Personal data protection is fundamental, which is why we hereby wish to inform you in detail of the data that we collect when you visit our Site, when you register your medical device in the GUARANTEE section or when you participate in our blog “The Spengler Institute” and how we use and process this data for the purposes defined below. We would also like to inform you of the protective measures that we have taken on a technical and organisational level to ensure a level of protection in accordance with our legal obligations.
In accordance with the General Data Protection Regulation adopted by the European Parliament on 14 April 2016, and the French Law on Information Technology, Data Files and Civil Liberties of 6 January 1978 as amended, SPENGLER would like to inform you of the following points:
- Identity of the data controller
The data controller is the company SPENGLERSAS, with its registered office at 30 rue Jean de Guiramand 13290 AIX EN PROVENCE (hereinafter “SPENGLER”).
The Data Protection Officer appointed by SPENGLER is: LACHAUX, NICOLAS, firstname.lastname@example.org.
- Purposes of processing AND LEGAL BASIS
SPENGLER collects your personal data through the Site for two main purposes:
- To register a SPENGLER medical device for warranty purposes in order to track your medical device and meet our traceability obligations. In this case, the processing is based on the execution of the purchase agreement of the medical device as well as on compliance with our legal obligations.
- If you wish to become a member of the SPENGLER Institute in order to receive the newsletter, participate in debates on various medical topics and R&D questions, test medical device prototypes and respond to one or two surveys on a specific subject per year. In this case, the processing of your data is based on your express and specific consent (check box), which you can withdraw at any time.
In addition, SPENGLER is likely to process your personal data:
– for the purpose of providing you with the information or services you have requested (in particular: sending the Newsletter, solicitation for product tests, questionnaires);
– for the purpose of collecting information allowing us to improve our Site, our products and services (in particular by means of cookies);
– in order to be able to contact you about various events relating to the medical device that you have registered via the form on our Site.
In these three scenarios, the processing of your data is based on your express and specific consent (check box), which you can withdraw at any time.
- Categories of data collected
For the registration of the medical device under warranty, the categories of data collected are: Surname, first name, email address, city, profession, medical device as well as its LOT number and serial number.
In this scenario, the medical device can be entered either by the health professional or by the patient him/herself.
For registration with the SPENGLER Institute, the categories of data collected are: Surname, first name, email address, city and specialisation of the health professional.
Your Personal Information is sent to:
– SPENGLER (Marketing Department and Quality and Regulatory Department)
– the IT service provider who, as a subcontractor, hosts the Site data.
SPENGLER undertakes to never sell your personal data to third parties.
- Retention period
Your personal data is kept by SPENGLER only for the time necessary to complete the purpose it was collected for, i.e.:
- With regard to data collected as part of the warranty of our medical devices: 10 years as per our legal obligations,
- With regard to data collected as part of your membership of the SPENGLER Institute: for the duration of your SPENGLER Institute membership, subject to the withdrawal of your consent,
- With regard to data collected to allow us to send you our newsletter or information relating to our products:
- If you are one of our customers, your Data used for commercial prospecting purposes will be kept for a maximum period of three (3) years from the end of our commercial relationship.
- If you are one of our prospects, not yet a customer, your Data will be kept for a period of three (3) years from its collection or from the date of last contact from you.
- At the end of this three (3) year period, we will contact you again to find out if you wish to continue to receive commercial solicitations. In the absence of a positive response from you, we undertake to delete or archive your Data.
- With regard to data collected via Cookies: 13 months from your acceptance (Banner), subject to the withdrawal of your consent.
- Computing Rights and Freedom of Information
You have the following rights with regard to the processing of your data:
- The right of access,
- The right of rectification,
- The right of limitation,
- The right of deletion,
- The right to object,
- The right to portability,
- The right to withdraw consent to processing based on this legal basis.
- The right to formulate post-mortem directives.
- The right to complain to the competent supervisory authority (in France, the CNIL: https://www.cnil.fr/fr/plaintes or by email to or by post by writing to: CNIL – 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07.).
These rights can be exercised by sending us your request:
- Either by email to the following address: contact[@]spengler.fr;
- or by post to the following address: SPENGLER SAS30 rue Jean de Guiramand 13290 AIX EN PROVENCE
To access your request, we will need to confirm your identity.
We may therefore request a photocopy of one of your identity documents bearing your signature.
Please provide an address to which the reply should be sent.
We will endeavour to send you a response within one (1) month of the date of receipt of your request. This period may be extended by two (2) additional months given the complexity and number of requests.
Security is our key concern.
We therefore use the appropriate technical and organisational measures, and in particular physical, material and software measures, to preserve the security, integrity and confidentiality of your personal data, and to protect it against any access, use, misappropriation, modification, alteration, disclosure or destruction by unauthorised persons.
SPENGLER stores your personal data on servers located in the European Union.
“Cookies” (or connection trackers) are small text files of limited size which allow us to recognise your computer, tablet or mobile in order to personalise the services we offer you.
To better inform you about the information that cookies identify, you will find a table below listing the different types of cookies that may be used on the Website, their name, their purpose and their retention period:
|Sendinblue Cookies||Allow the automation of marketing actions, content and form publication.|
Google Analytics Cookies
|Allow statistics on how often you access and use various elements of the website (such as the content/pages you have visited) to be established. This data helps us improve the ergonomics of the SPENGLER website.|
|Duration||Maximum duration of 13 months, subject to the withdrawal of your consent.|
Each Internet browser offers its own cookie management settings. To find out how to change your cookie preferences, you will find links below to the help menu you need to access your browser menu provided for this purpose:
For more information on tools for controlling cookies, go to the CNIL website: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.