Privacy Policy Commercial, Scientific, Sponsorship or Partnership

The categories of data that we may collect from persons with whom we have a commercial or scientific relationship are as follows:

Identification data: First and last name, position, concerned legal entity, professional contact information (email, address, land line and mobile telephone numbers), signature, photo;
Professional data: Department, entity, and address of the entity in which the person practices/works, professional identification number (also called "RPPS" number), professional background (résumé), contract(s) entered into with us (where applicable), information relating to participation in scientific events (podiums, speaking engagements, number of speaking engagements, information relating to events and participations such as place, date, interactions with other industry players when this information is publicly available);Where applicable : information relating to scientific publications (date, title of publications, number of publications, reviews/journals concerned, journal identification number, article reference number, volume, publication content, publisher identification, publisher legal notice, questions/answers with peers (in the context of the compulsory “peer review” process), revision comments with timestamps, date of submissions, date of revision and acceptance of texts existence of not of author conflicts of interest;Where applicable: Bank details, remuneration, hospitality, dates of interactions with us,
Commercial data: Dates of solicitations for prospects, place and date of contact, any email exchanges, data relating to an invoice, payment terms, and deadlines, bank identification number, information on services/products offered/sold, data relating to signing contracts, to delivery notes, to product maintenance and installation, attendance or non-attendance at our events, data relating to training courses completed (date and certificate of successful completion);
Data relating to the use of our products: Authentication logs, connection data, procedure stop and start data, data relating to the equipment used (machine ID, center, operator, software version, mode, number of procedures performed, certain action data (booster mode and automatic tagging activation and deactivation data, manual or automatic tagging, data relating to parameter changes made), data relating to any incident reports or other information relating to the use of our products and services;
Data relating to reports of malfunctions and/or technical incidents without serious consequences related to the use of our products (known as "complaints"): date of knowledge of the event, date and time of occurrence, time of start of the procedure, content of the free comments transmitted in the context of the report, product and center concerned, identity of the author of the report, type of event, information to establish whether the procedure concerns a patient included in a study conducted by Volta Medical, if so, identification of the study, as well as data relating to the contact person of the center concerned (name, position, telephone number and e-mail address);
Data concerning your consent to the collection of personal data and exercise of your rights
In the context of the organization of videoconference meetings: we may process certain data about you, in particular your image, your voice and the content of your exchanges. As a matter of principle, we do not make any video recordings of the meetings, so the data is only stored for the duration of the meeting. However, in order to ensure the follow-up of the exchanges and the agreed actions, we may or may not automatically draw up a written transcript (minutes) of the meeting. In the exceptional event that a recording (audio and/or video and/or transcription) is made, you will be informed in advance, and your information will be processed in accordance with our legal obligations; In addition, we use the Microsoft Teams tool to organize our meetings. When you participate in a meeting organized by us, an attendance report is automatically generated by this tool. This report can include the following data: name, email address used, and duration of the meeting;
With regard to any messages/emails you may send us: content and timestamp of these messages, any attachments to your messages and, where applicable, analysis data enabling this content to be analyzed for cybersecurity purposes, and data related to receipts and readings;
With regard to any events in which you may participate: data relating to registration and participation in interventions and events.
With respect to background checks that may prevent us from entering into a contractual relationship: The categories of data collected are limited to the information necessary to assess the risk of corruption, or violations of sanctions or export control laws. It includes identification data, professional data, commercial data, as well as Background Data of corporate officers, major shareholders and any information relating to professional and business life. In addition, there is the following data on an identity document (passport, national identity card, etc.), including the nationality, date and place of birth, the authority of the entity issuing the document with the date of issue and expiry, as well as the place, name and address of the banks used to receive payments and the name of the holder of the bank account, the account number and currency of payment, the shareholdings held in the entity concerned, the status of the persons (public officials, civil servants, elected or appointed representatives of the government, a department, a state agency or others, employees of a parastatal or state-owned enterprise, persons working for a government agency (including local, regional, national, administrative, (legislative or executive), a person acting for or on behalf of a public official, a government agency or any enterprise exercising a governmental function, or a public authority or one of their public establishments, administrative authorities, candidates for public office, employees or persons acting on behalf of a political party, a public international organization), any profits derived by public officials, the date of termination of duties, any family ties with a public official, the existence of a commercial relationship with customers or users of Volta's products, of a competitor of Volta Medical, Background Data is information intended to determine whether there is a real or suspected reputational or breach of probity history such as the ongoing or past existence of an investigation, an indictment or conviction for violation of applicable international anti-corruption laws or other probity or securities criminal laws or regulations, bankruptcy, receivership or liquidation.

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

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Purpose n°2.: Data processing carried out for the purpose of event management and participation in external events

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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.

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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.

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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.

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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.

Purpose n°8.: Management of reports related to malfunctions and/or technical incidents without serious consequences (known as "complaints"), occurring when the use of Volta Medical's products, including their collection, analysis, detection of trends, as well as, where applicable, the implementation of the necessary measures to prevent, correct and resolve these incidents.

Purpose n°9: Fight against corruption and make the declarations and authorizations necessary to comply with Volta Medical's legal and regulatory obligations, in particular with regard to the benefits granted to health professionals and the transparency of links of interest.

Purpose n°10: Defense of Volta Medical's interests in the context of any litigation or pre-litigation.

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.

Purpose no. 8: The processing is based on Volta Medical's legal obligation, in particular under Regulation (EU) 2017/745, to implement a post-marketing surveillance system allowing the collection and recording of complaints and non-serious incidents related to the use of its medical devices, their systematic analysis, the detection of trends and the implementation of the necessary corrective actions.

Purpose no. 9 : The processing is based on Volta Medical's legal obligation, with regard to its compliance with international and national anti-corruption laws, the framework of benefits and transparency. The processing is also based on Volta Medical's legitimate interest in putting in place specific procedures to investigate, prevent or take action regarding potentially illegal activities.

Purpose no. 10: The processing is based on Volta Medical's legitimate interest in defending itself in court or amicably.

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.

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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.

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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.

Purpose no. 8: The data is kept in an active database for the duration of the management and processing of the complaint. The data is then archived in an intermediate database for a period of 10 years from the date on which the last device concerned is placed on the market.

Purpose no.9 : The data is kept in an active database for three years after the completion of the due diligence process. It is then archived for seven years in order to justify Volta Medical's performance of its due diligence obligations to the authorities.

Purpose no. 10: The data is kept for the duration of the dispute, to which is added the duration relating to the limitation period in this matter.

- For all the purposes mentioned above: Volta Medical's authorized internal employees (only when they strictly need access to the data to fulfill their missions) as well as, where applicable, joint data controllers, our subcontractors and authorized service providers.

- With regard to the management of reports related to malfunctions and/or technical incidents without serious consequences (known as "complaints"), occurring during the use of Volta Medical's products: as part of the management of reports of adverse events and malfunctions related to the use of our products ("complaints"), we may use the Qualio® software platform published by the company Qualio Inc. Qualio Inc. also processes your data in its capacity as a data controller and anonymises it in order to use it on its own behalf. For more information on the data processing carried out by Qualio Inc., you can consult their privacy policy: here.‍

- Only with regard to the data contained in the scientific publications to which Volta Medical may collaborate: the staff of the publishing entities of the journals concerned, their subcontractors, collaborators and authorized service providers as well as more broadly any member of the public interested in these publications are also recipients of the data;

- When the processing is necessary to enable Volta Medical to comply with its legal obligations: the authorities and notified bodies may also be recipients of the data.

- In the event of sharing opinions, suggestions for improvement and feedback from users (current or potential) of our products: Volta Medical may use the Monday.com software solution, published by Monday.com Ltd, in order to collect these contributions directly from the people concerned. In this context, personal data may be processed by Monday.com, in particular for the purposes of analysis, the production of trends and the development of statistical data. As such, the solution can classify comments into three different categories (neutral, positive, negative). For more information on the data processing carried out by Monday.com, you can consult their privacy policy, which can be accessed here.
- In any event, this data may also be transmitted:

To the competent judicial or administrative authorities and their authorized staff in the event of an investigation or inspection;
To any agent(s), subcontractor(s), consultant(s) authorized by Volta Medical for (i) the analysis or remediation of possible security incidents involving your data ;(ii) the establishment of evidence, (iii) the assessment of the risk of corruption, the violation of sanctions and export control laws, (iii) the provision of IT resources in the context of these activities,
To the company's statutory auditors. In this context, the latter act as independent data controllers. To obtain information relating to their identity and the methods of processing your personal data, you can contact our DPO the contact details appear in the "Contact" tab.

Privacy Policy for persons with whom we maintain or are likely to maintain a commercial, scientific, sponsorship or partnership relationship