Comet BioBank website privacy policy

AxLR, SATT DU LANGUEDOC ROUSSILLON (hereinafter “SATT AxLR”) considers that the protection and respect of the User’s privacy on the https://cometbiobank.com/ website (hereinafter the “Website”) is of great importance.

SATT AxLR is committed to implementing the necessary measures for the protection, privacy, and security of Users’ Personal Data in accordance with applicable European and French regulations concerning personal data protection, in particular the European Union Regulation (EU) 2016/679 of April 27, 2016 on the protection of natural persons with regard to the processing of personal data, as well as the national legal regulations implemented for its application. This Privacy Policy describes how SATT AxLR processes the Users’ Personal Data in its function as Data Controller.

1. Definitions 

The User (or “You”): any Internet user who browses, reads, views, and uses the Website.

Personal Data: any and all information relating to an identified or identifiable natural person. An “identifiable natural person” is defined as a natural person who can be identified either directly or indirectly, notably through reference to a specific identifier, such as a name, identification number, location data, online identifier, or to one or more elements specific to his/her physical, physiological, genetic, psychological, economic, cultural, or social identity.

Processing: any operation or series of operations relating to Personal Data, regardless of the process used (including, but not limited to collection, recording, organization, storage, adaptation, modification, extraction, retrieval, use, communication by broadcast transmission or any other form of dissemination, matching or interconnection, blocking, deletion or destruction, etc.).

Data Controller: the person or entity that determines the purposes and means to be used for processing Personal Data.

2. Data controller

The Data Controller  is AxLR, SATT DU LANGUEDOC ROUSSILLON, a simplified joint stock company with equity capital of 1,112,000 euros, located at 950 rue Saint-Priest – CSUM Bâtiment 6 – 34090 Montpellier, France (Business registry RCS Montpellier 753 642 248 00029).

For any questions concerning this Privacy Policy, or if you wish to exercise your rights under applicable Personal Data protection legislation, please feel free to contact SATT AxLR by writing to dpo@axlr.com or by sending postal mail to the following address: SATT AxLR – DPO, 950 rue Saint Priest, CSU, Bâtiment 6 – 34090 Montpellier, France.

You are also welcome to visit the website of the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés - CNIL) – www.cnil.fr) www.cnil.fr – for further information on personal data protection.

By using this Website, the User agrees to the collection and use of his/her Personal Data as described in this Privacy Policy. If the User does not agree with the terms of these practices, he/she is free to choose not to use this Website and not to provide any Personal Data.

3. Collected personal data

The User’s Personal Data that may be collected on the Website and processed by SATT AxLR is the following:

  • Identity and contact details: last name, first name, address, telephone number, e-mail address
  • Professional information: User’s company and job title, curriculum vitae
  • IP (Internet Protocol) address of the User’s Internet connection
  • Connection and navigation data:
    • Location (city, country)
    • Data related to server connections (incoming path, pages visited, URLs visited and/or people who will be visited, time stamp) 
    • Computer equipment identifiers (device type, screen resolution, brands, operating system) 
    • Login details (service provider, browser)
  • Cookies
  • If the User shares Website information on social networks (Facebook, Google +, Twitter, LinkedIn): the shared page, platform, number of users that have shared it
  • All other personal data that may be provided voluntarily to SATT AxLR by the User

4. Purposes for processing personal data

SATT AxLR only uses Personal Data strictly for the purposes for which it is collected.

Personal Data processing operations performed by SATT AxLR have the following purposes, to:

  • Enable and improve navigation on the Website; manage and track connection data and use of the Website;
  • Improve Website content relevance and optimize Website exposure;
  • Process requests received from the User;
  • Produce anonymous statistics;
  • Evaluate responses to calls for proposals;
  • Carry out candidate recruitment actions (jobs, competitions, calls-for-projects, etc.);
  • Conduct optional satisfaction surveys;
  • Analyze company creation projects to use innovative technology from a public laboratory;
  • Expand SATT AxLR network to prepare for potential partnerships/collaborations;

To this end, SATT AxLR shall only process your Personal Data on one of the following legal grounds:

  • Your consent;
  • Processing is necessary to execute a contract to which you are a party, or to take action upon your request before entering into a contract;
  • Processing is necessary so that SATT AxLR can comply with its legal obligations;
  • Processing is necessary for the pursuit of SATT AxLR’s legitimate interests.

5. Collection of personal data

Personal Data is collected:

  • Directly from the User when he/she:
    • Fills in a form on the Website for information or correspondence purposes;
    • Contacts SATT AxLR by any communication method (e-mail, telephone, postal mail, etc.);
  • Indirectly, through the use of browser tracking tools or cookies, when the User:
    • Navigates on the Website and views advertisements
    • Shares an offering or information via social networks such as Facebook, Google +, Twitter, and LinkedIn.

SATT AxLR automatically stores some Personal Data related to Users’ browsing on the Website. Such Personal Data is compiled and analyzed globally and may include the URL that the User visited previously, the URL to which the User goes afterwards (regardless of whether those URLs are on the Website), which browser is used, and the User’s IP address.

6. Cookie warning

What are cookies?

The term cookie comprises several technologies that can be used to monitor the User’s browsing or perform behavioral analysis. There are several such technologies, including cookies, tags, pixels, and JavaScript code. A cookie is a small text file placed on the User’s computer or mobile device when he/she visits a website. Cookies are stored by SATT AxLR on the User’s computer when he/she visits the Website. These cookies cannot identify the User, but they do record information relating to the User’s connection and navigation as indicated in Article 5.

Cookies stored by SATT AxLR when the User navigates around the Website to:

  • Ensure the proper operation of the Website;
  • Record data provided by the User to personalize his/her browsing experience.

Third-party cookies may also be used to identify services accessed on the Website and to compile statistics. These cookies allow SATT AxLR to understand Website use and performance, compile statistics, and track visitor traffic and usage volumes for the various sections of the Website (content visited, paths taken) to improve the appeal and ergonomics of its services.

Cookies are stored by Google Analytics and are thus covered by Google Analytics’ cookie policy (see Article 7).

Cookies from other third-party partners may also be placed on the Website. To find out more, the User is encouraged to check the cookie management panel available in the lower right-hand corner of each page of the “Service Management” site.

All third-party cookies are subject to the privacy policies of those third parties. SATT AxLR does not have access to those privacy policies and does not control them.

How to configure cookie storage?

The User has several ways to manage his/her choices regarding cookies:

  • The User’s web browser can be configured to notify the User when cookies are stored on his/her device and ask whether or not to accept them on a case-by-case basis, or refuse them systematically.
  • The User can configure cookies directly on the Website using the displayed banner. He/she can accept all cookies, customize or forbid all cookies by making changes in the cookie management panel.

Since cookies collect personal information about the User indirectly, the User also has the right to access, delete, and modify that information. How long is the data collected by cookies stored?

Cookies placed by SATT AxLR retain the information collected on the User’s computer for a period of twelve (12) months from the time of browsing.

7. Google analytics privacy policy

Google Analytics is a tool for web traffic analysis provided by Google, Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). Google Analytics provides information about how often the User visited the Website, pages visited, session duration, and how he/she interacted with the Website. This means that the information generated by cookies may be transmitted and stored by Google on servers abroad, in compliance with the legal requirements of the countries in which those servers are located.

The User has the option to decline Google Analytics cookies by making changes in the cookie control panel as described in Article 6.

To find out more about Google Analytics’ privacy policy, the User is encouraged to review the information available on the following page: https://policies.google.com/privacy.

If the browser is used to configure cookies, SATT AxLR informs the User that his/her browsing and experience on the Website may be limited.

8. Minors

This Website is not designed for minors. However, in case of use by a minor, the data collection must be carried out with the explicit consent of the person having parental responsibility for any child under 15 years old, to be sent by e-mail to the following address: dpo@axlr.com.

9. Storage duration for personal data 

Unless the User asks SATT AxLR to delete his/her Personal Data, which is accepted under the conditions stipulated in Article 12, SATT AxLR will retain the User’s Personal Data for the time necessary to achieve the purposes mentioned in Article 4, for a maximum period of twelve (12) months unless a longer storage period is required by legal obligation.

10. Recipients and transfer of personal data

Only SATT AxLR employees and subcontractors who need to know the User’s Personal Data for the purposes of carrying out the processing operations described in Article 4, and who have been made aware of the need to comply with rules on Personal Data privacy and security, may access Personal Data.

The Personal Data collected and processed by SATT AxLR via the Website is not transferred or rented, free of charge or for compensation, in any manner whatsoever, to third parties or transferred outside the European Union. If SATT AxLR is called to transfer Personal Data outside the European Union, it shall first notify the User and shall, in all cases, ensure that such data is transferred to a country for which a European Commission decision regarding its adequacy has been taken or, in the absence thereof, that the legal tools used to secure the transfer of Personal Data are applied in compliance with applicable regulations.

Personal Data about SATT AxLR employees that is available on the Website may not be collected or processed without the prior written consent of the person in question.

In addition, all Users are prohibited from collecting and using such Personal Data, either manually or automatically, to send advertising messages or any other type of message that is unrelated to SATT AxLR activities and those of its employees.

11. Security of personal data

SATT AxLR has implemented protective measures to ensure confidentiality, security, and integrity for Users’ Personal Data. In particular, SATT AxLR makes sure that (i) the User’s Personal Data is not altered and/or damaged, and that (ii) no unauthorized third parties have access to that data.

However, if an incident that affects the integrity and/or privacy of the User’s Personal Data comes to SATT AxLR’s attention, and poses a significant risk to the User’s rights and freedoms, SATT AxLR will inform the User of the situation as soon as possible and of the corrective measures being taken or planned to remedy the Personal Data breach.

12. The user's rights

In compliance with French law no. 78-17 of January 6, 1978 (amended) on data processing, files, and freedoms, and European Regulation 2016/679 of April 27, 2016 on the protection of personal data, people from whom Personal Data is collected have various rights regarding the management of their data:

  • The right to access: the User may request confirmation as to whether or not his/her Personal Data is being processed by SATT AxLR. If Personal Data is being processed, the User may request a copy of that data at no cost, on the condition that the request is not patently abusive, notably due to its repetitive or systematic nature.
  • The right to rectification: the User may request that incorrect information concerning him/her be modified or updated.
  • The right to be forgotten: the User may request that information concerning him/her contained in SATT AxLR databases be deleted to the extent that the information is no longer relevant for any of the purposes stated above, and on the condition that there is no legitimate interest for SATT AxLR or legal obligation requiring such information to be retained.
  • The right to oppose and revoke consent: at any time, the User may request to no longer be included in a file in SATT AxLR databases, unless SATT AxLR demonstrates legitimate and compelling reasons that may prevail over the User’s interests, rights, and freedoms.
  • The right to request restriction of Processing: the User may request that Processing concerning him/her be suspended under the circumstances stipulated by regulations, namely when:
  • The User disputes the accuracy of his/her Personal Data for a period of time that is sufficient for SATT AxLR to verify the accuracy of that Personal Data;
  • The Processing faces a legal challenge and the User objects to the deletion of his/her Personal Data, but instead demands that the use of such data be limited;
  • SATT AxLR no longer has any need for the Personal Data for processing purposes, but such Personal Data is still needed to establish, exercise, or defend the User’s legal rights;
  • The User has opposed Processing, while checking whether the legitimate motivations pursued by the Data Controller prevail over those of the User.
  • The right to portability: the User may request the transmission of his/her Personal Data in a structured format to SATT AxLR or another data controller, to the extent that (i) it is technically possible to do so, and (ii) the Processing of Personal Data is based on the User’s consent.
  • The right to determine general and/or specific instructions regarding the Processing of Personal Data, and the manner in which the User wishes his/her rights to be exercised after his/her death. In the event that SATT AxLR is informed of a User’s death, that User’s Personal Data will be deleted, unless there is a requirement to retain it for a specified period of time for reasons related to legal and regulatory obligations and/or statutory limitation periods imposed on SATT AxLR, and if applicable, after having transmitted the Personal Data to a third-party designated by the User.

The User is hereby advised that he/she may file a complaint with the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés - CNIL) in the event of a dispute.

The User’s rights mentioned above can be exercised by sending e-mail to dpo@axlr.comdpo@axlr.com or by writing to the following address: SATT AxLR – Protection des données DPO, 950 rue Saint Priest, CSU, Bâtiment 6 – 34090 Montpellier, France.

To ensure the privacy and protection of Personal Data, SATT AxLR must verify the person’s identity before responding to any such a request. The User must therefore provide a copy of his/her identity document (identity card or passport) as proof of identity.