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BioLogic Data Privacy Policy.

Introduction

BIO-LOGIC’s privacy policy was established in compliance with Law n°78-17 date January 6th, 1978 and the General Data Protection Regulation (« GDPR ») n°2016/679.

BIO-LOGIC respects your privacy and is committed to protecting its users’ personal data.

This policy provides information as to how BIO-LOGIC looks after its users’ personal data when they visit our website (regardless of wherefrom) and about your privacy rights and how they are protected by law.

Please refer to the Glossary, at the end of the document for a better understanding of the meaning of some of the terms used in this policy.

1. IMPORTANT INFORMATION

Purpose of this privacy policy

This privacy policy aims to give information on how BIO-LOGIC collects and processes its users’ personal data through their use of this website, including any data they may provide through this website when they sign up to our newsletter or fill a form through the website or create an account or subscribe to one of our training session, conference or meeting or any other interaction we may offer in the future.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important to read this privacy policy together with any other privacy policy or fair processing policy BIO-LOGIC may provide on specific occasions when collecting or processing users’ personal data in order to be fully aware of how and why BIO-LOGIC is using such data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

BIO-LOGIC is the controller and responsible for the personal data collected (collectively referred to as “BIO-LOGIC”, “we”, “us” or “our” in this privacy policy).

BIO-LOGIC’s data protection officer (DPO) is responsible for overseeing questions in relation to this privacy policy. Any questions about this privacy policy, including any requests to exercise legal rights, should be sent to the DPO using the details set out below.

Contact details

https://www.biologic.net/contact/?form=support Users have the right to make a complaint at any time to the Commission Nationale Informatique et Libertés (CNIL), the French regulator for data protection issues (www.cnil.fr). BIO-LOGIC would, however, appreciate the chance to deal with your concerns before you approach the CNIL so please contact us in the first instance.

Changes to the privacy policy and duty to inform BIO-LOGIC of modifications of your data

This privacy policy is under regular review. This version was last updated on [date], 2023. Previous versions can be obtained by contacting us.

It is important that users’ personal data is accurate and current. Please keep us informed if your data change during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your data. BIO-LOGIC does not control these third-party websites and is not responsible for their privacy statements.

When leaving our website, it is safer to read the privacy policy of every website you visit.

2. WHICH DATA IS COLLECTED

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

BIO-LOGIC may collect, use, store and transfer different kinds of personal data about its users which are grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, position in the company, full details relating to your company, postal address, zip code, country.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Transaction Data includes details of products, accessories and services purchased by customers from BIO-LOGIC].
  • Technical Data includes the users’ internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices used to access this website, definition of the product bought from BIO-LOGIC, to be registered and its related serial number.
  • Profile Data includes the users’ username and password, purchases or orders, interests, preferences, feedback and survey responses, emails and messages via the website sent to and received from BIO-LOGIC.
  • Usage Data includes information about how the users use this website, products and services.
  • Marketing and Communications Data includes our users’ preferences in receiving marketing from BIO-LOGIC and our third parties and communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from our users’ personal data but is not considered personal data in law as this data will not directly or indirectly reveal the related identity. For example, BIO-LOGIC may aggregate Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with our users’ personal data so that it can directly or indirectly identify them, we treat the combined data as personal data which will be used in accordance with this privacy policy.

BIO-LOGIC does not collect any Special Categories of Personal Data (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health, and genetic and biometric data). Nor does BIO-LOGIC collect any information about criminal convictions and offences.

BIO-LOGIC may also, in the future, collect additional data, on subjects such as user applications, user research subjects, etc. in order to enable its users to download whitepapers and other specific documentation. In such case, the present Policy shall be amended.

Failure to provide personal data

Where BIO-LOGIC needs to collect personal data by law, or under the terms of a contract with its users and they fail to provide that data when requested, BIO-LOGIC may not be able to perform the related contract (for example, to provide the related customer with products or services). In this case, BIO-LOGIC may have to cancel a product or service but shall notify you if this is the case at the time.

3. HOW IS THE PERSONAL DATA COLLECTED?

  • BIO-LOGIC uses different methods to collect data from and about its users including through direct interactions. Our users may give us their Identity and Contact data by filling in forms or by corresponding with BIO-LOGIC by post, phone, email or otherwise. This includes personal data provided by our users when they:

    apply for BIO-LOGIC’s products or services;

    apply for BIO-LOGIC’s support and maintenance services;

    require BIO-LOGIC to submit a quotation or a cost estimate;

    register the products purchased from BIO-LOGIC;

    create an account on BIO-LOGIC website;

    subscribe to BIO-LOGIC service or publications;

    request marketing to be sent;

    enter a competition, promotion, or survey; or

    give feedback to or contact BIO-LOGIC.

  • Automated technologies or interactions. when interacting with BIO-LOGIC website, we will automatically collect Technical Data about our users’ equipment, browsing actions and patterns. BIO-LOGIC collects this personal data by using cookies, server logs and other similar technologies. BIO-LOGIC may also receive Technical Data if you visit other BIO-LOGIC group sites, including distributor sites employing BIO-LOGIC cookies.
  • Third parties or publicly available sources. BIO-LOGIC will receive personal data about its users from various third parties and public sources as set out below:
    exhibition attendees listed by exhibition organisers
  • Technical Data from the following parties:
    analytics providers, such as Google.

4. USE OF THE PERSONAL DATA COLLECTED

BIO-LOGIC may only use the personal data collected when the law allows us to. Most commonly, BIO-LOGIC will use such personal data in the following circumstances:

  • Where BIO-LOGIC needs to perform or finalize a contract with the related user.
  • Where it is necessary for BIO-LOGIC’s legitimate interests (or those of a third party) and our users’ interests and fundamental rights do not override those interests.
  • Where BIO-LOGIC needs to comply with a legal obligation.

Please refer to Glossary, “lawful basis”, to find out more about the types of lawful basis that BIO-LOGIC will rely on to process the personal data collected from its users.

Generally, BIO-LOGIC does not rely on consent as a legal basis for processing personal data. You have the right to withdraw consent to marketing at any time by contacting BIO-LOGIC.

Purposes for which BIO-LOGIC will use the personal data collected

The table below provides a description of all the ways BIO-LOGIC plans to use such data, and which of the legal bases allow such use. BIO-LOGIC has also identified our legitimate interests where appropriate.

Note that the personal data may be processed for more than one lawful ground depending on the specific purpose for which BIO-LOGIC is using your data. Please contact us if you need further details

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register a new customer (a) Identity (b) Contact Performance of a contract
To manage the relationship with BIO-LOGIC’s users which will include:
(a) Notification about changes to the terms or privacy policy
(b) Request to leave a review or take a survey 		(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications 		(a) Performance of a contract
(b) Necessary to comply with a legal obligation
(c) Necessary for BIO-LOGIC’s legitimate interests (to keep its records updated and to study how customers use the products/services)
To enable BIO-LOGIC’s users to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications 		(a) Performance of a contract
(b) Necessary for BIO-LOGIC’s legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our users’ business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical 		(a) Necessary for BIO-LOGIC’s legitimate interests (for running the Company’s business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to BIO-LOGIC users’ and measure or understand the effectiveness of the advertising served to them by BIO-LOGIC (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical 		Necessary for BIO-LOGIC’s legitimate interests (to study how customers use BIO-LOGIC’s products/services, to develop them, to grow BIO-LOGIC’s business and to inform our marketing strategy)
To use data analytics to improve BIO-LOGIC’s website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage 		Necessary for BIO-LOGIC’s legitimate interests (to define types of customers for BIO-LOGIC’s products and services, to keep the website updated and relevant, to develop BIOLOGIC’s business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications 		Necessary for BIO-LOGIC’s legitimate interests (to develop BIO-LOGIC’s products/services and grow BIOLOGIC’s business)

Promotional offers

BIO-LOGIC may use the Identity, Contact, Technical, Usage and Profile Data collected to form a view on what the related user may want or need. This is how BIO-LOGIC decides which products, services, and offers may be relevant for such user.

Marketing communications will be sent by BIO-LOGIC, upon request or in case of purchase of products or services from BIO-LOGIC, to prospects, to exhibition participants, to webinar attendees who have not opted out of receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you, or by contacting us at any time.

Opting-out will not apply to personal data already provided as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

The browser may be set to refuse all or some browser cookies, or to alert the user when websites set or access cookies. Disabling or refusing cookies may result in some parts of this website to become inaccessible or not function properly. For more information, please see our cookies policy set out in section 10 below.

Change of purpose

BIO-LOGIC will only use the personal data collected for the purposes for which it was collected, unless BIO-LOGIC reasonably consider that it needs to use it for another reason which is compatible with the original purpose. For further explanations as to how the processing for the new purpose is compatible with the original purpose, please contact BIO-LOGIC.

If BIO-LOGIC needs to use the personal data collected for an unrelated purpose, a notification shall be sent to explain the legal basis allowing BIO-LOGIC to do so.

Please note that BIO-LOGIC may process the personal data collected without the user or the customers’ knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF PERSONAL DATA

BIO-LOGIC may share the personal data with the parties set out below for the purposes set out in the table above:

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Third parties to whom BIO-LOGIC may choose to sell, transfer or merge parts of our business or assets. Alternatively, BIO-LOGIC may seek to acquire other businesses or merge with them. If a change happens to BIO-LOGIC’s business, then the new owners may use the personal data already collected in the same way as set out in this privacy policy.

BIO-LOGIC requires all third parties to respect the security of the personal data collected and to treat it in accordance with the law. BIO-LOGIC does not allow its third-party service providers to use the personal data collected for their own purposes and only permit them to process it for specified purposes and in accordance with BIO-LOGIC’s instructions.

6.INTERNATIONAL TRANSFERS

BIO-LOGIC shares your personal data within Bio-Logic Group and its network of distributors, if your country or request falls into their area of intervention. This may involve transferring the related data outside the European Union.

Whenever BIO-LOGIC transfers your personal data out of the European Union, it ensures a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • BIO-LOGIC will only transfer the personal data collected to countries that have been deemed to provide an adequate level of protection for personal data.
  • BIO-LOGIC will conclude appropriate contracts with Group companies and distributors.

Please contact BIO-LOGIC for further information on the specific mechanism used when transferring the personal data out of the European Union.

7. DATA SECURITY

BIO-LOGIC has put in place appropriate security measures to prevent personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, access to personal data is limited to those employees, agents, contractors and other third parties who have a business need to know. They will only process the personal data on BIO-LOGIC’s instructions, and they are subject to a duty of confidentiality.

BIO-LOGIC has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where it is legally required to do so.

8. DATA RETENTION

BIO-LOGIC shall only retain the personal data collected for as long as reasonably necessary to fulfil the purposes it collected that data for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. By law, BIO-LOGIC has to keep basic information about its customers (including Contact, Identity, Financial and Transaction Data) for ten years after they cease being customers, for tax and legal purposes.
BIO-LOGIC may retain the personal data collected for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with such user or customer.

In some circumstances, deletion of the data may be requested: see below for further information.

In some circumstances BIO-LOGIC shall anonymise the personal data (so that it can no longer be associated with the related user or customer) for research or statistical purposes, in which case BIO-LOGIC may use this information indefinitely without further notice.

9. USERS’ LEGAL RIGHTS

Under certain circumstances, users have rights under data protection laws in relation to their personal data.

  • Request access to your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing your personal data
  • Request transfer of your personal data
  • Right to withdraw consent

In order to exercise any of the rights set out above, please contact us.

No fee usually required

No fee is required to access your personal data (or to exercise any of the other rights). However, BIO-LOGIC may charge a reasonable fee if a request is clearly unfounded, repetitive, or excessive. Alternatively, BIO-LOGIC could refuse to comply with such kind of request in these circumstances.

Specific information that may be needed

BIO-LOGIC may need to request specific information to help confirm your identity and ensure your right to access the personal data requested (or to exercise other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. BIO-LOGIC may also contact you to ask for further information in relation to the request to speed up our response.

Time limit to respond

BIO-LOGIC tries to respond to all legitimate requests within one month. Occasionally it could take longer than a month if the request is particularly complex or there are a number of requests. In this case, BIO-LOGIC will notify you and keep you updated.

10. COOKIES POLICY

Definition of cookies

The BIO-LOGIC website uses cookies.

A cookie is a small text file which is stored on the user’s computer, tablet or phone when visiting a website. These cookies enable BIO-LOGIC to distinguish the relevant user from other users of the website. This helps BIO-LOGIC to provide its users with a good experience when browsing its website and also allows BIO-LOGIC to improve it.

There are two main types of cookies:

  • session cookies—these are deleted when you finish browsing a website and are not stored on the computer longer than this.
  • persistent cookies—these are stored on the computer after the use of a website so that the website provider can remember the user’s preferences the next time they visit the website. These cookies are used as part of BIO-LOGIC’s web analytics to actively monitor traffic and compile reporting about how users are using BIO-LOGIC’s website.

Cookies can be set by the website you have browsed, i.e. the website displayed in the uniform resource locator (URL) window. These are called first party cookies. Third party cookies are set by a website other than the one you are browsing.

Consent: On a first visit to the BIO-LOGIC website, the user is asked if he accepts or refuses the installation of all non-essential cookies or chooses the non-essential cookies he wishes to use. This choice will be recorded and applied on his successive visits to BIO-LOGIC website and can be modified at any time by activating the cookies dialogue icon (a yellow oval, white tick) in the lower left corner on each page of the www.biologic.net website.

Queries: For any questions or comments regarding this Cookies policy, please use the following link https://www.biologic.net/contact/?form=support

11. GLOSSARY

USERS

A user is any person who browses BIO-LOGIC’s website for business purposes.

LAWFUL BASIS

Legitimate Interest means the interest in BIO-LOGIC’s business in conducting and managing its business to enable it to give the best service/product and the best and most secure experience. BIO-LOGIC makes sure to consider and balance any potential impact on its users (both positive and negative) and their rights before we process their personal data for BIO-LOGIC’s legitimate interests. BIO-LOGIC does not use the personal data collected for activities where our interests are overridden by the impact on its users (unless we have their consent or are otherwise required or permitted to by law).
Please contact BIO-LOGIC to obtain further information about how we assess our legitimate interests against any potential impact on our users in respect of specific activities.

Performance of Contract means processing personal data where it is necessary for the performance of a contract to which our user or customer is a party or to take steps upon request before entering into such a contract.

Comply with a legal obligation means processing the personal data collected where it is necessary for compliance with a legal obligation that BIO-LOGIC is subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the BIO-LOGIC Group acting as joint controllers or processors and who are based in Germany, United States, India, Singapore, United Kingdom, and Spain and who act as sales, marketing, and post-sales service support to customers in their respective countries and regions.

External Third Parties

  • Service providers acting as processors based in Europe who provide IT, system administration services and marketing services.
  • Professional advisers acting as processors or joint controllers including accountants, lawyers, bankers, auditors, experts, and insurers based in each country where BioLogic has a subsidiary who provide related services to that subsidiary.
  • French Tax Authority, regulators and other authorities acting as processors or joint controllers based in France, who require reporting of processing activities in certain circumstances.
  • BIO-LOGIC’s distributor network.

LEGAL RIGHTS

Users have the right to:

Request access to their personal data (commonly known as a “data subject access request”). This enables them to receive a copy of the personal data we hold about them and to check that BIO-LOGIC is lawfully processing it.

Request correction of the personal data that we hold about our users. This enables them to have any incomplete or inaccurate data we hold about them corrected, though BIO-LOGIC may need to verify the accuracy of the new data provided to it.

Request erasure. This enables our users to ask BIO-LOGIC to delete or remove personal data where there is no good reason for continuing to process it. This also enables them to ask BIO-LOGIC to delete or remove their personal data where they have successfully exercised their right to object to processing (see below), where BIO-LOGIC may have processed their information unlawfully or where BIO-LOGIC is required to erase the related personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons to be notified, if applicable, at the time of related request.

Request restriction of processing of personal data. This enables BIO-LOGIC to ask for the suspension of the processing of the personal data collected in the following scenarios:

  • If the related user or customer wants BIO-LOGIC to establish the data’s accuracy.
  • Where BIO-LOGIC’s use of the data is unlawful, but the related user or customer does not want us to erase it.
  • Where the related user or customer needs BIO-LOGIC to hold the data even if we BIO-LOGIC no longer requires it as he needs it to establish, exercise or defend legal claims.
  • The related user or customer has objected to BIO-LOGIC’s use of his data, but BIO-LOGIC needs to verify whether it has been overriding legitimate grounds to use it.

Request the transfer of the personal data to you or to a third party. BIO-LOGIC will provide to you, or a third party you have chosen, such data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information initially provided with consent for BIO-LOGIC to use or where BIO-LOGIC used the information to perform a contract with you.

Withdraw consent at any time where BIO-LOGIC is relying on consent to process the personal data collected. However, this will not affect the lawfulness of any processing carried out before such withdrawal. The withdrawal may prevent BIO-LOGIC to provide certain products or services to you. We will advise you if this is the case.