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Privacy Policy

INFORMATION ON THE PROCESSING OF USERS' PERSONAL DATA PURSUANT TO ARTICLE 13 OF REGULATION (EU) 2016/679 ("GDPR") - "CORCYM"

	DATA CONTROLLER	Company name: Corcym S.r.l. Address: Via Giovanni Spadolini 7, 20141, Milan, (Italy) E-mail address: privacy@corcym.com ('Company').

	DATA PROTECTION OFFICER (DPO)	Company name: Corcym S.r.l. Address: Via Giovanni Spadolini 7, 20141, Milan, (Italy) E-mail address: dpo@corcym.com

COLLECTION AND PROCESSING OF DATA

Navigation data
The computer systems and software procedures used to operate this Website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified.
This category of data includes the IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user's operating system and IT environment.
These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct operation, and are deleted immediately after processing.
The data could be used to ascertain liability in the event of hypothetical computer crimes against the site.
Such data are as a rule deleted immediately after processing.

PERSONAL DATA PROCESSED

When you browse the site www.corcym.com the Company, in addition to your browsing data (see Cookie Policy which can also be accessed via the link at the bottom of the page), processes data that you directly provide in order to take advantage of certain services provided by the Company and which are better specified below. By way of example, this is "common data" such as your personal details, contact details, country of residence, information relating to your professional role and the hospital where you work, as well as an indication of the training course you are interested in.

PURPOSE OF PROCESSING

LEGAL BASIS OF PROCESSING

DATA RETENTION

Handling of user requests received by filling in the online form and eventual re-contacting of the same if the request is received by the competent office via one of the territorially competent email addresses. The services provided through the Contact Us channel are as follows: Customer service; Investigator-initiated research as well as Donations and grants (the processing of common data relates to the management of a request for sponsorship for the initiation and management of a research project; Product Safety and Patient Card (data processing relates to the handling of a user request, which may concern both the patient card or registration form received following implantation of the medical device and any observations and/or reports on the implanted medical device.	The processing of common data is necessary for the performance of the contract to which the data subject is a party pursuant to Art. 6(1)(b) GDPR. With regard to the possible processing of special categories of data transmitted with the request under letter c), the Data Controller is legitimized for reasons of public interest in health care consisting in guaranteeing high parameters of quality and safety of the medical device pursuant to Art. 9(2)(i), GDPR.	The data are kept by the competent office for as long as is necessary to process the request.
Collection of personal data for the receipt of information and marketing material on activities implemented by Corcym, including invitations to events or other initiatives	The processing of common data requires the consent of the data subject pursuant to Art. 6(1)(a) GDPR	Data are retained until consent is revoked by the data subject
Communication, by e-mail, of information on how to register for and manage the event to which individual professionals are invited either individually or through their companies	The processing of common data is necessary for the pursuit of the legitimate interest of the Controller pursuant to Art. 6(2)(f) GDPR	Data are kept until the data subject objects in order to inform the individual professional of further events of interest to him/her
Technical administration and management of website operation	The processing of common data is necessary for the performance of the contract to which the data subject is party pursuant to Art. 6(1)(b) GDPR	Data are retained for the duration of navigation on the Site
If necessary, to ascertain, exercise or defend the Controller's rights in extrajudicial and/or judicial proceedings	The processing of common data is necessary for the pursuit of the legitimate interest of the Controller (legal protection) pursuant to Art. 6(2)(f) GDPR	The data are kept for the duration of the litigation, until the time limit for appeals is exhausted.

After the storage periods indicated above, the Data will be destroyed, erased or anonymised compatibly with the technical procedures of erasure and backup and with the accountability requirements of the owner.

	PURPOSE OF PROCESSING
Handling of user requests received by filling in the online form and eventual re-contacting of the same if the request is received by the competent office via one of the territorially competent email addresses. The services provided through the Contact Us channel are as follows: Customer service; Investigator-initiated research as well as Donations and grants (the processing of common data relates to the management of a request for sponsorship for the initiation and management of a research project; Product Safety and Patient Card (data processing relates to the handling of a user request, which may concern both the patient card or registration form received following implantation of the medical device and any observations and/or reports on the implanted medical device.
Collection of personal data for the receipt of information and marketing material on activities implemented by Corcym, including invitations to events or other initiatives
Communication, by e-mail, of information on how to register for and manage the event to which individual professionals are invited either individually or through their companies
Technical administration and management of website operation
If necessary, to ascertain, exercise or defend the Controller's rights in extrajudicial and/or judicial proceedings
	LEGAL BASIS OF PROCESSING
The processing of common data is necessary for the performance of the contract to which the data subject is a party pursuant to Art. 6(1)(b) GDPR. With regard to the possible processing of special categories of data transmitted with the request under letter c), the Data Controller is legitimized for reasons of public interest in health care consisting in guaranteeing high parameters of quality and safety of the medical device pursuant to Art. 9(2)(i), GDPR.
The processing of common data requires the consent of the data subject pursuant to Art. 6(1)(a) GDPR
The processing of common data is necessary for the pursuit of the legitimate interest of the Controller pursuant to Art. 6(2)(f) GDPR
The processing of common data is necessary for the performance of the contract to which the data subject is party pursuant to Art. 6(1)(b) GDPR
The processing of common data is necessary for the pursuit of the legitimate interest of the Controller (legal protection) pursuant to Art. 6(2)(f) GDPR
	DATA RETENTION
The data are kept by the competent office for as long as is necessary to process the request.
Data are retained until consent is revoked by the data subject
Data are kept until the data subject objects in order to inform the individual professional of further events of interest to him/her
Data are retained for the duration of navigation on the Site
The data are kept for the duration of the litigation, until the time limit for appeals is exhausted.
After the storage periods indicated above, the Data will be destroyed, erased or anonymised compatibly with the technical procedures of erasure and backup and with the accountability requirements of the owner.

OBLIGATION TO PROVIDE DATA

Browsing data are necessary in order to carry out computer and telematic protocols, therefore, failure to provide them would not allow this website to function.
The provision of data by filling in the online form in the Contact Us section is optional, but failure to provide it will not allow the user to forward their request. The provision of data for the purposes of registering on the web portal and creating a personal account is necessary in order to proceed with registration for the training course, webinar of your interest.

DATA RECIPIENTS
Data may be processed by external parties acting as autonomous data controllers such as, for example, authorities and supervisory and control bodies.
The data may also be processed, on behalf of the Company, by external parties designated as data processors (pursuant to Article 28 of the GDPR), who are given appropriate operating instructions. These subjects, by way of example, may be companies that perform the management and/or maintenance service of the Company's website.

SUBJECTS AUTHORISED TO PROCESS
The data may be processed by employees and/or collaborators of the Controller and/or the Manager entrusted with the pursuit of the aforementioned purposes, who have been expressly authorized to process them and who have received appropriate operating instructions.

TRANSFER OF PERSONAL DATA TO COUNTRIES OUTSIDE THE EUROPEAN UNION

Personal Data collected through the website will not be transferred to third countries and/or International Organizations outside the European Union; the server is located within the European Union.

The Data may be processed by Data Processors that are also based in countries outside the European Union, whose level of data protection has been deemed adequate by the European Commission pursuant to Article 45 of the GDPR.

The transfer of your personal data may also be carried out following the signing of Standard Contractual Clauses (Standard Contractual Clauses) provided for in Article 46(2)(c) of the GDPR.

RIGHTS OF THE DATA SUBJECT - COMPLAINT TO THE SUPERVISORY AUTHORITY
By contacting the Privacy Office, by mail at privacy@corcym.com, or the DPO (Data Protection Officer), by mail at dpo@corcym.com, data subjects may request from the data controller access to the data concerning them, their deletion, the rectification of inaccurate data, the integration of incomplete data, the restriction of processing in the cases provided for by Article 18 GDPR, as well as opposition to processing, for reasons related to their particular situation, in cases of legitimate interest of the data controller.
Data subjects may at any time request the withdrawal of their consent to receive information and promotional material.
In addition, where the processing is based on consent or contract and is carried out by automated means, data subjects have the right to receive the data in a structured, commonly used and machine-readable format and, if technically feasible, to transmit them to another data controller without hindrance.
Data subjects have the right to lodge a complaint with the competent supervisory authority in the Member State where they habitually reside or work or in the State where the alleged infringement occurred.

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