SIERRA Neurovision, hereinafter referred to as the “Organization”, as data controller within the meaning of European Regulation No. 2016-679 of April 27, 2016 and the amended French Data Protection Act (“Informatique et Libertés”) of January 6, 1978 (hereinafter, together, the “Regulations”), is committed to protecting your information as effectively as possible and to complying with applicable European and French regulations. The protection of personal data, at the heart of our concerns, is a key condition of the trust placed in us by our customers and prospects, as well as our partners.

SCOPE

The purpose of this policy is to explain how we use your personal data, in particular via our website sierra-neurovision.com, hereinafter the “website”.

It applies to any processing carried out by SIERRA Neurovision on personal data.

It is intended to inform you, in accordance with the Regulations, about our practices regarding the collection, use and sharing of personal information provided through our website.

This policy applies only to the processing of personal information that may identify, or make identifiable, users of the website, directly or indirectly (hereinafter “personal data”).

COLLECTION OF PERSONAL DATA

• WHAT PERSONAL DATA DO WE PROCESS?

Personal data is information relating to a natural person who can be identified, directly or indirectly.

By using our website, in particular by accepting the installation of cookies or by using our contact forms, you may be required to provide us with personal data such as:

> For our prospecting: last name, first name, telephone number, company, contact email.

• HOW DO WE COLLECT YOUR DATA?

We may collect your data at different times during your relationship with our company, and in particular when you visit our website, which may use cookies or other trackers.

When certain data is essential for us to comply with a legal or regulatory obligation, we will inform you at the time of collection.

PROCESSING OF YOUR DATA

Processing is an operation or set of operations performed using automated or non-automated processes and applied to personal data.

We process your data for lawful and legitimate purposes. This is justified either by your consent, compliance with one or more legal obligations, or our legitimate interest or that of a third party.

The lawfulness of processing is based on several legal grounds. Our processing activities rely on several legal bases, which we detail below:

• Carrying out prospecting activities: This processing is based on your consent. You have been informed of this purpose, you may object at any time, and we do not retain this information for more than 2 years after our last exchange with you.
• Responding to your requests for information and contact submitted via our website: This processing is necessary to communicate with you in response to a request from you.
• Managing our website and carrying out internal technical operations for troubleshooting, data analysis, testing, research, analysis, studies and surveys: This processing is based on our legitimate interest in improving our website’s features and your browsing experience.

RECIPIENTS OF PERSONAL DATA

In the course of our activities, we may use third parties to whom we may grant access to or transmit data, solely for the purposes required to carry out their assignment and in accordance with our agreements with them.

Some of these partners are processors under the GDPR, as they carry out such processing on our behalf. We ensure by contract that they act only on our instructions and implement appropriate technical and organizational measures, so that the personal data processing they perform meets the GDPR requirements and guarantees the protection of your rights, and that they do not use your data for purposes other than those you have been informed of:

• IT services necessary for the proper operation of the website (database management, hosting, storage, maintenance, etc.).
• Hosting services located in France, necessary for storing your data.

Unless expressly stated otherwise, the conditions relating to the personal data processing carried out by these service providers and the rights you have in this regard are the same as those described in this Policy.

In accordance with applicable legislative provisions, your personal data may be disclosed to any administrative or judicial authority authorized by law that requests it.

RETENTION PERIOD

We ensure that your personal data is not retained beyond the period strictly necessary for the purposes pursued as set out in the policy, in accordance with the Regulations and applicable laws. In this regard, the data is retained for 36 months, i.e., 3 years.

In the event of judicial or administrative proceedings, your data will be retained for the period necessary to resolve them.

TRANSFER OUTSIDE THE EUROPEAN UNION

We do not transfer your personal data outside the European Union.

DATA PROTECTION

We ensure that your data is processed in a manner that guarantees an appropriate level of security through the implementation of technical and organizational measures.

YOUR RIGHTS

With regard to the protection of your data, you have rights that allow you to correct, modify or delete it, such as:

• Right of access,
• Right to rectification,
• Right to restriction of processing,
• Right to erasure (except for processing based on a legal obligation or the public interest),
• Right to object (except for processing based on a contract, a legal obligation or vital interests),
• Right to data portability (except for processing based on legitimate interest, a legal obligation, the public interest or vital interests),
• Right to define instructions regarding the retention, erasure and disclosure of personal data after your death,
• Right to lodge a complaint with a supervisory authority (in France, the CNIL) if we are unable to respond adequately to requests.

These rights may be exercised at any time, subject to certain conditions. We will do our best to respond to your request as soon as possible and no later than within 1 month, in accordance with Article 12 of the GDPR.

EXERCISING YOUR RIGHTS

You may exercise your rights by email to or by post to the following address: 21 Grande Rue 31380 Montastruc-la-Conseillère.

To ensure the prompt and correct handling of your requests to exercise your rights, the following information is required: last name, first name, email, postal address, company, telephone number. In certain cases (right of access, right to data portability and rights for heirs), in particular to protect you against identity theft and to verify the validity of your request, you will need to attach a copy of an identity document and provide any information or document useful in support of your request.

Visit cnil.fr for more information about your rights to rectify and delete data: WWW.CNIL.FR

UPDATES TO THE PERSONAL DATA PROTECTION POLICY

Our personal data protection policy may be amended and updated at any time. In the event of a change or update, the revised personal data protection policy will be posted on the website, with the date of the latest update indicated.

COOKIE MANAGEMENT POLICY

When using the website, cookies may be placed on your device by the browser. Cookies make it possible, during their period of validity or storage, to identify your device during subsequent visits.

We use the Axeptio system to manage cookies on our website. This system is recommended by the CNIL and is set by default.

Some cookies are essential for browsing the website securely. Other cookies are used to improve your user experience by offering services or offers corresponding to your interests and to present you with relevant advertisements.

Only the issuer of a cookie is likely to read or modify the information contained in that cookie.

Through browser settings, it is possible at any time, simply and free of charge, to choose whether or not to accept the storage of cookies on a computer, with the exception of cookies necessary for browsing. It is up to you to configure your browser. Each browser’s configuration is different and is generally described in the help menu.

What is a Cookie?

It is a text file placed on a device when visiting the website or viewing an advertisement. A cookie is intended in particular to collect information relating to the User’s browsing on the website and to provide the User with personalized services and content.

Cookie identification

There are different types of Cookies:

• Third-party cookies and first-party cookies: A cookie is referred to as “first-party” or “third-party” depending on the domain from which it originates. First-party cookies are those installed by the website the User is currently visiting. Third-party cookies are cookies installed by a domain other than that of the website the User is currently visiting. When a User visits a website and another entity installs a cookie through that website, that cookie is a third-party cookie.
• Session cookies: They allow website operators to track a User’s actions during a browsing session. The browsing session starts when the User opens the browser window and ends when the User closes that window. Session cookies are temporary. Once the browser is closed, all session cookies are deleted.
• Persistent cookies: They remain on the User’s device after the browser session is closed, for the duration specified by each cookie. They are activated each time the User visits the website that generated them.

Types of cookies used by our company and their purposes

Different types of cookies are used on our website for different purposes. Some are necessary to use the website.

• Strictly necessary technical cookies: These cookies are necessary for the operation of our website. They allow the User to use the main features of our website. Without these cookies, the User cannot use the website normally. These cookies require only that the User be informed in order to be placed on the User’s device and do not allow any behavioral tracking or identification.
• Audience measurement cookies: Audience measurement cookies help establish statistics on visits and use of the various elements making up the website (sections and content visited, user journeys). They enable the publisher to improve the interest and ergonomics of its website.
• Social media sharing cookies: Our company SIERRA Neurovision offers Users features that allow them to share editorial or other content published on the website via social networks. These cookies also allow social networks to target their advertising offers. Social network cookies are managed by the social network publisher. The User is invited to review the social networks’ cookie management policy on the relevant website.

How can you manage cookies?

When you first connect, you are informed that the identified third parties may place cookies via the website. Only the issuer of a cookie is likely to read the information contained in it, and our company has no access to cookies that third parties may use. The issuance and use of cookies by third parties are subject to those third parties’ privacy policies in addition to the provisions of this policy. Consequently, you are invited to visit these third parties’ websites for more information about the cookies they store and how you can manage them.

You can manage the placement of cookies as follows:

• The placement of strictly necessary technical cookies is enabled by default and cannot be disabled by the User, as these cookies are essential for the operation of the website.
• The User may disable or enable the placement of cookies subject to the collection of their consent (audience measurement cookies, advertising cookies, etc.) via the information banner, with the option to make changes whenever they wish. Any deactivation results in the User refusing the placement of the cookies in question.

If you enable the storage of cookies on your device, those integrated into the pages and content you have viewed may be temporarily stored in a dedicated space on your device. They will be readable only by their issuer.

The consent you give is valid for a maximum period of thirteen (13) months from the first placement on your device.

If you disable the storage of cookies on your device or in your browser, or if you delete those stored there, you are informed that your browsing and experience on the website may differ from other users who have enabled cookies (non-personalized content).

This may also be the case when our company or one of our service providers is unable to recognize, for technical compatibility purposes, the type of browser used by the device, the language and display settings, or the country from which the device appears to be connected to the Internet.

Where applicable, our company SIERRA Neurovision declines all liability for consequences related to the degraded operation of our website resulting from your refusal of cookies.

For more information on this subject, please visit the CNIL website: https://www.cnil.fr/fr/site-web-cookies-et-autres-traceurs