GLOBAL PERSONAL DATA PRIVACY POLICY OF LA COOPÉRATIVE WELCOOP AND ITS AFFILIATES

We are LA COOPÉRATIVE WELCOOP and any of its affiliates or subsidiaries directly or indirectly controlled by LA COOPÉRATIVE WELCOOP (collectively, “LA COOPÉRATIVE WELCOOP“, “we“, “us” or “our“).

The subsidiary or affiliate of LA COOPÉRATIVE WELCOOP with which you, your employer, your Healthcare Provider, or your patient interacts, or which owns and operates the product or service is, where applicable, the entity responsible for the collection and use of your Personal Data (known as the “Data Processor“). You can find a list of all LA COOPÉRATIVE WELCOOP entities and their contact details by referring to Appendix 1 of this Policy (the “Policy”).

In the Policy, we refer to you as “you” or “your“. We use the term “Processing” or “Use” when we refer to any operation or set of operations carried out or not using automated processes and applied to your data or sets of personal data, such as collecting, recording, organizing, structuring, storage, adaptation or modification, retrieval, consultation, use, communication by transmission, dissemination or otherwise making available, alignment or combination, limitation, erasure or destruction or any other Use of your Personal Data.

1. DATA TRANSFER BETWEEN COMPANIES OF LA COOPÉRATIVE WELCOOP GROUP

The entity responsible for collecting and using your Personal Data, i.e. the Data Controller, may share your Personal Data with other companies in LA COOPÉRATIVE WELCOOP group. This sharing is carried out on the basis of the Data Controller’s legitimate interest in offering you products and/or services which, in view of your status, profession and activities, may be of interest to you. You may object to the sharing of your Personal Data at any time by contacting directly LA COOPÉRATIVE WELCOOP group company concerned by referring to Appendix 1 of this Policy. You may also object to receiving communications from companies in LA COOPÉRATIVE WELCOOP group that are recipients of your Personal Data by contacting the companies from which you received the communication by referring to Appendix 1 of this Policy for the relevant contact details.

Also, please note that your Personal Data may be shared by the entity responsible for its collection and use with the parent company of LA COOPÉRATIVE WELCOOP group (the entity that directly or indirectly holds more than half of the capital of the other entities) for the purpose of consolidating all the data of LA COOPÉRATIVE WELCOOP group. This processing by the parent company of LA COOPÉRATIVE WELCOOP group is based on the legitimate interest of the parent company of LA COOPÉRATIVE WELCOOP group in consolidating all the data of the companies in its group.

For transfers of personal data between its group companies, LA COOPÉRATIVE WELCOOP has adopted an intra-group agreement relating to the processing and transfer of personal data (to which all LA COOPERATIVE WELCOOP entities are party) to ensure that this global exchange of personal data complies with data protection laws and in which LA COOPÉRATIVE WELCOOP relies on the Standard Contractual Clauses approved by the European Commission as the relevant transfer mechanism for transfers of personal data outside the EEA.

HOW DOES THIS POLICY APPLY TO YOU?

This Policy is a global document. It describes how LA COOPÉRATIVE WELCOOP may use information about you (“Personal Information”):

that we collect or process online (through websites, applications, e-mails and the like) (the “Online Services”);
when we process your Personal Data for your possible participation as a research subject in clinical trials or consumer tests;
when we process Personal Data for your possible participation in clinical trials as an investigator or member of the investigator’s team;
when we process medical data and in connection with pharmacovigilance, materiolovigilance, cosmetovigilance and adverse events, complaints and reports;
when we provide products or services to you or your pharmacist, physician, hospital, EPHAD or any other healthcare provider (collectively, “Healthcare Providers“, which refers to the Healthcare Provider’s establishment, organization, or business, and to individuals employed by or working for or with that organization), or your patients;
and in other situations where you interact with us, including but not limited to using or consulting our sites and visiting our offices or events (e.g. trade shows and conferences) (such products, services, Online Services, and other systems being collectively referred to as “Products and Services“);
when we process your data as an employee of a company for which we provide Products or services;
or wherever the Policy is published or referenced;
also applies to Personal Data collected or processed when you interact with us in person, by telephone, mail, e-mail, or fax.

The Policy therefore applies whether you are:

a patient or user of our products and services;
a member of the public;
a visitor;
a member of a regulatory body or authority;
a healthcare provider customer,
a business partner (a person, group, community, organization, or entity with whom LA COOPÉRATIVE WELCOOP associates or allies itself to carry out a common action in a business, undertaking, negotiation or project) such as but not limited to: (i) a cooperator, shareholder, or investor, (ii) a non-healthcare provider customer, (iii) a supplier, distributor, retailer, consultant, or service provider;
a job or internship applicant; or
any other person with whom we have a relationship or who is involved in our business activities.

In some cases, we may Use your Personal Information in ways that are not described in this Policy. LA COOPÉRATIVE WELCOOP may therefore have separate privacy policies that apply to particular situations, including informed consent forms. To the extent that you have received another privacy policy or notice, and those policies or notices apply, those policies or notices will govern our interactions with you and take precedence over this Policy.

If you provide us with the Personal Data of someone other than yourself (such as a patient or family member), please note that you are responsible for complying with all applicable privacy and data protection laws before providing such information to LA COOPÉRATIVE WELCOOP (including obtaining the consent of the person concerned, if applicable).

When we use your Personal Data in the course of our business, we do so in compliance with applicable data protection laws, including regulatory and national law requirements that may apply to such Use.

Finally, this Policy also informs you of your privacy rights, the measures and processes we put in place to protect your data and more generally about your right to privacy.

OUR COMMITMENT AND PRINCIPLES

At LA COOPÉRATIVE WELCOOP, your privacy is very important to us. For us, the confidentiality of Personal Data goes beyond simple compliance with law. LA COOPÉRATIVE WELCOOP strives to collect, use, and share the data we obtain about you in a manner consistent with our corporate values. In particular, we do so according to high ethical standards, with integrity, inclusiveness, fairness, and transparency. We strive to base our privacy practices on recognized principles of privacy and data protection in all our activities. These principles include:

Transparency: be transparent about privacy practices, policies, and developments, as well as details of any processing carried out; specify the purposes for which Personal Data is collected and processed before collection begins.
Fair processing: obtaining Personal Data in good faith by legitimate, lawful, and fair means, and processing Personal Data only in accordance with the purposes for which it was collected.
Privacy by design: ensuring that we create solutions and process data with privacy at the forefront and in accordance with these principles.
Responsibility: to be responsible for compliance with the measures that implement these principles, in particular by ensuring the responsibility of third parties with whom we collaborate through appropriate contracts.
Respecting the requests of the people concerned: being responsive to people’s rights to privacy granted by law.
Protection: protect Personal Data by using reasonable security measures to ensure data accuracy and limit use to what is necessary for the purpose of processing.

USE OF YOUR PERSONAL DATA

Firstly, it is necessary to remember that “Personal Data” refers to any information, as recorded in electronic or other format, that can be used to identify a person or that we can link directly to a person, such as name, postal address, e-mail address, telephone number or credit card number, where applicable. Personal Data may include information that indirectly identifies the individual, such as a unique number assigned to the patient by a Healthcare Provider or a participant in a clinical trial, even in the absence of other identifying data. Personal Data may include information considered sensitive, such as biometric data, genetic data, medical records or health data, financial account information, geolocation, ethnic or racial origin, information about your sex life or sexual orientation, and other information. Please note that for patients, and as described below, we may receive information about you from your Healthcare Provider or others, where permitted by law.

The tables below show:

the categories of Personal Data we use for each purpose;
for what purposes we process your Personal Data;
the legal basis (in accordance with applicable regulations) on which we process your Personal Data.

Here is a general explanation of each legal basis to help you understand the tables:

Performance of a contract: where it is necessary for LA COOPÉRATIVE WELCOOP (or a third party) to process your Personal Data in order to fulfil obligations arising from a contract entered into with you; or to verify information prior to entering into a new contract with you.
Legitimate Interest: where LA COOPÉRATIVE WELCOOP or a third party has an interest in using your Personal Data in a certain way, after balancing our interests against your interests or fundamental rights and freedoms by incorporating your reasonable expectations.
Consent: when LA COOPÉRATIVE WELCOOP asks you to actively indicate your agreement regarding the use of your Personal Data by LA COOPÉRATIVE WELCOOP for a certain purpose.
Compliance with legal obligations: when LA COOPÉRATIVE WELCOOP must process your Personal Data to comply with a law.
Public interest: this is the basis for processing that is necessary for the performance of a mission in the public interest, or a mission involving the exercise of public authority for which the data controller is responsible. It is mainly used by public authorities.
Safeguarding vital interests: its use is limited to certain data processing activities. It is mainly used by healthcare establishments. This is the case, for example, when a hospital processes the data of a patient requiring emergency care. If the patient is unconscious, he or she cannot consent to the processing of his or her data. However, this processing is necessary for the patient’s care. The hospital must treat the patient and act quickly to save his or her life. However, the hospital still processes the patient’s data, without the patient’s consent, so that a file can be created, and the patient can be treated.

Users of the Online Services, users of our Web sites, visitors to our facilities and enquirers We may process your Personal Data when you: (1) consult our websites or visit our facilities; (2) submit requests to us both online (e.g. by e-mail) and offline (e.g. by post); (3) subscribe to our newsletters or other information or marketing materials; and/or (4) you register, view, or use our online Products and services.
What data do we process?	Where do we obtain your Data?	Why do we process your Data?	On what legal basis do we process your Data?	Who receives or may receive your Data?	How long do we keep your Data?
Identity-related data, such as: first and last name e-mail address postal address phone number username and password Other data relating to identity and personal life, such as: age genre family situation disability if necessary date of birth Visual and audio information, such as: photos video (including video-surveillance) recordings of your calls to our customer service representatives Technical data, such as: Internet Protocol (IP) addresses (which can identify your general geographic location or your company) browser type and language device type advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Device Identifier (AAID)) date and time you use our products and services URLs or uniform resource locators (i.e., addresses of websites) consulted before and after our products and services activity on our Products and Services and reference websites or applications data collected from cookies or other similar technologies**. location data Anonymized/de-identified data* Anonymized data is data in which your individual personal characteristics have been removed so that you are not identifiable, and the information is no longer considered Personal Data under data protection laws.	you directly your devices our security systems (including video surveillance) third party	to provide you with our products and services to contact you (regarding your inquiry) to manage our relationship with your organization to send you updates to identify and authenticate yourself to personalize your content to detect security incidents to protect us against malicious or illegal activities to ensure the proper use of our products and services to improve our products and services for short-term transitional use for administrative purposes for marketing (including sales prospecting), internal research and development purposes for quality assurance purposes and to help train and develop our agents	for our legitimate interests in preparation for or performance of a contract with you if we have requested and received your consent; to meet a legal obligation to which we are bound*.	LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies partners who help us provide the Products or services or improve our marketing activities (including sales prospecting) or management**.	For the duration of the relationship between you and us, and 5 years from the end of the relationship. Your data may be kept for a longer period of time for evidential purposes in the event of litigation.

Users of the Online Services, users of our Web sites, visitors to our facilities and enquirers

We may process your Personal Data when you:

(1) consult our websites or visit our facilities;

(2) submit requests to us both online (e.g. by e-mail) and offline (e.g. by post);

(3) subscribe to our newsletters or other information or marketing materials; and/or

(4) you register, view, or use our online Products and services.

What data do we process?

Where do we obtain your Data?

Why do we process your Data?

On what legal basis do we process your Data?

Who receives or may receive your Data?

How long do we keep your Data?

Identity-related data, such as:

first and last name
e-mail address
postal address
phone number
username and password

Other data relating to identity and personal life, such as:

age
genre
family situation
disability if necessary
date of birth

Visual and audio information, such as:

photos
video (including video-surveillance)
recordings of your calls to our customer service representatives

Technical data, such as:

Internet Protocol (IP) addresses (which can identify your general geographic location or your company)
browser type and language
device type
advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Device Identifier (AAID))
date and time you use our products and services
URLs or uniform resource locators (i.e., addresses of
websites) consulted before and after our products and services
activity on our Products and Services and reference websites or applications
data collected from cookies or other similar technologies***.
location data

Anonymized/de-identified data

Anonymized data is data in which your individual personal characteristics have been removed so that you are not identifiable, and the information is no longer considered Personal Data under data protection laws.

you directly
your devices
our security systems (including video surveillance)
third party

to provide you with our products and services
to contact you (regarding your inquiry)
to manage our relationship with your organization
to send you updates
to identify and authenticate yourself
to personalize your content
to detect security incidents
to protect us against malicious or illegal activities
to ensure the proper use of our products and services
to improve our products and services
for short-term transitional use
for administrative purposes
for marketing (including sales prospecting), internal research and development purposes
for quality assurance purposes and to help train and develop our agents

for our legitimate interests
in preparation for or performance of a contract with you
if we have requested and received your consent;
to meet a legal obligation to which we are bound*.

LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies
partners who help us provide the Products or services or improve our marketing activities (including sales prospecting) or management**.

For the duration of the relationship between you and us, and 5 years from the end of the relationship.

Your data may be kept for a longer period of time for evidential purposes in the event of litigation.

Patients and users of our medical products and services We may process your Personal Data when you are an existing or potential patient of a LA COOPÉRATIVE WELCOOP client Healthcare Provider and/or when you receive or use LA COOPÉRATIVE WELCOOP medical products and services (including, where applicable, mobile applications).
What data do we process?	Where do we obtain your Data?	Why do we process your Data?	On what legal basis do we process your Data?	Who receives or may receive your Data?	How long do we keep your Data?
Identity-related data, such as: first and last name e-mail address postal address phone number username and password Other data relating to identity and personal life, such as: age genre family situation disability if necessary date of birth Visual and audio information, such as: photos and videos of processing activities Technical data, such as: Internet Protocol (IP) addresses (which can identify your general geographic location or your company) browser type and language device type advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Device Identifier (AAID)) date and time you use our products and services URLs or uniform resource locators (i.e., addresses of websites) consulted before and after our products and services activity on our Products and Services and reference websites or applications data collected from cookies or other similar technologies**. location data Data relating to your health, such as:* date of birth sex/gender genetic data blood and tissue samples identification of pathologies/diseases areas of interest in medical research processing dates medical history and treatment information patient-reported outcome measures (e.g. responses to questionnaires and surveys) X-rays, MRIs (magnetic resonance imaging) and medical scanners user activity details of treatment completion and use communications with your Healthcare Provider, including audio and/or video of telehealth sessions Commercial and economic information, such as: products and services purchased, obtained or planned documentation requests customer care files financial transaction history bank account number Anonymized/de-identified data Anonymized data is data in which your individual personal characteristics have been removed so that you are not identifiable, and the information is no longer considered Personal Data under data protection laws.	you directly your healthcare provider your devices our business partners and other third parties	to provide you with our products and services to contact you (regarding your inquiry) to manage our relationship with you to send you updates to contact you to identify and authenticate yourself to detect security incidents to protect us against malicious or illegal activities to ensure the proper use of our products and services to improve our products and services for short-term transitional use for administrative purposes for quality assurance purposes	for our legitimate interests to safeguard vital interests in preparation for or performance of a contract with you if we have requested and received your consent; to meet a legal obligation to which we are bound*.	LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies healthcare providers partners who help us provide the Products or services or improve our marketing (including sales prospecting) or management activities**.	For the duration of the relationship between you and us, and 5 years from the end of the relationship. Your data may be kept for a longer period of time for evidential purposes in the event of litigation.

Patients and users of our medical products and services

We may process your Personal Data when you are an existing or potential patient of a LA COOPÉRATIVE WELCOOP client Healthcare Provider and/or when you receive or use LA COOPÉRATIVE WELCOOP medical products and services (including, where applicable, mobile applications).

What data do we process?

Where do we obtain your Data?

Why do we process your Data?

On what legal basis do we process your Data?

Who receives or may receive your Data?

How long do we keep your Data?

Identity-related data, such as:

first and last name
e-mail address
postal address
phone number
username and password

Other data relating to identity and personal life, such as:

age
genre
family situation
disability if necessary
date of birth

Visual and audio information, such as:

photos and videos of processing activities

Technical data, such as:

Internet Protocol (IP) addresses (which can identify your general geographic location or your company)
browser type and language
device type
advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Device Identifier (AAID))
date and time you use our products and services
URLs or uniform resource locators (i.e., addresses of
websites) consulted before and after our products and services
activity on our Products and Services and reference websites or applications
data collected from cookies or other similar technologies***.
location data

Data relating to your health, such as:

date of birth
sex/gender
genetic data
blood and tissue samples
identification of pathologies/diseases
areas of interest in medical research
processing dates
medical history and treatment information
patient-reported outcome measures (e.g. responses to questionnaires and surveys)
X-rays, MRIs (magnetic resonance imaging) and medical scanners
user activity
details of treatment completion and use
communications with your Healthcare Provider, including audio and/or video of telehealth sessions

Commercial and economic information, such as:

products and services purchased, obtained or planned
documentation requests
customer care files
financial transaction history
bank account number

Anonymized/de-identified data

you directly
your healthcare provider
your devices
our business partners and other third parties

to provide you with our products and services
to contact you (regarding your inquiry)
to manage our relationship with you
to send you updates
to contact you
to identify and authenticate yourself
to detect security incidents
to protect us against malicious or illegal activities
to ensure the proper use of our products and services
to improve our products and services
for short-term transitional use
for administrative purposes
for quality assurance purposes

for our legitimate interests
to safeguard vital interests
in preparation for or performance of a contract with you
if we have requested and received your consent;
to meet a legal obligation to which we are bound*.

LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies
healthcare providers
partners who help us provide the Products or services or improve our marketing (including sales prospecting) or management activities**.

For the duration of the relationship between you and us, and 5 years from the end of the relationship.

Your data may be kept for a longer period of time for evidential purposes in the event of litigation.

Participants in clinical studies and/or consumer tests

We may process your Personal Data when you participate in a trial, investigation, or clinical study as well as a consumer test that we sponsor or conduct on behalf of a third party.

If you are participating in a clinical study, clinical trial, other health-related research, or consumer test, you should receive separate information about the Personal Data we process for these purposes.

This accessory information notice, and not this Policy, will govern our use of your Personal Data.

Candidates for clinical trials and/or consumer tests We may process your Personal Data when you have been identified as a potential candidate for clinical studies and/or consumer tests that we sponsor or conduct on behalf of a third party. If you are participating in a clinical study, clinical trial, other health-related research, or consumer test, you must receive separate information about the Personal Data we process for these purposes. This accessory information notice, and not this Policy, will govern our use of your Personal Data.
What data do we process?	Where do we obtain your Data?	Why do we process your Data?	On what legal basis do we process your Data?	Who receives or may receive your Data?	How long do we keep your Data?
Identity-related data, such as: first and last name e-mail address postal address phone number Other data relating to identity and personal life, such as: age genre family situation disability if necessary date of birth Technical data, such as: Internet Protocol (IP) addresses (which can identify your general geographic location or your company) browser type and language device type advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Device Identifier (AAID)) date and time you use our Products and services URLs or uniform resource locators (i.e. website addresses) consulted before and after our Products and services activity on our products and services and reference websites or applications data collected from cookies or other similar technologies**. location data Data concerning your health, such as:* date of birth sex/gender genetic data identification of pathologies/diseases areas of interest in medical research processing dates medical history and treatment information X-rays, MRIs (magnetic resonance imaging) and medical scanners user activity details of treatment completion and use Anonymized/de-identified data Anonymized data is data in which your individual personal characteristics have been removed so that you are not identifiable, and the information is no longer considered Personal Data under data protection laws	you directly your healthcare provider your devices our business partners and other third parties your friends or family	to contact you (regarding your inquiry) to manage our relationship with you to send you updates to determine your eligibility for one or more clinical trials to identify and authenticate yourself to detect security incidents to protect us against malicious or illegal activities	for our legitimate interests in the public interest to safeguard vital interests in preparation for or performance of a contract with you if we have requested and received your consent; to meet a legal obligation to which we are bound*.	LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies our customers healthcare providers clinical investigators and/or members of investigator teams partners who help us provide the Products or services or improve our marketing activities (including sales prospecting) or management**.	For the periods stipulated by law for different types of research (see CNIL guide to data retention periods in the field of health research).

Candidates for clinical trials and/or consumer tests

We may process your Personal Data when you have been identified as a potential candidate for clinical studies and/or consumer tests that we sponsor or conduct on behalf of a third party.

If you are participating in a clinical study, clinical trial, other health-related research, or consumer test, you must receive separate information about the Personal Data we process for these purposes.

This accessory information notice, and not this Policy, will govern our use of your Personal Data.

What data do we process?

Where do we obtain your Data?

Why do we process your Data?

On what legal basis do we process your Data?

Who receives or may receive your Data?

How long do we keep your Data?

Identity-related data, such as:

first and last name
e-mail address
postal address
phone number

Other data relating to identity and personal life, such as:

age
genre
family situation
disability if necessary
date of birth

Technical data, such as:

Internet Protocol (IP) addresses (which can identify your general geographic location or your company)
browser type and language
device type
advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Device Identifier (AAID))
date and time you use our Products and services
URLs or uniform resource locators (i.e. website addresses) consulted before and after our Products and services
activity on our products and services and reference websites or applications
data collected from cookies or other similar technologies***.
location data

Data concerning your health, such as:

date of birth
sex/gender
genetic data
identification of pathologies/diseases
areas of interest in medical research
processing dates
medical history and treatment information
X-rays, MRIs (magnetic resonance imaging) and medical scanners
user activity
details of treatment completion and use

Anonymized/de-identified data

you directly
your healthcare provider
your devices
our business partners and other third parties
your friends or family

to contact you (regarding your inquiry)
to manage our relationship with you
to send you updates
to determine your eligibility for one or more clinical trials
to identify and authenticate yourself
to detect security incidents
to protect us against malicious or illegal activities

for our legitimate interests
in the public interest
to safeguard vital interests
in preparation for or performance of a contract with you
if we have requested and received your consent;
to meet a legal obligation to which we are bound*.

LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies
our customers
healthcare providers
clinical investigators and/or members of investigator teams
partners who help us provide the Products or services or improve our marketing activities (including sales prospecting) or management**.

For the periods stipulated by law for different types of research (see CNIL guide to data retention periods in the field of health research).

Clinical investigators and investigator team members We may process your Personal Data if you are an existing or potential clinical investigator or a member of a team of investigators for a clinical study that LA COOPÉRATIVE WELCOOP is implementing on its behalf or managing on behalf of a client.
What data do we process?	Where do we obtain your Data?	Why do we process your Data?	On what legal basis do we process your Data?	Who receives or may receive your Data?	How long do we keep your Data?
Identity-related data, such as: first and last name company/employer e-mail address postal address phone number Other data relating to identity and personal life, such as: age genre family situation disability if necessary date of birth Technical data, such as: Internet Protocol (IP) addresses (which can identify your general geographic location or your company) browser type and language device type advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Identifier (AAID)) date and time you use our Products and services URLs or uniform resource locators (i.e. website addresses) consulted before and after our Products and services activity on our products and services and reference websites or applications data collected from cookies or other similar technologies**. location data Commercial and economic information, such as:* products and services purchased, obtained or planned documentation requests customer care files financial transaction history bank account number Data relating to professional life, such as: job title employer supplier’s national identification number state medical license number professional skills professional background higher education diplomas certifications specialized training responses to surveys and questionnaires registration history for our educational and training events Anonymized/de-identified data Anonymized data is data in which your individual personal characteristics have been removed so that you are not identifiable, and the information is no longer considered Personal Data under data protection laws.	you directly your devices our business partners and other third parties our customers your employer or principal	to provide you with our products and services to contact you (regarding your inquiry) to manage our relationship with your organization to send you updates to contact you to identify and authenticate yourself to detect security incidents to protect us against malicious or illegal activities to ensure the proper use of our products and services to improve our products and services for short-term transitional use for administrative purposes for quality assurance purposes for marketing (including sales prospecting), internal research and development purposes for quality assurance purposes to personalize your content	for our legitimate interests in the public interest to safeguard vital interests in preparation for or performance of a contract with you if we have requested and received your consent; to meet a legal obligation to which we are bound*.	LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies our customers other clinical investigators and/or members of investigator teams partners who help us provide the Products or services or improve our marketing (including sales prospecting) or management activities**.	For the legal retention periods for different types of research (see CNIL guide to data retention periods in the field of health research).

Clinical investigators and investigator team members

We may process your Personal Data if you are an existing or potential clinical investigator or a member of a team of investigators for a clinical study that LA COOPÉRATIVE WELCOOP is implementing on its behalf or managing on behalf of a client.

What data do we process?

Where do we obtain your Data?

Why do we process your Data?

On what legal basis do we process your Data?

Who receives or may receive your Data?

How long do we keep your Data?

Identity-related data, such as:

first and last name
company/employer
e-mail address
postal address
phone number

Other data relating to identity and personal life, such as:

age
genre
family situation
disability if necessary
date of birth

Technical data, such as:

Internet Protocol (IP) addresses (which can identify your general geographic location or your company)
browser type and language
device type
advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Identifier (AAID))
date and time you use our Products and services
URLs or uniform resource locators (i.e. website addresses) consulted before and after our Products and services
activity on our products and services and reference websites or applications
data collected from cookies or other similar technologies***.
location data

Commercial and economic information, such as:

products and services purchased, obtained or planned
documentation requests
customer care files
financial transaction history
bank account number

Data relating to professional life, such as:

job title
employer
supplier’s national identification number
state medical license number
professional skills
professional background
higher education diplomas
certifications
specialized training
responses to surveys and questionnaires
registration history for our educational and training events

Anonymized/de-identified data

you directly
your devices
our business partners and other third parties
our customers
your employer or principal

to provide you with our products and services
to contact you (regarding your inquiry)
to manage our relationship with your organization
to send you updates
to contact you
to identify and authenticate yourself
to detect security incidents
to protect us against malicious or illegal activities
to ensure the proper use of our products and services
to improve our products and services
for short-term transitional use
for administrative purposes
for quality assurance purposes
for marketing (including sales prospecting), internal research and development purposes
for quality assurance purposes
to personalize your content

for our legitimate interests
in the public interest
to safeguard vital interests
in preparation for or performance of a contract with you
if we have requested and received your consent;
to meet a legal obligation to which we are bound*.

LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies
our customers
other clinical investigators and/or members of investigator teams
partners who help us provide the Products or services or improve our marketing (including sales prospecting) or management activities**.

For the legal retention periods for different types of research (see CNIL guide to data retention periods in the field of health research).

Health care providers We may process your Personal Data if you are a Healthcare Provider who is an existing or potential client of LA COOPÉRATIVE WELCOOP, who uses LA COOPÉRATIVE WELCOOP’s Products and services or who treats patients with LA COOPÉRATIVE WELCOOP’s Products and services, including the use of LA COOPÉRATIVE WELCOOP’s online portals.
What data do we process?	Where do we obtain your Data?	Why do we process your Data?	On what legal basis do we process your Data?	Who receives or may receive your Data?	How long do we keep your Data?
Identity-related data, such as: first and last name company/employer e-mail address postal address phone number username and password Other data relating to identity and personal life, such as: age genre family situation disability if necessary date of birth Technical data, such as: IP (Internet Protocol) addresses browser type and language device type advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Device Identifier (AAID)) date and time you use our Products and services URLs or uniform resource locators (i.e., addresses of websites) consulted before and after our products and services activity on our Products and Services and reference websites or applications data collected from cookies or other similar technologies**. location data Commercial and economic data, such as:* products and services purchased, obtained or planned documentation requests customer care files financial transaction history bank account number Data relating to professional life, such as: job title employer supplier’s national identification number state medical license number professional skills professional background higher education diplomas certifications specialized training responses to surveys and questionnaires registration history for our educational and training events Anonymized/de-identified data Anonymized data is data in which your individual personal characteristics have been removed so that you are not identifiable, and the information is no longer considered Personal Data under data protection laws.	you directly your devices our business partners and other third parties your employer or principal your patients Other healthcare providers	to provide you with our products and services to contact you (regarding your inquiry) to manage our relationship with your organization to send you updates to contact you to identify and authenticate yourself to detect security incidents to protect us against malicious or illegal activities to ensure the proper use of our products and services to improve our products and services for short-term transitional use for administrative purposes for quality assurance purposes for marketing (including sales prospecting), internal research and development purposes for quality assurance purposes to personalize your content	for our legitimate interests in preparation for or performance of a contract with you if we have requested and received your consent; to meet a legal obligation to which we are bound*.	LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies Other health care providers your patients partners who help us provide the Products or services or improve our marketing activities (including sales prospecting) or management**.	For the duration of the relationship between you and us, and 5 years from the end of the relationship. Your data may be kept for a longer period of time for evidential purposes in the event of litigation.

Health care providers

We may process your Personal Data if you are a Healthcare Provider who is an existing or potential client of LA COOPÉRATIVE WELCOOP, who uses LA COOPÉRATIVE WELCOOP’s Products and services or who treats patients with LA COOPÉRATIVE WELCOOP’s Products and services, including the use of LA COOPÉRATIVE WELCOOP’s online portals.

What data do we process?

Where do we obtain your Data?

Why do we process your Data?

On what legal basis do we process your Data?

Who receives or may receive your Data?

How long do we keep your Data?

Identity-related data, such as:

first and last name
company/employer
e-mail address
postal address
phone number
username and password

Other data relating to identity and personal life, such as:

age
genre
family situation
disability if necessary
date of birth

Technical data, such as:

IP (Internet Protocol) addresses
browser type and language
device type
advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Device Identifier (AAID))
date and time you use our Products and services
URLs or uniform resource locators (i.e., addresses of
websites) consulted before and after our products and services
activity on our Products and Services and reference websites or applications
data collected from cookies or other similar technologies***.
location data

Commercial and economic data, such as:

products and services purchased, obtained or planned
documentation requests
customer care files
financial transaction history
bank account number

Data relating to professional life, such as:

job title
employer
supplier’s national identification number
state medical license number
professional skills
professional background
higher education diplomas
certifications
specialized training
responses to surveys and questionnaires
registration history for our educational and training events

Anonymized/de-identified data

you directly
your devices
our business partners and other third parties
your employer or principal
your patients
Other healthcare providers

to provide you with our products and services
to contact you (regarding your inquiry)
to manage our relationship with your organization
to send you updates
to contact you
to identify and authenticate yourself
to detect security incidents
to protect us against malicious or illegal activities
to ensure the proper use of our products and services
to improve our products and services
for short-term transitional use
for administrative purposes
for quality assurance purposes
for marketing (including sales prospecting), internal research and development purposes
for quality assurance purposes
to personalize your content

for our legitimate interests
in preparation for or performance of a contract with you
if we have requested and received your consent;
to meet a legal obligation to which we are bound*.

LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies
Other health care providers
your patients
partners who help us provide the Products or services or improve our marketing activities (including sales prospecting) or management**.

For the duration of the relationship between you and us, and 5 years from the end of the relationship.

Your data may be kept for a longer period of time for evidential purposes in the event of litigation.

Job and apprenticeship applicants We may process your Personal Information when you apply for or are a candidate for a job, internship, or apprenticeship with LA COOPÉRATIVE WELCOOP.
What data do we process?	Where do we obtain your Data?	Why do we process your Data?	On what legal basis do we process your Data?	Who receives or may receive your Data?	How long do we keep your Data?
Identity-related data, such as: first and last name company/employer e-mail address postal address phone number username and password Other data relating to identity and personal life, such as: age genre family situation disability if necessary date of birth Technical data, such as: IP (Internet Protocol) addresses browser type and language device type advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Device Identifier (AAID)) date and time you use our Products and services URLs or uniform resource locators (i.e., addresses of websites) consulted before and after our products and services activity on our Products and Services and reference websites or applications data collected from cookies or other similar technologies**. location data Data relating to working life, such as:* job title employer professional skills professional background higher education diplomas certifications salary claims specialized training responses to surveys and questionnaires Anonymized/de-identified data Anonymized data is data in which your individual personal characteristics have been removed so that you are not identifiable, and the information is no longer considered Personal Data under data protection laws	you directly your employer or principal your devices our business partners and other third parties indirectly through social networks	to contact you to identify and authenticate yourself to detect security incidents to protect us against malicious or illegal activities for short-term transitional use for administrative purposes to obtain professional references for marketing (including sales prospecting), internal research and development purposes	for our legitimate interests in preparation for or performance of a contract with you if we have requested and received your consent; to meet a legal obligation to which we are bound*.	LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies partners who help us provide the Products or services or improve our marketing (including sales prospecting) or management activities**.	For candidates selected and hired: The data of successful candidates is kept in an active database for the duration of the recruitment procedure, until the hiring decision is made; Once this decision has been taken, the data can be reused and stored for personnel management purposes; Only data strictly necessary for evidentiary purposes will be kept in the intermediate database. For unsuccessful candidates: The data of unsuccessful candidates is kept in an active database for the duration of the recruitment procedure, until the decision to hire is made; At the end of the recruitment process, the data of unsuccessful candidates is kept, with the consent of the unsuccessful candidate, for a period of 2 years in order to be able to contact them again at a later date in the event of new job opportunities

Job and apprenticeship applicants

We may process your Personal Information when you apply for or are a candidate for a job, internship, or apprenticeship with LA COOPÉRATIVE WELCOOP.

What data do we process?

Where do we obtain your Data?

Why do we process your Data?

On what legal basis do we process your Data?

Who receives or may receive your Data?

How long do we keep your Data?

Identity-related data, such as:

first and last name
company/employer
e-mail address
postal address
phone number
username and password

Other data relating to identity and personal life, such as:

age
genre
family situation
disability if necessary
date of birth

Technical data, such as:

IP (Internet Protocol) addresses
browser type and language
device type
advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Device Identifier (AAID))
date and time you use our Products and services
URLs or uniform resource locators (i.e., addresses of
websites) consulted before and after our products and services
activity on our Products and Services and reference websites or applications
data collected from cookies or other similar technologies***.
location data

Data relating to working life, such as:

job title
employer
professional skills
professional background
higher education diplomas
certifications
salary claims
specialized training
responses to surveys and questionnaires

Anonymized/de-identified data

you directly
your employer or principal
your devices
our business partners and other third parties
indirectly through social networks

to contact you
to identify and authenticate yourself
to detect security incidents
to protect us against malicious or illegal activities
for short-term transitional use
for administrative purposes
to obtain professional references
for marketing (including sales prospecting), internal research and development purposes

for our legitimate interests
in preparation for or performance of a contract with you
if we have requested and received your consent;
to meet a legal obligation to which we are bound*.

LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies
partners who help us provide the Products or services or improve our marketing (including sales prospecting) or management activities**.

For candidates selected and hired:

The data of successful candidates is kept in an active database for the duration of the recruitment procedure, until the hiring decision is made;
Once this decision has been taken, the data can be reused and stored for personnel management purposes;
Only data strictly necessary for evidentiary purposes will be kept in the intermediate database.

For unsuccessful candidates:

The data of unsuccessful candidates is kept in an active database for the duration of the recruitment procedure, until the decision to hire is made;
At the end of the recruitment process, the data of unsuccessful candidates is kept, with the consent of the unsuccessful candidate, for a period of 2 years in order to be able to contact them again at a later date in the event of new job opportunities

Business partners and their employees, agents, and subcontractors We may process your Personal Data when you act as a business partner such as a cooperator, shareholder or investor, a non-Healthcare Provider customer or a supplier, distributor, retailer, consultant, or service provider.
What data do we process?	Where do we obtain your Data?	Why do we process your Data?	On what legal basis do we process your Data?	Who receives or may receive your Data?	How long do we keep your Data?
Identity-related data, such as: first and last name company/employer e-mail address postal address phone number username and password Other data relating to identity and personal life, such as: age genre family situation disability if necessary date of birth Technical data, such as: IP (Internet Protocol) addresses browser type and language device type advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Device Identifier (AAID)) date and time you use our Products and services URLs or uniform resource locators (i.e., addresses of websites) consulted before and after our products and services activity on our Products and Services and reference websites or applications data collected from cookies or other similar technologies**. location data Commercial and economic data, such as:* products and services purchased, obtained or planned documentation requests customer care files financial transaction history bank account number Anonymized/de-identified data Anonymized data is data in which your individual personal characteristics have been removed so that you are not identifiable, and the information is no longer considered Personal Data under data protection laws	you directly our business partners and other third parties your employer or principal your devices	to contact you (regarding your inquiry) to manage our relationship with your organization to send you updates to identify and authenticate yourself to detect security incidents to protect us against malicious or illegal activities for short-term transitional use for administrative purposes for marketing (including sales prospecting), internal research and development purposes to provide you with our products and services to contact you	for our legitimate interests in the public interest to safeguard vital interests in preparation for or performance of a contract with you if we have requested and received your consent; to meet a legal obligation to which we are bound*.	LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies our customers healthcare providers patients partners who help us provide the Products or services or improve our marketing (including sales prospecting) or management activities**.	For the duration of the relationship between you and us, and 5 years from the end of the relationship. Your data may be kept for a longer period of time for evidential purposes in the event of litigation.

Business partners and their employees, agents, and subcontractors

We may process your Personal Data when you act as a business partner such as a cooperator, shareholder or investor, a non-Healthcare Provider customer or a supplier, distributor, retailer, consultant, or service provider.

What data do we process?

Where do we obtain your Data?

Why do we process your Data?

On what legal basis do we process your Data?

Who receives or may receive your Data?

How long do we keep your Data?

Identity-related data, such as:

first and last name
company/employer
e-mail address
postal address
phone number
username and password

Other data relating to identity and personal life, such as:

age
genre
family situation
disability if necessary
date of birth

Technical data, such as:

IP (Internet Protocol) addresses
browser type and language
device type
advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Device Identifier (AAID))
date and time you use our Products and services
URLs or uniform resource locators (i.e., addresses of
websites) consulted before and after our products and services
activity on our Products and Services and reference websites or applications
data collected from cookies or other similar technologies***.
location data

Commercial and economic data, such as:

products and services purchased, obtained or planned
documentation requests
customer care files
financial transaction history
bank account number

Anonymized/de-identified data

you directly
our business partners and other third parties
your employer or principal
your devices

to contact you (regarding your inquiry)
to manage our relationship with your organization
to send you updates
to identify and authenticate yourself
to detect security incidents
to protect us against malicious or illegal activities
for short-term transitional use
for administrative purposes
for marketing (including sales prospecting), internal research and development purposes
to provide you with our products and services
to contact you

for our legitimate interests
in the public interest
to safeguard vital interests
in preparation for or performance of a contract with you
if we have requested and received your consent;
to meet a legal obligation to which we are bound*.

LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies
our customers
healthcare providers
patients
partners who help us provide the Products or services or improve our marketing (including sales prospecting) or management activities**.

For the duration of the relationship between you and us, and 5 years from the end of the relationship.

Your data may be kept for a longer period of time for evidential purposes in the event of litigation.

Speakers and event participants We may process your Personal Data when you attend or participate in professional and educational events that we sponsor or organize.
What data do we process?	Where do we obtain your Data?	Why do we process your Data?	On what legal basis do we process your Data?	Who receives or may receive your Data?	How long do we keep your Data?
Identity-related data, such as: first and last name company/employer e-mail address postal address phone number username and password Other data relating to identity and personal life, such as: age genre family situation disability if necessary date of birth Technical data, such as: IP (Internet Protocol) addresses browser type and language device type advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Device Identifier (AAID)) date and time you use our Products and services URLs or uniform resource locators (i.e., addresses of websites) consulted before and after our products and services activity on our Products and Services and reference websites or applications data collected from cookies or other similar technologies**. location data Data relating to professional life, such as:* job title employer professional skills professional background higher education diplomas certifications specialized training responses to surveys and questionnaires Visual and audio information, such as: photos video (including CCTV) Anonymized/de-identified data Anonymized data is data in which your individual personal characteristics have been removed so that you are not identifiable, and the information is no longer considered Personal Data under data protection laws	you directly your employer or principal your devices our sales partners	to contact you (regarding your inquiry) to manage our relationship with your organization to send you updates to contact you to identify and authenticate yourself to detect security incidents to protect us against malicious or illegal activities for short-term transitional use for administrative purposes for marketing (including sales prospecting), internal research and development purposes	for our legitimate interests in preparation for or performance of a contract with you if we have requested and received your consent; to meet a legal obligation to which we are bound*.	LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies other speakers and event participants partners who help us provide the Products or services or improve our marketing activities (including sales prospecting) or management**.	For the duration of the event and then for 1 year from the end of the event. Your data may be kept for a longer period of time for evidential purposes in the event of litigation.

Speakers and event participants

We may process your Personal Data when you attend or participate in professional and educational events that we sponsor or organize.

What data do we process?

Where do we obtain your Data?

Why do we process your Data?

On what legal basis do we process your Data?

Who receives or may receive your Data?

How long do we keep your Data?

Identity-related data, such as:

first and last name
company/employer
e-mail address
postal address
phone number
username and password

Other data relating to identity and personal life, such as:

age
genre
family situation
disability if necessary
date of birth

Technical data, such as:

IP (Internet Protocol) addresses
browser type and language
device type
advertising identifiers associated with your device (such as the Apple Advertising Device Identifier (IDFA) or the Android Advertising Device Identifier (AAID))
date and time you use our Products and services
URLs or uniform resource locators (i.e., addresses of
websites) consulted before and after our products and services
activity on our Products and Services and reference websites or applications
data collected from cookies or other similar technologies***.
location data

Data relating to professional life, such as:

job title
employer
professional skills
professional background
higher education diplomas
certifications
specialized training
responses to surveys and questionnaires

Visual and audio information, such as:

photos
video (including CCTV)

Anonymized/de-identified data

you directly
your employer or principal
your devices
our sales partners

to contact you (regarding your inquiry)
to manage our relationship with your organization
to send you updates
to contact you
to identify and authenticate yourself
to detect security incidents
to protect us against malicious or illegal activities
for short-term transitional use
for administrative purposes
for marketing (including sales prospecting), internal research and development purposes

for our legitimate interests
in preparation for or performance of a contract with you
if we have requested and received your consent;
to meet a legal obligation to which we are bound*.

LA COOPÉRATIVE WELCOOP, its subsidiaries, affiliates, and associated companies
other speakers and event participants
partners who help us provide the Products or services or improve our marketing activities (including sales prospecting) or management**.

For the duration of the event and then for 1 year from the end of the event.

Your data may be kept for a longer period of time for evidential purposes in the event of litigation.

* The legal basis invoked by LA COOPÉRATIVE WELCOOP include those listed in Article 6 of the European Union’s General Data Protection Regulation (“GDPR”), depending on the type of Personal Data.

** In limited cases, recipients may include, (1) in the event of a sale, assignment or transfer to the purchaser, assignee, or transferee; and (2) regulatory officials or agents, law enforcement agencies, courts, public authorities, or others, where permitted by this Policy or required by law.

*** Please see the cookies section of this Policy for more information on how we use cookies and similar technologies.

6. HOW LONG WE KEEP YOUR PERSONAL DATA

We will keep your Personal Data on our systems for the longest of the following periods:

the length of time necessary to achieve the objective or objectives pursued at the time of collection;
the retention, archiving and limitation periods stipulated by law or regulation;
the end of the limitation period applicable following a dispute or investigation in connection with one of our offers or proposals, or one of our services.

7. THE SECURITY MEASURES WE PUT IN PLACE

To protect your Personal Information, LA COOPÉRATIVE WELCOOP employs reasonable and appropriate security measures.

Although LA COOPÉRATIVE WELCOOP takes all appropriate security measures at the time of collection of your Personal Data and in connection with any processing of Personal Data, the transmission of data over the Internet (including by e-mail) is never completely secure.

8. PROTECTION OF MINORS’ PERSONAL DATA

LA COOPÉRATIVE WELCOOP does not normally process Personal Data of minors.

However, in certain specific cases (for example: trainees within our entities, minor patients, etc.), LA COOPÉRATIVE WELCOOP may collect Personal Data from children of at least 15 years of age with the prior joint consent of the minor concerned and the legal representatives or guardians in order to provide certain Products and services.

Together, the legal representative or guardian and the minor concerned may, on simple request, access the information provided by the child and/or request its deletion.

9. TRANSFER TO OTHER COUNTRIES

LA COOPÉRATIVE WELCOOP may share Personal Data internationally with LA COOPÉRATIVE WELCOOP group companies, subcontractors and partners when carrying out the activities described in this Policy. They may process your data in countries whose data protection laws are not considered as strict as those of the European Union. For example, they may not give you the same rights over your data.

Whenever we transfer Personal Data internationally, we use tools to:

ensure that the transfer of data complies with applicable law;
enable us to guarantee the same level of protection for your data as within the EU.

To ensure that each data transfer complies with applicable European legislation, we use the following legal mechanisms:

Standard Contractual Clauses (“SCC”). These clauses require the other party to protect your data and provide you with protections and rights equivalent to those in the European Union.
Adequacy decisions. We transfer Personal Data to countries outside the European Economic Area that apply adequate laws to protect Personal Data, as defined by the European Commission. For example, this may include the following countries: Canada, United States, United Kingdom, Switzerland, Japan, etc.

We also identify and use additional safeguards as appropriate for each data transfer. These include:

technical safeguards, such as encryption and pseudonymization;
policies and processes for challenging disproportionate or unlawful requests from government authorities.

10. YOUR RIGHTS CONCERNING YOUR PERSONAL DATA

Please note that, in many cases, we cannot work effectively with you without processing certain Personal Data about you (e.g. your contact details). Among other things, when you contact our customer service staff, we may ask you to provide information to verify your identity in order to answer your questions. If you are unable to provide this information, we may not be able to process your request.

You have the right to access, rectify and delete your data, the right to restrict processing, the right to portability of your data and the right to specify what happens to your data after your death.

Where your consent is required, you may withdraw it at any time without this affecting lawfulness of the processing carried out prior to the withdrawal.

Furthermore, the legitimate interests pursued by LA COOPÉRATIVE WELCOOP are systematically weighed against your interests, freedoms and fundamental rights which require the protection of your Personal Data. LA COOPÉRATIVE WELCOOP’s interests may in no case prevail over yours. Therefore, you may legitimately request clarification regarding the balancing of LA COOPÉRATIVE WELCOOP’s legitimate interests against your own by contacting the relevant LA COOPÉRATIVE WELCOOP company and referring to Appendix 1 of this Policy.

The table below explains:

your rights;
the circumstances in which they apply (such as the required legal basis);
how to promote them.

You have the right…		How ?
Be informed	to be informed about the Personal Data we process about you and how we process it.	Please note: through this Policy; through information provided to you when you use our Products and services; by answering your specific questions and requests when you contact us.
Access	request access to the Personal Data we process about you.	To request a copy of your Personal Data, please contact us.
Rectification	ask us to modify or update your Personal Information if it is inaccurate or incomplete.	To request rectification of your Personal Data, please contact us.
Delete	request the deletion of some of your Personal Data. For example, you can ask us to delete personal data: that we no longer need for the purposes for which they were collected; that we process on the legal basis of consent, and for which you withdraw your consent; when you express your opposition (see “Opposition” below) and your opposition is justified, or when you oppose direct marketing (including commercial prospecting). In some cases, LA COOPÉRATIVE WELCOOP will be unable to delete your data, for example: when it is still necessary for us to process the data for the purposes for which it was collected; when LA COOPÉRATIVE WELCOOP’s interest in using this data outweighs your interest in deleting it. For example, if we need this data to protect our services against fraud; if LA COOPÉRATIVE WELCOOP is legally obliged to keep the data; or if LA COOPÉRATIVE WELCOOP needs this data to establish, exercise or defend its rights.	To request the deletion of your Personal Data, please contact us.
Restriction	ask us to stop processing all or part of your Personal Data. You can do this if: your Personal Data is inaccurate; our processing of your data is unlawful; we do not need your information for a specific purpose; or you object to the processing of your data, and we will evaluate your objection. See “Objection” below. You can ask us to stop this processing temporarily or permanently.	You can exercise your right of restriction by contacting us.
Opposition	to object to the processing of your Personal Data. You can do this if: LA COOPÉRATIVE WELCOOP processes your Personal Data on the legal basis of legitimate interests; or LA COOPÉRATIVE WELCOOP processes your Personal Data in order to offer you personalized advertising.	To exercise your right to object, please contact us.
Data portability	request a copy of your Personal Data in electronic format and transmit such Personal Data for use by a third-party service. You may ask us to pass on your data when we process your Personal Data on the legal basis of consent or contract performance.	To find out more about exercising your right to portability, see “Access” above.
Not subject to automated decision-making	not to be the subject of a decision based solely on automated decision-making (decisions not involving human beings), including profiling, where the decision would have a legal effect on you or produce a similar significant effect.	LA COOPÉRATIVE WELCOOP does not normally make this type of automated decision.
Withdrawal of consent	withdraw your consent to the collection or use of your Personal Data. You may withdraw your consent if LA COOPÉRATIVE WELCOOP processes your Personal Data on the legal basis of consent.	To withdraw your consent, you must contact us.
Right to file a complaint	Contact your local privacy authority if you have any questions or concerns.	As far as the French authority, the CNIL, is concerned, you can consult its website: https://www.cnil.fr/fr/saisir-la-cnil/contacter-la-cnil-standard-et-permanences-telephoniques For all other European authorities, please consult the following link: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

When we receive your Personal Data from our customers, partners or third parties and process your Personal Data on their behalf, we do so as a processor. We have no control over the privacy and security practices and processes of our customers, partners or third parties. If your Personal Data has been submitted to us by a customer, partner or third party of LA COOPÉRATIVE WELCOOP and you wish to exercise any of the above rights, please contact the customer directly.

11. INTERACTIVE FEATURES ON OUR WEBSITES

To the extent that we offer public or group forums on our Products or services, such as news feeds, blogs, forums, or similar tools (“Interactive Features”), any postings or comments you make may be public and viewed by others.

You should exercise caution before posting any information about yourself, including Personal Information. You confirm and agree that you have no expectation of privacy in the content you submit to the Interactive Features on the Products and Services. Except where required by applicable law, we assume no obligation to delete any Personal Data you post on our Products and services, and any disclosure of Personal Data you make via the Interactive Features is at your own risk.

12. LINKS TO OTHER WEBSITES

Our Products or services may contain links to other websites, applications, products, or services that are not owned or operated by LA COOPÉRATIVE WELCOOP, such as social networking websites and applications like Facebook and X. You should carefully review the privacy policies and practices of other websites, products, and services, as we cannot control and are not responsible for the privacy policies, notices or practices of third-party websites, applications, products, and services.

13. COOKIES AND TRACKING TECHNOLOGIES

Depending on the country in which you reside, you can manage your preferences regarding cookies and other tracking technologies by using consent management tools available on our websites, applications, and devices. This section applies to cookies and other tracking technologies. Here we explain what our use of cookies and other tracking technologies means for you, and how to disable tracking (for example, by using opt-in or opt-out preferences). Where we collect data that may enable us to identify you, the other sections of this Policy will apply.

What are cookies?

A cookie is a small file that a website asks your browser to store on your device in order to remember data about you, such as your language preferences or login details. These cookies, when placed by us, are called first-party cookies. We may also use third-party cookies, which are cookies from a domain different from that of the website you are visiting (for example, those used by social networks, instant messengers, CRM or marketing platforms, or advertising companies). For more information on cookies, cookie types and how to manage cookies, including how to block and delete them, please visit http://www.allaboutcookies.org.

We list below the main categories of cookies and other tracking technologies that we may use when you connect to our websites, use our web-based platforms, applications, and devices, interact with us electronically or receive electronic communications from us (“Online Use“). You can learn more about the purposes for which LA COOPÉRATIVE WELCOOP may use these technologies in connection with your Online Use.

What categories of cookies may LA COOPÉRATIVE WELCOOP use?

We generally use certain types of cookies during your session on our website (“session cookies”). To enhance your experience or remember your preferences or choices, we may use cookies that will remain on your device unless you delete them (“persistent cookies”). When using cookies on our websites and other digital services, this technology may include:

Categories of cookies and tracking technologies that LA COOPÉRATIVE WELCOOP may use
Strictly necessary cookies (“required”)	These cookies and tracking technologies enable our websites to function and improve the security of our website for your Online Use, for example when you need to authenticate yourself or use login features to access restricted parts of our websites (such as using a patient or doctor login or selecting pages to access other pages or restricted areas of a website or application).
Performance cookies	These cookies may allow LA COOPÉRATIVE WELCOOP: to improve our websites; remember language or other preferences when you browse; or use other features on our websites, applications, platforms, and devices to enhance your Online Experience.
Social network cookies	On some LA COOPÉRATIVE WELCOOP websites, we may use social network plugins to allow you to share interesting content or to connect to certain accounts to share your Personal Data with us. These platforms may access your browsing history and collect information about your browsing history on their own terms. You can access additional information by logging on to our sites.
Statistical cookies	These cookies enable us to better understand how our websites are used, and to compile statistics on their use and visits (for example, information on each page visited, how long a user navigates on a particular page, how long it takes to download a particular page, what actions users take on each page (click, selection, etc.).

Other tracking technologies

When using third-party software or websites, mobile applications, devices, web platforms or through another Online Use, the technology may involve certain embedded tracking technologies. This may include the following:

web beacons, web server data and similar technologies;
tracking pixels, which we may include as images in the communications we send you.

This may enable us to understand when you read the e-mail messages we send you, to send you more accurate and relevant content and to improve our communications with you. By using this technology, we may receive aggregated or anonymous information. In some cases, we may collect Personal Data about you which includes:

location data (such as the city, region, and location from which you opened your e-mail);
your IP address;
browser and device information: such as your mobile or desktop operating system (OS), type of e-mail software, device, and user agent; or
the time and date you open our electronic communications.

other tracking tools that enable features such as remote interactions with you through chatbots, instant messaging and other online features on our websites or third-party software we use for our business.

Why do we use cookies on our website?

In addition to the explanations provided in this Policy and in the section above, we use cookies or similar tracking technologies in various cases, including for the following purposes:

Making your experience more efficient, faster, and easier: by remembering your preferences, such as language, display, and other preferred settings, by maintaining your session and for authentication purposes. This enables us to offer you a better user experience. These cookies are also known as session identification cookies, authentication cookies and user interface personalization cookies.
Obtain useful knowledge about how the site is used: by collecting information about the number of visitors and other uses. This helps us to improve our sites. These cookies are also known as statistical cookies. To this end, we use services such as Google Analytics, which means that Google and similar providers will also have access to this information (including your IP address and any other equipment identifiers such as IMEI number and MAC address).
Ensure easy access to our websites. This enables us to direct you, to share our content with you on sites such as Facebook, X, LinkedIn, YouTube, or Pinterest or to allow you to share content that interests you. To the extent that we use this technology, these “social network plug-ins” may store cookies and similar technologies on your computer or other device. This means that social networking sites can access this information (including your IP address) and may know that you have interacted with LA COOPÉRATIVE WELCOOP’s site.
To improve our marketing communications to you. Some cookies, such as web beacons or tracking pixels, may be used by third-party systems such as customer relationship management systems or other service providers that help us manage email campaigns. These tracking tools enable us to better understand the success of our communications and the relevance of the content we share with you. This may enable us to reduce the number of e-mails we send you and to offer you content, scientific information or initiatives better adapted to your interests.

How can you oppose or refuse cookies?

Subject to specific provisions of Law of your country, in particular in the European Union, we will inform you, request your prior consent (consent / opt-in) before placing tracking technologies on your device, or grant you a right of opposition (opposition / opt-out) to the purposes we describe in this section. Your web browser, e-mail software (such as Microsoft Outlook or Google Gmail) and other clients you use may be configured to manage cookies and similar tracking tools, or even refuse them by default. Please bear in mind that if you set your browser to automatically refuse cookies, your user experience when visiting websites will not be the same: your preferences may not be remembered, some functionality may be lost, and you may not be able to access certain areas or features of the sites.

14. WHO TO CONTACT IF YOU HAVE ANY QUESTIONS OR WISH TO EXERCISE YOUR RIGHTS?

For any questions relating to the Processing of your Personal Data or requests relating to the exercise of your rights with regard to the protection of Personal Data, you may contact LA COOPÉRATIVE WELCOOP group company concerned by referring to Appendix 1 of this Policy.

In the event of a request to exercise one of your rights, you may be asked to provide proof of your identity. LA COOPÉRATIVE WELCOOP will not keep a copy of this document after verifying your identity.

We will use reasonable efforts to respond promptly to your requests in accordance with applicable laws.

15. POLICY UPDATE

LA COOPÉRATIVE WELCOOP may make changes to this Policy from time to time. In this case, any changes will be indicated directly on this website (via pop-ups or other notification). In certain cases, and if required by applicable law, we will send you an e-mail to inform you of any updates to this Policy.

We recommend that you check this Policy regularly for any changes.

APPENDIX 1

LIST OF COMPANIES IN LA COOPÉRATIVE WELCOOP GROUP

LA COOPERATIVE WELCOOP	Dpo.lcw@lacooperativewelcoop.com
LABORATOIRE MARQUE VERTE	Dpo.lmv@lacooperativewelcoop.com
IXAGE	dpo.ixage@lacooperativewelcoop.com
WELCOOP SOLUTION PRODUITS	dpo.wsp@lacooperativewelcoop.com
WELCOOP LOGISTIQUE	Dpo.wlog@lacooperativewelcoop.com
PHARMA LAB	dpo@pharmalab.fr
CRISTERS	Dpo.cristers@lacooperativewelcoop.com
WELLPHARMA	Dpo@wellpharma.com
GLOBALE SANTE	dpo@anton-et-willem.com
D’MEDICA	Dpo.dmedica@lacooperativewelcoop.com
DMS D’MEDICA SEDAN	dpo.dms@lacooperativewelcoop.com
PHARM’ACCESS	dpo@pharm-access.fr
PHARMA LAB INTERNATIONAL	anthony.guchet@pharmalab.fr
EQUASENS	dpo@equasens.com
DIGIPHARMACIE	dpo@digipharmacie.fr
HEALTHLEASE	dpo-healthlease@equasens.com
NANCEO	dpo@nanceo.com
DISPAY	dpo@dispay.fr
ASCA INFORMATIQUE	dpo@asca-pharma.com
EHLS	dpo-ehls@equasens.com
ATOOPHARM	dpo@atoopharm.net
BGM INFORMATIQUE	dpo-bgm@equasens.com
KAPELSE	dpo@kapelse.com
PROKOV EDITIONS	dpo-prokov@equasens.com
ICT	dpo-ict@equasens.com
CALIMED	dpo-calimed@equasens.com
EREVO	dpo@erevo.fr
MALTA INFORMATIQUE	dpo-malta@equasens.com
DICSIT INFORMATIQUE	dpo-dicsit@equasens.com
AXIGATE	dpo-axigate@equasens.com
PANDALAB	dpo@pandalab.fr
MALTA BELGIUM	dpo-malta.be@equasens.com
CAREMEDS	dpo@caremeds.co.uk
PHARMAGEST BELGIUM	dpo@pharmagest.be
PHARMAGEST GERMANY	datenschutz@pharmagest.de
I-MEDS	dpo@i-meds.de
PHARMAGEST ITALIA	privacy.italia@equasens.com
MULTIMEDS	dpo@multimeds.eu
HDM	antish.bundhoo@iqeq.com