We have updated our entire Privacy Policy to clarify how we use your data, and to provide you with the most transparent and understandable information possible.
Updates to our Privacy Policy take effect on April 10th, 2024.
This Privacy Policy describes all the data processing that we may carry out as part of the management of our commercial, scientific or sponsorship relationship with you. For complete information on the nature of the processing we carry out, and also on your rights and how to exercise them, please also consult the information contained in Volta Medical's General Data Protection Policy.
The categories of data that we may collect from persons with whom we have a commercial or scientific relationship are as follows:
We may also collect information automatically at our discretion during our relationship with you. For example, when you attend events we organize
As data controller, we may process your data for a number of objectives (also referred to as "purposes"):
Purpose n°1: Data processing carried out for the purpose of making contact with individuals (prospects) who have confirmed their interest in our products or services (except when they object to direct marketing), for our marketing and promotional activities, and/or with prospects likely to take part in our research or trials activities or to provide us with services, specifically as counsels or consultants, or for the purpose of responding to and ensuring the proper management of any requests or e-mails you may send us
Purpose n°2.: Data processing carried out for the purpose of event management and participation in external events
Purpose n°3: Data processing carried out to provide you with technical information on our products or services or relating to our research and trials activity (such as to invite you to participate in data collection projects and/or research and development projects carried out by Volta Medical, with the explicit understanding that Volta Medical does not promise to offer you any collaboration whatsoever), for sending communications, managing your consent history.-
Purpose n°4: Data processing for the purposes of preparing and sending contractual proposals, including commercial proposals, sales/licensing materials, technical and commercial assistance, after-sales service/maintenance, contracting, invoicing, managing disputes, sub-contracting, procurement of goods and services.
Purpose n°5: Management of products and services commercialized by Volta Medica, including verification and authentication of persons authorized for their use, tracking access, training and monitoring of access, performance analysis of our products, management of recommendations for use, compilation of usage statistics, user satisfaction metrics, management, remediation, and prevention of malfunctions and technical incidents, management of suggestions or feedback or complaints from customers and handling of litigation.
Purpose n°6: Management of scientific publications produced in collaboration with Volta Medical, including participation in the compulsory “peer review” process.
Purpose n°7: Management of sponsorship and/or partnership operations.
The legal basis for processing depends on the purpose of the intended processing. Please refer to the section corresponding to your situation.
Purpose no. 1: Depending on the sub-purpose envisaged, the legal basis for such processing is the legitimate interests of Volta Medical or the consent of data subjects. You may withdraw your consent at any time by exercising your rights as set out under the tab "What are your rights regarding the processing of your data and how can you exercise them?" of Volta Medical's General Data Protection Policy.
Purpose no. 2 : Data processing is based on Volta Medical’s legitimate interest in the proper management of the events in which it participates.
Purpose no. 3: Processing is based on Volta Medical's legitimate interest in prospecting and in managing its commercial or scientific activities.
Purpose no. 4: Depending on the sub-purpose of the processing, the legal basis for the processing will be the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, or compliance with a legal obligation to which we are bound.
Purpose no. 5: Depending on the sub-purpose of the processing, the legal basis for the processing will be performing a contract in force between us, or the implementation of pre-contractual measures taken at your request, or the compliance by Volta Medical with its legal and regulatory obligations. In terms of statistical use, the legal basis is our legitimate interest in the statistical monitoring of the use of our products.
Purpose no. 6: The legal basis for the processing is the Volta-s legitimate interest in the proper management of the scientific publications in which it collaborates.
Purpose no. 7: The legal basis for the processing is Volta's legitimate interest in securing the sponsorship and partnership operations it intends to set up.
The length of time your data is kept depends on the purpose for which it is processed. Please refer to the section corresponding to your situation.
Purpose no. 1: The retention periods depend on the sub-purpose envisaged:
- In the case of data relating to prospection : In the absence of opposition, your data will be kept for a period of 3 years from the date of your consent.
- For other sub-purposes, data will be kept in the active database for the time necessary to achieve the purpose for which it was collected. At the end of this period, the data may be archived securely for a period of 5 years to enable Volta Medical to protect itself against any litigation.
Purpose no.2 : Data is securely archived for 5 years after the concerned event.
Purpose no. 3: Unless you object, your data is retained for a period of 3 years beginning from the date of collection of your data.
Purpose no. 4: Retention periods depend on the intended sub-purpose:
- when the legal basis is the contract: Data is retained for the duration of the contractual relationship, after which it is securely archived for 5 years;
- when the legal basis is a legal obligation: The duration depends on the legal obligation concerned.
Purpose no. 5: Retention periods depend on the intended sub-purpose: - when the legal basis is the contract: Data is retained for the duration of the contractual relationship, after which it is securely archived for 5 years;
- When the legal basis is the legitimate interest of Volta Medical: Data is retained for the time strictly necessary to fulfill the secondary purpose in question. The data is then permanently deleted from every medium;
- When the legal basis is Volta’s compliance with its legal and regulatory obligations: data is kept in our active database for the duration of the medical’s device commercialization, and is then archived in a secure manner for a period of 10 years from the last time the concerned medical device was introduced into circulation.
Purpose no.6: Retention periods depend on the sub-purpose envisaged:
- With regard to personal data that may be processed within the scientific publication itself: The data retention period is governed by the provisions applicable to public archives in France (article L.211-11 et seq. of the French Code du Patrimoine).
- With regard to data relating to the publication and the management of the publication process: data is retained for the duration strictly necessary to achieve the purpose for which it was collected. Data is then permanently deleted from any medium.
Purpose no.7: Data is kept in the active database for the time required to make a decision on the sponsorship or partnership operation, and is then archived in the intermediate database for a period of 5 years.
The recipients of the data include Volta Medical's authorized internal collaborators (and only when access to the data is strictly required for them to perform their duties) and, where applicable, the joint data processors, our authorized processors and service providers.
- Only with regard to data contained in scientific publications in which Volta Medical may collaborate: the data is also received by the staff of the publishing entities of the journals/periodicals concerned, their subcontractors, authorized collaborators and service providers and, more generally, by any public interested in these publications;
- Where processing is necessary to enable Volta to comply with its legal obligations: the authorities and notified bodies are also likely to be recipients of the data.
- In any case, the data may also be transmitted:
The mandatory or non-mandatory nature of data collection depends on the intended purposes.
Purpose no. 1 and Purpose no. 3: Data collection is not mandatory.
Purpose no. 2: When you participate in an event for which we are likely to manage your attendance and/or interventions, the collection of your data is mandatory to manage and ensure your participation in the said event.
Purpose no. 4 and Purpose no. 7 : For the majority of sub-purposes of processing, data collection is mandatory and is necessary for the proper performance of the contract or pre-contractual measures or the fulfillment of our legal obligations.
Purpose no. 5: When the legal basis for collection is the performance of a contract, data collection is mandatory or Volta Medical's compliance with its legal or regulatory obligations. When the legal basis for data processing is Volta Medical's interests, data collection is not mandatory.
Purpose no. 6: The collection and processing of data is mandatory in order to ensure the proper publication of scientific publications.
In the context of processing operations based on persons with whom we have a commercial or scientific relationship, we collect data directly from the data subjects. With regard to prospect data, data may be collected from publicly available data such as scientific journals and reviews, event programs, public presentations/conferences, and information available online, such as professional social media in particular. With regard to information available from publicly accessible sources, persons whose profiles have been consulted and who do not attract our interest will not be informed of this consultation because of the low impact of the processing on them. Conversely, where individuals in whom we take interest are concerned, we will only store data about you at Volta Medical once we have contacted you and notified you accordingly. You have the right to object to this processing at any time.
With regard to Background Data, we collect data directly from you or from the entity in which you have an interest. We also collect data from publicly available information. If we need to collect data from other sources, we will notify you in advance.
We may carry out data transfers to a country outside of the European Union in the framework of our operations. In this case, we will take all appropriate measures to ensure compliance with applicable regulations within the European Union. You may obtain a copy of these safeguards from our Data Protection Officer, whose contact details are specified in the “Contact” section of Volta Medical’s General Data Protection Policy.
We may modify the content of this Policy at any time, following the evolution of our activities and/or in order to comply with our legal obligations. In the event of any amendments, these will be made and posted on the relevant pages of this Policy on our website. We recommend that you refer to these pages each time you visit our website. However, if the amendments to this Policy are substantial, we will draw your attention to this by publishing a disclaimer on our website.