Cookies Policy

Legal disclaimer

This cookies policy (hereinafter referred to as the "Cookies Policy") defines the legal framework for the collection, use and processing by PERSONA, a company in the process of being incorporated (hereinafter referred to as the "Company"), of personal data relating to persons browsing and/or using the services offered by the Company (hereinafter referred to as the "Users") via cookies and other tracers stored on the "Persona" platform accessible at www.persona.healthcare (hereinafter referred to as the "Platform") designed, developed and operated by the Company.

Under the terms of the cookies policy, the Company is responsible for processing personal data.

As data controller, the Company retains full control over the Personal Data and determines the object, nature, purposes, means and duration of the processing of the Personal Data collected.

Some of these cookies and trackers are strictly necessary for the Platform to function properly and to optimise its technical performance (strictly necessary cookies). For example, strictly necessary cookies enable the Company to provide secure, high-performance access to the Platform. These cookies do not collect information about Users for marketing purposes. This category of cookies is essential to the operation of the Platform and cannot be deactivated.

Other cookies are used to improve the User's experience by personalising functions and remembering their choices, measuring the audience and displaying personalised advertising:

Functional or preference cookies: the Company may use functional cookies to remember the User's choices in order to adapt the Platform and provide improved functionalities and personalised content. For example, these cookies may be used to remember the User's name or preferences on the Platform. The Company will not use functional cookies to target the User and provide personalised advertising. Although these cookies may be deactivated, this may lead to a reduction in functionality when using the Platform.
Performance or analytical cookies: These cookies collect passive information about how the User uses the Platform, including the web pages they visit and the links they click on. The Company will use the information collected by these cookies to improve and optimise the Platform and not to target the User and offer personalised advertising. The User may deactivate these cookies.
Targeting or advertising cookies: These cookies are used to generate online advertising of interest to the User by building up a picture of what interests them based on their use of the Internet. Cookies can limit the number of times a User sees an advertisement and help measure the effectiveness of any advertising. They remember that the User has visited a website and this information may be shared with other organisations or advertisers. The Company may use these cookies in limited circumstances associated with its public sites.

The Company may also use tracking technologies to collect browsing data, such as the domain name of the service providing the User with Internet access, type of device, IP address used, browser type and version, operating system, average time spent on sites, web pages viewed, content searched, access times and other relevant statistics, and assign unique identifiers to the device or other identifying information used to access information systems. The Platform's pages and e-mails may contain small electronic files called web beacons (also known as clear GIFs, web beacons and single-pixel GIFs) which are used, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, to record the popularity of certain website content and to verify system and server integrity).

Some of the purposes for which cookies and tracers are used may require the User's consent. Where consent is given, it may be freely withdrawn at any time by following the instructions provided in this document.

The periods of validity and expiry of cookies and other tracers may vary depending on the lifetime defined by their owner. Some expire at the end of the User's browsing session.

The Company undertakes to comply with the applicable regulations on the protection of personal data and in particular the obligations arising from European Regulation no. 2016/679 on the protection of personal data (hereinafter the "RGPD"), Directive 2002/58/EC of 12 July 2002 known as the ePrivacy Directive, and CNIL deliberation no. 2020-091 of 17 September 2020 (hereinafter the "Applicable European Regulations").

The Company collects personal data in accordance with the terms of this Cookie Policy and any reasonable and lawful instructions given by the User at any time. Full details of each processing operation are provided in this Cookie Policy or in specific explanatory texts published prior to data collection.

In addition to what is specified in the descriptions of each of the categories below, Users can find more precise and up-to-date information concerning the description of the lifetime and any other useful information in the privacy policies of the respective linked third-party suppliers or by contacting the Company.

The Company can be contacted at any time at dpo@persona.healthcare or by using the contact details at the top of this document.

The Company reserves the right to modify this Cookie Policy at any time, by informing its Users on this page and possibly on the Platform - insofar as this is technically and legally possible - by sending a notice to Users via the contact details available to the Company. Users are strongly advised to consult this page frequently, referring to the date of the last modification indicated at the bottom.

If the changes affect the processing activities carried out on the basis of the User's consent, the Company must obtain a new consent from the User if necessary.

Information collected

Personal data may be provided freely by the User, or collected automatically when the User uses the Platform.

The Company (including its technical service providers) may collect directly or indirectly :

Data relating to the User's activity,
Data relating to the User's browsing, in particular the anonymised IP address, the browser used, the browsing time, the operating system used, the language and the pages consulted,
The unique universal identifier,
Unique device identification for advertising purposes,
Data relating to the use of the Platform by the User, in particular traffic data, the number of notifications, the number of visits, the number of data updates, the number of launches of the Platform and any other data or means of communication that the User uses when accessing the Platform.

Unless otherwise indicated, the collection of data on the Platform is compulsory and necessary for the provision of services by the Company. In the event that the Platform specifies that certain data is not compulsory, Users are free not to provide it without any consequences for the availability or operation of the Service.

Any use of cookies - or other tracking tools - by the Platform is intended to provide the service requested by the User, in addition to the other purposes described in this document.

Users are responsible for all Personal Data of third parties obtained, published or communicated via the Platform and confirm that they have consented to obtain the consent of any third party to provide the data.

Purposes of processing

The Company uses, stores and processes personal data for the following purposes:

Displaying content from external platforms
Analysis
Contact the User
User database management
Productivity management - related activities
Tag management
Management of support and contact requests
Web hosting and backend infrastructure
Traffic optimisation and distribution
Anti-SPAM protection
Advertisements
Collection of confidentiality preferences
Remarketing and behavioural targeting
Infrastructure monitoring
Performance and functionality tests

Finally, the Company grants itself the right to examine, browse or analyse personal data, including communications exchanged between the Company and Users via the Platform or otherwise, in order to comply with its legal obligations and in particular for the purposes of fraud prevention, risk assessment, regulatory compliance and investigation.

Legal basis for processing

The Company or the third party owner of the cookies/trackers is likely to process personal data relating to Users if one of the following conditions applies:

Users have given their consent for one or more specific purposes; in accordance with certain legislation, the Company or the third party owner may be authorised to process personal data until the User objects ("opt-out"), without having to rely on consent or one of the following legal bases. However, this condition does not apply where the processing of personal data is subject to Applicable European Regulations.

the supply of personal data is necessary for the performance of a contract with the User or for any pre-contractual obligation of the User.

processing is necessary to comply with a legal obligation to which the Company or the third party owner is subject.

the processing is linked to a task carried out in the public interest or in the exercise of official authority vested in the Company or the third party owner.

processing is necessary for the purposes of the legitimate interests pursued by the Company or the third party owner.

In all cases, the Company will provide assistance to Users to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a legal or contractual requirement.

Storage of personal data

Personal data is processed and stored for as long as is necessary for the purposes for which it was collected.

Therefore :

Personal data collected for purposes relating to the performance of a contract between the Owner and the User must be retained until the contract has been fully performed.
Personal data collected for the purposes of the Company's legitimate interests will be retained for as long as necessary to achieve those purposes. Users can find specific information about the legitimate interests pursued by the Company in the relevant sections of this document or by contacting the Company.
The Company may be entitled to retain personal data for a longer period whenever the User has given his consent to such processing, for as long as such consent is not withdrawn. In addition, the Company may be obliged to retain personal data for longer periods whenever this is necessary for the performance of a legal obligation or by order of an authority.

Once the retention period has expired, the personal data will be deleted or made anonymous.

Consequently, the right of access, the right of erasure, the right of rectification and the right to data portability cannot be applied after the retention period has expired.

Safety

The Company ensures that personal data is adequately and appropriately secured and has taken the necessary precautions to preserve the security and confidentiality of the data and in particular to prevent it from being distorted, damaged or communicated to unauthorised persons.

The Company will implement all the technical and organisational measures necessary to protect personal data and prevent unauthorised processing.

Personal data is processed using computers or IT tools, following organisational procedures and methods closely related to the purposes indicated. In addition to the Company, the data may be accessible, in certain cases, to certain categories of persons in charge of operating the Platform (administration, sales, marketing, legal, system administration) or to third parties (such as third-party technical service providers, messaging services, hosting companies, IT companies, communications agencies) designated, where applicable, as subcontractors by the Company.

Personal data is processed at the Company's head office and at all other locations where the data controllers are located. Depending on the User's location, data sharing may involve the transfer of the User's data to a country other than his/her own. To find out more about where such transferred data is processed, Users may consult the section of the Company's Privacy Policy that contains details on data sharing.

If the Company becomes aware of a violation of rights in connection with the processing of personal data, this violation will be notified to the CNIL within no more than seventy-two (72) hours of becoming aware of it.

Any violation relating to the processing of personal data will be notified by e-mail, within one (1) month, by the Company to the User concerned.

User rights

Users may exercise certain rights concerning their personal data processed by the Company.

In particular, Users may exercise the following rights with the Company:

Right to withdraw consent: Users have the right to withdraw their consent if they have already given their consent to the processing of their personal data.
Right to object: Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent.
Right of access: Users have the right to know what data is processed by the Company, to obtain information on certain aspects of the processing and to obtain a copy of the data processed.
Right of rectification: Users have the right to check the accuracy of their data and request that it be updated or corrected.
Right of restriction: Users have the right, under certain conditions, to restrict the processing of personal data.
Right of deletion: Users have the right, under certain conditions, to obtain the deletion of their personal data.
Right to portability: Users have the right to recover their personal data in a structured, commonly used and machine-readable format and, if technically possible, to transmit it to another data controller without hindrance of any kind. This provision applies provided that the data is processed by automated means and that the processing is based on the User's consent, on a contract to which the User is a party or on pre-contractual obligations.

These rights must be exercised by contacting the Company at the following address: dpo@persona.healthcare, indicating the User's surname, first name, place of residence, e-mail address and telephone number, as well as the purpose of the request.

Users may also lodge a complaint with their competent data protection authority.

Cookie settings

The Company also informs Users that cookies and other tracers record certain information which is stored in the memory of their hard disk.

The Company undertakes to comply with the regulations applicable to the protection of personal data and cookies, in particular the obligations arising from the RGPD, Directive 2002/58/EC of 12 July 2002, known as the ePrivacy Directive, and CNIL deliberation no. 2020-091 of 17 September 2020.

These tools enable the Platform to function properly, offer a better User experience, understand how the Platform works, analyse where it needs to be improved and how it can speed up Users' future interactions with the Platform.

Some cookies are essential for Users to be able to take advantage of all the Platform's features and do not collect confidential information about Users.

Some third-party cookies are used for non-essential purposes such as understanding how the Platform works and how the User interacts with the Platform, generating audience statistics, providing personalised advertising and offering products based on those already selected during previous visits.

The cookies present on the Platform are in particular :

Statistical cookies which store information such as the number of visitors to the Platform, the pages of the Platform that have been visited, the IP address and all information relating to the use of the Platform,
Advertising cookies, which use information to personalise the advertisements displayed on the Platform,
Functional cookies which activate certain features of the Platform, whether essential or not, including preference cookies which store Users' browsing preference settings.

An alert message, in the form of a banner, asks each person visiting the Platform (on the home page or on another page of the Platform) whether they wish to accept cookies. On this occasion, the User is informed of the precise purposes of the cookies used and the possibility of objecting to them and modifying the cookie settings.

Cookies will not be deposited if the User does not express his or her wish by a clear act of acceptance or refusal, and continued browsing does not constitute consent to the deposit of cookies on the User's terminal.

The User may at any time choose to deactivate cookies and other tracking devices. The User's browser can be configured to notify the User of cookies placed on the User's terminal and to ask the User whether or not to accept them.

The configuration of each browser is different. It is described in the browser's help menu, which will tell the User how to modify his or her wishes regarding cookies.

"Firefox:

Click on the menu button and select "Options".
Select the "Confidentiality" panel.
Set the "Retention rules" menu to "Use personalised settings for history".
Uncheck the "Accept cookies" box.
Any changes you make will be automatically saved.

"Internet Explorer:

Click on the Tools button, then on Internet Options.
Click on the "Confidentiality" tab, then under "Settings", move the cursor up to block all cookies or down to authorise all cookies, then click OK.

"Google Chrome:

Select the Chrome menu icon.
Select "Settings".
At the bottom of the page, select "Show advanced settings".
In the "Confidentiality" section, select "Content settings".
Select "Prevent all sites from storing data".
Select OK.

"Safari:

Click on "Settings" > "Safari" > "Privacy" > "Cookies and website data".