CRYOTHERAPEUTICS SA – PRIVACY NOTICE
WEBSITE VISITORS, BUSINESS CUSTOMERS AND SUPPLIERS
Cryotherapeutics SA (“Cryotherapeutics”) has a registered office at Rue de Bruxelles, 174, 4340 Awans, Belgium and is registered with the Crossroads Bank for Enterprises under the number 0713.882.584
This privacy notice provides information to individuals who visit the Cryotherapeutics website(s) and those who work for, on behalf of, or are representatives of business customers and suppliers of Cryotherapeutics (hereinafter an “Individual Representative”) regarding how their personal information is collected and processed by Cryotherapeutics, in compliance with applicable data protection laws, in particular the European Regulation 2016/679 of 27 April 2016 called the General Data Protection Regulation (hereinafter “GDPR”).
This privacy notice explains why and how personal information about Individual Representatives (hereinafter, “Personal Data”) is collected, what Personal Data is processed, who has access to Personal Data, how Personal Data is protected, how long Personal Data is retained, the rights of Individual Representatives and who to contact for further information. This notice is without prejudice to specific provisions set out in any contract entered into between Cryotherapeutics and the applicable customer or supplier.
Why Cryotherapeutics processes Personal Data
Cryotherapeutics keeps and processes Personal Data for administrative, marketing and customer/supplier management purposes, including for the following activities:
- responding to any communication, inquiry or request which an Individual Representative submits to Cryotherapeutics (including via the website);
- managing relationships and maintaining contact with existing and prospective customers and suppliers;
- negotiating and executing agreements with customers and suppliers;
- processing information relating to a proposed or actual purchase or sale of products or services by Cryotherapeutics, including sending statements and invoices;
- customer service purposes, including providing newsletters and marketing communications and/or conducting surveys and market research;
- improving Cryotherapeutics’s products and/or services; and
- legal and/or regulatory compliance, including dispute resolution.
Legal grounds for processing Personal Data
Personal Data covered by this privacy notice is only processed:
- in order to take steps to enter into and manage the performance of a contract with the applicable customer or supplier;
- where necessary to comply with a legal or regulatory obligation that Cryotherapeutics is subject to;
- where processing is necessary for the legitimate interests of Cryotherapeutics and/or a third-party; and
- where the Individual Representative has provided explicit consent to allow the processing of their Personal Data.
The nature in which Cryotherapeutics and/or a third-party processes Personal Data for legitimate interests is to communicate with Individual Representative(s) from time to time regarding products, services or events offered by Cryotherapeutics or other communications such as research and insights that may be of interest to the relevant business customer or supplier. Cryotherapeutics will never process Personal Data for its legitimate interests unless the processing is appropriately balanced against the interests and fundamental rights and freedoms of the Individual Representative.
Categories of Personal Data processed
Personal Data is all personal information relating to an identified or identifiable natural person who is an Individual Representative. For the abovementioned purposes, the processing of Personal Data includes the following categories:
- personal identification data, such as name and address;
- electronic identification data, such as email address and phone number;
- employment related data, such as job title, related employer and dealings with Cryotherapeutics on behalf of the individual concerned or the applicable customer or supplier;
- personal details, such as language spoken and gender;
- participation to events (including family members as the case may be); and
- survey data.
In addition, to comply with legal and regulatory obligations regarding trade control, anti-money laundering and/or bribery and corruption laws, Cryotherapeutics may carry out screening on potential or existing counter-parties before any contract is entered into and on a periodic basis during the term of the contract. This screening takes place against publicly available or government issued sanctions lists and media sources and would include relevant individuals such as directors, officers and key stakeholders. This data may include Personal Data regarding suspected and actual criminal behaviour, criminal records or proceedings regarding criminal or unlawful behaviour but only for the purposes of ensuring Cryotherapeutics’s compliance with legal and regulatory obligations and/or to the extent permitted or required by local law. No automated decision making results from such screening.
Where Personal Data comes from
Where an Individual Representative contacts Cryotherapeutics, Personal Data will likely come directly from the individual concerned. Cryotherapeutics may also contact an Individual Representative for prospective purposes if initial contact information has not been obtained directly from such individual, including receiving such information from publicly available sources or any referrals from other customers or suppliers of Cryotherapeutics. During the course of the business relationship, the individual concerned or another representative of the applicable customer or supplier will provide Cryotherapeutics with further information as needed for the management of the business relationship with such customer or supplier.
Cryotherapeutics may also receive or generate data relating to an Individual Representative from other customers, suppliers or those to whom such individual communicates by email or other systems.
The Personal Data collected directly or indirectly by Cryotherapeutics is required to fulfil legal requirements and/or to enter into a contract and maintain contact with a customer or supplier for the duration of the business relationship. Failure to provide Cryotherapeutics with required information will negatively affect Cryotherapeutics’ ability to communicate with an Individual Representative of a customer or supplier (including the ability to provide any applicable electronic newsletters if an Individual Representative does not wish to share their email address), Cryotherapeutics’ ability to enter into a contract with the applicable customer or supplier or continue the performance of a contract once entered into without access to necessary Personal Data.
Who has access to Personal Data
For the abovementioned purposes, Personal Data covered by this privacy notice will only be shared on a strict need to know basis with:
- the Individual Representatives themselves or other individuals employed by or representing the applicable customer or supplier;
- personnel of Cryotherapeutics;
- authorized third party agents, service providers, professional advisors and/or subcontractors of Cryotherapeutics; and
- government, regulatory bodies and/or public authorities where it is necessary to comply with legal or regulatory obligations which Cryotherapeutics is subject to or as permitted by applicable local law.
Personal Data transferred Internationally
It may be necessary in limited circumstances to transfer Personal Data abroad or to an international organisation to process and/or store this information to comply with our legal or contractual requirements. For transfers of data internationally, Cryotherapeutics has implemented appropriate safeguards in line with GDPR requirements. To ensure an appropriate level of protection for Personal Data, Cryotherapeutics will either use a data transfer agreement with the third-party recipient based on standard contractual clauses approved by the European Commission, ensure that the transfer is to a jurisdiction that is the subject of an adequacy decision by the European Commission or to the United States under the EU-US Privacy Shield framework.
Retention of Personal Data
Personal Data will be retained no longer than necessary for the processing purposes described in this privacy notice. Personal Data provided in respect of an Individual Representative is retained no longer than a normal sales cycle length, with a maximum period of 5 years after the end of the prospecting procedure. Where a contract is entered into with a customer or supplier, typically (and unless otherwise stated in other related documents for specific categories of data) Personal Data will be retained during the term of the contract as well as following the expiration or termination of the contract for as long as there may be legal liability for which the use of Personal Data may be relevant, taking into consideration the applicable statutory periods of limitation and legal retention obligations.
Information may be retained for a shorter period of time where an Individual Representative objects to the processing of their Personal Data and there is no longer a legitimate purpose to retain such information.
How Personal Data is protected
Cryotherapeutics has implemented adequate technical and organisational measures to protect Personal Data and keep it as safe and secure as reasonably possible, protecting it against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of the Personal Data in question.
What are the Individual Representative’s rights and who can they contact
Individual Representatives who have Personal Data collected and processed have the right at any time to contact Cryotherapeutics to access their Personal Data and request a correction of any incorrect or incomplete information.
Subject to and in accordance with applicable law, individuals may also have the right to:
- request the deletion of their Personal Data;
- request restrictions or object to the processing of their Personal Data;
- data portability, allowing the individual to copy or transfer their Personal Data;
- withdraw their consent at any time where consent was provided to process their Personal Data, provided this will not affect the validity of the processing prior to such withdrawal of consent; and
- receive more information about the safeguards in case of international data transfers.
Individual Representatives also have a right to lodge a complaint with the Belgian Data Protection Authority or another EU supervisory authority if such individual thinks Cryotherapeutics has not acted in line with any applicable data protection laws in respect of dealing with their Personal Data.
For any further information about these rights or to make a request please contact the Privacy Officer Bertrand Grimmonpré at Cryotherapeutics at:
Rue de Bruxelles, 174
4340 Awans, Belgium
Phone Number: +32 4 220 88 00
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Changes to Privacy Notice
This privacy notice may be updated from time to time as needed, notably to comply with changes in any applicable laws, regulations or requirements introduced by data protection authorities. This privacy notice was last updated on 26 June 2019.