Data Protection Policy

For the purposes of its activity, VirtualiSurg collects and processes personal data relating to users (hereinafter the « User ») of a virtual reality simulator (hereinafter the « Simulator »). 

 

This data is protected by law. For this reason, VirtualiSurg, in its capacity as data controller, has put in place appropriate security measures in order to protect your personal data. 

 

Please take the time to familiarise yourself with this policy, which explains how your personal data is used by VirtualiSurg. This policy is intended to supplement any document or notice that refers to the policy. 

 

If necessary, you can address all your questions directly to VirtualiSurg’s data protection officer by sending an email to contact@virtualisurg.com or a letter to the following address: 

 

 

 

VIRTUALISURG 

Département données personnelles 

191-195, Avenue Charles de Gaulle 92000 Neuilly-sur-Seine 

 

 

 

  1. 1. WHAT PERSONAL DATA MAY BE PROCESSED BY VIRTUALISURG? 

All the data that you enter when you register or during each simulation session or when you communicate with VirtualiSurg, if applicable, and which is strictly limited to the data required for the provision of the services offered by the Simulator, namely: 

 

Categories of data 

Examples of data 

 

Identity data 

 

Surname, first name, date of birth, gender 

 

Contact details 

 

E-mail address, user profile password 

 

Physical data 

 

Height, weight 

 

Data relating to your language skills 

 

Languages spoken 

 

Data relating to your professional situation 

 

Professional situation, practice or training structure 

 

Data relating to your surgical experience 

 

Specialisation(s), experience 

Data relating to your digital experience 

 

Hobbies, experience with video games or a musical instrument, 

playing sports, experience with virtual reality 

 

 

Data relating to your physical and mental 

condition during a simulation session 

 

Fatigue, sense of achievement 

 

Data from your simulation sessions 

 

Results and videos of the simulation sessions 

 

 

In addition, some data will be automatically collected by the Simulator, namely: 

 

Categories of data 

Examples of data 

Purposes 

Location data 

 

Location data by geographical area 

 

This data is only collected and processed 

with your prior consent 

Login and    browsing data 

Date and time of login, IP address, location of IP address, IP of newsletter subscription, pages visited, browser type, browser 

language, event logs 

 

This data is required for the proper technical operation of the simulation software and any associated equipment, as well as for measuring the use of the Simulator 

 

Some of this data is mandatory, whilst other data is optional in order to allow you to benefit from all the services offered by the Simulator. The mandatory or optional nature of the personal data to be provided is indicated at the time of collection. If you refuse to provide the mandatory data, VirtualiSurg will not be able to provide you with the services requested (such as the creation of your account on the Simulator), or respond to any other requests you may have.

 

 

  1. 2. WHY DOES VIRTUALISURG USE YOUR PERSONAL DATA?

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VirtualiSurg processes your personal data solely for the following reasons:

 

Purposes

Examples of how your personal data is used

Legal basis

Supply of personalised simulations

to provide you with a personalised training experience

Contract

Supply of personal interest 

communications

to provide you with evaluations and 

performance reports

to offer you versions of services and 

content

to invite you to training courses 

to answer your questions

to respond to your requests for assistance

Contract

Monitoring your simulations

to enable you to monitor your progress and your learning curve

Contract

Improving your user experience

to offer you a service that meets your training needs

Legitimate interests of VirtualiSurg

Improving the adaptive learning   system and machine learning

to improve the simulations to correct any errors

Legitimate interests of VirtualiSurg

Carrying out statistical studies for internal use

to evaluate the use of the Simulator to improve your user experience for research and development

Legitimate interests of VirtualiSurg

Information from our clients about the training developed for them

to improve our customer experience to provide a follow-up sales service to develop our business

Legitimate interests of 

VirtualiSurg

Presentation and training conferences arranged by our clients

to communicate about our business

to improve user handling of the Simulator to develop our business

Legitimate interests of 

VirtualiSurg

Management of pre-litigation and litigation disputes

to sanction any breach of the General Terms of Use of the Simulator or any other identified breach to manage any dispute or litigation

Legitimate interests of 

VirtualiSurg in order to 

defend its rights and 

interests

Compliance with legal and regulatory obligations

to answer your requests regarding the exercise of your rights

Legal and regulatory 

obligations which are 

binding on VirtualiSurg

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  3. 3. WHO CAN ACCESS YOUR PERSONAL DATA?

  4.  

When accessing, consulting and using the Simulator and the services it provides, your personal data may be communicated to the following recipients:

 

Recipients

Purposes

VirtualiSurg and its authorised personnel

For the purpose of providing the services offered on the Simulator and developing the Simulator

Access providers

For the purpose of providing the services offered on the Simulator

Third party service providers

For the purpose of data analysis, payment processing, information technology and the provision of related infrastructure, customer service, email delivery, auditing and other similar services

VirtualiSurg clients

For the purpose of creating and financing certain specific training simulations

VirtualiSurg affiliates

  For the purpose of developing VirtualiSurg’s  business

VirtualiSurg’s external counsel

Solely for the management of any disputes or for any other legal matter, if applicable

Administrative or legal authorities

Only if they make an express, substantiated request, in the event of an established breach of any laws or regulations

In the event of a corporate restructuring

As a result of or in connection with the restructuring, reorganisation, acquisition, debt financing, merger or sale of the assets of VirtualiSurg or similar transaction, or in the event of insolvency, bankruptcy or receivership pursuant to which personal data is transferred to one or more third parties as part of the assets of VirtualiSurg

Other third parties

Only those recipients who are necessary or appropriate for the purposes of this data protection policy, and to protect the rights, privacy, safety or property of VirtualiSurg and/or that of other persons

  1. 4. IS YOUR PERSONAL DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?

  2.  

No data concerning you that is collected and processed by VirtualiSurg is transferred to a country outside the European Union.

 

 

  1. 5. HOW DOES VIRTUALISURG PROTECT YOUR PERSONAL DATA?

  2.  

VirtualiSurg has put technical and organisational measures in place to protect your personal data, including in particular against possible breaches that could lead to the accidental or unlawful destruction, loss or alteration, or the unauthorised access or disclosure of your personal data. These measures ensure an appropriate level of data security and take into account the state of knowledge, the costs of implementation compared to the risks and the nature of the data to be protected.

Furthermore, VirtualiSurg guarantees that the members of its staff and any person called upon to process your personal data will comply with the internal rules and procedures relating to the processing of personal data, including in particular the technical and organisational security measures put in place to protect your personal data.

 

 

  1. 6. HOW LONG WILL YOUR PERSONAL DATA BE KEPT FOR?

  2.  

In general, your personal data will only be kept for the period of time required in order to achieve the purposes for which it was collected or to comply with legal or regulatory requirements.

 

Data

Purposes How long kept

Surname, first name, date of birth, gender

Monitoring your simulations

Carrying out statistical studies for internal use

Carrying out statistical studies for our clients

Management of pre-litigation or litigation disputes

Management and follow-up of requests to exercise personal rights

Up to two (2) years after your last 

contact with VirtualiSurg, unless you ask for your personal account to be deleted.

After the expiry of this two (2) year 

period, only data that is required for pre-litigation or litigation purposes is archived until the expiry of the legal statute of limitations – it being noted that the ordinary legal statute of limitations in civil and commercial matters is five (5) years.

In the event of pre-litigation or 

litigation disputes, your data will be kept for the duration of the pre- litigation or litigation dispute.

E-mail address, user profile password

Monitoring your simulations Management of pre-litigation or litigation disputes

Up to two (2) years after your last contact with VirtualiSurg, unless you ask for your personal account to be deleted.

After the expiry of this two (2) year period, only data that is required for pre-litigation or litigation purposes is archived until the expiry of the legal statute of limitations – it being noted that the ordinary legal statute of limitations in civil and commercial matters is five (5) years.

In the event of pre-litigation or litigation disputes, your data will be kept for the duration of the pre-litigation or litigation dispute.

Height, weight

Effect of your (physical and/or psychological) condition on the use of a virtual reality simulator

Provision of personalised simulation sessions

Improving your user experience Improving the adaptive learning system and machine learning

Carrying out statistical studies for internal use

Carrying out statistical studies for our clients’ use

Up to two (2) years after your last contact with VirtualiSurg, unless you ask for your personal account to be deleted.

Languages spoken

Improving your user experience

Up to two (2) years after your last contact with VirtualiSurg, unless you ask for your personal account to be deleted.

Professional situation, practice or training structure

Provision of personalised simulation sessions

Improving the adaptive learning system and machine learning

Carrying out statistical studies for internal use

Carrying out statistical studies for our

clients’ use

Up to two (2) years after your last contact with VirtualiSurg, unless you ask for your personal account to be deleted.

Specialisation(s), experience

Provision of personalised simulation sessions

Improving the adaptive learning system and machine learning

Carrying out statistical studies for internal use

Carrying out statistical studies for our clients’ use

Up to two (2) years after your last contact with VirtualiSurg, unless you ask for your personal account to be deleted.

Hobbies, experience with video games or a musical instrument, playing sports,

experience with virtual reality

Provision of personalised simulation sessions

Improving the adaptive learning

system and machine learning

Carrying out statistical studies for internal use

Carrying out statistical studies for our clients’ use

Up to two (2) years after your last contact with VirtualiSurg, unless you ask for your personal account to be deleted.

Simulation results and videos

Monitoring your simulations Improving your user experience

Conducting personal performance reviews 

Improving the adaptive learning system and machine learning

Carrying out statistical studies for internal use

Carrying out statistical studies for our clients

  Up to six (6) months.

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  3. 7. WHAT ARE YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA?

  4.  

In accordance with the applicable data protection regulations, you have the following rights with respect to your personal data:

you can request access to the personal data concerning you which is held by VirtualiSurg and obtain a copy thereof, including in electronic format;

you can ask for your personal data to be corrected, updated and deleted, and for its processing to be restricted; 

you can request that VirtualiSurg stop using your personal data;

you can request the portability of your personal data;

you may withdraw any consent you have given, although that withdrawal will not affect the legality of any processing effected before hand;

you can communicate to VirtualiSurg your “last wishes” with regard to your personal data in the event of your death (e.g. their deletion or transmission to any person of your choice).

In some cases, you will have to explain to VirtualiSurg why you are exercising one of these rights and you may have to prove your identity.

If you have any questions or wish to exercise your rights, you can contact VirtualiSurg’s data protection officer directly by sending an email to contact@virtualisurg.com or a letter to the following address:

 

 

VIRTUALISURG

Département données personnelles

191-195, Avenue Charles de Gaulle 92000 Neuilly-sur Seine

 

 

If necessary, you may submit a request to the CNIL via its website or by post: 3, place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07. This right can be exercised at any time free of charge, apart from the postage costs and the costs of any assistance or representation if you choose to be assisted in this procedure by a third party.

 

 

  1. 8. POLICYUPDATES

  2.  

This policy may be amended, particularly in the event of changes to the services offered by VirtualiSurg on its Simulator. We therefore recommend that you consult this policy each time you access the Simulators.

Date de mise à jour : 11 juin 2021
Date d’édition : 1er septembre 2021