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. 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.
-
2. WHY DOES VIRTUALISURG USE YOUR PERSONAL DATA?
-
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 |
-
-
-
3. WHO CAN ACCESS YOUR PERSONAL DATA?
-
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 |
-
4. IS YOUR PERSONAL DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?
-
No data concerning you that is collected and processed by VirtualiSurg is transferred to a country outside the European Union.
-
5. HOW DOES VIRTUALISURG PROTECT YOUR PERSONAL DATA?
-
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.
-
6. HOW LONG WILL YOUR PERSONAL DATA BE KEPT FOR?
-
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. |
-
-
-
7. WHAT ARE YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA?
-
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.
-
8. POLICYUPDATES
-
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.