Polyplus-transfection fully understands the importance of privacy and the protection of personal data in the digital era and is committed to ensure an adequate level of data protection for all persons with whom Polyplus-transfection has dealings. This includes:
- users of our products and services, including websites and apps users,
- representatives of our contractors and business partners,
- representatives of the scientific community etc.,
- job applicants.
What you will find in this document
This Global Privacy & Data Protection Policy (“Policy”) describes Polyplus-transfection’s global practices to ensure an adequate protection of personal data, i.e. any information relating to an identified or identifiable natural person, for all data processing carried out in the framework of its business and activities (“Personal Data”).
The objective of this Policy is to help you understand:
- THE PURPOSES: for what reasons and purposes Polyplus-transfection processes your Personal Data,
- ON WHAT GROUND: on what basis does Polyplus-transfection process your Personal Data,
- WHERE FROM: from what sources does Polyplus-transfection collect your Personal Data,
- WHO: who are the authorized parties that Polyplus-transfection may disclose your Personal Data to,
- WHERE: where Polyplus-transfection and its authorized parties may process your Personal Data,
- HOW SECURE: what Polyplus-transfection does to protect your Personal Data,
- HOW LONG: Polyplus-transfection’s approach to defining the term of retention of your Personal Data,
- YOUR RIGHTS: what your rights are and how you can exercise them,
- HOW TO CONTACT US: how you can reach us if you wish to exercise your rights or if you have a question.
What processing activities does this policy cover
This Policy is intended to apply to all processing activities Polyplus-transfection conducts towards the persons it deals with in its professional business activities. Specific privacy and data protection information notices (“Privacy Notice”) and/or consent forms will, if necessary, be communicated to you regarding specific situations where Polyplus-transfection may process your Personal Data. These Privacy Notices shall describe in more detail how your Personal Data will be processed in relation with the processing in question. If the legislation of your country so requires, this Policy and/or Privacy Notices may be supplemented by local mandatory provisions, as the case may be.
For the purposes of this Policy Polyplus-transfection means Polyplus-transfection SA. and all its affiliates. Each Privacy Notice shall set out which Polyplus-transfection legal entity determines for what reasons (i.e. the purposes) your Personal Data is processed as well as the resources (i.e. the means) allocated to such processing.
Validity and evolution of this policy
This Policy may be modified by Polyplus-transfection, from time to time, in particular to adapt its terms to evolutions or changes of applicable legislations and/or to Polyplus-transfection’s practices. Changes will be available on this page. We invite you to check this Policy periodically.
Polyplus-transfection will always collect your Personal Data for explicit and legitimate purposes.
Polyplus-transfection collects your Personal Data for the following purposes:
- to carry out our business operations; carry out marketing and sales; respond to your requests; to keep track of our interactions and meetings, such as when you contact us for information and support;
- to comply with legal or regulatory obligations that apply to Polyplus-transfection; monitor safety; manage adverse events; carry out prevention and investigatory activities; carry out administrative formalities, registration, declarations or audits.
- to provide you access to online services, application and platforms; manage your online accounts;
- to allow us to identify or authenticate you; provide or verify your credentials including via passwords, password hints, security information and questions, government-issued ID;
- to improve and develop our products and services; identify usage trends and develop new products and services; understand how you and your device interacts with our services; track and respond to safety concerns; determine the effectiveness of our promotional campaigns, conduct surveys;
- to personalize your experience when using our services; ensure that our services are presented in the way that best suits you; understand your professional and personal interests in our content, products and services or other content and adapt our content to your needs and preferences; present you products and offers tailored to you;
- to allow us to communicate with you; respond to your requests or inquiries; provide support for products and services; provide you with important information, administrative information, required notices, and promotional materials; send you news and information about our products, our services, our brands, our operations; organize and manage professional events and congresses, including your participation to such events;
- to process payments, we may need to issue in a specific situation; verify your financial data; facilitate further payments;
- to respond to legal requests from administrative or judicial authorities, in accordance with applicable laws; comply with a subpoena, required registration, or legal process;
- to protect our rights and interests ; protect the health, safety, and security of Polyplus-transfection personnel and premises ; carry out internal audits, asset management, system and other business controls ; manage business administration (finance and accounting, fraud monitoring and prevention) ; maintain the security of our services and operations ; protect our rights, privacy, safety or property, to allow us to pursue available remedies or limit the damages that we may incur as necessary ; to protect ourselves against possible fraudulent actions.
On what ground
Polyplus-transfection will always process your Personal Data lawfully.
Depending on the data processing at stake, Polyplus-transfection will generally process your Personal Data on either one of the following legal bases:
- your prior consent: where you have clearly expressed your approval of Polyplus-transfection’s processing of your Personal Data. In practice, this will generally mean that Polyplus-transfection will ask you to sign a document, or to fill-in an online “opt-in” form or to follow any relevant procedure to allow you to be fully informed and then either clearly accept or refuse the data processing envisaged,
- a contractual relationship between you and Polyplus-transfection: in such case, the processing of your Personal Data is generally necessary to the execution or the performance of the contract; this means that if you do not wish Polyplus-transfection to process your Personal Data in that context, Polyplus-transfection may or will be obliged to refuse to enter into such contract with you or will not be able to provide the products or services covered in this contract,
- legal obligations applicable to Polyplus-transfection’s activities; for instance, Polyplus-transfection is required to implement pharmacovigilance procedures to monitor adverse effects of marketed products, which generally involves the collection and retention of Personal Data,
- the “legitimate interest” of Polyplus-transfection in the sense of applicable data protection law. In such a case, Polyplus-transfection shall consider your fundamental rights and interests in determining whether the processing is legitimate and lawful.
Polyplus-transfection may, on a case-by-case basis, rely on other legal grounds, such as the protection of your vital interests, in accordance with applicable data protection law, as set forth in the applicable Privacy Notice.
Where does the personnal data come from
Polyplus-transfection will always collect Personal Data from trusted sources.
Polyplus-transfection may collect your Personal Data from different sources:
- Data that you communicate to us through various media, through registrations, applications surveys or direct and indirect interactions with Polyplus-transfection. For example, data you provide to register to scientific events sponsored by Polyplus-transfection, to submit an online application, to send us a request for information, etc.
- Data that we collect automatically, for instance when following your interactions with our websites, platforms, applications and services through certain technologies, such as cookies.
- Data that we collect in accordance with applicable law from public sources available, including data that is published by you in all supports.
- Data that we obtain legally from third parties, for example, when we may need to confirm contact or financial information. In such case, we generally receive such Personal Data from third-parties that are authorized to do so in the framework of their own privacy and data protection policies or in accordance with the law. As applicable, we will inform you in the Privacy Notice of the identity of those third-parties and will invite you to refer to their privacy and data protection policies to inquire on the origin of such Personal Data and the condition of their collection.
Who has access to personnal data
Polyplus-transfection will share your Personal Data only with authorized parties.
For the purposes described above, Polyplus-transfection may need to share your Personal Data with the following authorized third-parties:
- Polyplus-transfection SA. and its affiliates
- our partners (distributors, other members of the healthcare and pharmaceutical industry)
- selected suppliers, service providers or vendors acting upon our instructions for website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, etc.
- legal or administrative authorities, as required by applicable laws including laws outside your country of residence
- potential acquirers and other stakeholders in the event of a merger, legal restructuring operation such as, acquisition, joint venture, assignment, spin-off or divestitures.
Polyplus-transfection may need to share your Personal Data with other third-parties, in which case you will be duly informed through the applicable Privacy Notice.
In any case, Polyplus-transfection will require that such third-parties:
- undertake to comply with data protection laws and the principles of this Policy;
- will only process the Personal Data for the purposes described in this Policy; and
- implement appropriate technical and organizational security measures designed to protect the integrity and confidentiality of your Personal Data.
Where personnal data may be transferred
Polyplus-transfection will ensure that transfers of your Personal Data outside EU are safeguarded.
Polyplus-transfection SA. is an organization with affiliates, partners and subcontractors located in many countries around the world. For that reason, Polyplus-transfection may need to transfer (via access, visualization, storage.) your Personal Data in other jurisdictions, including from the European Economic Area to outside the European Economic Area, in countries which may not be regarded as providing the same level of protection as the jurisdiction you are based in.
Safeguards for international transfers of Personal Data: In cases where Polyplus-transfection needs to transfer Personal Data outside the European Union, it shall ensure that adequate safeguards, as required under applicable data protection legislation, will be implemented.
Polyplus-transfection will implement security measures to protect your Personal Data.
We have implemented a variety of technological and organizational procedures and measures to ensure the integrity and confidentiality of your Personal Data from unauthorized access, use and disclosure. These measures shall consider the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.
For instance, we store your Personal Data on servers that have various types of technical and physical access controls, which may include, for instance, if appropriate, encryption. We may also aggregate, pseudonymize or anonymize Personal Data to ensure that no personally identifiable information is communicated to third parties.
We will retain your Personal Data for no longer than necessary.
Polyplus-transfection will retain your Personal Data only for the period necessary to fulfill the purposes outlined in this Policy. As an exception, Polyplus-transfection may be required to retain your Personal Data for longer periods as required or permitted by law, or as necessary to protect its rights and interests. In such a case, you will be informed of the intended retention period in the applicable Privacy Notice.
Polyplus-transfection will ensure that you can exercise your rights pertaining to your Personal Data.
You can exercise your rights as provided by data protection laws.
To that end, Polyplus-transfection informs you that you are entitled:
- to have access upon simple request to your Personal Data – in which case you may receive a copy of such data (if requested), unless such data is made directly available to you, for instance within your personal account;
- to obtain a rectification of your Personal Data should your Personal Data be inaccurate, incomplete or obsolete;
- to obtain the deletion of your Personal Data in the situations set forth by applicable data protection law (‘right to be forgotten’);
- to withdraw your consent to the data processing without affecting the lawfulness of processing, where your Personal Data has been collected and processed on the basis of your consent;
- to object to the processing of your Personal Data, where your Personal Data has been collected and processed on the basis of legitimate interests of Polyplus-transfection, in which case you will need to justify your request by explaining to us your particular situation;
- to request a limitation of the data processing in the situations set forth by applicable law;
- to receive your Personal Data for transmission from Polyplus-transfection to a third-party or to have your Personal Data directly transferred by Polyplus-transfection to the third-party of your choice, where technically feasible (data portability right allowed only where the processing is based on your consent).
If you would like to exercise any of these rights, please contact us as described in the “How to Contact Us” section below and we will take necessary steps to respond as soon as possible.
If you experience difficulties in exercising your Personal Data protection rights, you have the right to file complaints with the competent authority for the protection of personal data.
How to contact us
You can send any request pertaining to Polyplus-transfection’s use of your Personal Data at the following email address: email@example.com.