The terms “you”, “your”, and “yours” refer to the user navigating on the French website of Otoneuro Monaco.
The terms “Otoneuro Monaco”, “we”, “our”, and “ours” refer to Otoneuro Monaco.
Otoneuro Monaco is committed to preserving the confidentiality of data and protecting the data entrusted to it. Due to its fundamental obligations, Otoneuro Monaco commits to implementing an adequate level of protection for the personal data collected online from users.
Generally, we aim to collect only the personal data voluntarily provided by users of our sites, in order to provide them with information and/or services, or to communicate information about job opportunities within Otoneuro Monaco entities.
We thank you for consulting this Online Data Privacy Statement to learn more about how we collect, use, share, and protect the personal data obtained from you.
Collection and Use of Personal Data
1. What information do we collect?
We obtain personal data about you when you decide to communicate it to us, for example, when you contact us by messaging or register on our sites to benefit from certain services. In some cases, you may have previously provided personal data about yourself to Otoneuro Monaco (for example, if you are a former employee).
When you decide to register or log in to Otoneuro Monaco’s sites using a third-party single sign-on service that authenticates your identity and connects your social network identifiers (such as LinkedIn, Google, or Twitter) to the Otoneuro Monaco site, we collect from the social network provider the data and content necessary for registration or connection that you have authorized, such as your name and email address. Other data we collect depends on the privacy settings you have set with your social network provider, and we therefore invite you to consult the applicable privacy policy of the concerned service.
By registering and/or providing personal data to Otoneuro Monaco, you also agree to the use of these personal data in accordance with this Online Data Privacy Statement. We do not use your personal data for other purposes, unless we obtain your consent for this, or if the law or professional standards allow or require it. For example, if you register on an Otoneuro Monaco site and provide data about your preferences, we will use them to personalize your user experience.
If you register or log in using a third-party single sign-on service, we may also identify you as the same user across all devices you use, to personalize your user experience on all other Otoneuro Monaco sites you visit. If you have sent us your resume (CV) to apply online for a job at Otoneuro Monaco, we will use the personal data you have provided to review your application and/or offer you job opportunities at Otoneuro Monaco that match your profile.
In some cases, when you register for certain services, we may temporarily retain your email address until we receive confirmation of the information you have provided by email (i.e., when we send an email to the address provided during your registration to confirm your subscription).
2. Legal bases applicable to the processing of your personal data
Generally, Otoneuro Monaco collects only the personal data necessary to respond to your requests. When we request additional optional data, you are informed at the time of their collection. The law in Europe allows us to process personal data, provided we justify a legal basis for doing so. We are also required to inform you of the nature of this basis.
Therefore, when we process your personal data, we will rely on one of the following legal bases :
- Performance of a contract: when the processing of your personal data is necessary to fulfill our obligations under a contract to which you are a party.
- Legal obligation: when we are required to process your personal data to comply with a legal obligation, including for archiving purposes to meet our tax obligations, or to communicate information to a public body or law enforcement authority.
- Legitimate interests: we will process your personal data if it is in our legitimate interest to do so, in order to best manage the affairs of our business in accordance with the law, and to the extent that this interest does not override your own interests.
- Your consent: in some cases, we will ask for specific permission to process some of your personal data, and we will process them only for the purposes to which you have consented. You have the ability to withdraw your consent at any time by contacting the Data Protection Officer of Otoneuro Monaco (dpo@otoneuromonaco.com).
Examples of “legitimate interests” referred to above:
- Providing information and/or services to visitors of our sites or providing information about job opportunities;
- Preventing fraud or criminal activities and safeguarding our IT systems;
- Personalizing your online user experience and improving the performance, usability, and efficiency of Otoneuro Monaco’s online presence;
- Conducting and measuring the effectiveness of our marketing activities;
- Fulfilling our corporate social responsibility obligations.
- Exercising our fundamental rights within the European Union, in accordance with Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and our right to property.
In some cases, and to the extent expressly provided or authorized by law, the personal data we collect may include special categories of data, such as diversity information (including information about race, ethnic origin, religious beliefs, and other similar signs of belonging, union membership, and data concerning a natural person’s sex life or sexual orientation), health data, or data relating to offenses.
3 Automatic Collection of Personal Data
In some cases, Otoneuro Monaco and its service providers use cookies, web beacons, and other technologies to automatically collect certain types of data when you visit our online sites, and in the context of emails we may exchange. The collection of these data allows us to personalize your online experience, improve the performance, usability, and efficiency of Otoneuro Monaco’s online presence, and measure the effectiveness of our marketing activities.
3.1. IP Addresses
An IP address is an address assigned to your computer each time you access the Internet. This allows computers and servers to recognize and communicate with each other. The original IP addresses of our visitors may be collected for security and diagnostic purposes of computer systems. We may also use these aggregated data to analyze trends and performance of our sites.
3.2. Cookies
We may record cookies on your computer or connected device when you visit our online sites. This allows the site to remember your computer or device, and thus allows cookies to fulfill several purposes.
Some of our sites display an information banner that requests your consent to the collection of cookies. If you refuse, we will not be able to track your computer or connected device for marketing activities.
However, a second type of cookies, “user input” cookies, remains necessary for the execution of certain functionalities. The information banner does not allow them to be blocked. Your decision is recorded in a cookie kept for 90 days.
You can revoke your choice at any time by deleting the cookies from your browser. If most browsers automatically accept cookies, you can decide to accept them or not by setting your browser (usually in the Tools or Preferences menu of the browser). You can also delete cookies from your devices at any time.
However, you must understand that if you refuse cookies, you may not be able to fully benefit from certain features of our sites. You can find more information on managing cookies in the help tab of your browser and on some sites like www.allaboutcookies.org.
Below is a list of the types of cookies used on our sites:
| Usage of the cookie | Cookie description | Type and expiration |
|---|---|---|
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Performance (i.e. user’s browser) |
Our sites are developed from common Internet platforms. Built-in cookies help to solve compatibility problems (eg, by identifying browser type) and improve performance (eg, to load content faster).
|
Session Deleted at the close of the browser |
|
Security cookies (e.g. Asp.NET) |
If you register to access a restricted area, our cookies will keep your device connected during your visit. To access restricted spaces, you will need a username and password.
|
Session Deleted at the close of the browser |
|
Preferences |
Our cookies also allow you to remember your preferences for the site (eg, language) or to improve your user experience (eg by personalizing a greeting or content). This applies to the areas for which you have specifically subscribed or for which you have created an account.
|
Session Deleted at the close of the browser |
|
Analysis |
We use several third-party analytics tools to better understand how our visitors use our site. This allows us to improve the quality and content of OTONEURO MONACO for our visitors. Aggregated statistical data covers such things as the total number of visits or pageviews, and referencing to our sites. |
Persistent, but automatically deleted after two years if you no longer visit OTONEURO MONACO.
|
|
Feedbacks from the websites visitors |
We use a third-party survey tool to invite a number of visitors to share their comments. We use cookies to avoid soliciting several times the same visitor.
The first cookie (A) is saved if the visitor is not invited to participate in the survey, to ensure that visitors are not invited after their first consultation of a page. The second cookie (B) is recorded if the visitor is invited to participate in the survey, to ensure that the visitor is not requested more than once for a period of 90 days. |
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|
Sharing on social networks |
We use social network widgets or buttons to provide you with additional features to share the content of our web pages on sites, social networks and e-mail. When using these widgets and buttons, cookies may be saved on your device to facilitate the use of the service, ensure the display of your interactions on our web pages (eg update of the counting cache of social networks) and record information about your activities on the Internet and on our sites. We invite you to inquire about each provider’s data protection policy before using these services. For more information on our use of widgets and social networking applications, see § 1.4 below. |
Persistent, but automatically deleted after 13 months if you no longer visit OTONEURO MONACO |
WHEN YOU BROWSE OUR SITES OR ENTER YOUR CREDENTIALS TO ACCESS RESTRICTED AREAS FOR REGISTERED USERS, YOU AGREE THAT WE MAY RECORD THESE COOKIES ON YOUR COMPUTER OR CONNECTED DEVICE.
3.3. Google Analytics
Otoneuro Monaco uses Google Analytics. You can find more information on how Otoneuro Monaco uses Google Analytics at the following address: http://www.google.com/analytics/learn/privacy.html.
To give site visitors more choice about how their data is collected by Google Analytics, Google has developed a browser add-on to disable Google Analytics. This add-on communicates with the Google Analytics JavaScript (ga.js) to instruct it not to send data about this site to Google Analytics. The Google Analytics deactivation browser add-on does not prevent data from being sent to the site itself or to other web analysis services.
3.4. Web beacons
A web beacon is a small image file on a web page that can be used to collect certain data from your computer, such as the IP address, the time of viewing content, the type of browser, and the existence of cookies previously recorded by the same server. Otoneuro Monaco uses web beacons only in accordance with applicable law.
Otoneuro Monaco or its service providers may use web beacons to monitor the effectiveness of third-party sites providing recruitment or marketing services, or to collect aggregated statistics on visitors and manage cookies.
You have the option to make certain web beacons unusable by refusing cookies. The web beacon will still record an anonymous visit from your IP address, but no cookie data will be recorded.
For some newsletters and other communications, we may monitor the actions of recipients, such as the email open rate, through embedded links in the messages. We collect this data to assess interest in our communications and improve future user experiences.
3.5 Outils géolocalisés
Otoneuro Monaco may collect and use data about the geographic location of your computer or mobile device. These location data are collected to provide you with information about services that may be of interest to you and to improve our geolocated products and services.
4. Widgets and Social Network Applications
Otoneuro Monaco’s sites may include features to enhance sharing through third-party social network applications, such as Facebook’s Like button or Twitter’s widget. These social network applications may collect and use data about your use of Otoneuro Monaco’s sites (for more information, please refer to the “Social Media Sharing” section of the cookie table above). The personal data you provide through these social network applications may be collected and used by other members of these applications. These interactions are governed by the data protection policies of the companies providing the application. We have no control and disclaim any responsibility for the use of your data by these companies.
In addition, the Otoneuro Monaco site may host a blog, a forum, crowdfunding applications and services, and others (collectively referred to as “social network features”). These social network features are intended to facilitate the sharing of knowledge and content. The personal data you provide through Otoneuro Monaco’s social network features may be shared with other users of these features (unless otherwise indicated at the point of collection), over whom we have no control or only limited control.
5. Children
Otoneuro Monaco understands the importance of protecting children’s privacy, especially online. Thus, our sites have not been intentionally designed for or intended for children under the age of 13. It is our policy never to knowingly collect or retain data about minors under the age of 13, unless it is necessary as part of an engagement to provide professional services.
Sharing and Transfer of Personal Data
1. Transfer within Otoneuro Monaco Entities
We share your personal data between Otoneuro Monaco entities as part of international engagements or when it is desirable to comply with our legal and regulatory obligations worldwide. Other parts of Otoneuro Monaco are also used to provide us with services, for example, we host and manage computer applications, and provide certain forms of insurance to member companies and their clients, we perform client conflict checks and anti-money laundering checks, with client engagement services and as needed to continue to run Otoneuro Monaco’s business.
2. Transfer to Third Parties
We do not share any personal data with unaffiliated third parties, unless it is necessary for our legitimate professional and commercial interests, to process your requests and/or if the law or professional standards allow or require it.
In addition, Otoneuro Monaco may transfer some of your personal data outside the EEA to external companies working with us or on our behalf, for the purposes set out in this Online Privacy Statement. In this case, your personal data will continue to be protected under contracts we have entered into with these organizations located outside the EEA, which contain standard data protection clauses approved by the European Commission
3. Consent
In general, you are not asked to provide personal data to Otoneuro Monaco online, and we may ask you to provide certain personal data in order to send you additional information about our services and events. Otoneuro Monaco may also ask for your consent to certain uses of your personal data, which you may choose to give or withhold. If you request specific services or communications, such as e-newsletters, you may unsubscribe at any time by following the instructions contained in each communication. If you decide to unsubscribe from a service or communication, we will ensure that your data is deleted promptly, but we may need further information before we can process your request.
As mentioned in the “Cookies” section above, if you do not wish to have cookies track your browsing on our sites, you can set your browser to refuse all cookies, or to alert you when a cookie is being sent. You should understand, however, that some parts of our site may not function properly if you choose to refuse cookies.
4. Your rights
If Otoneuro Monaco processes your personal data, you have the following rights:
- Access and rectification: you have the right to access your data (“Request for right of access”). If we comply with your request, we will provide you with your personal data free of charge. Before doing so, we have the right to ask you for proof of identity and some relevant information about your relationship with us, in order to locate your personal data. If the information we hold on you is inaccurate, you have the right to ask us to rectify it.
- Objection to processing: you have the right to object to us processing your personal data for legitimate reasons.
- Other rights: In addition, you have the right to delete your personal data, to restrict its processing in certain circumstances and/or to obtain a copy of the personal data we hold in a structured electronic format (portability).
You can exercise these rights by contacting Otoneuro Monaco’s Data Protection Officer ( dpo@otoneuromonaco.com ) and we will ensure that your request is met, provided that it complies with applicable laws and professional standards.
5. Security and integrity
Otoneuro Monaco has implemented reasonable security procedures and policies to protect personal data against misuse, loss, alteration or unauthorized destruction. Despite Otoneuro Monaco’s best efforts, absolute protection against all threats cannot be guaranteed. We make every effort to ensure that access to your personal data is limited to those who need to know. Persons with access to data are required to treat it confidentially.
We will only retain personal data for as long as is necessary (i) to process your requests, (ii) to comply with any legal, regulatory or professional obligations imposed on us, or (iii) until such time as these persons request the deletion of their data.
The period for which data is kept depends both on its nature and the specific circumstances that led us to collect it.
6. Links to other sites
When you register on one of Otoneuro Monaco’s sites and then navigate to another Otoneuro Monaco site without logging out, you agree to the use of your personal data in accordance with the Otoneuro Monaco Online Data Privacy Statement you are viewing.
7. Modification of this Statement
Otoneuro Monaco may amend this Online Privacy Statement from time to time to reflect changes in our privacy practices. When we change this Online Privacy Statement, we will also change the “Last Updated” date at the top of this page. Any changes in the way we process personal data as described in this Online Privacy Statement will be communicated to you by an appropriate means, depending on how we normally communicate with you. We encourage you to periodically review this Online Data Privacy Statement to be informed of how Otoneuro Monaco is protecting your data.
8. Questions about the policy and its application
Otoneuro Monaco is committed to protecting your privacy online. If you have any comments, questions or complaints about our handling of your personal data, please contact us at dpo@otoneuromonaco.com. You can also use this address to let us know if you have any questions about our compliance with this Online Data Privacy Statement.
We have the option of accepting your complaint (in which case we will implement one of the measures referred to in the “Your rights” section above) or refusing to deal with it for legitimate reasons.
In all cases, you may lodge a complaint with the CCIN (Commission de Contrôle des Informations Nominatives) of Monaco, https://www.ccin.mc/
