PERSONAL DATA PROTECTION POLICY


Update 2/14/2024

1. GLOSSARY

2. PREAMBLE

MN Santé Holding places the protection of personal data at the heart of its missions and the services it offers you. This Policy sets out the principles and guidelines for the protection of your Personal Data and aims to inform you about :

This Policy applies to the processing of Personal Data in the context of the provision of MN Santé Holding services and products, excluding any partner sites. All operations involving your Personal Data are carried out in compliance with the regulations in force and in particular with the European regulations on the protection of personal data, the French law n°78-17 "Informatique, Fichiers et Libertés" of 6 January 1978 as amended and its application decrees.

3. HOW DOES MN SANTE HOLDING TAKE INTO ACCOUNT THE PROTECTION OF PERSONAL DATA?

MN Santé Holding is committed to taking into account the protection of your Personal Data and your private life from the very beginning of the design of new products or services offered to you. To ensure security and guarantee the respect and proper exercise of your rights, measures are implemented to ensure the protection of your personal data.

4. HOW DOES MN SANTE HOLDING COLLECT YOUR PERSONAL DATA?

MN Santé Holding undertakes to only collect data that is strictly necessary for the direct or indirect provision of the services subscribed to when they require the processing of customers' personal data.

In the event that you are asked for optional data, MN Santé Holding will clearly inform you of the Personal Data that is essential for the performance of the subscribed service.

Personal Data is collected directly from you and is used only for the purposes for which you have been notified.

Personal data is used to offer you other services, only if you have agreed to receive commercial communications.

Certain data processed by MN Santé Holding is collected indirectly from the following sources :

In the event of indirect collection, MN Santé Holding undertakes to inform individuals in accordance with the conditions set out in Article 14 of the GDPR.

Some services may be used by minors. In this case, minors must obtain the consent of their parents or legal representatives.

5. WHAT ARE THE PURPOSES OF THE PROCESSING CARRIED OUT BY MN SANTE HOLDING, THEIR LEGAL BASIS AND THE RETENTION PERIOD OF PERSONAL DATA?

Depending on the personal data processing implemented, MN Santé Holding acts as a Data Controller or Subcontractor for its customers. When MN Santé Holding acts as a Data Controller, the purposes of the processing carried out and the length of time the Personal Data is kept are set by MN Santé Holding.

You can consult the purposes of the processing operations as well as their legal basis and the retention periods for personal data resulting from the processing operations carried out by MN Santé Holding, in its capacity as Data Controller, by clicking on the following link: Processing of Personal Data implemented in the context of MN Santé Holding's services and processing

Generally speaking, the purposes, the retention period and the legal basis differ according to the services and products concerned. At the end of the retention periods, the Personal Data are anonymized or permanently deleted

When MN Santé Holding acts as a Subcontractor for its customers, the purposes of the processing and the length of time the Personal Data is kept are determined by the customer who is responsible for processing. In this context, MN Santé Holding only acts on the instructions of the Data Controller. The processing operations for which MN Santé Holding acts as a Subcontractor are specified in the table accessible by clicking on the following link : Processing for which MN Santé Holding acts as a subcontractor

For any information on the retention periods for Personal Data processed by MN Santé Holding as a subcontractor, we invite you to contact the healthcare establishment, which is responsible for processing, and which provided for the opening of your account on one of MN Santé Holding's solutions for monitoring your health.

Healthcare facilities may be subject to legal obligations to retain Personal Data, on their own environments, for longer periods than those set forth in this Data Protection Policy.

6. TO WHICH SERVICES OR COMPANIES ARE YOUR PERSONAL DATA COMMUNICATED?

The personal data that you communicate to MN Santé Holding may be transmitted to the following recipients :

7. CAN YOUR PERSONAL DATA BE TRANSFERRED OUTSIDE THE EUROPEAN UNION?

The Personal Data processed by MN Santé Holding is hosted within the European Union (EU) or the European Economic Area (EEA). However, for certain specific services, MN Santé Holding may use subcontractors established outside the EU or the EEA (for example, in the United States). These subcontractors may have access to Personal Data that is strictly necessary for the performance of their tasks. In this case, in accordance with the regulations in force, MN Santé Holding requires its subcontractors to provide appropriate guarantees, in particular the signing of standard contractual clauses by the European Commission or the adoption by the latter of Binding Corporate Rules.

8. IS YOUR PERSONAL DATA PROTECTED?

MN Santé Holding is committed to taking all measures to ensure the security and confidentiality of Personal Data.

In particular, MN Santé Holding implements all the technical and organisational measures required to guarantee the security and confidentiality of the Personal Data collected and processed and in particular to prevent it from being distorted, damaged or communicated to unauthorised third parties, by ensuring a level of security adapted to the risks associated with the processing and the nature of the personal data to be protected.

The treatments performed may be subject to audit.

Furthermore, in the event of a personal data breach, as defined in Article 4 of the GDPR, affecting your Personal Data (destruction, loss, alteration or disclosure), MN Santé Holding undertakes to comply with the obligation to notify Personal Data breaches, notably to the CNIL.

9. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA AND HOW TO EXERCISE THEM?

10. HOW TO CONTACT THE PERSONAL DATA PROTECTION OFFICER APPOINTED BY MN SANTE HOLDING?

You can contact the Data Protection Officer at the following address :

MN SANTE - Monsieur le délégué à la Protection des Données
9 RUE DU COLONEL PIERRE AVIA, 75015 PARIS 15

Or by email at the following address :

dpo-mns@careside.care

If you believe, after having contacted us, that your rights on your data are not respected, you can address a complaint to the Commission Nationale de l'Informatique et des Libertés (3 place de Fontenoy - TSA 80715 – 75334 Paris cedex 07 ; tél. : 01 53 73 22 22).


PROCESSING OF PERSONAL DATA CARRIED OUT BY MN SANTE HOLDING, AS DATA CONTROLLER, FOR THE REALIZATION OF THE SERVICES OFFERED ON THE SITE MN Santé Holding
SERVICES PURPOSE LEGAL BASES SHELF LIFE
Contact requests sent by users via the form « Contact »
accessible in the menu and in the footer of the site MN Santé Holding
  • To allow site users to communicate with MN Santé Holding.
  • Manage user requests for information.
  • Follow up on responses to contact requests.
  • Communicate on MN Santé Holding news.
  • Elaborate statistics related to the service
Consent Retention for 3 years after the last
contact with MN Santé Holding.
Contact requests sent by :
- the professionals of the health institutions transmitted via the form
« Tell us about your e-health projects »
- or journalists via the "send an email" button accessible in the button
« CONTACT » available on the site
  • To enable healthcare professionals
    and journalists to communicate with MN Santé Holding
    and learn about its products and services.
  • Manage requests for information from
    healthcare professionals and journalists
  • Follow up on responses to contact requests.
  • Communicate on MN Santé Holding news.
  • Elaborate statistics related to the service
Consent Retention for 3 years after the last contact with MN Santé Holding.
Subscribe to the Newsletter via the dedicated form on the website
  • Handle newsletter registration requests
  • Manage subscriptions
  • Send Newsletter
  • Elaborate statistics related to the service
 Consent

Performance of the service (contract) 		Storage of the necessary data for the duration of the subscription to the newsletter.
Recruiting
Submit your application via the dedicated form available on MN Santé Holding
  • To allow users to consult and
    apply for MN Santé Holding job offers
  • Allow users to submit a spontaneous application
  • Process applications
  • Communicate on MN Santé Holding news.
  • Contact the candidates
MN Santé Holding's legitimate interest in recruiting candidates Data retention for the duration of the recruitment process and 2 years from the last contact with the candidate



OTHER PROCESSING OPERATIONS CARRIED OUT BY MN SANTE HOLDING, IN ITS CAPACITY AS DATA CONTROLLER, FOR THE PROVISION OF THESE SERVICES
SERVICES PURPOSE LEGAL BASES SHELF LIFE
Commercial prospecting by MN Santé Holding
  • Carrying out commercial prospecting and
    marketing operations by electronic means,
    by mail or through a MN Santé Holding employee (surveys, etc.)
 Legitimate interest of MN Santé Holding, with regard to prospecting:
- by telephone;
- by electronic means

when it is intended for persons
who are already customers and when the prospecting concerns products and services similar< br> to those already subscribed by these persons;

Consent of the prospects/customers regarding electronic prospecting (SMS, email) 		Retention for 3 years from the last contact or until consent is withdrawn
Management of commercial activities
  • The management of the operations necessary for the products or services subscribed to.
  • Management of our commercial relations, including responses to contact requests received.
  • Management of complaints to the customer service
  • Management of the after-sales service;
  • Management of newsletter subscriptions
Performance of the service (contract)

Consent

Legitimate interest (improving the quality of service)

Conservation for the entire duration of the contractual relationship,
after which only the data necessary for pre-litigation or litigation
purposes are archived until the acquisition of the legal prescription.
The limitation period of common law in civil and commercial matters is
five (5) years. The data is kept until the subscriber unsubscribes

For the realization of satisfaction surveys:
conservation during 1 year as from the survey. For the management of complaints:
conservation during 13 months as from the date of reception of the complaint

Health vigilance management
  • To ensure the prevention, monitoring, evaluation and management of adverse health events
 Legal obligation

Retention of data in the active database for as long as necessary
to manage the adverse health event.

Data retention in intermediate database 10 years after
the end of the health event.

Once the retention periods have expired, the data will be deleted
or archived in an anonymized form for 25 years.
Post-Market Surveillance
  • Analyze relevant data on the quality,
    performance and safety of the medical device throughout its lifetime;
  • Draw the appropriate conclusions;
  • Define and apply any preventive or corrective measures, and ensure their follow-up.
 Legal obligation

Retention of data from analytical documents
(clinical evaluation, reports, surveillance report, periodic safety report)
for 2 years after the last publication of the analytical documents.

At the end of the retention period,
the data is archived in an anonymized form for 25 years.
Official requests from public or judicial authorities empowered to do so
  • Management of responses to official requests
    from public or judicial authorities empowered to do so
 Legal obligation

Retention for the duration of the procedure,
plus the period of acquisition of the legal requirements.

The limitation period of common law in civil and commercial matters
is five (5) years from the end of the contract
Detection, prevention and fight against fraud and cybercrime
  • Identify user accounts with incidents or anomalies to notify them and
    possibly trigger suspension or closure procedures;
 Legitimate interest (fight against counterfeiting, fight against fraud,
fight against cybercrime, ...)

Retention for the duration of the qualification of an alert for fraud
or cybercrime: 12 months from the date of the alert;
Detection, prevention and fight against fraud and cybercrime
  • Identify user accounts with incidents or anomalies to notify them and
    possibly trigger suspension or closure procedures;
 Legitimate interest (fight against counterfeiting, fight against fraud,
fight against cybercrime, ...)

Retention for the duration of the qualification of an alert for fraud
or cybercrime: 12 months from the date of the alert;

Alerts not qualified at the end of
the twelve (12) month period are deleted.

Qualified alerts are retained for a maximum of five (5) years
after the fraud or cybercrime case is closed.
Management of requests to exercise rights
  • Processing your requests to exercise your rights
 Legal obligation

Retention of data related to the processing of your requests for 5 years
from the receipt of the request. Retention of supporting
identity documents for one year.




PROCESSING FOR WHICH MN SANTE HOLDING ACTS AS A SUBCONTRACTOR (Solutions E-fitback, ONCO’nect, Covidom, Léa Santé)
SERVICES PURPOSE LEGAL BASES SHELF LIFE
Creation of a User account on the Solutions implemented by the healthcare facility (patients, employees of the healthcare facility)
  • Allow the authentication of Users who access the services subscribed to by the health establishment clients within the framework of the provision of the remote medical monitoring Solution

Execution of the contract concluded with the Client (Health Care Facility)

Consent of the persons collected by the health establishment subscribing the service

Retention of data necessary for the management of the account until the account is deleted

Provision of a Remote Medical Monitoring Solution and Services

(management of the remote monitoring of patients who have subscribed to the service offered by their health establishment as part of the monitoring of their care pathway)
  • Enable health care institutions to offer their patients and implement a remote medical monitoring system
  • Allow patients to benefit from follow-up by their health care facility

Execution of the contract concluded with the Client (Health Care Facility)

Patient consent collected on behalf of the health establishment, responsible for processing, which implements the remote medical monitoring solution

Defined by the health care facility :

Duration of the patient's course of care with the health care facility

+ retention period specific to health care institutions in accordance with the regulations applicable to them
Management of the care pathways of patients in health care institutions according to the health protocols defined by the latter
  • Integrate the health protocols defined by the health establishment into the solution
  • Enable healthcare institutions to collect information from their patients as part of the health protocol set up via the subscribed remote monitoring system
  • Allow Users to have access to remote monitoring information according to the health protocols implemented by the health facility

Execution of the contract concluded with the Client (Health Care Facility)

Patient consent collected on behalf of the healthcare facility implementing the Remote Medical Monitoring Solution

Defined by the health care facility :

Duration of the patient's course of care with the health care facility

+ retention period specific to health care institutions in accordance with the regulations applicable to them
Management of support requests from healthcare institutions on the operation of the Solutions
  • Handle technical anomalies reported by customers
  • Implementation of diagnostics and necessary corrective actions
Execution of the contract concluded with the Client (Health Care Facility) Retention of data for the duration of the contract concluded with the Customer

Support for healthcare institutions in the event of complaints and requests to exercise the rights of users of the Solutions (patients, employees of the healthcare institution)

(Health care institutions manage their patients' complaints and requests to exercise their rights as data controllers)
  • Provide assistance to healthcare facility clients to enable them to respond to :
    • any claim and request to exercise rights by their users
    • any request for information from supervisory authorities and personal data protection authorities
 Execution of the contract concluded with the Client (Health Care Facility) Retention of data relating to the processing of requests for assistance from the institution, in the context of a dispute, for 5 years from the receipt of the request.

Conducting surveys on behalf of the client healthcare institution

(example: satisfaction survey, survey on the use of the Solution, quality of the remote monitoring set up...)
  • Carrying out surveys at the request of and on behalf of the client health institution responsible for processing

Execution of the contract concluded with the Client (Health Care Facility)

Legitimate interest of the health care institution

Patient consent collected as part of the survey

 Retention for 1 year from the date of the investigation.
Clinical studies and research conducted by the client healthcare facility using data collected as part of the Remote Monitoring Solution implemented by the healthcare facility
  • Provide assistance to the health care institution in the context of the research protocol implemented

Execution of the contract concluded with the Client (Health Care Facility)

Patient consent obtained by the health care institution, responsible for the treatment, within the framework of the study/research protocol set up by it

 Defined by the health care institution: Retention period specific to health care institutions in accordance with the regulations applicable to them for clinical research