Policy last updated: 15/06/2023
The use of information and communication technologies requires particular attention to be paid to the protection of privacy.
Circle Anatoscope Intuitive Design (C.A.I.D.), in its capacity as data controller, attaches paramount importance to the confidentiality of the personal information it collects and is committed to complying with the applicable regulations regarding the processing of personal data, in particular the General Data Protection Regulation (EU) No. 2016/679 (known as the "GDPR").
The purpose of this policy is to inform you of our practices regarding the collection, use and sharing of information that you may actively or passively provide to us through our website (hereinafter referred to as the "Site"). We recommend that you read it carefully before using our services.
1. What type of information do we collect about you?
When you use our Site, you may be asked to provide us with information, some of which may identify you directly or indirectly ("Personal Data").
This may include in particular:
Data provided when you request contact or register for our newsletter: this includes your surname, first name and email address. Data relating to your use of the Site: we collect browsing data that may make it possible to identify your terminal (computer, telephone, tablet) when you consult our Site. In this context, we may collect the IP address of your terminal, the type of browser and operating system used, as well as other information such as your Internet service provider, the website from which you visited our Site, the number of pages consulted and the time spent on each page of our Site, etc. This data is used to ensure the proper functioning of the Site, in particular its performance and security. It is also used to analyze visitor traffic, within the limits and under the conditions set out in this policy.
Data relating to your request to exercise your rights: this includes your surname, first name and contact details, as well as proof of identity if requested.
2. How do we collect your personal data?
Your personal data is collected passively and actively:
Passive collection: information relating to your use of our Site is automatically collected when you interact with its functionalities. To this end, we use so-called "cookie" technology to collect information about visitors. Cookies are small files that are stored on any communication device used by the user (e.g. computer, telephone and tablet) when browsing the Site. These files enable the exchange of status information between the Site and the user's terminal. You can configure your choices in this respect by clicking on the cookies tab. However, some cookies are necessary for the operation and security of the Site and cannot be refused.
Active collection: we collect data directly from you when you provide information via our Site. If you do not wish your personal data to be processed, please do not provide it. However, if this information is necessary for the provision of our services and you refuse to provide it, you will not be able to benefit from said services.
3.For what purposes and on what legal bases do we process your personal data?
Your personal data is collected and processed for the following purposes and on the following legal bases:
- Managing your contact requests: the information you provide in this context is processed on the basis of our legitimate interest in responding to your requests.
- Newsletter management: this processing is based on your consent. You can withdraw your consent at any time by clicking on the unsubscribe link included in each newsletter.
- Measuring and analyzing the Site's audience: we use your browsing data to measure and analyze the number of visitors to our Site. This processing is based on your consent. You can withdraw your consent to cookies at any time by accessing the cookie management module in the footer.
- Analysis of ad performance: when you access the Site via commercial ad links ("landing page") we collect information enabling us to analyze ad performance. This processing is based on your consent. You can withdraw your consent to cookies at any time by accessing the cookie management module in the footer.
- Video content distribution: we offer video content that requires cookies to function. This processing is based on your consent. You can withdraw your consent to cookies at any time by accessing the cookie management module in the footer.
- Management of your requests to exercise your rights relating to your personal data: this processing is based on our legal obligations arising from applicable data protection regulations.
- Optimization of our Website: the use of browsing data is aimed in particular at ensuring a suitable display on your device and guaranteeing seamless and secure browsing. This processing is based on our legitimate interest in providing you with a satisfactory and secure browsing experience.
4. How long do we keep your personal data?
Your personal information will be kept for as long as is necessary to achieve the various purposes for which it is to be used.
The table below summarizes our retention and archiving policy.
5. To whom will your personal data be disclosed?
The personal data we collect is intended for use by C.A.I.D.'s internal departments, each of which processes only the data necessary for the performance of its tasks.
The main departments concerned are
- Marketing / communications department
- IT department
- Quality department
Your personal information may also be made accessible to our subcontractors, who are bound by contractual confidentiality and security obligations.
Our subcontractors fall into the following categories:
- Website hosting provider.
- Service provider in charge of sending digital communications (newsletters, emailing, etc.).
- Site audience analysis services .
- Ad performance analysis services.
- Video content display services.
When you accept the deposit of cookies and according to your preferences expressed on our site (acceptance of audience measurement, video or performance cookies), your data is also shared with the third-party companies behind these cookies, some of which are located outside the European Union or the European Economic Area.
When your data is transferred outside the European Economic Area to countries that are not subject to an adequacy decision by the European Commission, C.A.I.D. undertakes to secure the transfers with appropriate guarantees, such as standard contractual clauses approved by the European Commission.
The subcontractors and partners linked to C.A.I.D to date are as follows:
6. What are the main security measures implemented to protect your personal data?
We are committed to ensuring the security of the data you entrust to us.
In order to prevent any unauthorized access, use, modification, destruction, loss, damage or disclosure, and to protect the data collected, appropriate technical and organizational measures are put in place. The personal data we collect is stored in a secure environment.
Our employees are bound by contractual confidentiality obligations and must comply with an internal charter governing the proper use of the information system. We also check that our subcontractors offer sufficient guarantees in terms of
security and confidentiality. In addition, if we become aware that a breach of your personal data for which we are responsible presents a high risk to your privacy, we will inform you as soon as possible so that you can take all necessary precautions to limit the consequences (change your passwords, etc.).
7. What rights do you have regarding your personal data and the processing we carry out?
Pursuant to Articles 15 to 22 of the General Data Protection Regulation, subject to meeting the conditions laid down by these provisions, you have the option:
- To access all your personal data;
- To rectify inaccurate, outdated and/or incomplete data;
- To have your data erased;
- To obtain the portability of your data, if technically possible;
- To request the restriction of the processing of your data;
- To object at any time, for reasons relating to your personal situation, to the processing of your data;
- To withdraw your consent to the processing of your data for a specific purpose, where such processing was based on that consent;
- To define advance directives concerning the fate of your data after your death.
To enable you to exercise these rights, we may ask you to provide proof of identity where there is reasonable doubt as to the identity of the applicant.
In this case, the copy of the proof is not kept beyond the time required for verification. To exercise your rights, or if you have any questions concerning the processing of your data by C.A.I.D., please contact our Data Protection Officer at dpo@circle.dental.
If you are not satisfied with the outcome of your request, you can send a complaint to the French Commission Nationale de l'Informatique et des Libertés (CNIL) via its website or by post.
8. What happens if this Privacy Policy is modified?
The Site and our activity may evolve, for example in the event of a change in commercial policy or new technological choices. As a result, we may modify this Privacy Policy accordingly. We reserve the right to update and amend it at any time and without reason.
We invite you to consult this policy regularly, and in particular before communicating personal data. This Privacy Policy was last updated on the date indicated above.
Continued use of the Site following the implementation of changes to this Privacy Policy constitutes acceptance of the provisions of the revised Policy, as it now applies.
