Declaration of GDPR Conformity
The following text is aimed at website visitors, job applicants, customers, suppliers, distributors, receivers of newsletters and patients treated by ROBERT®.
Data controller and contact:
Life Science Robotics ApS, Sofiendalsvej 83, 9200 Aalborg SV, CVR-no. 36394390 is responsible for the processing of your personal data (hereinafter referred to as “we” or “us”).
If you have any questions about the processing or wish to exercise your rights, as described below, please contact us at info@lifescience-robotics.com or at the telephone number +45 2242 0139.
Processing activities:
Below you can see what personal data we process and for what purposes. You can also see the legal basis on which we base the processing as well as when the data is deleted.
This page is used to inform website visitors regarding our policies with the collection, use, and disclosure of Personal Information if anyone decided to use our Service, the Life Science Robotics website.
If you choose to use our Service, then you agree to the collection and use of information in relation with this policy. The Personal Information that we collect are used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy.
The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at www.lifescience-robotics.com, unless otherwise defined in this Privacy Policy.
Information Collection and Use
For a better experience while using our Service, we may require you to provide us with certain personally identifiable information, including but not limited to your name, phone number, and postal address. The information that we collect will be used to contact or identify you.
Log Data
We want to inform you that whenever you visit our Service, we collect information that your browser sends to us that is called Log Data. This Log Data may include information such as your computer’s Internet Protocol (“IP”) ad-dress, browser version, pages of our Service that you visit, the time and date of your visit, the time spent on those pages, and other statistics.
Cookies
Cookies are files with small amount of data that is commonly used an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your computer’s hard drive.
Our website uses these “cookies” to collection information and to improve our Service. You have the option to either accept or refuse these cookies, and know when a cookie is being sent to your computer. If you choose to refuse our cookies, you may not be able to use some portions of our Service.
Security
We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.
Links to Other Sites
Our Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Children’s Privacy
Our Services do not address anyone under the age of 13. We do not knowingly collect personal identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. Thus, we advise you to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately, after they are posted on this page.
Categories of personal data
Identification and contact information, general information in CV and job application, criminal record (on employees responsible for trusted funds)
Basis for treatment
Criminal records are obtained on candidates for positions in which trusted funds must be handled (e.g., financial controller), cf. Section 8 (3) of the Data Protection Act. Criminal records are not obtained until the final stages of the application round, when a maximum of 3 candidates remain.
Other information is processed based on our legitimate interests, including the reason that the applicant has chosen to apply for the job, cf. GDPR Article 6(1)(f).
Deletion deadline
Unsolicited job applications will be deleted after reading if the candidate is not relevant to a current or imminent position within the next 3 months unless consent is obtained for longer retention. Invited applications will be deleted after the recruitment round has been completed unless the candidate is relevant to a current or imminent position within the next 3 months or unless consent to longer retention is obtained.
Recipients and, where appropriate, transfers to third countries
Data controller: We do not disclose your personal data to other data controllers.
Data processors: In connection with the use of Jobindex and their function, where we can access the job-seeking candidate’s CV and application material, Jobindex acts as a data processor for us. In addition, we use Dropbox for general storage of documents, emails, etc.
There is no transfer of personal data to third countries.
Categories of personal data
Contact information and payment information (only in case of sole proprietorships and small partnerships)
Basis for treatment
The processing will be based on GDPR Article 6 (1)(f) because it is our legitimate interest to be able to contact customers and suppliers or, in so far as they are sole proprietorships or smaller I/Ss, the processing is based on Article 6 (1)(b) to the extent that it is necessary to conclude or fulfil a contract with them.
Deletion deadline
According to the EU Medical Device Regulation, information on suppliers, distributors, etc. must be kept at least 5 years after the end of the business relationship.
In addition, personal data is stored until 3 years after the end of the business relationship, unless longer storage is necessary, for example, according to the rules of the Danish Bookkeeping Act (5 years of storage of accounting material), or if the information is necessary for a claim or in connection with a service agreement that goes beyond the 3 years.
Recipients and, where appropriate, transfers to third countries
Data controller: We pass on information to Tüv Süd AG, Westendstraße 199, D-80686 Munich about our suppliers, distributors, etc. and their contact persons for the purpose of risk management of suppliers, distributors, etc., in accordance with the requirements for the CE marking referred to in Article11(1) of Directive 91/414/EEC. EU Regulation on Medical Devices.
Data processors: We use Dropbox for general storage of documents, emails, etc.
There is no transfer of personal data to third countries.
Categories of personal data
Regarding website visitors, we process identification information, including IP address.
Regarding newsletter recipients, we process contact information.
Basis for treatment
Information about website visitors is processed according to Article 6 (1)(f) because it is our legitimate interest to market our business, and the information is not sufficiently intrusive for consent to be necessary. Consent to cookies etc. follows the applicable rules in the Cookie Regulations.
The processing of information for newsletters is done because it is necessary to comply with the agreement to send the newsletters in question in accordance with Article 6 (1)(b).
Deletion deadline
Information necessary for newsletters is stored until consent is withdrawn or consent has not been used for one consecutive year. To defend ourselves against any claims made for violation of the Marketing Act, cf. Section 37(3) of the Danish Penal Code and Section 93(1)(1) of the Penal Code we keep evidence that you have withdrawn your consent for up to 2 years after the consent has been withdrawn.
Personal data contained in cookies is deleted when the cookies expire or is deleted by the user (see our cookie policy https://www.lifescience-robotics.com/privacy-policy/).
We use Google Analytics 4, and user and event-level data are anonymized according to the strictest possible settings (https://support.google.com/analytics/answer/7667196?hl=en), i.e. currently 2 months.
Recipients and, where appropriate, transfers to third countries
Data controller: We do not disclose your personal data to other data controllers.
Data processors: We use Dropbox for general storage of documents, emails, and so on, including the newsletter email list. In addition, Google Analytics is used to measure traffic on the website, in which context Google Ireland Ltd. act as our data processor.
There is no transfer of personal data to third countries.
Categories of personal data
Unique ID, name (one-way encrypted by state-of-the-art encryption methods), date of birth, medical condition relevant for ROBERT® (on a superficial level, i. e. “stroke”) and how severe the condition is.
Basis for treatment
UID, name (encrypted to be able to enrich data on the same patient), training data and age are processed in order to document the effectiveness and clinical effect of ROBERT® in accordance with the requirements of the EU Medical Device Regulation, see GDPR Article 6(1)(c) and because it is our legitimate interest to conduct meaningful analysis of how our product works, see Article 6(1)(f). The interests of the data subject do not outweigh our interests since the data subject cannot be identified directly.
Information on the patient’s condition, including the severity hereof, is only processed subject to the patient’s explicit consent which the clinician obtains, through functions implemented in ROBERT® software, in accordance with GDPR Article 9(2)(a) and because it is a requirement indirectly set out in the EU Medical Device Regulation, see Article 6(1)(c) and because it is on our legitimate interest to document this and to improve the products , see Article 6(1)(f).
Deletion deadline
Information gathered through the ROBERT® data module is stored in up to five years to adhere to the requirements in the EU Medical Device Regulation which requires manufacturers of medical devices to prove a clinical effect of their devices.
Other than that, all data stored in the module itself that is older than 6 months is automatically deleted. When ROBERT® is detached and installed anew, all existing data in the module is also deleted.
Recipients and, where appropriate, transfers to third countries
Data controllers: No transfer to other data controllers
Data processors: We use Dropbox to store documents, e-mails, etc. which include training data from ROBERT®.
No transfer of personal data to third countries takes place.
Your rights: You have the following rights, which you can exercise by contacting us via the contact information above. Your request will be answered free of charge, as soon as possible and no later than one month after receival, but up to two months if necessary because of the complexity or number of the request. In the case of unfounded or excessive requests, we have the right to reject it or to charge a reasonable fee to respond to it.
Insight: You have the right to gain access to the personal data that we process about you, as well as additional information about how the processing is carried out. For your sake, no insight information can be requested that could give away information to public or private interests.
Corrigendum: You have the right to have incorrect personal data corrected or to have incomplete personal data about you completed.
Delete: You have the right to have information about you deleted in the circumstances set out in Article 17 of the GDPR. For instance, if the information is no longer necessary for the fulfilment of our obligations and rights, or if the information is processed based on your consent, which is withdrawn.
Constraint: In the circumstances referred to in GDPR Article 18, you have the right to have the processing of your personal data restricted , e.g. if the accuracy of the data is disputed, in the period until we have had the opportunity to establish whether the personal data is correct or if we no longer need the personal data for the processing, but the date is necessary in order to establish, enforce or defend out legal claims.
Objections: You have the right to object to the processing of personal data that we process based on Article 6(1)(f) (the balancing rule) and always if the processing is for direct marketing purposes.
Data portability: If the processing is based on your consent or contract, you have the right to receive the information in a common and readable format and to transmit the information to another data controller. We transmit the information directly to this controller if you wish and if is technically possible.
Automatic decisions: You have the right not to be the subject of an automatic decision that has legal effect or similarly and significantly affecting you, which is based solely on automatic processing, including profiling.
Right of appeal: Any time you can complain about the processing by contacting us. In addition, you can always complain to the Danish Data Protection Agency (http://datatilsynet.dk, dt@datatilsynet.dk, +45 33 19 32 00), or to the supervision in the country where you reside or in the country where you believe the breach of the GDPR or the Data Protection Act has taken place.
Sofiendalsvej 83
DK-9200 Aalborg SV
This project has received funding from the European Union’s Horizon 2020 research and innovation programme under grant agreement No 779966
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