Date of entry into force: 21/05/2018

This Online Confidentiality Statement (“Confidentiality Statement”) explains how ITENA Clinical handles the personal data with which it is provided via its websites, mobile phones, mobile applications and other digital services and products controlled by ITENA Clinical, related to this Confidentiality Policy. ITENA Clinical monitors the data during personal data processing in accordance with applicable law.

ITENA Clinical sites are identified as: www.itena-clinical.com / www.x-cellium.itena-clinical.com

This Confidentiality Statement does not apply to ITENA Clinical sites not related to this Confidentiality Statement or to third party sites related to ITENA Clinical sites.

Type of information collected online

The type of personal data that we can collect when you are using ITENA Clinical sites is described in this section and includes the information with which you provide us and the information that we collect automatically when you use ITENA Clinical sites.

In the context of this Confidentiality Statement, “personal data” means any information providing identification or which could reasonably be used as identification. Examples of personal data include your name, address, telephone number and email address.

Information that you provide

It is not generally necessary to register with a specific service or programme to receive the majority of information available via the ITENA Clinical sites. Personal data that you provide when you visit ITENA Clinical sites

ITENA Clinical collects the personal data that you provide on ITENA Clinical sites in order, for example, to receive sample products or marketing information, when you contact ITENA Clinical customer services or when you respond to ITENA Clinical questionnaires and surveys. This personal data may include:

• your details, such as your name, address, telephone number or email address;
• your registration details, such as your user name and password;
• any content that you may provide (for example, when you fill out an on-line contact form or submit other information).

Personal data that you share during other interactions with ITENA Clinical.

You may contact ITENA Clinical to ask us questions, express your concerns or tell us about problems related to our products. If you communicate with ITENA Clinical or request information from us, we might ask you to provide your details and personal data relevant to your request.

Information that might be collected automatically

When you use ITENA Clinical sites, we may also collect some information about your device and its usage automatically, as described below.

IP Address

We may record the Internet Protocol (“IP”) of your computer or electronic device when you visit ITENA Clinical sites. The IP address identifies the electronic device that you are using to access the sites, which enables us to maintain communication with your computer when you navigate around ITENA Clinical sites and personalise our content.

Cookies and other tracking technology

We also collect information regarding your use of ITENA Clinical sites by means of tracking technology such as cookies and website tags. A cookie is a unique digital code transferred to your computer to track your interests and preferences and to recognise you as a returning visitor. A website tag is a transparent graphic image placed on a website, an email or advert that enables certain things to be monitored, such as users’ activity and site traffic. These technologies store your preferences and allow us to provide you with content and features that interest you based on clickstream data which shows your prior activities on ITENA Clinical sites.
We use Google Display Advertising (such as Google Analytics retargeting, Google Display Network impression reporting, DoubleClick campaign manager integration and the Google Analytics demographics and interests data report function) to (1) send you our adverts on other sites based on your previous visits to the ITENA Clinical sites and (2) gain a better understanding of our ad impressions and the use of advertising services. In addition to the Google Analytics demographics and interests data report function, we may use advertising data based on Google interest and third-party data (on age, gender and areas of interest) with Google Analytics to understand and improve our marketing campaigns and site content.

We distribute some of our ads via Google Display Advertising. As part of this program, we use Google Analytics functions, such as retargeting. In conjunction with this function and other functions offered by advertising networks, advertising network operators and ourselves, in particular Google, may use third-party cookies (such as the DoubleClick cookie) and in certain cases first-party cookies (such as the Google Analytics cookie), to inform, optimise and distribute adverts on the Internet, on the basis of prior visits by the user to ITENA Clinical sites.

You can unsubscribe from Google Ads by going to http://www.google.com/ads/preferences. If you do not wish your data to be used by Google Analytics, you can install the Google Analytics opt-out function on your browser, on the Google Analytics opt-out page.
The ITENA Clinical site is not designed to respond to browsers’ “unfollow” signals.
To find out more about cookies and other tracking technology, especially how to disable them, go to http://www.allaboutcookies.org/. Note that some cookies are essential for the functioning of our sites and deleting or disabling them will reduce the sites’ functionality.

Mobile tracking

ITENA Clinical sites are available via mobile sites that can be used on your mobile device. If you use a mobile device to access and use ITENA Clinical sites, we may collect the following information about the mobile, in addition to the other information described above:

• -        device or advertising ID,
• -        type of device, type of hardware, media access control address (“MAC”),
• -        international mobile equipment identity (“IMEI”)
• -        the version of your mobile operating system, platform used to access the ITENA Clinical site
• -        location and use information about your device and your use of ITENA Clinical sites

Information collected via other sources

We may cross-check information about you collected on an ITENA Clinical site against other information collected.

Use of your information

We use your personal data to provide you with the goods and services that you request, to communicate with you, to improve your experience of ITENA Clinical sites, to improve our products and services in general and for other internal commercial purposes. These uses may also include recording, organisation, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data. Personal data collected may be stored, then archived, only during a period that is reasonably necessary for the purposes described above, in accordance to applicable law.

Provision of the goods and services requested

If you decide to have recourse to our services, we use the personal data that you supply via the ITENA Clinical sites in order to answer your questions, provide you with the services that you request and offer you the best possible customer experience.

Marketing

You may also receive marketing information from ITENA Clinical and its associated affiliates, such as offers in relation to goods and services connected to ITENA Clinical, invitations to participate in a survey on our products or notifications about special promotions. In these cases, we will use your details and other personal details to send you marketing information.

Personalised user experiences

The personal data that you provide may be used to create personalised offers and information or services that target your interests and preferences. We may also use your IP address and the data that we obtain automatically via cookies or similar tracking technologies to facilitate use and browsing of our ITENA Clinical sites and to personalise the content of the ITENA Clinical sites, by anticipating the information and services that may interest you.

Improving our business and our products

ITENA Clinical analyses the information that you provide to discover new information that may give ITENA Clinical a better understanding of its customers’ needs and to improve, develop and evaluate its products, services and documentation. ITENA Clinical does not use any information that may identify you directly for this purpose.

Analyses and site improvement

We may use the information that you provide and that we collect automatically on your use of the ITENA Clinical sites with the aim of monitoring user traffic trends and preferences in order to improve the site, its analysis and optimisation.

Processing requests and general communication with you

In general, we process your personal data when you contact us and send us queries, or to monitor your requests and questions.

Legal basis for processing

Under European data protection laws, the processing of your personal data by ITENA Clinical must have a valid legal basis. The legal basis that applies in each different scenario depends on the specific purposes for which ITENA Clinical is processing your data, stipulated below:

In certain cases, ITENA Clinical may seek your consent for collecting and processing your personal data. If you decide to give your consent, you can retract it subsequently by contacting us via the procedure described in the section “Your choices with regard to confidentiality”. Please note that withdrawal of consent does not have any impact on any processing that has already taken place.

In other situations, the processing of your personal data may be required under a particular law or regulation, or to honour a contract by which you are obliged. It is possible you may not be able to refuse this processing, or that if you refuse, our capacity to honour our contractual obligations towards you may be affected.

In other circumstances, ITENA Clinical may process your personal data if it is in its interest to communicate with you on the subject of its goods and services or its scientific research and training possibilities. You have the right to refuse such processing of your personal data. To do so, contact us by the procedure described in the section “Your choices with regard to confidentiality”.  

Sharing information

We only share your information with third parties as described below. We do not sell or lease your personal data to third parties for their own marketing purposes.

Third-party advertising and online behavioural advertising

Third-party sites and mobile services may bring up customized online advertisements for ITENA Clinical goods and services. These may be personalised on the basis of the information that you have provided to ITENA Clinical, a third-party site that you visit, as a result of your browsing activity, your purchases or your interests. This type of targeted online advertising may come from different sources, such as:

• We may give your non-identifying information, obtained via cookies and other tracking technologies on our ITENA Clinical sites, to our advertising services providers.
• Certain internet browsers may send “unfollow” signals to sites with which they communicate. At the date of this Confidentiality Statement, no sectoral regulation has been drawn up on the processing of these signals. ITENA Clinical does not, therefore, take these signals into account.

Affiliates, suppliers and providers

We have built relations with suppliers and affiliated companies that help us to carry out our business. They may need to have access to your personal data in the context of the services that they provide to ITENA Clinical. We will not authorise any of these third parties to use your personal data for any commercial use other than that of ITENA Clinical and its associated affiliates. We do not share personal data from countries that require consent, unless a sharing agreement has been reached with the associated affiliates in advance. We require them to process our personal data in respect of this Confidentiality Statement.

Co-branded sites

We may sign a partnership agreement with other companies to provide you with joint or “co-branded” content or services. When a site is co-branded, the ITENA Clinical logo and that of the co-branding partner will appear on your screen. You should consult the confidentiality policies of each of our co-branding partners as they may differ from ours in certain aspects. If you read these policies, you can take informed decisions when you are asked to provide information on a particular site.

Report on products

If you contact ITENA Clinical on the subject of your experience with one of our products, we may send the information that you provide in your report to regulatory government authorities, if required to do so by law.

Legal rights and obligations

In certain defined circumstances ITENA Clinical may disclose your personal data to comply with a legal obligation or requirement, such as respect of reporting obligations to regulatory governmental authorities on the subject of the safety of our products, or with regard to the sale or transfer of one of our ranges of products or divisions, including the services provided via the ITENA Clinical sites. In these situations, we will take measures to protect your personal data as far as possible. We likewise reserve the right to use our personal data to investigate and prosecute users who breach our regulations or who participate in illegal conduct or conduct that is dangerous to others or others’ property.

Changes within the company

If ITENA Clinical decides to reorganise or transfer its business by sale, merger or acquisition, ITENA Clinical may share personal data about you with actual or potential buyers. We will ensure that these actual or potential buyers process this personal data in respect of this Statement.

Protection of children’s privacy

The Company does not collect or use any personal data originating directly from minors on the Company’s websites. We do not allow children to order our products, to communicate with us or to use our on-line services. If you are a parent and you realise that your child has provided us with information, please contact us by one of the methods specified below and we will work with you to resolve the problem.

Your choices regarding confidentiality

You are entitled to consult and obtain a copy of the personal data that we hold about you, and ask us to rectify any inaccurate or incomplete data. You are entitled to receive the data with which you provide us in a format that can be read by machine and to send it to another monitoring body. You may also request that your personal data be deleted, prohibit the processing of your personal data or object to the processing of your personal data. To request access to your personal data, raise a concern, register a complaint, request a correction or unsubscribe from a programme, contact us by email at contact@itena-clinical.com. You can also write to the following address:

ITENA Clinical
For the attention of the regulatory department
31 avenue Georges Clémenceau

93420 Villepinte

For more information on your rights regarding confidentiality, or if you cannot resolve a problem directly with us and wish to ensure that your rights are respected, contact your local data protection authority.

When contacting ITENA Clinical, please always give your email address, the site address and/or the specific ITENA Clinical product for which you provided your personal data (e.g. www.itena-clinical.com), together with a detailed explanation of your request. If you are emailing us because you wish to delete, amend or correct your personal data, please put “Request for deletion” or “Request for amendment/correction” in the subject line. We will respond to reasonable requests as quickly as possible. We may also ask you confirm your identity in order to deal with certain requests. 

Data security

ITENA Clinical uses reasonable technical, administrative and physical controls to ensure that the personal data collected on the ITENA Clinical sites is kept secure. However, there is always the risk that an unauthorised third party may intercept a transmission by internet or find a way of bypassing our security systems. We would ask you to be very careful when sending personal data via the Internet, particularly when it relates to personal financial information. ITENA Clinical cannot guarantee that third parties will not access your personal data; consequently, when you submit personal data on ITENA Clinical sites, you should consider the advantages and risks. 

Third-party sites and social network plug-ins.

This confidentiality notice does not apply to the Company sites that are not related to this confidentiality notice or to third-party websites with which the Company sites may be linked. Company websites may use social media plug-ins (for example, the Facebook “Like” button, the Twitter “Retweet” button) to enable you to share information easily with other people. When you visit the Company websites, the operator of the social media plug-in may place a cookie on your computer or any other electronic device which will enable this operator to recognise people who have already visited our Site. If you are connected to the social media website (e.g. Facebook, Twitter), while you are navigating our company website, the social media plug-in will enable this website to receive the information that you have visited on our company website. Social media plug-ins likewise enable social media websites to share information on your activities on our company’s site with other users of their social-media website. These sharing parameters are managed by the social media website and governed by its confidentiality policy.

Changes to our Confidentiality Policy

We will only use personal data in the manner described in this Confidentiality Policy applicable when collecting information from you or that you have authorised. However, depending on the applicable requirements for consent, we reserve the right to amend the terms of this Confidentiality Policy at any time. Any change to this Confidentiality Policy will be shown on this page, with the new date when it comes into force. ITENA Clinical invites you to read this Confidentiality Policy frequently, to check whether there have been any amendments. Any personal data collected in the context of your continuous use of ITENA Clinical sites will be processed on the basis of the most recently published Confidentiality Policy. 

Contact

In the event of any question, concern or comment on this Confidentiality Policy, or forms of processing, access to and correction of your personal data by ITENA Clinical, please contact us at the following email address: contact@itena-clinical.com. You can also write to the following address:

ITENA Clinical
For the attention of the regulatory department
31 avenue Georges Clémenceau

93420 Villepinte

I accept