address, email address, phone number, and so on). If you use this Website to submit or request information related to a grant proposal or donation, additional information we may collect includes your hospital affiliation and details of your proposal. In some cases, we may collect non-personally identifiable information that you elect to provide voluntarily, such as gender or zip code. This Website may also offer some features and activities (such as newsletter subscriptions, downloads, etc.), which may require you to submit information to receive or benefit from them. You will be informed at each information collection point what information is required and what information is optional.

b. Website Usage Information.Like many other Websites, this Website may or may not also collect some information passively as you navigate through the Website (that is, this information is gathered without your actively providing the information), using various technologies and means, such as navigational data collection. Navigational data ("log files," "server logs," and "clickstream" data) are used for system management, to improve the content of the Website, market research purposes, and to communicate information to visitors. One of the ways information may be passively collected is by use of Internet Protocol (IP) addresses. An IP address is a number assigned to your computer by your Internet service provider so you can access the Internet. IP addresses are generally considered to be non-personally identifiable information, because most IP addresses are dynamic (they change each time you connect to the Internet), rather than static (unique to any one user’s computer). We may use your IP address to improve or administer the Website, diagnose server problems, report aggregate information, or to determine the fastest connection route between your computer and our Website. We may also collect your website usage information by means of "cookies." A cookie is a small data text file, which a website stores on your computer's hard drive (if your Web browser permits) that can later be retrieved to identify you. "Session cookies" are temporary bits of information that are erased once you exit your Web browser window or otherwise turn your computer off. Session cookies are used to improve navigation on websites and to collect aggregate statistical information. This Website may use both cookies and session cookies. If you do not wish to receive cookies from this or any other website, you can change your computer's settings so that it will no longer accept cookies. Internet tags (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the Website server information such as the IP address and browser type related to the visitor's computer. This Website may or may not use Internet tags.

c. Information Use and Disclosure.Your name, address, email address, and any other personally identifiable information you provide may be used by MicroVention to provide you with information about MicroVention products, clinical or other health issues, or to develop services concerning neurovascular diseases and related topics. MicroVention will not sell or rent the personally identifiable information collected via this Website to a third party. We reserve the right to disclose information to respond to duly authorized information requests of governmental authorities, where required by law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Website, or to prevent imminent harm to any person or group of people, and also to share all information submitted without restriction with affiliate and/or related entities and other third parties engaged to provide services to MicroVention. If ownership of all or substantially all of MicroVention were to change, your information may be transferred to the new owner so that the Site can continue to operate. In any such transfer of information, your information would remain subject to the promises made in any pre-existing privacy policy. You can notify MicroVention that you wish to discontinue receiving information at any time. We may use your information to improve the value of our Website's content, to present the Website in a fashion customized to match your preferences, to supply information to you (if you requested it), for research and marketing purposes, and for the purposes specified in this Data Privacy and Cookies Policy. We may combine personally identifiable information with other actively collected information unless we specify otherwise at the point of collection. We will also make full use of all information acquired through this Website that is not personally identifiable.

d. Security.Please bear in mind that no Internet transmission is ever 100% secure or error-free. More specifically, email sent to or from this Website may not be secure. As a result, you should take particular care in deciding what information you send via email. Please take care to safeguard any passwords, ID numbers, or other special access numbers you might use to access any part of this Website; such information is your responsibility. MicroVention takes reasonable steps to protect your personally identifiable information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, but does not and cannot guarantee such protection.

e. Links to Other Websites.Links or references to other websites may appear within this Website. We do not control these websites. You should be aware that this Data Privacy and Cookies Policy does not apply to any websites other than those operated by MicroVention. Visitors to other Websites are encouraged to read those privacy policies before exploring them.

f. Children’s Privacy.Children should always get permission from their parents before sending any information about themselves (such as their names, email addresses, and phone numbers) over the Internet, to us or to anyone else. The Website is not directed at individuals under 18, and we will not knowingly allow anyone under 18 to provide us any personally identifying information; if you are under 18, please do not provide any information about yourself on this Website.

g. How to Contact Us.If you have any questions, comments, or concerns about this Data Privacy and Cookies Policy or the information collection practices of this Website, please contact us.

h. Changes to This Data Privacy and Cookies Policy.MicroVention reserves the right to modify, add or remove portions of this Data Privacy and Cookies Policy at any time and in its sole and absolute discretion. Any changes to this Data Privacy and Cookies Policy will be posted on this Website. Please check back periodically, and especially before you provide any personally identifiable information. This Data Privacy and Cookies Policy was last updated on November 4, 2020.

Some products and/or services that we provide require the involvement of third parties. We do not sell, rent, distribute or otherwise make Personal Data commercially available to any third party, except that we may share information within our group of companies, with our service providers and other third parties for the purposes set out in this Policy.

We have carefully selected these service providers and taken steps to ensure that your Personal Data is adequately protected. All of our service providers are bound by written contract to process Personal Data provided to them only for the purposes of providing the specific service to us and to maintain appropriate security measures to protect your Personal Data.

3. International Transfers of Personal Data outside of EEA

The transfer of your Personal Data to and between the Affiliates, service providers or other recipients may involve your Personal Data being sent outside of the European Economic Area (“EEA”), to locations that may not provide the same level of protection as those within the EEA countries, including to third countries that are not covered by an adequacy decision of the European Commission, including to such countries as the United States.

However, we may only transfer your Personal Data outside of the EEA:

• where the transfer is to a place or by a method or in circumstances that is regarded by the European Commission as providing adequate protection for your Personal Data;
• where we have put in place standard data protection clauses adopted by the European Commission or a relevant data protection authority; or
• where none of the above apply but we are still legally permitted to do so, for example if the transfer is necessary for the performance of a contract concluded with you or in your interest, or for the establishment, exercise or defense of legal claims.

To know more please visit our EMEA dedicated section or you can request further details about the safeguards that we have in place in respect of transfers of Personal Data outside of the EEA and where applicable a copy of the standard data protection clauses that we have in place by contacting us at: dataprotection@microvention.com.

4. How Long Do We Store Personal Data?

It is our policy to retain your Personal Data for the length of time required for the specific purpose or purposes for which it was collected (e.g., for the fulfilment of an agreement with you). However, we may be obliged to store some Personal Data for a longer time, taking into account factors including:

• legal obligation(s) under applicable law to retain data for a certain period of time (e.g. compliance with tax and accountancy requirements);
• the establishment, exercise or defense of legal claims (e.g., for the purposes of a potential dispute).

Whilst we continue to process your Personal Data, we will ensure that it is treated in accordance with this Data Data Privacy and Cookies Policy. Otherwise, we securely erase or anonymize your Personal Data once it is no longer needed.

If you would like to find out how long we keep your Personal Data for a particular purpose, you can contact us at: dataprotection@microvention.com.

5. How Do We Protect Your Data?

We acknowledge that your Personal Data may be confidential. We will maintain the confidentiality of and protect your Personal Data in accordance with our Privacy Statement and all applicable laws, including the General Data Protection Regulation 2016/679 (“GDPR”).

We have implemented technological and operational security measures in order to protect your Personal Data from loss, misuse, or unauthorized alteration or destruction. Such measures include the use of firewalls, encryption, proper access rights management processes, careful selection of processors and other technically and commercially reasonable measures to provide appropriate protection for your Personal Data. Where appropriate, we may also make backup copies and use other such means to prevent accidental damage to or destruction of your Personal Data. These measures ensure an appropriate level of security in relation to the risks inherent in the processing and the nature of the Personal Data to be protected.

Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure. We will notify you promptly in the event of any breach of your Personal Data that might expose you to serious risk.

6. Affiliated Entities

We may share (or receive) information about you, including personal information, with the companies of our group which are:

• MicroVention Europe
• MicroVention UK
• MicroVention Gmbh

When such sharing of information involves transfers outside the European Union, these transfers are based on standard contractual clauses.

7. Your Rights

The following section explains your rights that you may exercise. The various rights are not absolute and each is subject to certain exceptions or qualifications in accordance with the GDPR and other generally applicable provisions of data privacy law.

The right to be informed – you have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Data. This is why we are providing you with the information in this Data Data Privacy and Cookies Policy and in any legal notices or terms and conditions provided to you.

The right of access – you have the right to obtain from us confirmation as to whether or not your Personal Data is being processed by us, and about certain other information (similar to that provided in this Policy) about how it is used. You also have the right to access your Personal Data, by requesting a copy of the Personal Data concerning you. This is so you are aware and can check that we are using your information in accordance with data protection law. We can refuse to provide information where to do so may reveal personal data about another person or would otherwise negatively impact another person's rights.

The right to rectification – you can ask us to take measures to correct your Personal Data if it is inaccurate or incomplete (e.g., if we have the wrong name or address for you).

The right to erasure – this is also known as the ‘right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Data where, for example, there is no compelling reason for us to keep using it or its use is unlawful. This is however not a general right to erasure and there are some exceptions, e.g. where we need to use the information in defense of a legal claim or to be able to comply with a legal obligation.

The right to restrict processing – you have the right to ‘block’ or suppress the further use of your Personal Data when we are assessing a request for rectification or as an alternative to erasure. When processing is restricted, we can still store your Personal Data, but may not use it further.

The right to data portability – you have the right to obtain and reuse certain Personal Data for your own purposes across different organizations (being separate data controllers). This only applies to your Personal Data that you have provided to us that we are processing with your consent and for the purposes of contract fulfilment, which is being processed by automated means. In such a case we will provide you with a copy of your data in a structured, commonly used and machine-readable format or (where technically feasible) we may transmit your data directly to a separate data controller.

The right to object – you have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of legitimate interests pursued by MicroVention Europe, any of the Affiliates, or by a data recipient. We will be allowed to continue to process the Personal Data if we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or we need this for the establishment, exercise or defense of legal claims. If you object to the processing of your Personal Data for direct marketing purposes, we will no longer process your Personal Data for such purposes.

The right to withdraw consent – where we process your Personal Data on the basis of your consent, you have the right to withdraw your consent at any time. However, such withdrawal does not affect the lawfulness of the processing that occurred prior to such withdrawal.

The right to provide us with directives regarding the use of your personal information after your death (only for French people) – you have the right to provide us with instructions on the management (e.g., retention, erasure and disclosure) of your personal information after your death. You can change or revoke your instructions at any time.

The right to lodge a complaint – if you believe that we do not comply with applicable data protection laws, you have the right to lodge a complaint before any competent data protection authority.

8. How to Contact Us

If you wish to request further information or exercise any of the above rights, or if you are unhappy with how we have handled your Personal Data, contact:

• for European countries our Data Protection Officer at dataprotection@microvention.com
• for all other countries:  hello@microvention.com

Before assessing your request, we may request additional information in order to identify you. If you do not provide the requested information and, as a result, we are not in a position to identify you, we may refuse to action your request.

We will generally respond to your request within one month of receiving your request. We can extend this period by an additional two months if this is necessary taking into account the complexity and number of requests that you have submitted.

We will not charge you for such communications or actions we take, unless you request additional copies of your Personal Data undergoing processing, in which case we may charge for our reasonable administrative costs, or you submit manifestly unfounded or excessive requests, in particular because of their repetitive character, in which case we may either charge for our reasonable administrative costs or refuse to act on the request.

If you, as European citizen, are not satisfied with our response to your complaint or believe our processing of your Personal Data does not comply with data protection law, you can file a complaint to the relevant data protection authority, the French Commission Nationale de l’Informatique et des Libertés(CNIL).

Initial Request Form - English

Initial Request Form - French

Data Privacy and Cookies Policy - English

Data Privacy and Cookies Policy - French

DATA PRIVACY AND COOKIES POLICY

Last update: 16.10.2020

Contents

A. ABOUT THIS POLICY

B. WHO IS ACCOUNTABLE FOR YOUR DATA?

C. WHAT DATA DO WE PROCESS AND WHY?

D. HOW AND WHEN DO WE SHARE DATA WITH THIRD PARTIES?

E. INTERNATIONAL TRANSFERS OF PERSONAL DATA

F. HOW LONG DO WE STORE PERSONAL DATA?

G. HOW DO WE PROTECT YOUR DATA?

H. LINK TO OTHER WEBSITES

I. DO WE USE COOKIES TO GATHER INFORMATION?

J. CHILDREN’S PRIVACY

K. AFFILIATED ENTITIES

L. YOUR RIGHTS

M. HOW TO CONTACT US

1. ABOUT THIS POLICY

We are committed to providing you with professional and valuable products and services whilst safeguarding your privacy.

This Data Privacy and Cookies Policy (also “Policy”) covers both our online and offline data collection activities and outlines when, why and how we collect, use and otherwise handle (collectively “process”) personal information about our customers, potential customers, business partners (including healthcare professionals), patients, distributors, association representative, suppliers and users of our websites (“Data Subjects”). “Personal Data” is any information relating to you, which can be used to personally identify you, either directly or indirectly.

It also tells you how you can access and update your information and make choices about how your information is used. More information on how to contact us to exercise your data subject rights is in Section M below.

We may process your Personal Data, as described in this Data Privacy and Cookies Policy.

Where you use our websites, we will process your Personal Data collected by using cookies in accordance with this Policy.  

If we decide to change the way we handle your information, we will post those changes in this Policy. For some changes, we will notify you more prominently and/or give you prior choice, depending on the legal requirements we will have to comply with. We reserve the right to make changes to our practices and this Policy at any time, provided that we follow the procedures above.

2. WHO IS ACCOUNTABLE FOR YOUR DATA?     

We - MicroVention Europe, a French limited liability company, with its head office at 30 bis rue du Vieil Abreuvoir - 78100 Saint-Germain-en-Late, registered with the Registry of Commerce and Companies of Versailles under number 440 775 674 RCS ("MicroVention Europe") - are the data controller of your Personal Data. We can be contacted at dataprotection@microvention.com

In this Policy, references to “we”, “us” or “our” means MicroVention Europe and/or our Affiliates. References to “you” and “your” are to the Data Subjects.

3. WHAT DATA DO WE PROCESS AND WHY?

The types of information that we may collect from you, depending on how you interact with us (e.g. how you use our websites), and the purposes of processing, include:

1. Customers

• Type of information
  • your name
  • your address (business and personal)
  • your e-mail address
  • your telephone numbers (business and personal)
  • shared directory of healthcare professionals (“RPPS”)
• Purposes of processing
  • management of tenders
  • order management
  • provide commercial offers
  • reply to your requests
  • customer relationship
  • management of clinical trials
  • product and services improvement
• Legal basis of processing
  • performance of an agreement with you we have in place
  • your consent (if requested and provided)

2. Potential customers

• Type of information
  • your name
  • your address (business and personal)
  • your e-mail address
  • your telephone numbers (business and personal)
• Purposes of processing
  • sending you marketing communications (including our email newsletter) relating to our products or services, if you have requested them
• Legal basis of processing
  • your consent (if requested and provided)

3. Healthcare professionals (including physician, dispenser, manipulator etc.)

• Type of information
  • your name
  • your address (business and personal)
  • your e-mail address
  • your telephone numbers (business and personal)
  • your job title, role, working life, participation to clinical studies, registration number to professional association role
  • compensation and benefits
  • bank details
  • travel data for visa (family status, personal life, insurance certificate etc.)
  • professional publications
• Purposes of processing
  • sending you expert opinion
  • performance of clinical studies (as part of MR-003 methodology, standard case studies, non-interventional research)
  • performance of an agreement with you we have in place
  • proctoring
  • donation management (grant, instructions)
  • organization of travels and registration to congress
• Legal basis of processing
  • to comply with our legal and regulatory obligations (clinical studies in accordance with MR-003 and applicable regulation, transparency obligation)
  • performance of an agreement with you we have in place (consulting agreement)
  • your consent (if requested and provided)

4. Patient

• Type of information
  • operating details
  • patient identification in case of clinical studies, materiovigilance or improvement of products and services quality
  • identification data (age, gender)
  • health data (medical history, clinical study participation, radiographic image)
• Purposes of processing
  • materiovigilance
  • improvement of MVE’s products and services (quality)
  • sending to healthcare professionals our experience and know-how
• Legal basis of processing
  • regulatory obligation of materiovigilance
  • our legitimate interest in order to provide our expert opinion

5. Distributors and sales representatives

• Type of information
  • standard identification data
• Purposes of processing
  • communication and logistic organization with healthcare professionals outside France
• Legal basis of processing
  • performance of an agreement with you we have in place

6. Associations representatives

• Type of information
  • standard identification data
• Purposes of processing
  • donation management
• Legal basis of processing
  • performance of an agreement with you we have in place

7. Suppliers

• Type of information
  • standard identification data
• Purposes of processing
  • general services, relationship with suppliers and management of disputes
• Legal basis of processing
  • our legitimate interest

8. Users of our websites

• Type of information
  • cookies
  • IP address
  • geographical location
  • browser type and version
  • operating system
  • information about your visits to and use of our websites
• Purposes of processing
  • administering our websites
  • personalizing our websites
  • enabling your use of the services available on our websites
• Legal basis of processing
  • our legitimate interest
  • your consent (if requested and provided)

Legitimate Interests- Where we use your Personal data for our Legitimate Interests, this can include business purposes such as:

• record keeping, statistical analysis, internal reporting and research purposes;
• to investigate any complaints you make;
• to provide evidence in any disputes or anticipated disputes between you and us;
• for the detection and prevention of fraud, other criminal offences and for risk management purposes;
• for business and disaster recovery (e.g. to create back-ups);
• to ensure network and information security;
• to host, maintain and otherwise support the operation of our websites, including to customise various aspects of our websites to improve your experience;
• for document and data retention/storage;
• to protect the rights, property, and/or safety of MicroVention Europe, any of the Affiliates, its personnel and others; and
• to ensure the quality of the services we provide to our clients and other Data Subjects.

We believe the risk to your data protection rights in connection with Personal Data that we process on the basis of our legitimate interests is not excessive or overly intrusive. We have also put in place protections for your rights by ensuring proper retention periods and security controls.

In addition, we may use your Personal Data for additional specific purposes made clear at the point of collection of your Personal Data.

If you choose not to provide the Personal Data requested by us, we may not be able to provide you with the products and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the Personal Data.

4. HOW AND WHEN DO WE SHARE DATA WITH THIRD PARTIES?

Some products and/or services that we provide require the involvement of third parties. We do not sell, rent, distribute or otherwise make Personal Data commercially available to any third party, except that we may share information within our group of companies, with our service providers and other third parties for the purposes set out in this Policy:

1. Data sharing within MicroVention group

MicroVention Europe may share your Personal Data with our Affiliates:

• where we need to do so in order to provide the products and/or services or information that you have requested;
• if you consent to us doing so (e.g. when you give us consent for marketing communications with our Affiliates).

2. Data sharing with service providers

We also share your Personal Data with our third party service providers, whom we engage to provide various services, in relation to:

• deliveries of our products;
• marketing and advertising services (e.g. marketing agencies, interactive agencies, e-mailing solution providers);
• travel and congress organizer , hotels, carriers, embassies (visas);
• our websites (e.g., hosting and maintaining our websites);
• IT services and solutions (e.g., providing data storage, assisting us with database management).

We have carefully selected these service providers and taken steps to ensure that your Personal Data is adequately protected. All of our service providers are bound by written contract to process Personal Data provided to them only for the purposes of providing the specific service to us and to maintain appropriate security measures to protect your Personal Data.

3. Data sharing for materiovigilance, expert opinion and transparency obligation

We may also share your Personal Data, including health data, with:

• the national health agency for health and medicine (ANSM), the recipient of materiovigilance data;
• the French health authority;
• healthcare professionals in order to provide our expert opinion;
• clinical research organization (CRO) and other processors in accordance with the MR-003 regulation;
• institutional affiliation of healthcare professionals in order to obtain authorisation or provide them with information.

4. Data sharing with other recipients

We may also share your Personal Data with:

• our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advice;
• any other third party if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or to protect the rights, property and/or safety of MicroVention Europe, any of the Affiliates, its personnel and others;
• any other third party for the purposes of acting in accordance with the requirements of a court, regulator or government agency, for example, complying with a court order or acting in accordance with an applicable law or regulation; or
• investors and other relevant third parties in the event of an potential sale or other corporate transaction related to MicroVention Europe and/or any of the Affiliates.

5.   INTERNATIONAL TRANSFERS OF PERSONAL DATA

The transfer of your Personal Data to and between the Affiliates, service providers or other recipients may involve your Personal Data being sent outside of the European Economic Area (“EEA”), to locations that may not provide the same level of protection as those within the EEA countries, including to third countries that are not covered by an adequacy decision of the European Commission, including to such countries as the United States.  

However, we may only transfer your Personal Data outside of the EEA:

• where the transfer is to a place or by a method or in circumstances that is regarded by the European Commission as providing adequate protection for your Personal Data;
• where we have put in place standard data protection clauses adopted by the European Commission or a relevant data protection authority, including as the case maybe supplemental clauses containing additional safeguards; or
• where none of the above apply but we are still legally permitted to do so, for example if the transfer is necessary for the performance of a contract concluded with you or in your interest, or for the establishment, exercise or defence of legal claims.

You can request further details about the safeguards that we have in place in respect of transfers of Personal Data outside of the EEA and where applicable a copy of the standard data protection clauses that we have in place by contacting us at: dataprotection@microvention.com.

6. HOW LONG DO WE STORE PERSONAL DATA?

It is our policy to retain your Personal Data for the length of time required for the specific purpose or purposes for which it was collected (e.g., for the fulfilment of an agreement with you). However, we may be obliged to store some Personal Data for a longer time, taking into account factors including: 

• legal obligation(s) under applicable law to retain data for a certain period of time (e.g. compliance with tax and accountancy requirements);
• the establishment, exercise or defence of legal claims (e.g. for the purposes of a potential dispute).

Whilst we continue to process your Personal Data, we will ensure that it is treated in accordance with this Policy. Otherwise, we securely erase or anonymise your Personal Data once it is no longer needed.

If you would like to find out how long we keep your Personal Data for a particular purpose, you can contact us at: dataprotection@microvention.com. For more information on how long cookies are stored, please refer to section I.

7. HOW DO WE PROTECT YOUR DATA?

We acknowledge that your Personal Data may be confidential. We will maintain the confidentiality of and protect your Personal Data in accordance with our Policy and all applicable laws, including the General Data Protection Regulation 2016/679 (“GDPR”).

We have implemented technological and operational security measures in order to protect your Personal Data from loss, misuse, or unauthorised alteration or destruction. Such measures include the use of firewalls, encryption, proper access rights management processes, careful selection of processors and other technically and commercially reasonable measures to provide appropriate protection for your Personal Data.  Where appropriate, we may also make backup copies and use other such means to prevent accidental damage to or destruction of your Personal Data. These measures ensure an appropriate level of security in relation to the risks inherent in the processing and the nature of the Personal Data to be protected.

Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.

We will notify you promptly in the event of any breach of your Personal Data that might expose you to serious risk.

8.   LINK TO OTHER WEBSITES

Links or references to other websites may appear within our websites. We do not control these websites. You should be aware that this Policy does not apply to any websites other than those operated by MicroVention Europe. Visitors to other websites are encouraged to read those privacy policies before exploring them.

1.   DO WE USE COOKIES TO GATHER INFORMATION?

When you visit or interact with our website, we (or our third-party providers) may use "cookies" or other similar technologies to personalize and enhance your experience. A “cookie” is a small piece of information sent to a visitor’s computer or other Internet-connected devices to uniquely identify the visitor’s browser or to store information or settings in the browser. Cookies are used in particular to make our websites work, or work more efficiently, as well as to provide data to the website owners. Our websites use required cookies, functional cookies, and analytics and performance cookies.

When your prior consent is required for their use, the period of validity of the consent to the deposit of cookies is six (6) months. At the end of this period, we will ask for your consent again.

When your prior consent is not required, the cookies lifetime is limited to thirteen (13) months (this period is enough for a relevant comparison of audience measure) and information collected through the cookies is retained for a maximum of twenty-five (25) months.

Our websites use:

• Required cookies enable you to move from page to page and to use features on our websites while your browser remains open. If a user blocks these cookies via the browser then we cannot guarantee how the website will perform. For example, remembering the user is not a first time user to the website,
• Functional and preference cookies. For example, functional cookies may be used to recognize you as a previous visitor in order to provide a more personalized experience (remembering the preferred language etc.). They are stored in your computer, device, or browser until you choose to delete them,
• Analytics and performance cookies allow us to collect data concerning the websites, including the number of visitors, where the visitors have come from, and the length of time visitors spend on the websites, which allows us or third-party service providers to analyse how our websites are used and how our websites are performing. We use this information to improve our website and provide a better user experience. You can learn more about their privacy policies and how to opt-out of their cookies by clicking on the appropriate link below:

            Google Analytics: http://www.google.com/analytics/learn/privacy.html.

Our websites also use “social buttons” for third party social media sites to enable visitors to share or bookmark web pages. We provide social buttons to the following social media sites, and you can learn more about their privacy policies and how to opt-out of their cookies by clicking on the appropriate link below:

Facebook: https://www.facebook.com/policies/cookies/

Instagram: https://help.instagram.com/519522125107875

LinkedIn: https://privacy.linkedin.com/

YouTube: https://policies.google.com/privacy?hl=en

Vimeo: https://vimeo.com/privacy

The majority of web browsers accept cookies and similar files, but you can usually change your browser settings to prevent this. If for any reason you decide that you do not like our use of certain cookies, you can simply change your settings at any time. However, if you do so, some functionality of our websites may be lost.

The setting of each browser is different. It is described in the browser's help menu.

» Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

• Click the access Menu button and then choose "Options"
• Choose "Privacy & Security"
• Set the History Section on "Use custom settings for History"
•  Uncheck the box "Accept cookies from websites".
• All changes you have made will be automatically saved.

» Internet Explorer:  https://support.microsoft.com/en-us/topic/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

• Select the Tool button, then Internet Options.
• Select Privacy Tab, and then under Settings, move the cursor to the top to block all cookies or to the bottom to allow cookies, then click on OK.

» Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

• Select the Chrome menu icon.
• Click on "Settings".
• At the bottom, click on "Advanced".
• Under "Privacy and security," click on "Content settings".
• Click on "Cookies".
• Turn "Allow sites to save and read cookie data" on or off.

» Safari:  https://support.apple.com/en-gb/guide/safari/sfri11471/mac

• Click on "Settings" > "Safari" > "Privacy" > "Cookies and website data"
• Then select "always block cookies".

» For Opera: http://help.opera.com/Windows/10.20/en/cookies.html

If you have any specific questions about the use of cookies on our websites, please feel free to contact us at any time by emailing dataprotection@microvention.com with the Subject line “Cookie Request.”

10.   CHILDREN'S PRIVACY

Children should always get permission from their parents before sending any information about themselves (such as their names, email addresses, and phone numbers) over the internet, to us or to anyone else. Our websites are not directed at individuals under 18, and we will not knowingly allow anyone under 18 to provide us any personally identifying information; if you are under 18, please do not provide any information about yourself on this website.

11.   AFFILIATED ENTITIES

We are in charge of the relationship with you and all the customers and data subjects on our territory of activities.

We may share (or receive) information about you, including personal information, with our parent entity MicroVention US which headquarter is located 35 Enterprise, Aliso Viejo, CA  92656.

We may share your personal information with the companies of our group which are:

• MicroVention UK
• MicroVention Deutschland GmbH
• Terumo’s group companies

When such sharing of information involves transfers outside the European Union, these transfers are based on standard contractual clauses as stated in section E.

50.   YOUR RIGHTS

The following section explains your rights that you may exercise. The various rights are not absolute and each is subject to certain exceptions or qualifications in accordance with the GDPR and other generally applicable provisions of data privacy law.

• The right to be informed – you have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Data. This is why we are providing you with the information in this Policy and in any legal notices or terms and conditions provided to you.
• The right of access – you have the right to obtain from us confirmation as to whether or not your Personal Data is being processed by us, and about certain other information (similar to that provided in this Policy) about how it is used. You also have the right to access your Personal Data, by requesting a copy of the Personal Data concerning you. This is so you are aware and can check that we are using your information in accordance with data protection law. We can refuse to provide information where to do so may reveal personal data about another person or would otherwise negatively impact another person's rights.
• The right to rectification – you can ask us to take measures to correct your Personal Data if it is inaccurate or incomplete (e.g., if we have the wrong name or address for you).
• The right to erasure – this is also known as the ‘right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Data where, for example, there is no compelling reason for us to keep using it or its use is unlawful. This is however not a general right to erasure and there are some exceptions, e.g. where we need to use the information in defence of a legal claim or to be able to comply with a legal obligation.
• The right to restrict processing – you have the right to ‘block’ or suppress the further use of your Personal Data when we are assessing a request for rectification or as an alternative to erasure. When processing is restricted, we can still store your Personal Data, but may not use it further.
• The right to data portability – you have the right to obtain and reuse certain Personal Data for your own purposes across different organisations (being separate data controllers). This only applies to your Personal Data that you have provided to us that we are processing with your consent and for the purposes of contract fulfilment, which is being processed by automated means. In such a case we will provide you with a copy of your data in a structured, commonly used and machine-readable format or (where technically feasible) we may transmit your data directly to a separate data controller.
• The right to object – you have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of legitimate interests pursued by MicroVention Europe, any of the Affiliates, or by a data recipient. We will be allowed to continue to process the Personal Data if we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or we need this for the establishment, exercise or defence of legal claims. If you object to the processing of your Personal Data for direct marketing purposes, we will no longer process your Personal Data for such purposes.
• The right to withdraw consent – where we process your Personal Data on the basis of your consent, you have the right to withdraw your consent at any time. However, such withdrawal does not affect the lawfulness of the processing that occurred prior to such withdrawal.
• The right to provide us with directives regarding the use of your personal information after your death – you have the right to provide us with instructions on the management (e.g., retention, erasure and disclosure) of your personal information after your death. You can change or revoke your instructions at any time.
• The right to lodge a complaint – if you believe that we do not comply with applicable data protection laws, you have the right to lodge a complaint before any competent data protection authority.

1000.   HOW TO CONTACT US

If you wish to request further information or exercise any of the above rights, or if you are unhappy with how we have handled your Personal Data, contact our Data Protection Officer at: dataprotection@microvention.com or send us a letter at:

MicroVention Europe : 20, quater Rue Schnapper, 78100 Saint-Germain-en-Laye.

Before assessing your request, we may request additional information in order to identify you.  If you do not provide the requested information and, as a result, we are not in a position to identify you, we may refuse to action your request.

We will generally respond to your request within one month of receiving your request. We can extend this period by an additional two months if this is necessary taking into account the complexity and number of requests that you have submitted.

We will not charge you for such communications or actions we take, unless:

• you request additional copies of your Personal Data undergoing processing, in which case we may charge for our reasonable administrative costs, or
• you submit manifestly unfounded or excessive requests, in particular because of their repetitive character, in which case we may either charge for our reasonable administrative costs or refuse to act on the request.

If you are not satisfied with our response to your complaint or believe our processing of your Personal Data does not comply with data protection law, you can file a complaint to the relevant data protection authority, the French Commission Nationale de l’Informatique et des Libertés (CNIL).

Initial Request Form - English

Initial Request Form - German

Data Privacy and Cookies Policy - English

Data Privacy and Cookies Policy - German

DATA PRIVACY AND COOKIES POLICY

Last update: 16.10.2020

Contents

A. ABOUT THIS POLICY

B. WHO IS ACCOUNTABLE FOR YOUR DATA?. 2

C. WHAT DATA DO WE PROCESS AND WHY?. 2

D. HOW AND WHEN DO WE SHARE DATA WITH THIRD PARTIES?. 5

E. INTERNATIONAL TRANSFERS OF PERSONAL DATA.. 6

F. HOW LONG DO WE STORE PERSONAL DATA?. 7

G. HOW DO WE PROTECT YOUR DATA?. 7

H. LINK TO OTHER WEBSITES. 8

I. DO WE USE COOKIES TO GATHER INFORMATION?. 8

J. CHILDREN’S PRIVACY.. 9

K. AFFILIATED ENTITIES. 10

L. YOUR RIGHTS. 10

M. HOW TO CONTACT US. 11

1. ABOUT THIS POLICY

We are committed to providing you with professional and valuable products and services whilst safeguarding your privacy.

This Data and Cookies Privacy Policy (also “Policy”) covers both our online and offline data collection activities and outlines when, why and how we collect, use and otherwise handle (collectively “process”) personal information about our customers, potential customers, business partners (including healthcare professionals), patients, distributors, association representative, suppliers and users of our websites (“Data Subjects”). “Personal Data” is any information relating to you, which can be used to personally identify you, either directly or indirectly.

It also tells you how you can access and update your information and make choices about how your information is used. More information on how to contact us to exercise your data subject rights is in Section M below.

We may process your Personal Data, as described in this Data Privacy and Cookies Policy.

Where you use our websites, we will process your Personal Data collected by using cookies in accordance with this Policy.  

If we decide to change the way we handle your information, we will post those changes in this Policy. For some changes, we will notify you more prominently and/or give you prior choice, depending on the legal requirements we will have to comply with. We reserve the right to make changes to our practices and this Policy at any time, provided that we follow the procedures above.

2.  WHO IS ACCOUNTABLE FOR YOUR DATA?

MicroVention Deutschland GmbH with its head office at: Hildebrandtstraße 4F, 40215 Düsseldorf, registered in the companies register under the number HRB-Nr.: 59061 (“MicroVention”) – are the data controller of your Personal Data. We can be contacted at dataprotection@microvention.com.

In this Policy, references to “we”, “us” or “our” means MicroVention Deutschland GmbH and/or our Affiliates. References to “you” and “your” are to the Data Subjects.

3. WHAT DATA DO WE PROCESS AND WHY?

The types of information that we may collect from you, depending on how you interact with us (e.g. how you use our websites), and the purposes of processing, include:

1. Customers

• Type of information
  • your name
  • your address (business and personal)
  • your e-mail address
  • your telephone numbers (business and personal)
  • shared directory of healthcare professionals
• Purposes of processing
  • management of tenders
  • order management
  • provide commercial offers
  • reply to your requests
  • customer relationship
  • management of clinical trials
  • product and services improvement
• Legal basis of processing
  • performance of an agreement with you we have in place
  • your consent (if requested and provided)

2. Potential customers

• Type of information
  • your name
  • your address (business and personal)
  • your e-mail address
  • your telephone numbers (business and personal)
• Purposes of processing
  • sending you marketing communications (including our email newsletter) relating to our products or services, if you have requested them
• Legal basis of processing
  • your consent (if requested and provided)

3. Healthcare professionals (including physician, dispenser, manipulator etc.)

• Type of information
  • your name
  • your address (business and personal)
  • your e-mail address
  • your telephone numbers (business and personal)
  • your job title, role, working life, participation to clinical studies, registration number to professional association role
  • compensation and benefits
  • bank details
  • travel data for visa (family status, personal life, insurance certificate etc.)
  • professional publications
• Purposes of processing
  • sending you expert opinion
  • performance of clinical studies
  • performance of an agreement with you we have in place
  • proctoring
  • donation management (grant, instructions)
  • organization of travels and registration to congress
• Legal basis of processing
  • to comply with our legal and regulatory obligations (clinical studies, transparency obligation)
  • performance of an agreement with you we have in place (consulting agreement)
  • your consent (if requested and provided)

4. Patient

• Type of information
  • operating details
  • patient identification in case of clinical studies, materiovigilance or improvement of products and services quality
  • identification data (age, gender)
  • health data (medical history, clinical study participation, radiographic image)
• Purposes of processing
  • materiovigilance
  • improvement of MVE’s products and services (quality)
  • sending to healthcare professionals our experience and know-how
• Legal basis of processing
• regulatory obligation of materiovigilance
• our legitimate interest in order to provide our expert opinion

5. Distributors and sales representatives

• Type of information
  • standard identification data
• Purposes of processing
  • communication and logistic organization with healthcare professionals outside France
• Legal basis of processing
  • performance of an agreement with you we have in place

6. Associations representatives

• Type of information
  • standard identification data
• Purposes of processing
  • donation management
• Legal basis of processing
  • performance of an agreement with you we have in place

7. Suppliers

• Type of information
  • standard identification data
• Purposes of processing
  • general services, relationship with suppliers and management of disputes
• Legal basis of processing
  • our legitimate interest

8. Users of our websites

• Type of information
  • cookies
  • IP address
  • geographical location
  • browser type and version
  • operating system
  • information about your visits to and use of our websites
• Purposes of processing
  • administering our websites
  • personalizing our websites
  • enabling your use of the services available on our websites
• Legal basis of processing
  • our legitimate interest
  • your consent (if requested and provided)

Legitimate Interests- Where we use your Personal data for our Legitimate Interests, this can include business purposes such as:

• record keeping, statistical analysis, internal reporting and research purposes;
• to investigate any complaints you make;
• to provide evidence in any disputes or anticipated disputes between you and us;
• for the detection and prevention of fraud, other criminal offences and for risk management purposes;
• for business and disaster recovery (e.g. to create back-ups);
• to ensure network and information security;
• to host, maintain and otherwise support the operation of our websites, including to customise various aspects of our websites to improve your experience;
• for document and data retention/storage;
• to protect the rights, property, and/or safety of MicroVention GmbH, any of the Affiliates, its personnel and others; and
• to ensure the quality of the services we provide to our clients and other Data Subjects.

We believe the risk to your data protection rights in connection with Personal Data that we process on the basis of our legitimate interests is not excessive or overly intrusive. We have also put in place protections for your rights by ensuring proper retention periods and security controls.

In addition, we may use your Personal Data for additional specific purposes made clear at the point of collection of your Personal Data.

If you choose not to provide the Personal Data requested by us, we may not be able to provide you with the products and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the Personal Data.

4. HOW AND WHEN DO WE SHARE DATA WITH THIRD PARTIES?

Some products and/or services that we provide require the involvement of third parties. We do not sell, rent, distribute or otherwise make Personal Data commercially available to any third party, except that we may share information within our group of companies, with our service providers and other third parties for the purposes set out in this Policy:

1. Data sharing within MicroVention group

MicroVention GmbH may share your Personal Data with the Affiliates:

• where we need to do so in order to provide the products and/or services or information that you have requested;
• if you consent to us doing so (e.g. when you give us consent for marketing communications with our Affiliates).

2. Data sharing with service providers

We also share your Personal Data with our third party service providers, whom we engage to provide various services, in relation to:

• deliveries of our products;
• marketing and advertising services (e.g. marketing agencies, interactive agencies, e-mailing solution providers);
• travel and congress organizer , hotels, carriers, embassies (visas);
• our websites (e.g., hosting and maintaining our websites);
• IT services and solutions (e.g., providing data storage, assisting us with database management).

We have carefully selected these service providers and taken steps to ensure that your Personal Data is adequately protected. All of our service providers are bound by written contract to process Personal Data provided to them only for the purposes of providing the specific service to us and to maintain appropriate security measures to protect your Personal Data.

3. Data sharing for materiovigilance, expert opinion and transparency obligation

We may also share your Personal Data, including health data, with:

• the national health agency for health and medicine, the recipient of materiovigilance data;
• the competent health authority;
• healthcare professionals in order to provide our expert opinion;
• clinical research organization (CRO) and other processors in accordance regulation;
• institutional affiliation of healthcare professionals in order to obtain authorisation or provide them with information.

4. Data sharing with other recipients

We may also share your Personal Data with:

• our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advice;
• any other third party if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or to protect the rights, property and/or safety of MicroVention GmbH, any of the Affiliates, its personnel and others;
• any other third party for the purposes of acting in accordance with the requirements of a court, regulator or government agency, for example, complying with a court order or acting in accordance with an applicable law or regulation; or
• investors and other relevant third parties in the event of an potential sale or other corporate transaction related to MicroVention GmbH and/or any of the Affiliates.

5.  INTERNATIONAL TRANSFERS OF PERSONAL DATA

The transfer of your Personal Data to and between the Affiliates, service providers or other recipients may involve your Personal Data being sent outside of the European Economic Area (“EEA”), to locations that may not provide the same level of protection as those within the EEA countries, including to third countries that are not covered by an adequacy decision of the European Commission, including to such countries as the United States.  

However, we may only transfer your Personal Data outside of the EEA:

• where the transfer is to a place or by a method or in circumstances that is regarded by the European Commission as providing adequate protection for your Personal Data;
• where we have put in place standard data protection clauses adopted by the European Commission or a relevant data protection authority, including as the case maybe supplemental clauses containing additional safeguards; or
• where none of the above apply but we are still legally permitted to do so, for example if the transfer is necessary for the performance of a contract concluded with you or in your interest, or for the establishment, exercise or defence of legal claims.

You can request further details about the safeguards that we have in place in respect of transfers of Personal Data outside of the EEA and where applicable a copy of the standard data protection clauses that we have in place by contacting us at: dataprotection@microvention.com.

6. HOW LONG DO WE STORE PERSONAL DATA?

It is our policy to retain your Personal Data for the length of time required for the specific purpose or purposes for which it was collected (e.g., for the fulfilment of an agreement with you). However, we may be obliged to store some Personal Data for a longer time, taking into account factors including: 

• legal obligation(s) under applicable law to retain data for a certain period of time (e.g. compliance with tax and accountancy requirements);
• the establishment, exercise or defence of legal claims (e.g., for the purposes of a potential dispute).

Whilst we continue to process your Personal Data, we will ensure that it is treated in accordance with this Policy. Otherwise, we securely erase or anonymise your Personal Data once it is no longer needed.

If you would like to find out how long we keep your Personal Data for a particular purpose, you can contact us at: dataprotection@microvention.com. For more information on how long cookies are stored, please refer to section I.

7. HOW DO WE PROTECT YOUR DATA?

We acknowledge that your Personal Data may be confidential. We will maintain the confidentiality of and protect your Personal Data in accordance with our Policy and all applicable laws, including the General Data Protection Regulation 2016/679 (“GDPR”).

We have implemented technological and operational security measures in order to protect your Personal Data from loss, misuse, or unauthorised alteration or destruction. Such measures include the use of firewalls, encryption, proper access rights management processes, careful selection of processors and other technically and commercially reasonable measures to provide appropriate protection for your Personal Data.  Where appropriate, we may also make backup copies and use other such means to prevent accidental damage to or destruction of your Personal Data. These measures ensure an appropriate level of security in relation to the risks inherent in the processing and the nature of the Personal Data to be protected.

Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure. For any payments which we take from you online we will use a recognised online secure payment system.

We will notify you promptly in the event of any breach of your Personal Data that might expose you to serious risk.

8.  LINK TO OTHER WEBSITES

Links or references to other websites may appear within our websites. We do not control these websites. You should be aware that this Policy does not apply to any websites other than those operated by MicroVention GmbH. Visitors to other websites are encouraged to read those privacy policies before exploring them.

1.  DO WE USE COOKIES TO GATHER INFORMATION?

When you visit or interact with our website, we (or our third-party providers) may use "cookies" or other similar technologies to personalize and enhance your experience. A “cookie” is a small piece of information sent to a visitor’s computer or other Internet-connected devices to uniquely identify the visitor’s browser or to store information or settings in the browser. Cookies are used in particular to make our websites work, or work more efficiently, as well as to provide data to the website owners. Our websites use required cookies, functional cookies, and analytics and performance cookies.

When your prior consent is required for their use, the period of validity of the consent to the deposit of cookies is six (6) months. At the end of this period, we will ask for your consent again.

When your prior consent is not required, the cookies lifetime is limited to thirteen (13) months (this period is enough for a relevant comparison of audience measure) and information collected through the cookies is retained for a maximum of twenty-five (25) months.

Our websites use:

• Required cookies enable you to move from page to page and to use features on our websites while your browser remains open. For example, required cookies allow you to add products to your shopping cart and carry the contents of your cart to checkout.
• Functional and preference cookies last from visit to visit. For example, functional cookies may be used to recognize you as a previous visitor to provide a more personalized experience such as the selected language. They are stored in your computer, device, or browser until you choose to delete them.
• Analytics and performance cookies allow us to collect data concerning the websites, including the number of visitors, where the visitors have come from, and the length of time visitors spend on the websites, which allows us or third-party service providers to analyse how our websites are used and how our websites are performing. We use the following service providers for analytics and performance tracking, and you can learn more about their privacy policies and how to opt-out of their cookies by clicking on the appropriate link below:

            Google Analytics: http://www.google.com/analytics/learn/privacy.html.

Our websites also use “social buttons” for third party social media sites to enable visitors to share or bookmark web pages. We provide social buttons to the following social media sites, and you can learn more about their privacy policies and how to opt-out of their cookies by clicking on the appropriate link below:

Facebook: https://www.facebook.com/policies/cookies/

Instagram: https://help.instagram.com/519522125107875

LinkedIn: https://privacy.linkedin.com/  

YouTube: https://policies.google.com/privacy?hl=en

Vimeo: https://vimeo.com/privacy

The majority of web browsers accept cookies and similar files, but you can usually change your browser settings to prevent this. If for any reason you decide that you do not like our use of certain cookies, you can simply change your settings. However, if you do so, some functionality of our websites may be lost.

The setting of each browser is different. It is described in the browser's help menu.

» Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

• Click the access Menu button and then choose "Options"
• Choose "Privacy & Security"
• Set the History Section on "Use custom settings for History"
•  Uncheck the box "Accept cookies from websites".
• All changes you have made will be automatically saved.

» Internet Explorer: https://support.microsoft.com/en-us/topic/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

• Select the Tool button, then Internet Options.
• Select Privacy Tab, and then under Settings, move the cursor to the top to block all cookies or to the bottom to allow cookies, then click on OK.

» Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

• Select the Chrome menu icon.
• Click on "Settings".
• At the bottom, click on "Advanced".
• Under "Privacy and security," click on "Content settings".
• Click on "Cookies".
• Turn "Allow sites to save and read cookie data" on or off.

» Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac

• Click on "Settings" > "Safari" > "Privacy" > "Cookies and website data"
• Then select "always block cookies".

» For Opera: http://help.opera.com/Windows/10.20/en/cookies.html

If you have any specific questions about the use of cookies on our websites, please feel free to contact us at any time by emailing dataprotection@microvention.com with the Subject line “Cookie Request.”

10.  CHILDREN'S PRIVACY

Children should always get permission from their parents before sending any information about themselves (such as their names, email addresses, and phone numbers) over the internet, to us or to anyone else. Our websites are not directed at individuals under 18, and we will not knowingly allow anyone under 18 to provide us any personally identifying information; if you are under 18, please do not provide any information about yourself on this website.

11.  AFFILIATED ENTITIES

We are in charge of the relationship with you and all the customers and data subjects on our territory of activities.

We may share (or receive) information about you, including personal information, with our parent entity MicroVention US which headquarter is located 35 Enterprise, Aliso Viejo, CA  92656

We may share your personal information with the companies of our group which are:

• MicroVention UK
• Microvention Europe
• Terumo’s group companies

When such sharing of information involves transfers outside the European Union, these transfers are based on standard contractual clauses as stated in section E.

50.  YOUR RIGHTS

The following section explains your rights that you may exercise. The various rights are not absolute and each is subject to certain exceptions or qualifications in accordance with the GDPR and other generally applicable provisions of data privacy law.

• The right to be informed – you have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Data. This is why we are providing you with the information in this Policy and in any legal notices or terms and conditions provided to you.
• The right of access – you have the right to obtain from us confirmation as to whether or not your Personal Data is being processed by us, and about certain other information (similar to that provided in this Policy) about how it is used. You also have the right to access your Personal Data, by requesting a copy of the Personal Data concerning you. This is so you are aware and can check that we are using your information in accordance with data protection law. We can refuse to provide information where to do so may reveal personal data about another person or would otherwise negatively impact another person's rights.
• The right to rectification – you can ask us to take measures to correct your Personal Data if it is inaccurate or incomplete (e.g., if we have the wrong name or address for you).
• The right to erasure – this is also known as the ‘right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Data where, for example, there is no compelling reason for us to keep using it or its use is unlawful. This is however not a general right to erasure and there are some exceptions, e.g. where we need to use the information in defence of a legal claim or to be able to comply with a legal obligation.
• The right to restrict processing – you have the right to ‘block’ or suppress the further use of your Personal Data when we are assessing a request for rectification or as an alternative to erasure. When processing is restricted, we can still store your Personal Data, but may not use it further.
• The right to data portability – you have the right to obtain and reuse certain Personal Data for your own purposes across different organisations (being separate data controllers). This only applies to your Personal Data that you have provided to us that we are processing with your consent and for the purposes of contract fulfilment, which is being processed by automated means. In such a case we will provide you with a copy of your data in a structured, commonly used and machine-readable format or upon your request (where technically feasible) we may transmit your data directly to a separate data controller.
• The right to object – you have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of legitimate interests pursued by MicroVention Europe, any of the Affiliates, or by a data recipient. We will be allowed to continue to process the Personal Data if we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or we need this for the establishment, exercise or defence of legal claims. If you object to the processing of your Personal Data for direct marketing purposes, we will no longer process your Personal Data for such purposes.
• The right to withdraw consent – where we process your Personal Data on the basis of your consent, you have the right to withdraw your consent at any time. However, such withdrawal does not affect the lawfulness of the processing that occurred prior to such withdrawal.
• The right to lodge a complaint – if you believe that we do not comply with applicable data protection laws, you have the right to lodge a complaint before any competent data protection authority.

1000.  HOW TO CONTACT US

If you wish to request further information or exercise any of the above rights, or if you are unhappy with how we have handled your Personal Data, contact our Data Protection Officer at: dataprotection@microvention.com or send us a letter at:

Hildebrandtstraße 4F, 40215 Düsseldorf, Germany

Before assessing your request, we may request additional information in order to identify you.  If you do not provide the requested information and, as a result, we are not in a position to identify you, we may refuse to action your request.

We will generally respond to your request within one month of receiving your request. We can extend this period by an additional two months if this is necessary taking into account the complexity and number of requests that you have submitted.

We will not charge you for such communications or actions we take, unless:

you request additional copies of your Personal Data undergoing processing, in which case we may charge for our reasonable administrative costs, or

you submit manifestly unfounded or excessive requests, in particular because of their repetitive character, in which case we may either charge for our reasonable administrative costs or refuse to act on the request.

If you are not satisfied with our response to your complaint or believe our processing of your Personal Data does not comply with data protection law, you can file a complaint to a data protection authority of your choice. For us, the French Commission Nationale de l’Informatique et des Libertés (CNIL) is the competent data protection authority.

Initial Request Form - English

Data Privacy and Cookies Policy - English

DATA PRIVACY AND COOKIES POLICY

Last update: 16.10.2020

Contents

A. ABOUT THIS POLICY

B. WHO IS ACCOUNTABLE FOR YOUR DATA?

C. WHAT DATA DO WE PROCESS AND WHY?

D. HOW AND WHEN DO WE SHARE DATA WITH THIRD PARTIES?

E. INTERNATIONAL TRANSFERS OF PERSONAL DATA

F. HOW LONG DO WE STORE PERSONAL DATA?

G. HOW DO WE PROTECT YOUR DATA?

H. LINK TO OTHER WEBSITES

I. DO WE USE COOKIES TO GATHER INFORMATION?

J. CHILDREN’S PRIVACY

K. AFFILIATED ENTITIES

L. YOUR RIGHTS

M. HOW TO CONTACT US

1. ABOUT THIS POLICY

We are committed to providing you with professional and valuable products and services whilst safeguarding your privacy.

This Data Privacy and Cookies Policy (also “Policy”) covers both our online and offline data collection activities and outlines when, why and how we collect, use and otherwise handle (collectively “process”) personal information about our customers, potential customers, business partners (including healthcare professionals), patients, distributors, association representative, suppliers and users of our websites (“Data Subjects”). “Personal Data” is any information relating to you, which can be used to personally identify you, either directly or indirectly.

It also tells you how you can access and update your information and make choices about how your information is used. More information on how to contact us to exercise your data subject rights is in Section M below.

We may process your Personal Data, as described in this Data Privacy and Cookies Policy.

Where you use our websites, we will process your Personal Data collected by using cookies in accordance with this Policy.  

If we decide to change the way we handle your information, we will post those changes in this Policy. For some changes, we will notify you more prominently and/or give you prior choice, depending on the legal requirements we will have to comply with. We reserve the right to make changes to our practices and this Policy at any time, provided that we follow the procedures above.

2.  WHO IS ACCOUNTABLE FOR YOUR DATA?

MicroVention UK Limited Suite 3 with its head office at: Barracks Building 10 Cliffords Fort, North Shields Tyne and Wear, NE301JE, registered in the companies register under the number 4492546 (“MicroVention”) – are the data controller of your Personal Data.

We can be contacted at dataprotection@microvention.com.

In this Policy, references to “we”, “us” or “our” means MicroVention UK and/or our Affiliates. References to “you” and “your” are to the Data Subjects.

3. WHAT DATA DO WE PROCESS AND WHY?

The types of information that we may collect from you, depending on how you interact with us (e.g. how you use our websites), and the purposes of processing, include:

1. Customers

• Type of information
  • your name
  • your address (business and personal)
  • your e-mail address
  • your telephone numbers (business and personal)
  • shared directory of healthcare professionals
• Purposes of processing
  • management of tenders
  • order management
  • provide commercial offers
  • reply to your requests
  • customer relationship
  • management of clinical trials
  • product and services improvement
• Legal basis of processing
  • performance of an agreement with you we have in place
  • your consent (if requested and provided)

2. Potential customers

• Type of information
  • your name
  • your address (business and personal)
  • your e-mail address
  • your telephone numbers (business and personal)
• Purposes of processing
  • sending you marketing communications (including our email newsletter) relating to our products or services, if you have requested them
• Legal basis of processing
  • your consent (if requested and provided)

3. Healthcare professionals (including physician, dispenser, manipulator etc.)

• Type of information
  • your name
  • your address (business and personal)
  • your e-mail address
  • your telephone numbers (business and personal)
  • your job title, role, working life, participation to clinical studies, registration number to professional association role
  • compensation and benefits
  • bank details
  • travel data for visa (family status, personal life, insurance certificate etc.)
  • professional publications
• Purposes of processing
  • sending you expert opinion
  • performance of clinical studies
  • performance of an agreement with you we have in place
  • proctoring
  • donation management (grant, instructions)
  • organization of travels and registration to congress
• Legal basis of processing
  • to comply with our legal and regulatory obligations (clinical studies, transparency obligation)
  • performance of an agreement with you we have in place (consulting agreement)
  • your consent (if requested and provided)

4. Patient

• Type of information
  • operating details
  • patient identification in case of clinical studies, materiovigilance or improvement of products and services quality
  • identification data (age, gender)
  • health data (medical history, clinical study participation, radiographic image)
• Purposes of processing
  • materiovigilance
  • improvement of MVE’s products and services (quality)
  • sending to healthcare professionals our experience and know-how
• Legal basis of processing
  • regulatory obligation of materiovigilance
  • our legitimate interest in order to provide our expert opinion

5. Distributors and sales representatives

• Type of information
  • standard identification data
• Purposes of processing
  • communication and logistic organization with healthcare professionals outside France
• Legal basis of processing
  • performance of an agreement with you we have in place

6. Associations representatives

• Type of information
  • standard identification data
• Purposes of processing
  • donation management
• Legal basis of processing
  • performance of an agreement with you we have in place

7. Suppliers

• Type of information
  • standard identification data
• Purposes of processing
  • general services, relationship with suppliers and management of disputes
• Legal basis of processing
  • our legitimate interest

8. Users of our websites

• Type of information
  • cookies
  • IP address
  • geographical location
  • browser type and version
  • operating system
  • information about your visits to and use of our websites
• Purposes of processing
  • administering our websites
  • personalizing our websites
  • enabling your use of the services available on our websites
• Legal basis of processing
  • our legitimate interest
  • your consent (if requested and provided)

Legitimate Interests- Where we use your Personal data for our Legitimate Interests, this can include business purposes such as:

• record keeping, statistical analysis, internal reporting and research purposes;
• to investigate any complaints you make;
• to provide evidence in any disputes or anticipated disputes between you and us;
• for the detection and prevention of fraud, other criminal offences and for risk management purposes;
• for business and disaster recovery (e.g. to create back-ups);
• to ensure network and information security;
• to host, maintain and otherwise support the operation of our websites, including to customise various aspects of our websites to improve your experience;
• for document and data retention/storage;
• to protect the rights, property, and/or safety of MicroVention UK, any of the Affiliates, its personnel and others; and
• to ensure the quality of the services we provide to our clients and other Data Subjects.

We believe the risk to your data protection rights in connection with Personal Data that we process on the basis of our legitimate interests is not excessive or overly intrusive. We have also put in place protections for your rights by ensuring proper retention periods and security controls.

In addition, we may use your Personal Data for additional specific purposes made clear at the point of collection of your Personal Data.

If you choose not to provide the Personal Data requested by us, we may not be able to provide you with the products and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the Personal Data.

4. HOW AND WHEN DO WE SHARE DATA WITH THIRD PARTIES?

Some products and/or services that we provide require the involvement of third parties. We do not sell, rent, distribute or otherwise make Personal Data commercially available to any third party, except that we may share information within our group of companies, with our service providers and other third parties for the purposes set out in this Policy:

1. Data sharing within MicroVention group

MicroVention UK may share your Personal Data with our Affiliates:

• where we need to do so in order to provide the products and/or services or information that you have requested;
• if you consent to us doing so (e.g. when you give us consent for marketing communications with our Affiliates).

2. Data sharing with service providers

We also share your Personal Data with our third party service providers, whom we engage to provide various services, in relation to:

• deliveries of our products;
• marketing and advertising services (e.g. marketing agencies, interactive agencies, e-mailing solution providers);
• travel and congress organizer , hotels, carriers, embassies (visas);
• our websites (e.g., hosting and maintaining our websites);
• IT services and solutions (e.g., providing data storage, assisting us with database management).

We have carefully selected these service providers and taken steps to ensure that your Personal Data is adequately protected. All of our service providers are bound by written contract to process Personal Data provided to them only for the purposes of providing the specific service to us and to maintain appropriate security measures to protect your Personal Data.

3. Data Sharing – sharing health data.

We may share health data for the purpose of studying and following incidents with medical devices. This may involve sharing your Personal Data, including health data, with:

• the national health agency for health and medicine, the recipient of materiovigilance data;
• the competent health authority;
• healthcare professionals in order to provide our expert opinion;
• clinical research organization (CRO) and other processors in accordance regulation;
• institutional affiliation of healthcare professionals in order to obtain authorisation or provide them with information.

4. Data sharing with other recipients

We may also share your Personal Data with:

• our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advice;
• any other third party if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or to protect the rights, property and/or safety of MicroVention UK, any of the Affiliates, its personnel and others;
• any other third party for the purposes of acting in accordance with the requirements of a court, regulator or government agency, for example, complying with a court order or acting in accordance with an applicable law or regulation; or
• investors and other relevant third parties in the event of an potential sale or other corporate transaction related to MicroVention UK and/or any of the Affiliates.

5.  INTERNATIONAL TRANSFERS OF PERSONAL DATA

The transfer of your Personal Data to and between the Affiliates, service providers or other recipients may involve your Personal Data being sent outside of the European Economic Area (“EEA”), to locations that may not provide the same level of protection as those within the EEA countries, including to third countries that are not covered by an adequacy decision of the European Commission, including to such countries as the United States.  

However, we may only transfer your Personal Data outside of the EEA:

• where the transfer is to a place or by a method or in circumstances that is regarded by the European Commission as providing adequate protection for your Personal Data;
• where we have put in place standard data protection clauses adopted by the European Commission or a relevant data protection authority, including as the case maybe supplemental clauses containing additional safeguards; or
• where none of the above apply but we are still legally permitted to do so, for example if the transfer is necessary for the performance of a contract concluded with you or in your interest, or for the establishment, exercise or defence of legal claims.

You can request further details about the safeguards that we have in place in respect of transfers of Personal Data outside of the EEA and where applicable a copy of the standard data protection clauses that we have in place by contacting us at: dataprotection@microvention.com.

6. HOW LONG DO WE STORE PERSONAL DATA?

It is our policy to retain your Personal Data for the length of time required for the specific purpose or purposes for which it was collected (e.g., for the fulfilment of an agreement with you). However, we may be obliged to store some Personal Data for a longer time, taking into account factors including: 

• legal obligation(s) under applicable law to retain data for a certain period of time (e.g. compliance with tax and accountancy requirements);
• the establishment, exercise or defence of legal claims (e.g. for the purposes of a potential dispute).

Whilst we continue to process your Personal Data, we will ensure that it is treated in accordance with this Policy. Otherwise, we securely erase or anonymise your Personal Data once it is no longer needed.

If you would like to find out how long we keep your Personal Data for a particular purpose, you can contact us at: dataprotection@microvention.com. For more information on how long cookies are stored, please refer to section I.

7. HOW DO WE PROTECT YOUR DATA?

We acknowledge that your Personal Data may be confidential. We will maintain the confidentiality of and protect your Personal Data in accordance with our Policy and all applicable laws, including the General Data Protection Regulation 2016/679 (“GDPR”).

We have implemented technological and operational security measures in order to protect your Personal Data from loss, misuse, or unauthorised alteration or destruction. Such measures include the use of firewalls, encryption, proper access rights management processes, careful selection of processors and other technically and commercially reasonable measures to provide appropriate protection for your Personal Data.  Where appropriate, we may also make backup copies and use other such means to prevent accidental damage to or destruction of your Personal Data. These measures ensure an appropriate level of security in relation to the risks inherent in the processing and the nature of the Personal Data to be protected.

Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.

We will notify you promptly in the event of any breach of your Personal Data that might expose you to serious risk.

8.  LINK TO OTHER WEBSITES

Links or references to other websites may appear within our websites. We do not control these websites. You should be aware that this Policy does not apply to any websites other than those operated by MicroVention UK. Visitors to other websites are encouraged to read those privacy policies before exploring them.

1.  DO WE USE COOKIES TO GATHER INFORMATION?

When you visit or interact with our website, we (or our third-party providers) may use "cookies" or other similar technologies to personalize and enhance your experience. A “cookie” is a small piece of information sent to a visitor’s computer or other Internet-connected devices to uniquely identify the visitor’s browser or to store information or settings in the browser. Cookies are used in particular to make our websites work, or work more efficiently, as well as to provide data to the website owners. Our websites use required cookies, functional cookies, and analytics and performance cookies.

When your prior consent is required for their use, the period of validity of the consent to the deposit of cookies is six (6) months. At the end of this period, we will ask for your consent again.

When your prior consent is not required, the cookies lifetime is limited to thirteen (13) months (this period is enough for a relevant comparison of audience measure) and information collected through the cookies is retained for a maximum of twenty-five (25) months.

Our websites use:

• Required cookies enable you to move from page to page and to use features on our websites while your browser remains open. For example, required cookies allow you to add products to your shopping cart and carry the contents of your cart to checkout.
• Functional and preference cookies last from visit to visit. For example, functional cookies may be used to recognize you as a previous visitor to provide a more personalized experience such as the selected language. They are stored in your computer, device, or browser until you choose to delete them.
• Analytics and performance cookies allow us to collect data concerning the websites, including the number of visitors, where the visitors have come from, and the length of time visitors spend on the websites, which allows us or third-party service providers to analyse how our websites are used and how our websites are performing. We use the following service providers for analytics and performance tracking, and you can learn more about their privacy policies and how to opt-out of their cookies by clicking on the appropriate link below:

            Google Analytics: http://www.google.com/analytics/learn/privacy.html.

Our websites also use “social buttons” for third party social media sites to enable visitors to share or bookmark web pages. We provide social buttons to the following social media sites, and you can learn more about their privacy policies and how to opt-out of their cookies by clicking on the appropriate link below:

Facebook: https://www.facebook.com/policies/cookies/

Instagram: https://help.instagram.com/519522125107875  

LinkedIn: https://privacy.linkedin.com/

YouTube: https://policies.google.com/privacy?hl=en

Vimeo: https://vimeo.com/privacy

The majority of web browsers accept cookies and similar files, but you can usually change your browser settings to prevent this. If for any reason you decide that you do not like our use of certain cookies, you can simply change your settings. However, if you do so, some functionality of our websites may be lost.

The setting of each browser is different. It is described in the browser's help menu.

» Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

• Click the access Menu button and then choose "Options"
• Choose "Privacy & Security"
• Set the History Section on "Use custom settings for History"
•  Uncheck the box "Accept cookies from websites".
• All changes you have made will be automatically saved.

» Internet Explorer: https://support.microsoft.com/en-us/topic/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

• Select the Tool button, then Internet Options.
• Select Privacy Tab, and then under Settings, move the cursor to the top to block all cookies or to the bottom to allow cookies, then click on OK.

» Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

• Select the Chrome menu icon.
• Click on "Settings".
• At the bottom, click on "Advanced".
• Under "Privacy and security," click on "Content settings".
• Click on "Cookies".
• Turn "Allow sites to save and read cookie data" on or off.

» Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac

• Click on "Settings" > "Safari" > "Privacy" > "Cookies and website data"
• Then select "always block cookies".

» For Opera: http://help.opera.com/Windows/10.20/en/cookies.html

If you have any specific questions about the use of cookies on our websites, please feel free to contact us at any time by emailing dataprotection@microvention.com with the Subject line “Cookie Request.”

10.  CHILDREN'S PRIVACY

Our websites are not directed at individuals under 18, and we will not knowingly allow anyone under 18 to provide us any personally identifying information; if you are under 18, please do not provide any information about yourself on this website. If you are a child and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible

11.  AFFILIATED ENTITIES

We are in charge of the relationship with you and all the customers and data subjects on our territory of activities.

We may share (or receive) information about you, including personal information, with our parent entity MicroVention US which headquarter is located 35 Enterprise, Aliso Viejo, CA  92656.

We may share your personal information with the companies of our group which are:

• Microvention Europe
• Microvention Deutschland
• Terumo’s group companies

When such sharing of information involves transfers outside the European Union, these transfers are based on standard contractual clauses as stated in section E.

50.  YOUR RIGHTS

The following section explains your rights that you may exercise. The various rights are not absolute and each is subject to certain exceptions or qualifications in accordance with the GDPR and other generally applicable provisions of data privacy law.

• The right to be informed – you have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Data. This is why we are providing you with the information in this Policy and in any legal notices or terms and conditions provided to you.
• The right of access – you have the right to obtain from us confirmation as to whether or not your Personal Data is being processed by us, and about certain other information (similar to that provided in this Policy) about how it is used. You also have the right to access your Personal Data, by requesting a copy of the Personal Data concerning you. This is so you are aware and can check that we are using your information in accordance with data protection law. We can refuse to provide information where to do so may reveal personal data about another person or would otherwise negatively impact another person's rights.
• The right to rectification – you can ask us to take measures to correct your Personal Data if it is inaccurate or incomplete (e.g., if we have the wrong name or address for you).
• The right to erasure – this is also known as the ‘right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Data where, for example, there is no compelling reason for us to keep using it or its use is unlawful. This is however not a general right to erasure and there are some exceptions, e.g. where we need to use the information in defence of a legal claim or to be able to comply with a legal obligation.
• The right to restrict processing – you have the right to ‘block’ or suppress the further use of your Personal Data when we are assessing a request for rectification or as an alternative to erasure. When processing is restricted, we can still store your Personal Data, but may not use it further.
• The right to data portability – you have the right to obtain and reuse certain Personal Data for your own purposes across different organisations (being separate data controllers). This only applies to your Personal Data that you have provided to us that we are processing with your consent and for the purposes of contract fulfilment, which is being processed by automated means. In such a case we will provide you with a copy of your data in a structured, commonly used and machine-readable format or (where technically feasible) we may transmit your data directly to a separate data controller.
• The right to object – you have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of legitimate interests pursued by MicroVention Europe, any of the Affiliates, or by a data recipient. We will be allowed to continue to process the Personal Data if we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or we need this for the establishment, exercise or defence of legal claims. If you object to the processing of your Personal Data for direct marketing purposes, we will no longer process your Personal Data for such purposes.
• The right to withdraw consent – where we process your Personal Data on the basis of your consent, you have the right to withdraw your consent at any time. However, such withdrawal does not affect the lawfulness of the processing that occurred prior to such withdrawal.
• The right to lodge a complaint – if you believe that we do not comply with applicable data protection laws, you have the right to lodge a complaint before any competent data protection authority.

1000.  HOW TO CONTACT US

If you wish to request further information or exercise any of the above rights, or if you are unhappy with how we have handled your Personal Data, contact our Data Protection Officer at: dataprotection@microvention.com or send us a letter at:

MicroVention Europe : 20, quater Rue Schnapper, 78100 Saint-Germain-en-Laye.

Before assessing your request, we may request additional information in order to identify you.  If you do not provide the requested information and, as a result, we are not in a position to identify you, we may refuse to action your request.

We will generally respond to your request within one month of receiving your request. We can extend this period by an additional two months if this is necessary taking into account the complexity and number of requests that you have submitted.

We will not charge you for such communications or actions we take, unless:

you request additional copies of your Personal Data undergoing processing, in which case we may charge for our reasonable administrative costs, or you submit manifestly unfounded or excessive requests, in particular because of their repetitive character, in which case we may either charge for our reasonable administrative costs or refuse to act on the request.

If you are not satisfied with our response to your complaint or believe our processing of your Personal Data does not comply with data protection law, you can file a complaint to a relevant data protection authority of your choice. For us, the French Commission Nationale de l’Informatique et des Libertés (CNIL) is the competent data protection authority.