Companion Spine respects your privacy and wants you to be familiar with how we collect, use, and disclose information.  This Privacy Policy describes our practices in connection with information that we collect through the website or application (hereinafter the “Site”) operated and controlled by us from which you are accessing this Privacy Policy. We encourage you to read the full Privacy Policy before using this Site or providing any personal information.  By providing personal information to us or by using the Site, you acknowledge that you have read and understand this Privacy Policy.

USE BY MINORS

The Site is not directed to individuals under the age of 18, and we request that these individuals not provide personal information through the Site. If your child has submitted Personal Information and you would like to request that such Personal Information be removed, please contact us as explained below under “Contacting Us”.

INFORMATION COLLECTION

We may ask you to submit personal information in order for you to benefit from certain features (such as newsletter subscriptions, tips/pointers, or order processing) or to participate in a particular activity. You will be informed what information is required and what information is optional.

We may combine the information you submit with other information we have collected from you, whether on or offline, including, for example, your purchase history.  We may also combine it with information we receive about you from other sources, publicly available information sources (including information from your publicly available social media profiles), and other third-party information providers.

If you submit any personal information relating to another individual to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

SENSITIVE INFORMATION

Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any sensitive personal information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, health or medical condition, sex life or sexual orientation, criminal background, or trade union membership, or biometric or genetic data for the purpose of uniquely identifying an individual) on or through the Site or otherwise directly to us.

AUTOMATIC INFORMATION COLLECTION AND USE

We and our service providers may automatically collect and use information in the following ways as you navigate around the Site:

Through your browser:  Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, and Internet browser type and version.  We may collect similar information, such as your device type and identifier, if you access the Site through a mobile device.  We use this information to ensure that the Site functions properly.

Using cookies:  Cookies are pieces of information stored directly on the computer you are using.  Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, and language preferences.  We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Site.  We also use cookies to recognize your computer or device, which makes your use of the Site easier. In addition, we use cookies to gather statistical information about Site usage in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it.  We may also use cookies in online advertising to track consumer responses to our advertisements.

You can refuse to accept these cookies by following your browser’s instructions; however, if you do not accept them, you may experience some inconvenience in your use of the Site.  You may also not receive advertising or other offers from us that are relevant to your interests and needs.  To learn more about cookies, please visit http://www.allaboutcookies.org.

Using pixel tags, web beacons, clear GIFs, or other similar technologies:  These may be used in connection with some Site pages and HTML formatted e-mail messages to, among other things, track the actions of users and e-mail recipients, measure the success of our marketing campaigns, and compile statistics about Site usage.

Device Information:  We may collect information about your mobile device, such as a unique device identifier, to understand how you use the Site.

HOW WE USE AND DISCLOSE INFORMATION

We use and disclose information you provide to us as described to you at the point of collection.  Please see the section entitled “Choices and Access” below to learn how you may opt-out of certain of our uses and disclosures.

Where required by applicable law, we will obtain your consent to our use of your personal information at the point of information collection.  We may also use information from or about you as necessary to perform a contract, to comply with a legal obligation, or for our legitimate business interests.  We may also rely on other legal bases, specifically for:

• Providing the functionality of the Site and fulfilling your requests.
  • to provide the functionality of the Site to you and providing you with related customer service;
  • to respond to your inquiries and fulfill your requests, such as to send you documents you request or for e-mail alerts;
  • to send you important information regarding our relationship with you or regarding the Site, changes to our terms, conditions, and policies and/or other administrative information.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Accomplishing our business purposes.
  • for data analysis, for example, to improve the efficiency of the Site;
  • for audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
  • for fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
  • for developing new products and services;
  • for enhancing, improving or modifying our website or products and services;
  • for identifying Site usage trends, for example, understanding which parts of our Site are of most interest to users; and
  • for determining the effectiveness of our promotional campaigns so that we can adapt our campaigns to the needs and interests of our users.

We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

• Analysis of Personal Information to provide personalized services.
  • to better understand you so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests;
  • to better understand your preferences so that we can deliver content via the Site that we believe will be relevant and interesting to you.

We will provide personalized services either with your consent or because we have a legitimate interest.

We also disclose information collected through the Site:

• to our third-party partners with whom we offer a co branded or co marketed promotion;
• to our third-party service providers who provide services, such as website hosting and moderating, mobile application hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, e-mail and direct mail delivery services, auditing, and other services, in order to enable them to provide services; and
• as permitted by applicable law, to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

In addition, we may use and disclose your information as we believe to be necessary or appropriate:  (a) to comply with legal process or applicable law which may include laws outside your country of residence; (b) as permitted by applicable law to respond to requests from public and government authorities, which may include authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.  We may also use and disclose your information in other ways, after obtaining your consent to do so.

We may use and disclose information we collect automatically as described above under “Automatic Information Collection and Use.”

In addition, where allowed by applicable law, we may use and disclose information that is not in personally identifiable form for any purpose.  If we combine information that is not in personally identifiable form with information that is identifiable (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your personal information

We give you choices regarding our use and disclosure of your personal information for marketing purposes.  You may opt-out from:

• Receiving marketing communications from us:  If you no longer want to receive marketing communications from us on a going forward basis, you may opt-out of receiving them at any time. We typically provide opt-out options in every piece of communication.
• Receiving reminders from us:  If you no longer want to receive medical reminders from us on a going forward basis, you may opt-out of receiving them at any time.

We will seek to comply with your request(s) as soon as reasonably practicable.  Please also note that if you opt-out of receiving marketing related messages from us, we may still send you important transactional and administrative messages from which you cannot opt-out.

How you can access, change, or delete your personal information

If you would like to review, correct, update, restrict, or delete your personal information, you may visit the Site at any time to update your online profile.

For further information, please contact dpo@companion-spine.com.

CROSS BORDER TRANSFER

Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Site or by providing consent to us (where required by law), your information may be transferred to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country of residence.  Nonetheless, appropriate contractual and other measures are in place to protect personal information when it is transferred to our affiliates or third parties in other countries.

Please note that the Personal Data we collect and process via the contact form will be transferred to and stored in the United States, a jurisdiction where privacy laws may not be as protective as where you are located.

Companion Spine has implemented legal transfer mechanisms and appropriate guarantees, in accordance with applicable legal requirements, to protect your Personal Data such as the processing of your Personal Data by only our own company employees.

SECURITY

We seek to use reasonable organizational, technical, and administrative measures designed to protect personal information under our control. However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.

RETENTION PERIOD

We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained.  The criteria used to determine our retention periods include:  (i) the length of time we have an ongoing relationship with you and provide the Site to you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

THIRD PARTY SITES AND SERVICES

This Site may contain links to sites of third parties. This Privacy Policy does not address, and we are not responsible for, the privacy, information, or practices of any third parties, including any third party operating any site or online service (including, without limitation, any application) that is available through this Site or to which this Site contains a link.  The availability of, or inclusion of a link to, any such site or property on the Site does not imply endorsement of it by us or by our affiliates.

CONTACTING US

Companion Spine, located at Immeuble le Bridge – Étage 5, 5 Allée Des Acacias, 33 700 Mérignac, France, is the company responsible for collection, use, and disclosure of personal information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us via:

Companion Spine
Immeuble le Bridge – Étage 5
5 Allée Des Acacias
33 700 Mérignac, France
Telephone Number: +33(0) 5 32 26 25 70

Email: dpo@companion-spine.com

UPDATES TO THIS PRIVACY POLICY
We may change this Privacy Policy.  Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Site.  Your use of the Site following these changes means that you accept the revised Privacy Policy.  We recommend that you regularly review the Privacy Policy when you visit the Site. This policy was last updated on January 15, 2022. 

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective: January 15, 2022

This Privacy Notice for California Residents supplements the information contained in the Global Privacy Policy (above), and applies only to California residents (“You,” “your” or “consumer”).

Personal Information Collection and Purposes of Use

We collect and use information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your devices when you visit this website, provide us your personal information, or have a contractual or business relationship with us or any of our affiliates, (“Personal Information”).  Such Personal Information includes direct identifiers like a name, postal address, email address, and indirect identifiers that may identify, relate to, or be associated with a particular individual, such as a telephone number, device identifier, IP address and browsing history, credit card information, or inferences about consumer preferences or characteristics.

We collect this Personal Information for the following purposes:

• to respond to your inquiries and to fulfill your requests;
• to send you important information regarding our relationship with you or regarding this website, changes to our terms, conditions, and policies and/or other administrative information;
• for audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
• for fraud or crime prevention, and for technical security monitoring purposes;
• to facilitate the development of new products and services;
• to enhance, improve or modify our website or products and services;
• for data analysis that will allow us to understand website usage trends;
• to determine the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
• to better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests;

 Unless specifically stated, we do not share, disclose or sell personal information to third parties for their own use, but we do share your personal information with our affiliates and trusted partners in arrangements that may meet the broad definition of “sale” under California law.  In these arrangements, use of the information we share is limited by policies, contracts, or similar restrictions.

Your Privacy Rights

You have the following rights regarding our collection and use of your personal information.  To exercise those rights, you must submit a request by either calling us at +33(0) 5 32 26 25 70, emailing us at dpo@companion-spine.com or through the privacy form.  We may ask you to provide additional information to verify your request.  We may not discriminate against you if you exercise your rights as described in this notice.  For example, we may not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality of products or services.

Right to Information

You have the right to request the following information regarding the personal information we have collected about you:

• Categories of personal information collected about you, and sources from which collected;
• Our purpose for collecting personal information;
• Categories of third parties with which the personal information was shared; and
• Specific pieces of personal information collected about consumers.

You have the right to request the following information regarding the personal information we have sold or disclosed about you:

• Categories of your personal information sold in the preceding 12 months;
• Categories of third parties to whom your personal information has been disclosed;
• Categories of personal information that we disclosed about consumers for a business purpose.

Right to Opt Out of Sharing, Disclosure, or Sale of Personal Information

You have the right to direct us to not share, disclose, or sell your personal information.  To exercise this right, you or your authorized representative may submit a request by emailing us at dpo@companion-spine.com.  Please use the subject line: “do not use my private information.”

Right to Request Deletion

You have the right to request that we delete the personal information we have about you.  However, we are not required to delete information if it is necessary to retain your information to:

• Complete the transaction for which the personal information was collected, provide a good or service requested by you, or a transaction reasonably anticipated within the context of our or one of our affiliate’s ongoing business relationship with you, or to otherwise perform a contract we have with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity or prosecute those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when deletion of the information is likely to render impossible or seriously impact the achievement of such research, if you have provided informed consent.
• Facilitate solely internal uses that are reasonably aligned with your expectations based on your relationship with us or one of our affiliates.
• Comply with a legal obligation.
• Otherwise use the personal information, internally, in a lawful manner that is compatible with the context in which it was provided. 

Contact Us

You can contact us with questions about this Privacy Notice for California Residents or to exercise your rights as described in this Notice.

Telephone number: +33(0) 5 32 26 25 70

Email: dpo@companion-spine.com

Postal address: