1) Purpose and scope of application of the Policy
SparingVision attaches great importance and care to the protection of privacy and Personal Data, as well as to compliance with the provisions of the Applicable Legislation.
2) Data Controller
In the context of your activity on the https://sparingvision.com/ website, we collect and use Personal Data relating to you, as a natural person ("Data Subject").
For all the Processing, SparingVision, SAS listed in the Paris Trade Register under the number 821 148 327 R.C.S Paris, with a capital of 161 426,00 EUROS having its head office 55 rue de Lyon, 75012 Paris, France, determines the means and purposes of the Processing. Thus, we act as a Data Controller, within the meaning of the Regulation on Personal Data, and in particular Regulation (EU) 2016/679 on the protection of individuals with regard to the Processing of Personal Data and on the free movement of such Data.
3) What Personal Data do we collect and how?
By using our website, or by contacting us you provide us information about yourself, some of which may identify you ("Personal Information"). This is the case when you browse our site, when you fill in online forms, or simply when you send us emails.
The nature and quality of the Personal Data collected about you varies according to the relationship you have with SparingVision, the main ones being:
- Identification data: this includes all information that would allow us to identify you, such as your name, first name, telephone number. We may also collect your e-mail address and your postal address.
- Documents of different natures (PDF, Office format, Image) with titles, contents, folder names, or information linked to a document, such as comments written in the documents, alert and reminder dates.
- Navigational information: As you browse our website, you interact with it. As a result, some browsing information is collected.
- Health data: this includes all the medical information that you willingly share with us.
4) Why do we collect your Personal Data and how?
We collect your Personal Data for specific purposes and on different legal grounds.
On the basis of the execution of the contract or pre-contractual measures, your Data is processed for the following purposes:
- Management of contracts.
On the basis of your consent, your Data is processed for the following purposes:
- Management of the newsletter;
- Management of cookies requiring your consent.
On the basis of SparingVision 's legitimate interests, your Data is processed for the following purposes:
- Establishment of statistics for the improvement of products and services;
- Management of users’ requests;
- Reception of patients’ information.
5) Do we share your Personal Data?
Your Data is intended for use by SparingVision's authorised employees in charge of the management and execution of contracts and legal obligations, according to the purposes of the collection and within the limits of their respective attributions.
It may be transmitted for certain activities related to the purposes, and within the limits of their respective missions and authorisations, to the following recipients:
- Service providers and Data Processor that we call upon to carry out a series of operations and tasks on our behalf, in particular:
o Consilium Healthcare Communications
- Duly authorised public authorities (judicial, supervisory, etc.), as part of our legal and regulatory obligations;
- Regulated professions (lawyers, bailiffs, etc.) who may be involved in the implementation of guarantees, collection or litigation;
When your Data is communicated to our service providers and Data Processor, they are also required not to use the Data for purposes other than those initially intended. We make every effort to ensure that these Third Parties maintain the confidentiality and security of your Data.
In all cases, only the necessary Data is provided. We make every effort to ensure that your Data is communicated or transmitted securely.
We do not sell your Data.
6) How long do we keep your Personal Data?
We keep your Personal Data only for as long as is necessary to fulfil the purpose for which we collect the Data and to meet your needs or our legal obligations.
Retention periods vary depending on several factors, such as:
- SPARING VISION business needs;
- Contractual requirements;
- Legal obligations;
- Recommendations from supervisory authorities.
The retention periods for your Data are as follows:
|Management of contracts||5 years starting from the end of the contract|
|Management of the newsletter||Duration of consent|
|Management of cookies requiring your consent||6 months|
|Establishment of statistics for the improvement of products and services||2 years|
|Management of users’ requests||5 years|
|Reception of patients’ information.||5 years|
7) How do we guarantee Personal Data security?
SPARING VISION is committed to protecting the Personal Data we collect or process from loss, destruction, alteration, unauthorised access or disclosure.
Therefore, we implement all appropriate technical and organisational measures, depending on the nature of the Data and the risks involved in processing it. These measures must preserve the security and confidentiality of your Personal Data. These measures may include practices such as restricted access to Personal Data by persons authorised by virtue of their functions, pseudonymisation or encryption.
In addition, our practices and policies and/or physical and/or logical security measures (secure access, authentication process, back-up, software, etc.) are regularly reviewed and updated as necessary.
8) What are your rights?
SPARING VISION undertakes to guarantee the effective exercise of the Data Subjects’ rights granted to them by the Applicable legislation. Subject to the Applicable legislation Data Subject have the following rights:
- Right to information: the right to have clear, precise and complete information about SparingVision 's use of their Personal Data.
- Right of access: the right to obtain a copy of the Personal Data that the Controller holds on the requester.
- Right of rectification: the right to have their Personal Data rectified if they are inaccurate or obsolete and/or to complete them if they are incomplete.
- Right to erasure / right to be forgotten: the right, under certain conditions, to have the Data erased or deleted, unless SPARING VISION has a legitimate interest in keeping them.
- Right to object: the right to object to the Processing of Personal Data by SPARING VISION for reasons related to the particular situation of the requester (under conditions).
- Right to withdraw Consent: the right at any time to withdraw Consent when the Processing is based on Consent.
- Right to restriction of Processing: the right, subject to specific conditions, to request that the Processing of Personal Data be temporarily suspended.
- Right to Data portability: subject to specific conditions, right to receive from the Controller Personal Data concerning the Data Subject, which he or she has provided to the Controller, in a structured, commonly used and machine-readable format.
- Right not to be the subject to an automated decision: subject to specific conditions, right not to be subject to a decision based solely on an automated Data Processing activity, including profiling, which produces legal effects concerning the Data Subject or similarly significantly affects him or her.
- Right to define post-mortem instructions: the right for the Data Subject to leave instructions regarding the fate of his/her Personal Data after death.
Additional rights may be granted by the Local Regulations to the Persons concerned.
To this end, SparingVision defines and implements a procedure for the management of Data Subjects’ rights in accordance with the requirements of the Applicable legislation. This procedure establishes:
- The standards to be respected to ensure the transparent information of Data Subjects;
- The legal requirements that must be respected;
- The authorised means of submitting an application for each right, according to the category of Data Subjects;
- The business processes to manage these requests in accordance with the above requirements;
- The parties involved in these processes, their roles and responsibilities.
Requests submitted by Data Subjects pursuant to their rights are recorded in a register for the purpose of demonstrating compliance. The procedure for managing the rights of persons referred to above defines the content and procedures for keeping this register.
When you send us a request to exercise a Right, you are asked to specify as far as possible the scope of the request, the type of right exercised, the Personal Data Processing concerned, and any other useful element, in order to facilitate the examination of your request. In addition, in case of reasonable doubt, you may be asked to prove your identity.
You also have the right to complain to the Commission Nationale de l'Informatique et des Libertés (CNIL), 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07, about the way in which SPARING VISION collects and processes your data.
9) Cookies Management
Cookies are computer files that are automatically deposited on the hard drive of your computer, tablet or cell phone when you browse our website. They are managed by your Internet browser (Internet Explorer, Firefox, Safari or Google Chrome).
- Are cookies deposited when you browse SparingVision’s website?
When you first visit SparingVision’s website, a banner will inform you of the presence of these cookies and invite you to indicate your choice. Cookies requiring your consent in accordance with the regulations are only deposited if you accept them. You may at any time inform yourself and configure your cookies to accept or refuse them by going to the [Cookie Management] page at the bottom of each page of the Site or by configuring your browser.
- What data is collected through cookies?
Cookies can be used to collect all data relating to a terminal at a given time, in particular :
- One or more technical identifiers that identify your Internet box;
- The date, time and duration of connection of a terminal to a website;
- The Internet address of the page from which the terminal accesses the website;
- The type of operative system of the terminal (e.g. Windows, MacOs, Linux, Unix, etc.);
- The type and version of the browser software used by the terminal (Internet Explorer, Firefox, Safari, Chrome, Opera, etc.);
- The brand and model of the mobile device or tablet;
- Possible download errors;
- The language of the browser software used by the terminal;
- The characteristics of the content consulted and shared (e.g type of service sought).
- What are the purposes of the cookies placed on SparingVision’s website?
- Cookies necessary for the personalization and operation of the website: they allow you to use the main features of our website and in particular to record information between two visits to the website on the same device, such as elements of personalization of the interface (choice of language or presentation). They do not require your prior consent. These cookies are essential to the proper functioning of the website. Without these cookies, you will not be able to use our website normally. Therefore, they cannot be deactivated.
- Analytical, statistical or audience measurement cookies that allow us to know the use and audience performance of our website and to improve its operation for our visitors; for example, to establish statistics and volumes of traffic and use of the various elements of the website in order to improve its interest and ergonomics;
- Social network cookies deposited by social networks when you share content from our website with others or let them know what you think about this content via a link. We have no control over the process used by these social networks to collect information about your browsing on our website and associated personal data they have. We invite you to consult their data protection policies in order to know your rights with respect to each of them, and to manage your privacy settings.
- Who deposits cookies on the website?
- The publisher of the website, which is SparingVision, and SparingVision’s data processor, i.e. the technical service providers who process your browsing data on behalf of SparingVision
- Third party social network publishers, i.e. Twitter and LinkedIn, which may deposit cookies for sharing purposes on social networks.
- How long are the cookies stored?
Cookies deposited by SparingVision or our data processors as well as the data collected, are kept for a maximum period of 6 months from the date when they are deposited on your terminal. At the end of this period, your consent is again required, and the cookie banner is displayed when you visit our website again.
- How do I configure cookies on web browsers?
You have the choice of configuring your browser to accept or reject all cookies, delete cookies periodically, or to see when a cookie is issued, how long it is valid, and its content, and to refuse to store it on your hard drive.
You can choose to block or disable these cookies at any time by adjusting the settings on your computer, tablet, or mobile internet browser in accordance with the instructions set by your internet browser provider.
10) Update of the Policy
This Policy may be regularly updated to take into account changes in the Personal Data Regulations.
Date of last update 09/04/2021.