The FH ORTHO GROUP is fully aware of the importance of privacy and personal data protection, and it undertakes to ensure appropriate personal data protection relative to all persons with whom it maintains relations.
What you will find in this document
This overall Privacy and Personal Data Protection Policy (the “Policy”) describes the general measures implemented by the FH ORTHO GROUP in order to ensure appropriate personal data protection, which means the protection of all information relative to an identified or identifiable natural person, for the major data processing obligations carried out in connection with its business relations and activities (“Personal Data”).
What processing activities are covered by this Policy?
This Policy applies to processing activities undertaken by the FH ORTHO GROUP relative to the people with whom it maintains relations in connection with its activities and business relations.
Collection of your Personal Data for explicit and legitimate purposes
The FH ORTHO GROUP can collect your Personal Data for the following purposes:
- to correctly perform the operations linked to our activities;
- to comply with the legal and regulatory obligations applicable to the FH ORTHO GROUP;
- to provide patients with assistance;
- to manage our research and development activities;
- to provide you with access to our online services, platforms and tools;
- to enable us to identify and authenticate you;
- to develop and improve our products and services;
- to customise your experience when you use our services;
- to enable us to communicate with you;
- to perform payments that we may have to make in specific situations;
- to make donations and carry out sponsorship operations;
- to meet demands coming from administrative or judicial authorities in compliance with the applicable law;
- to protect our rights and interests.
Personal Data Processing
Depending on the data processing in question, the FH ORTHO GROUP will process your personal data in accordance with one of the following legal bases:
– your prior consent when you have clearly given your approval for the FH ORTHO GROUP to process your Personal Data.
– a contractual relationship between you and the FH ORTHO GROUP: in this case, the processing of your Personal Data is generally needed as of the signing or fulfilment of the contract obligations; accordingly, if you do not wish for the FH ORTHO GROUP to process your Personal Data under these conditions, the FH ORTHO GROUP may or will be required to refuse to establish a commercial relationship with you, or will be unable to provide you with the products or services covered by this contract.
– legal, regulatory or ethical obligations applicable to the activities of the FH ORTHO GROUP; such as our publication obligations relative to the “transparency of links” in compliance with the Bertrand Law of 29 December 2011.
– a “legitimate interest” of the FH ORTHO GROUP within the meaning of the applicable legislation regarding Personal Data protection. In this case, the FH ORTHO GROUP will consider your interests and fundamental rights when determining if the processing is legitimate and lawful.
Data collection from reliable sources
The FH ORTHO GROUP can collect your Personal Data from various sources:
– Data that you provide to us via various media, during a registration or usage of an application or any other direct or indirect interaction with the FH ORTHO GROUP.
– Data that we collect automatically, for example when we monitor your interactions with our Internet sites, platforms, tools or services, notably by means of cookies.
– Data that we collect from public sources in conformity with the applicable law, including data published by you on various media.
Cookies are a standard feature of websites, that are used to store small volumes of data on your computer, relative to your visit to our site. They do not allow for identification of the user.
Certain services may not be available if the installation of a cookie is refused. However, you can configure your computer in order to refuse the installation of cookies.
Internet Explorer: tool tab (pictogram in form of a cogwheel in the upper right) / Internet options. Click on Privacy and select Block all cookies. Click OK to validate.
Firefox: at the top of the browser window, click on the Firefox button, then look under the Options tab. Click on the ‘Privacy’ tab. Adjust the History settings to: use custom settings for history. Finally, clear the box in order to deactivate cookies.
Safari: At the top right of the browser, click on the menu pictogram (in the shape of a cogwheel). Select Settings. Click on Display advanced settings. In the “Privacy” section, click on Content settings. In the “Cookies” section, you can block cookies.
Chrome: At the top right of the browser, click on the menu pictogram (in the shape of three horizontal lines). Select Settings. Click on Display advanced settings. In the “Privacy” section, click on content settings. In the “Privacy” section, you can block cookies.
Recipients of your Personal Data
For the purposes described above, the FH ORTHO GROUP may have to share your Personal Data with the following authorised parties:
– the FH ORTHO GROUP and its affiliated companies;
– our partners and selected suppliers;
– any administrative or judicial authority, when this is required in accordance with the applicable law, including in accordance with the provisions of foreign law;
– any potential buyer and other stakeholders;
In all cases, the FH ORTHO GROUP ensures that these third parties:
– undertake to observe the applicable legislation regarding data protection and the principles of this Policy;
– process the Personal Data only for the purposes described in this Policy, and implement appropriate technical and organisational security measures in order to protect the integrity and confidentiality of your Personal Data.
Transfers of your Personal Data outside of the EU
The FH ORTHO GROUP may be required to transfer your Personal Data (including by providing access, allowing visualization, or storing them) to subsidiaries, subcontractors and partners of the group in other jurisdictions, including from within the European Economic Area and outside of the European Economic Area.
Implementation of security measures to protect your Personal Data
The FH ORTHO GROUP implements all necessary and suitable oversight measures in order for your Personal Data to be stored on secure servers, and kept strictly confidential.
Retention of your Personal Data
The FH ORTHO GROUP will retain your Personal Data for the duration needed in order to carry out the aims described in this Policy.
Exercise of your rights relative to your Personal Data
You can exercise the rights granted to you under the applicable legislation regarding data protection.
To this end, the FH ORTHO GROUP informs you that you have the following rights:
– to access, when requested, your Personal Data in which case you will receive a copy, unless the said data are directly made available to you;
– to obtain rectification of your Personal Data in the event that they are inaccurate, incomplete or obsolete;
– to demand the erasure of your Personal Data in the situations anticipated by the applicable legislation on data protection (“right to erasure”);
– to withdraw your consent to the processing of your Personal Data (without this affecting the legality of the processing), when your Personal Data were processed and collected on the basis of your consent;
– to oppose the processing of your Personal Data, when they have been collected and processed on the basis of the legitimate interests of the FH ORTHO GROUP, in which case you must justify your request by providing us with an explanation of your specific situation;
– to request a limitation of processing in the situations indicated by the applicable law;
If you wish to exercise any of these rights, please contact us as indicated in the “Contact us” section. We will take all necessary measures in order to provide you with an answer as quickly as possible.
The FH ORTHO GROUP will be happy to receive your comments and to answer your questions relative to this Policy or its implementation. If you wish to contact us regarding the use of your Personal Data, or if you object to the processing of your Personal Data, please send an e-mail to the data protection officer, at the following address: firstname.lastname@example.org.
At the time of this request, we ask you to please specifically indicate the information that you wish to correct, modify or erase, and to enclose your identity document (for example identity card, passport).
Validity and evolution of this Policy
The FH ORTHO GROUP can modify this Policy over time, notably in order to adapt it to upgrades or changes of the applicable law or internal practices of the FH ORTHO GROUP. Changes will be listed on this page. We ask you to review this Policy on a regular basis.
Date of last update: September 2019