Privacy Policy
Welcome to our website, and thank you for your interest in our business and our offers. We attach great importance to respecting your privacy and protecting your personal data. We act with full transparency, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as the “General Data Protection Regulation” or “GDPR”).
This policy is issued by Cousin Biotech (trade name: Cousin Surgery), whose registered office is located at Allée des roses, 59117 Wervicq-Sud – France, registered with the Lille Métropole Trade and Companies Register (RCS) under number: 398460261 (hereinafter referred to as “Cousin Biotech” or “we” or “our organisation”).
It applies to the website “cousin-surgery.com” (hereinafter referred to as the “website”) and describes the methods we use to collect, process, store, destroy and protect your personal data.
It does not apply to your activities on the web pages of social networks or other providers that you access via links on our web pages. Please refer to those providers’ web pages, and more specifically to their data protection provisions.
You may respond to any of the practices described below by contacting us at the addresses mentioned in the “Contact us” section of this policy.
Data Controller
Cousin Biotech is identified as the controller of your personal data in accordance with Art. 4(7) of the General Data Protection Regulation (GDPR).
Data Protection Office
Cousin Biotech has appointed Mr Xavier Lanciaux as Data Protection Officer (hereinafter DPO). The privacy team and the DPO can be contacted by email at: contact-DPO@cousin-surgery.com or by post at Cousin Biotech – DPO – Allée des Roses, 59117 Wervicq-Sud – France.
How do we collect your data?
We collect your personal data in the following ways:
- Through one or more cookies;
- When you contact us via the form(s) available on our website.
What are cookies and what are they used for?
A cookie is the equivalent of a small text file, stored on the user’s device (computer hard drive, tablet, smartphone, or any other similar device) via their browser.
With different functions, it collects different types of information, such as visitors’ language preferences, statistics about visitors to our website (country, time spent per page, etc.), or ensures that the website operates under optimal conditions.
Some of these cookies are therefore necessary to allow you optimal access to our website. They are installed by default on your computer, without us being able to ask for your authorisation. Other cookies are only stored when you give your consent.
Most cookies only work for a single session or visit. None of them contains information that could enable you to be contacted by phone, email or post. You can configure your browser so that cookies are not stored on your computer, or delete cookies already stored. To find out how, use your browser’s help function.
If you disable certain cookies, some parts of the website may not be accessible and/or usable, or may only be partially accessible and/or usable.
Below, by clicking on the link, you will find information about the cookies we use on our website: Cookie Information Notice.
Categories of personal data collected, purposes and legal basis for processing
Cousin Biotech collects and processes different categories of personal data depending on how you use our products and services.
Depending on the context in which your data is collected, we rely on one of the following legal bases.
Consent
Once you have accepted the processing of your personal data (for example via a checkbox or the cookie banner), this consent constitutes the legal basis for the processing (Art. 6(1)(a) GDPR).
Contract performance
Art. 6(1)(b) GDPR is the legal basis for processing personal data for the purposes of initiating or performing a contract concluded with you (for example, processing an application or opening a professional customer account).
Legal obligation
If the processing of your personal data is necessary to comply with our legal and regulatory obligations (in particular the retention of invoicing data or mandatory materiovigilance monitoring related to medical devices), the legal basis will be Art. 6(1)(c) GDPR.
Legitimate interest
We also process personal data for the purposes of safeguarding our legitimate interests (Art. 6(1)(f) GDPR). This includes maintaining the security and functionality of our IT systems, promoting and marketing our own products and services, documenting business contacts, as well as connecting you with our network of authorised distributors to respond to your geographical requests.
Browser data
Cousin Biotech must process certain personal data in order to manage and operate its website and allow you to access our content without hindrance, but also to install certain cookies for optimisation, analysis, marketing and (re)targeting purposes. We do so because we want to ensure that when you visit all or part of our website, your journey is user-friendly and, above all, that you do not encounter technical problems or malfunctions, and also to protect our IT systems from attacks and other unlawful acts.
In general, when you visit our website, we may collect the IP address, the date and time of the request, the time zone, the content of the request, the volume of data, browser information, your country of origin, as well as the operating system as transmitted by your server to our servers.
The legal basis for processing this personal data is our legitimate interest (GDPR – Art. 6(1)(f)), or in some cases, your consent (GDPR – Art. 6(1)(a) and Art. 49(1)(a)).
With regard to the personal data collected and processed as part of web analytics and (re)marketing activities, as well as our use of cookies, please click on the following link: Cookie Information Notice.
Data collected via our web forms
2.1 Contact form
If you wish to contact us, you will use our dedicated form, which will collect the following categories of personal data:
- Your professional and personal identification data, such as your first name, last name, phone number and email address, as well as your company name.
The legal basis applied to the processing of this personal data is our legitimate interest (GDPR – Art. 6(1)(f)).
2.2 Application and recruitment form
Cousin Biotech regularly seeks new employees and, for this purpose, dedicated forms have been set up in the recruitment section of our website.
In order to process and retain your applications, we collect the following categories of personal data: your personal, professional and academic identification data, such as your first name, last name, phone number and email address, your CV as well as your cover letter.
The legal basis applied to the processing of this personal data used for processing applications is the performance of pre-contractual measures (GDPR – Art. 6(1)(b)) and, for building a CV database, legitimate interest (GDPR – Art. 6(1)(f)).
Recipients
Our staff members, who administer, maintain and develop Cousin Biotech’s website, products and services, may have access to your personal data. To this end, we have technical and organisational security measures in place to protect personal data against any unauthorised disclosure to third parties and to ensure that only authorised persons, acting within the scope of their job description, will have access to the data for which they have sufficient authorisation.
In addition, we use the services of external service providers. All third-party suppliers mentioned and the employees of these suppliers may have access to personal data through the service they provide.
Cousin Biotech carefully selects all third-party service providers, requires them to maintain confidentiality, and enters into data processing agreements with them in accordance with GDPR standards. We generally do not transfer your personal data outside the EU and/or the EEA. However, there are a few exceptions to this rule, which include data transfers for web analytics and (re-)marketing activities. For these purposes, we rely on a number of third-party providers as explained in more detail here: Cookie Information Notice.
As part of managing our network and in order to respond effectively to your information or commercial requests, your professional identification and contact data may be shared with our authorised distributors and exclusive business partners responsible for your geographical area.
Retention period for your data
Data collected via the contact form: we only retain your personal data for as long as is reasonably necessary for the purposes pursued and in accordance with legal and regulatory requirements, for a maximum of 2 years from its collection or from the last contact from the prospect.
Data collected via the application form: we only retain your personal data for as long as is reasonably necessary for the purposes pursued and in accordance with legal and regulatory requirements, for a maximum of 2 years from its collection or from the last contact from the candidate.
Security of your personal data
In order to ensure an optimal level of security for the data collected on the website, we implement appropriate technical and organisational measures (encryption technology and security measures to protect and prevent loss, misuse or alteration of the information collected on our website). We take into account the state of the art, implementation costs, and the nature, scope, context and purposes of the processing, as well as the risks to your rights and freedoms.
How can you exercise your rights?
In accordance with the provisions of Law No. 78-17 of 6 January 1978 on data processing, files and freedoms, as well as the General Data Protection Regulation, depending on the legal basis applied to the processing, you have the following rights (see table below):
In order to exercise your applicable rights when browsing our website (right to erasure and right to data portability), please complete the form below:
Select a request type:
- Export my personal data
- Delete my personal data
Your email address is required.
With regard to the exercise of other rights and rights applicable to data collected via our forms, you may exercise them by sending a request by post to the Data Protection Officer (DPO) – Cousin Biotech, Allée des Roses, 59117 Wervicq-Sud – France, providing proof of your identity (by enclosing a copy of your ID card/passport).
Online complaints – CNIL
If you wish to respond to any of the practices described in this policy, you can contact us at the addresses specified in the “Contact us” section.
You may lodge a complaint with the Commission Nationale de l’Informatique et des Libertés – CNIL at the following address:
Commission Nationale de l’Informatique et des Libertés – CNIL
3 place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07
+33 (0)1 53 73 22 22
Online: link
Contact us
For any information and/or complaints regarding this policy, you can contact us at the following addresses:
By email: dpo@cousin-surgery.com
By post: Cousin Biotech, Allée des Roses, 59117 Wervicq-Sud – France
Applicable law and competent jurisdiction
This policy is governed by French law.
Any dispute relating to the interpretation or performance of this policy will be subject to French law and will fall under the exclusive jurisdiction of the courts.
Update of this policy
This policy may be updated at any time without notice of amendment. We recommend that you consult it regularly.