Lifeaz Privacy Policy

At Lifeaz, protecting your personal data is a priority.

The purpose of this policy is to inform you about how we process this data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the “GDPR”).

The following terms and expressions, when used with capital initials, have the meanings ascribed to them in the Terms and Conditions of Use for Lifeaz Services (the “Services”) offered on the website (the “Site”).

When you subscribe to the Services and use the Site and Services, we may process personal data about you.

1. Who is the data controller?

The data controller is Lifeaz, a simplified joint stock company, registered in the Paris Trade and Companies Register under no. 814 042 958, having its registered office at 15 Rue Béranger, 75003 Paris (hereinafter referred to as “We”).

2. What data do we collect?

Personal data is data that can be used to identify an individual, either directly or by cross-referencing with other data.

We collect data in the following categories:

Identification data (e.g. surname, first name, e-mail address, postal delivery and billing address, telephone number);
Data relating to your orders (e.g. CLARK product serial number);
Browsing data (e.g. IP address, pages viewed, date and time of connection, browser used, operating system, user ID, IFA);
Economic and financial data (e.g. bank details, credit card data, invoices);
Data relating to our post-marketing clinical follow-up (surname, first name, email address, telephone number, postal address, CLARK serial number);
Data relating to alerts raised by CLARK (serial number, information on the software and its operation, IP address of the Clark, identification data (surname, first name) of and/or data relating to the private and/or professional life of the victim may be collected incidentally);
Any information you wish to send us as part of your contact request.

When we collect your personal data, we inform you whether certain information is mandatory or optional. Mandatory data is marked with an asterisk and is required for the operation of the Services. You are entirely free to choose whether or not to provide optional data. We will also inform you of the possible consequences of failing to do so.

3. On what legal grounds, for what purposes and for how long do we store your personal data?

Goals Legal basis Shelf life
Fulfill your order, carry out operations relating to the management of your contracts, orders, deliveries, invoices, and follow up our contractual relationship. Performance of the contract you or your company have entered into with us Personal data is kept for the duration of the contractual relationship.

In addition, your data (with the exception of your bank details) is archived for evidentiary purposes for a period of 5 years.

Your credit card details are kept by our payment service provider until the price has been paid in full.

Data relating to the visual cryptogram or CVV2, written on your bank card, is not stored.

Your credit card details may be kept in an intermediate archive for a period of thirteen (13) months following the debit date, for the purposes of proof in the event of a disputed transaction. This period may be extended to fifteen (15) months to take account of the possibility of using deferred debit cards.

Your invoices are archived for 10 years.
Build a file of customers and prospects Our legitimate interest in developing and promoting our business For customers: data is kept for the duration of the contractual relationship.

For prospects: data is kept for a period of 3 years from your last contact, for prospecting purposes.
Follow-up on alerts raised by our CLARKs Comply with our legal and regulatory obligations regarding medical devices Data retention for 15 years from the date the last device was placed on the market
Send our newsletter For professionals: our legitimate interest in building customer loyalty and informing our customers of our latest news
For individuals: your consent
Data is kept for 3 years from your last contact with us or until your consent is withdrawn.
Responding to your requests for information Our legitimate interest in responding to your requests Data is kept for the time necessary to process your request for information and is deleted once the request has been processed.
Comply with legal obligations applicable to our business Comply with our legal and regulatory accounting obligations Your invoices are archived for 10 years.
Post-Market Clinical Follow-up as part of the CE marking of our CLARK products Comply with our legal and regulatory obligations regarding medical devices Post-marketing clinical follow-up data is kept for the entire life of your Clark product.
To compile statistics on the Site's audience Your consent Data is kept for 2 years.

4. Who will receive your data?

Will have access to your personal data:

(i) Authorized personnel of our company;
(ii) Our subcontractors: hosting service providers, newsletter sending service provider, audience measurement tools, CRM tool, chatbot tool, online payment service provider, invoicing and bank transfer tools, data collection and visualization tools, telephony tool;
(iii) Our delivery and logistics partners for your orders;
(iv) Where applicable: public and private bodies, exclusively to meet our legal obligations.

5. Is your data likely to be transferred outside the European Union?

Your data is kept and stored for the duration of processing on the servers of AIRTABLE, located in the European Union, and GOOGLE CLOUD, located in Belgium in the European Union.

In the context of the tools we use (see article on recipients concerning our subcontractors), your data may be transferred outside the European Union. The transfer of your data in this context is secured using the following tools:

• or the data is transferred to a country that has been the subject of an adequacy decision by the European Commission, in accordance with Article 45 of the RGPD: in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the RGPD;

• or the data is transferred to a country whose level of data protection has not been recognized as adequate to the RGPD: in this case such transfers are based on appropriate safeguards indicated in Article 46 of the RGPD, tailored to each provider, including but not limited to the conclusion of standard contractual clauses approved by the European Commission, the application of binding corporate rules or under an approved certification mechanism.

• or the data is transferred on the basis of one of the appropriate guarantees described in Chapter V of the RGPD.

6. What are your rights regarding your data?

You have the following rights with regard to your personal data:

Right to information: this is precisely why we have drawn up this policy. This right is provided for in Articles 13 and 14 of the RGPD.

Right of access: you have the right to access all your personal data at any time, pursuant to Article 15 of the RGPD.

Right of rectification: you have the right to rectify inaccurate, incomplete or obsolete personal data at any time in accordance with Article 16 of the GDPR.

• Right to limitation: you have the right to obtain the limitation of the processing of your personal data in certain cases defined in Article 18 of the RGPD.

• Right to erasure: you have the right to demand that your personal data be erased, and to prohibit any future collection on the grounds set out in Article 17 of the GDPR.

• Right to lodge a complaint with a competent supervisory authority (in France, the CNIL), if you consider that the processing of your personal data constitutes a breach of the applicable texts. (Article 77 of the RGPD)

The right to define directives concerning the conservation, deletion and communication of your personal data after your death, in accordance with article 40-1 of the French Data Protection Act.

Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the RGPD states that you may withdraw your consent at any time. This withdrawal will not call into question the legality of the processing carried out prior to the withdrawal.

• Right to portability: under certain conditions specified in Article 20 of the RGPD, you have the right to receive the personal data you have provided to us in a standard machine-readable format and to demand its transfer to the recipient of your choice.

Right to object: under Article 21 of the RGPD, you have the right to object to the processing of your personal data. Please note, however, that we may continue to process them despite this objection, for legitimate reasons or the defense of legal rights.

You can exercise these rights by writing to us using the contact details below. We may ask you to provide additional information or documents to prove your identity.

7. Which cookies do we use?

8. Contact point for personal data OR Data Protection Officer

Contact email:
Adresse Contact: Lifeaz, 15 Rue Béranger, 75003 Paris

9. Modifications

We may modify this policy at any time, in particular in order to comply with any regulatory, legal, editorial or technical developments. These modifications will apply as of the effective date of the modified version. You are therefore invited to consult the latest version of this policy on a regular basis. Nevertheless, we will keep you informed of any significant changes to this privacy policy.

Effective date: 01/08/2022