Privacy Statement | VSY Biotechnology GmbH

INTRODUCTION

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY.

This Privacy Statement tells you how we use information that we collect about you through this VSY Biotechnology GmbH website operated by VSY Biotechnology GmbH based in Germany as well as any mobile sites, applications ('apps'), widgets, conferences, events , electronic newsletters, communications or other services (collectively the 'Services') that link to this Privacy Statement. This Privacy Statement does not apply to situations where we have notified you that an alternative privacy statement applies, nor does it apply to other VSY Biotechnology GmbH website, including other websites operated by other VSY Biotechnology GmbH.

This Privacy Statement also does not apply to data processing activities specifically relating to current or former VSY Biotechnology GmbH employees or applicants. The relevant Employee Privacy Statement or Applicant Privacy Statement may be requested by contacting career@vsybiotechnology.com, You should review the privacy statement posted on other VSY Biotechnology GmbH websites when you visit them. This website and this Privacy Statement are intended for global audiences. We intend to deal with your information in a manner that is fair and in line with your expectations and encourage you to read and consider the information provided in this Privacy Statement to confirm that is the case.

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

The information we receive, and how we use it, depends on what you do when visiting our website or using our Services. We collect and use non-personal information (information that does not identify you personally) differently to your personal information.

YOUR PERSONAL INFORMATION

first and last name
address, telephone number, e-mail address or other contact information
date of birth or age
qualifications (surgeon, nurses, clinic staff, etc.)
IP (Internet Protocol) address when such address is associated with a specific user

We collect personal information about our users in two ways:

1. when you directly provide information to us, e.g. by entering personal information on certain pages of the website. For example, you may fill out a registration form for a particular service, participate in a survey, or complete a contact form.
2. using automated means, specifically through cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website. For more information about cookie policy, please read below:

COOKIES AND OTHER TOOLS

VSY Biotechnology GmbH and its Providers collect information about you by using cookies, tracking pixels and other technologies (collectively, “Tools”). We use this information to better understand, customize and improve user experience with our websites, services and offerings as well as to manage our advertising. For example, we use web analytics services that leverage these Tools to help us to understand how visitors engage with and navigate our Site, e.g., how and when pages in a site are visited and by how many visitors. We are also able to offer our visitors a more customized, relevant experience on our sites using these Tools by delivering content and functionality based on your preferences and interests. If we have collected your personal data, e.g., through a registration or a request for certain materials, we may associate this personal data with information gathered through the Tools. This allows us to offer increased personalization and functionality on the Site. Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, visit www.aboutcookies.org Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language and Internet browser type and version. We use this information to ensure that the services function properly. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Site, along with the time of the visit and the pages visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Site. We may also derive your approximate location from your IP address. We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Site and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. We may use Flash Local Shared Objects (“Flash LSOs”) and other technologies to, among other things, collect and store information about your use of the Site. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including those used in connection with the Site.

We may use the information that you have shared with us through this website and relevant Services (other than sensitive information, which is discussed separately below) for the following purposes:

to respond to your requests
to provide the services or information you request
to allow you to register certain products or services, or enhance their functionality
to resolve and track the status of any consumer and/or product or service issues
to manage our relationship with you and facilitate any necessary follow up (e.g. by storing relevant information and preferences for a reasonable amount of time)
to enter into, or perform a contract with you (e.g. in case you wish to order products or services from us)
to enable you to participate in our online communities, including social media and blogs
to enable you to participate and join online meetings/webcats in this website
to contact you with information that might be of interest to you – see further the Marketing and Education section below
In other ways to which you consent

VSY Biotechnology GmbH may also use your personal information to the extent necessary to achieve the following legitimate interests, so long as compatible with your rights and expectations of privacy:

for analytical purposes in order to research, develop and improve programs, products, services and content
to anonymize your information by removing any personal identifiers (your name, e-mail address, etc.) so that it may be used for other purposes. In this case, the anonymized information would no longer identify you and may be treated like other non-personal information. For more details please see the relevant section below.
to enforce this Privacy Statement and other rules about your use of this website
to protect our rights or property

VSY Biotechnology GmbH also has legal grounds to use your personal information:

as necessary to protect someone's health, safety or welfare; and
in order to comply with a law or regulation, court order or other legal process

MORE INFORMATION ON OUR PROCESSING ACTIVITIES

This table outlines each website-related processing activity in greater detail and provides information on the categories of information collected for each activity as well as the legal basis of processing for each of these activities, if and to the extent the data processing is subject to GDPR.

Purpose and categories of data	Legal basis	Citation
Responding requests or inquiries We may use the information that you provide to us to take the steps necessary to respond to your request, for instance, you may submit a medical information request, inquire about a product, or subscribe to one of our mailing lists. Depending on your request, w emay ccollect your contact information (such as your name, mailing address, telephone number, job title, your interests and preferences (such as products or areas of interest), and any other information you provide to us. For more information about how collect Personal Data for Medical Information Requests, please refer to our > Privacy Notice for Pharmacovigilance, Medical Information, and Product Complaints.	We collect and process your personal Data for these purposes based on our legitimate interest to respond to your request. If you submitted sensitive Personal Data as part of your inquiry, we will also base such processing on your explicit consent. If reporting is required, w emay process your data to comply with our legal obligations.	Article 6(1)(f) GDPR Articles 6(1)(a) and 9(2)(a) of the GDPR Article 6(1)(c) and Article 9(2)(i) GDPR
Completing transactions Some parts of our website may collect your Personal Data to fulfill services that you have requested and to understand your interests and preferences. In these nstances, w emay collect your contact information as well as a history of your previous transactions with us. (such as order history, Customer account information)	We use this information to perform agreement with you.	Article 6(1)(b)
Personalizing Your Experience We may collect certain information about you, your preferences, and how you have interacted with us in the past in order to understand your interest in our products and services so that we can best serve you. This may include information about your contact and product preferences, languages, marketing preferences, and demographic data.	In cases where we collect this information automatically, we collect and process his information for our legitimate business interests. In other cases, we wll collect and process this information pursuant to your consent.	Article 6(1)(f) GDPR Articles 6(1)(a) of the GDPR
Website Analytics and Tracking Where permitted by law, we may combine Personal Data you provide with other information you’ve provided to VSY Biotechnology GmbH through our websites. Where permitted by law, we may combine Personal Data collected through our websites and online resources with VSY Biotechnology GmbH’s offline records and information provided to us by third parties. More information about this can be found in the section below and in our Cookie Policy	In cases where we collect this information automatically, we collect and process his information for our legitimate business interests. In other cases, we wll collect and process this information pursuant to your consent	Article 6(1)(f) GDPR Articles 6(1)(a) of the GDPR
Tracing and Monitoring Advers Events and Pharmacovigilance Some specified parts of our websitemay collect Personal Data related to adverse events or other activities related to pharmacovigilange. This information is very important for public health and will be used fort he detection, assessment, understanding, and prevention of adverse events or medicine related problems. For more information about how we use and disclose Personal Data for these purposes, please see our > Privacy Notice for Pharmacovigilance, Medical Information, and Product Complaints.	We collect and process your information for these purposes to comply with our legal obligations and may be required to report to data to regulatory authorities.	Article 6(1)(c) and Aritcle 9(2)(i) GDPR
To Run and Maintain our Website We use this information to secure our websites, network systems, and other assets. This may include information concerning your IP Address, geographic location, resources you have accessed, and similar information.	We collect this information automatically, for our legitimate business interests to run, maintain, and secure our websites.	Article 6(1)(f)

WHAT IS SENSITIVE INFORMATION?

Some types of personal information are sensitive information. Sensitive information is personal information revealing or relating to your health (such as your device serial number, or the date of a surgery, implantation, injection), genetic or biometric data, your racial or ethnic origin, religious or philosophical beliefs, sex life or sexual orientation, political opinions or trade union membership.

WILL VSY Biotechnology GmbH TREAT SENSITIVE INFORMATION DIFFERENTLY TO OTHER PERSONAL INFORMATION?

VSY Biotechnology GmbH will only collect and process your sensitive information:

in ways for which you have given your explicit consent
to protect the vital interests of you or another person, in cases where your explicit consent cannot be given or reasonably requested
according to applicable laws which include suitable and specific measures to safeguard your fundamental rights and interests
where the processing is necessary for medical purposes and we are, under the circumstances, under a duty of confidentiality equivalent to the duty of confidentiality of a health professional
to establish, exercise, or defend a legal claim

For example:

We may collect sensitive information directly from you, when you voluntarily provide it to us for a particular purpose (e.g. when you contact us with a question or suggestion about our products and services);
We may also collect sensitive information about patients through healthcare professionals who we work with to provide therapy or technical support for our products or services to you;
We may collect sensitive information as required by the U.S. Food and Drug Administration, European, and other governmental authorities in order to assure safe and effective use of our products and services;
We may collect sensitive information about participants who have explicitly consented to participate in clinical trials, studies, and other research initiatives.

NON-PERSONAL INFORMATION

Non-personal information is information that cannot identify you or be tied to you in any way. Therefore the non-personal information that we collect through this website does not identify you as an individual person, and will not be linked to you. It may include information such as the following:

the type of web browser software you use (for example, Safari or Internet Explorer)
the name of the domain from which you access the Internet
the Internet address of the website from which you linked directly to our website
the date and time you access our website
which pages you have visited on our website
the search terms you use
the links on which you click

If you visit our website to read or download information, such as information about a health condition or about one of our products, we may collect certain non-personal information from your computer. This information is collected from your computer's web browser. If you only read or simply click to download information on our website, we do not collect or learn your name, e-mail address, home address, or any other personal information about you. For more information about how we use cookies to collect information about visitors to our website, please click here.

WHAT DOES VSY Biotechnology GmbH DO WITH NON-PERSONAL INFORMATION?

We are always looking for ways to better serve you and improve our products, services and website experience. We will use non-personal information from you to make this website more useful to visitors. We may also use non-personal information for other business purposes. For example, we may use non-personal information or aggregate non-personal information to:

create reports for internal use to develop programs, products, services or content
adapt or improve the information or services provided
share or sell information to third parties
provide information on how our site is used, such as 'traffic statistics' and 'response rates' to third parties

DIRECT MARKETING AND EDUCATIONAL MATERIALS

VSY Biotechnology GmbH may wish to provide you with educational materials or other information about our products and services, as well as information about clinical trials or the products and services of others that might be of interest to you, based on the information you have shared with us and that we have collected through cookies or similar techniques regarding your use of VSY Biotechnology GmbH websites, social media and blogs. For more information on how we use cookies, and your choices in that regard, please click here. We will ask you to 'opt-in' or affirmatively consent to the use of your personal information for the purposes of such communications, in accordance with applicable laws. If at any time you decide not to receive any educational, commercial or promotional information related to our products and services or regarding the products or services of our affiliates or service providers, please email us at the contact details listed below and mention 'OPT-OUT' in the subject of your email. Alternatively, you may use the opt-out procedure provided in any relevant message you receive from us. Please note that if you opt not to receive promotional messages from us, we may still continue to send you relevant information for other lawful purposes, such as to administer any account you may have with us, to respond to your requests, to execute agreements with you, or to provide you with information that VSY Biotechnology GmbH is required by law to provide, e.g. regarding product recalls.

SURVEYS

From time to time, we may invite you to participate in a survey to determine customer satisfaction levels, identify areas of potential improvement or to carry out market research. We may send you a specific invite to participate in such a survey on the basis of our legitimate interests in conducting the survey, or on the basis of your prior “opt-in” consent to receive such communications, in accordance with applicable laws. You may opt-out of receiving any such future communications in the manner detailed in the section above. The personal data that is collected for the purpose of the survey may include your email address, phone number, survey results, and any free-text message you may have written in the survey. We process your personal information as part of the survey for carefully considered and specific business purposes which are in our legitimate interests and which we believe also often benefit you, based on our assessment that our legitimate interests do not override your freedom and data protection rights.

The business purpose of collecting your data is to reply to survey feedback you may have provided, specifically:

Should you have indicated an issue which we need to take action to resolve
In order to gain further insight to the experience you have described
To inform you of any action we might take internally to resolve your issue or enhance your experience

DOES VSY Biotechnology GmbH EVER SHARE PERSONAL INFORMATION WITH THIRD PARTIES?

VSY Biotechnology GmbH will not share your personal information with a third-party except as described in this Privacy Statement. In the ordinary course of business, we may share some personal information with VSY Biotechnology GmbH affiliates or third party companies that we hire to perform services or functions on our behalf.

For example, we may:

use a service provider to administer certain newsletter or informational mailings that you have signed up for, and provide access to your email address for this purpose.
uuse a third-party application or platform to allow us to manage and keep track of our communications with you.
uuse a third-party application or platform like Zoom or Microsoft Teams or any custom live streaming platform to conduct live video training events (webcast) to manage and keep track of our communications with you.
uuse our company affiliates to provide services relating to your personal information e.g. we may store your information on a secure server based at our affiliate’s site in Europe or the United States. For more information on the circumstances in which we may transfer your information to other countries, please see the relevant section below.
uuse a third-party application or platform to conduct surveys, which can include storage of the survey feedback.

In all cases we will not share more information than is necessary, and we will not authorize any third parties to keep, disclose or use your information except to provide the requested services in line with the purposes set out above. Please note that subject to applicable laws, we may disclose your personal information if we believe we are required to do so to comply with any law, regulation, court order, legal or government request. In the unlikely event that all or part of our business is acquired by a third party, your information may be transferred to the new corporate owner insofar as relevant to the business in question and subject to appropriate safeguards being in place.

In addition, we may use and disclose your personal information to third parties if necessary to:

enforce this Privacy Statement and the other rules about your use of this website
protect our rights or property
protect someone's health, safety or welfare
comply with a law or regulation, court order or other legal process
investigate or take action in cases of suspected fraud or illegal activities

In addition, please keep in mind that certain areas of our website may be interactive in nature, and allow you to post information that other users can see. If you do not wish to have information viewed publicly, please do not use those sections of the website.

DO WE TRANSFER PERSONAL INFORMATION TO OTHER COUNTRIES?

In certain cases VSY Biotechnology GmbH may transmit personal information collected on this website to our affiliates or third party service providers in other countries, but only in furtherance of the purposes set out in this Privacy Statement. In cases where personal information is transmitted from Europe to other countries we will ensure that safeguards equivalent to those provided by European data protection laws are in place. For more information on the safeguards implemented by VSY Biotechnology GmbH please contact dataprivacy@vsybiotechnology.com.

HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION FOR?

We will only keep your personal information for so long as necessary to fulfill the purposes for which we are allowed to use them, as set out in this Privacy Statement. For example, if you tell us that you no longer wish to receive a newsletter from us, we will immediately delete your email address from our mailing list. In case you participate in a program via our website we will delete the personal information provided as part of that program within a reasonable time after its completion (e.g. six months after completion will normally be considered reasonable unless we have lawful grounds to retain some of the information for longer (e.g. if necessary for validation or to comply with recordkeeping obligations)).

WHAT HAPPENS IF THE PRIVACY STATEMENT CHANGES?

This Privacy Statement was created on 23 August, 2021. We may change this Privacy Statement at any time and for any reason. If we decide to make a significant change to our Privacy Statement, we will post a notice on the homepage of our website for a period of time after the change is made. We encourage you to review this Privacy Statement each time you visit the website.

WHAT ABOUT PRIVACY ON OTHER WEBSITES?

This website may contain links to other websites. Some of those websites may be operated by VSY Biotechnology GmbH and its affiliates, and some may be operated by third parties. This Privacy Statement does not apply to other websites, even other VSY Biotechnology GmbH websites. Therefore whenever you leave this website we recommend that you review the privacy practices that apply to information you provide on other websites. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others. Neither are we are responsible for websites operated by third parties or your business dealings with them.

ARE THERE SPECIAL RULES ABOUT CHILDREN'S PRIVACY?

We care about protecting the online privacy of children. We will not intentionally collect any personal information (such as a child's name or e-mail address) from children under the age of 16 without the consent of someone holding parental responsibility. If you think that we have otherwise collected personal information from someone under the age of 16, please Contact Us.

WHAT ABOUT WEBSITE SECURITY?

Security is very important to us. We also understand that security is important to you. We use industry standard measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However no website or email transmission is 100% secure and we encourage you to therefore take special care in deciding what information you send or request via email, and take appropriate precautions such as keeping any usernames and passwords you use confidential.

YOUR RIGHTS

At any time, you may exercise your right to access, rectify and, as the case may be, erase, any personal information relating to you, or restrict the processing of your personal information, in compliance with applicable laws. You also have the right at any time to object, based on your particular situation, to any use or processing of your personal information which we have based on our legitimate interests. In case we are processing your personal information in an automated manner as part of a service to you or based on your consent then you also have the right to request a copy of your information in a structured, commonly used and machine-readable format (known as the right to “data portability”). Such requests can be sent to dataprivacy@vsybiotechnology.com or in writing to

VSY Biotechnology GmbH Esslingerst.
7 70771 Leinfelden-Echterdingen, Germany
Phone: +49 711-997606-333
E-Mail: contact@vsybiotechnology.com

Please note that we may ask you to provide proof of identity (such as a copy of your ID card or passport) before we can comply with your request. If we have based our collection or use of your personal information on your consent then you also have the right to withdraw your consent at any time in the same way as it was given, or by sending a request in the above manner. You may also at any time, free of charge and without having to provide any justification, opt-out of any direct marketing campaigns and request to no longer receive any promotional material as described above. Our Data Protection Officer may be contacted by email at dataprivacy@vsybiotechnology.com In case you are not satisfied with our handling of your request you may contact the applicable Data Protection Authority. See further: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html

HOW TO CONTACT VSY Biotechnology GmbH

If you have questions or comments about this Privacy Statement, please Contact Us through our website or via the contact details listed in the Your Rights section above.

Management & Deletion of Cookies and Withdrawal of Consent

When you visit our websites, a banner appears on our websites informing you about the use of Cookies. By clicking the Close (X) button, you agree to the use of Cookies on our websites.

You can withdraw your consent at any time by changing your browser settings, disabling the Cookie setting and deleting the previously set Cookies.
In case of withdrawal of consent regarding Third Party Cookies, please contact the respective Cookie provider.
Most browsers automatically accept the use of Cookies. You can use your browser settings to manage the use of cookies. If you do not want cookies to be automatically stored on your device, you can change your browser settings accordingly and disable the Cookie setting. You can also choose when you want to be informed about this use while using the website Cookies in your browser settings. For details on how to change your browser settings, please refer to your browser's instructions or help functions:
Please noted that you can visit and use our website after you disableCookies by changing your browser settings. In addition to this undercertain circumstances, disabling Cookies may mean that you can nolonger fully use the functions of our website.

Nonliability

We may make changes to this Cookie and Tracking Tool Policy from time to time. Changes may also be made to the terms of use of our websites regarding Cookies. We reserve the right to change the content of this policy at any time and without notice. New policies will apply when they are published. If you do not accept our policies, you should always change your preferences in your browser settings. By continuing to access our Websites or use our services after the changes take effect, you agree to be bound by the amended Cookie and Tracking Tool Policy. You can check this site for the latest version. If you share your device with other people, you must ensure that they are adequately informed and able to exercise their rights.