Info

Privacy statement

1. Introduction

Salvia BioElectronics (hereinafter: “Salvia’’ or “we/our’’ is a medical device company pioneering neuromodulation therapies for migraine. Salvia is at a clinical stage of development; accordingly, Salvia’s medical device is not yet approved for commercial use.

We understand that your privacy is important to you and that you care about how information relating to you (“Personal Data”) is used. Salvia is committed to ensuring the privacy and security of the Personal Data it processes and to protecting your privacy rights in accordance with our obligations under applicable Privacy and Data Protection laws.

This Privacy Statement applies to the processing of personal data of anyone who visits our website, and/ or in any other way engages with us.
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2. What processing activities are covered under this Privacy Statement?

This Privacy Statement describes how we, as a data controller, collect, use, disclose, and process your personal data in connection with:

Your use of our website;
Registration for any of our events
Your interaction with us on social media platforms (e.g., LinkedIn, Instagram, YouTube);
Understanding, diagnosing, analysing, and resolving issues with any of our services;
Filing a complaint or reporting a device deficiency related to any of our services;
Reporting any safety events related to our product;
Responding to you when you have express interest to invest;
Your subscription to any of our newsletters
Contacting us through any of our channels;
Applying for any of our vacancies, including open applications.

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3. What Personal Data do we collect and how do we collect data about you?

We use personal data on a day-to-day basis to run our business, provide our services, enter into a contract, and to protect our interests. We collect information from you when you provide it to us, for instance in the course of your dealings with us or when you visit our website or, in any other way, engage with us. We can also be provided with your data because your information is included in our, our customers’ or our vendors’ invoices, contracts, business documentation, files or systems.

Depending on the processing activity, the personal data we process may consist of:

First and/ or last name
Your email address and any other information you share with us when you contact us.
Phone number
Resume and other information you submit when you apply for a job with us, including motivation letter, professional information, certifications, and others.
Your complaint, device deficiency or safety event report: This includes, but is not limited to, the date, email address, and nature of the complaint, enquiry, or communication.
Usage data: data regarding your device such as an IP address.
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4. Purposes and legal grounds for processing

We process your personal data for certain purposes, described below. Under the applicable Privacy and Data Protection laws, we are only allowed to process your personal data for such purposes if we can rely on one or more of the legal grounds for processing, as described below:

Purpose	Legal ground
To manage our website	Our legitimate interest in: a) providing online content and information about what we do; b) providing a relevant and functioning website; c) providing a safe and secure website for our visitors; Your explicit consent when applicable.
For event planning and organizations and to communicate with you in relation to an event.	Your specific and explicit consent; For our legitimate interest in managing such Events. Performance of a contract: when you are a clinician or part of the scientific community and we invite you participate in any of our events, trainings or workshop.
For recruitment, managing job applications received through any of or channels.	Your specific and explicit consent; For our legitimate interest in managing your applications and our positions and personnel
For responding to your question or complaint.	Your consent when providing us the information. Legitimate Interest: our legitimate interest in fulfilling your requests.
To manage and send our Newsletter (‘Salvia Insights’)	Your specific and explicit consent when you subscribe to our newsletter. Legitimate Interest: our legitimate interest in fulfilling your requests.
If you are an investor or you have manifested your interest in investing and we need to communicate with you	Your specific and explicit consent when providing us with your information. Our legitimate interest in managing our business.
If you contact us in connection to any of our products and/ or services.	Your consent when providing us the information. Legitimate Interest: our legitimate interest in fulfilling your requests and communicating with you.
To measure the use and effectiveness of our website and to improve its functionality.	Your explicit consent when applicable Our legitimate interest in providing a well-functioning website.
Complying with legal obligations.	To comply with a legal obligation incumbent on us. For example, to handle complaints, or report adverse events as required by the governing European medical devices and clinical trials laws and regulations If it involves the processing of health related data, for a task carried out in the public interest in conjunction with a public interest in the area of public health, such as ensuring high standards of quality and safety of medical devices on the basis of the governing European medical devices and clinical trials laws and regulations (and others applicable).

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5. Who do we share your personal data with?

Access to personal data relating to you is limited. It is Salvia’s policy that persons within the organization should only have access to personal data on a need-to-know basis. Where applicable, we share your personal data in the following circumstances:
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Third parties

Salvia may share personal data with service providers or other third parties that carry out functions or services in our behalf or that assist or enable our operation. These service providers include recruitment agencies, background check providers, insurance companies, banks, freelancers and contractors providing specific services, vendors in general and professional advisors such as lawyers or accountants.

Additionally, other suppliers providing IT infrastructure or SaaS solutions can be recipients of your personal data. These include hosting, email and collaboration service providers, website analytics companies, customer support and IT processing systems.

Personal Data will only be disclosed if such service providers have provided sufficient guarantees to implement appropriate technical and organizational measures to protect your personal data and that is consistent with this Privacy Statement and applicable law.

Salvia’s entities, affiliates.

We may also share your personal data with our affiliates for purposes consistent with this Privacy Statement. Personal data may be transferred between Salvia’s Entities to ensure efficient and effective business operations and to enable the Salvia’s entities to provide information technology, legal, quality assurance, software/product development, and other support services.

Disclosures for Law Enforcement, and other Regulatory Reporting Obligations

We may share your personal information to ensure high standards of quality and safety of health care related to our medical devices and applications.
We may share personal information to comply with our legal or regulatory obligations including, but not limited to, our obligations related to safety reporting, pharmacovigilance, product safety and other regulatory reporting obligations.
Under certain circumstances, we may be required to disclose your personal data in response to valid requests by public authorities, including to meet national security or law enforcement requirements or to investigate fraud.
We may also disclose your personal information to third parties as necessary to investigate potential data incidents, or to protect the rights, property or safety of us, the users of our Websites, or others.
We may share your information with courts, law enforcement authorities, regulators, attorneys or other third parties to comply with laws and legal obligations, for the establishment, exercise, or defence of a legal or equitable claim, and to respond to law enforcement and regulatory requests.

Third parties to whom we transfer your personal data are themselves responsible for compliance with data protection law unless they act as our data processor. We are not responsible for the processing of your personal data by third parties if they act as an independent data controller.
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6. International transfers of personal data

Your personal data may be transferred and processed outside of your geographical zone, and in countries that may not provide for the same level of data protection as your geographical zone.

In such cases, Salvia ensures that the recipient of your personal data provides an adequate level of protection, for example by entering into appropriate processing agreements and, if necessary, standard contractual clauses or an alternative lawful data transfer mechanism.
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7. Retention period

We will retain your personal data for as long as is necessary in order to fulfil the purposes for which we collected it, including any legal requirements. To determine the retention period, we take the following into account:

Whether we are subject to any legal obligation;
Whether retention is required considering our legal position (such as for statutes of limitations, litigation or regulatory investigations); and
The length of time that we have an ongoing relationship with you, and provide our services to you.
At the end of the retention period, we will delete your personal data or anonymized in a manner designed to ensure that it cannot be reconstructed.
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8. Your rights

You, as a data subject, have the following rights with regard to your personal data:

The right to access your personal data;
The right to have your personal data rectified, corrected or updated;
The right to have your personal data deleted, including from any third parties where your personal data has been shared or disclosed;
The right to restriction of the processing;
The right to data portability, i.e., the right to receive your personal data in a structured, commonly used and machine-readable format, and the right to transmit those data to another controller;
The right to object to certain types of processing;
The right to withdraw your consent.
Right to anonymity or use of a pseudonym: please note that we may not be able to provide you with the information or service requested if you wish to remain anonymous or use a pseudonym.

In addition to these rights, you also have the right to lodge a complaint with your local data protection authority.

Please note that not all requests regarding your privacy rights can be completed; for example, deletion of your personal data is a right that can be limited due to Salvia’s compliance with legal obligations derived from the corresponding Medical Device and clinical trials laws and regulations. In such cases, we will inform you about this at the time of your request.

If you wish to exercise any of your rights above, please contact us using the information in the section ‘How To Contact Us’ at the end of this Privacy Statement.
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9. Changes to this Privacy Statement

We reserve the right to unilaterally change or update this privacy statement. Please make sure to check our privacy statement from time to time to read the latest version.
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10. How to contact us?

If you have any questions or comments about this Privacy Statement and/or the processing of your personal data, or if you wish to exercise your rights, please reach out to our Data Protection Officer at:

Email address: mb.dpo@salviabioelectronics.com
Address: High Tech Campus 37, 5656 AE Eindhoven, The Netherlands

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