Privacy Policy

This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally identifiable information’ (PII) is being used online. PII, as defined in US privacy law and information security and European regulations (General Data Protection Regulation 2016/679), is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance when you use our website, our software and our mobile application.

European General Data Protection Regulation (2016/679)

Who will use or process the data?

Quartier Latin SAS, under the leadership of its CEO Jean-Philippe Thirion is the data controller for the processing described in this policy.

• • Jean-Philippe Thirion

• • Fairway, Bât. D, 980 Avenue de Roumanille, 06410 BIOT, FRANCE

• • +33 (0)4 92 91 54 20

• • info.hq@qlatin.com

• • Data protection officer: dpo@qlatin.com
    
    

This policy covers our website, our commercial relationship with you and the LifeViz® Neo mobile application. The processing of data within LifeViz® Neo Cloud, including the data of the subjects photographed by our customers (for which our customers are data controllers and Quartier Latin acts as data processor), is described in Section V (Privacy Policy) of our Terms and Conditions.

What personal data do we collect?

When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, phone, country and specialty to be able to communicate with you on products or events that might interest you and to help improve your experience. We also collect your first name, last name and e-mail address as you submit your license information when installing our software. For the LifeViz® Neo mobile application, see “Mobile application and photographs” below.

When do we collect information?

We collect information from you when you:

• • subscribe to a newsletter,

• • fill out a form,

• • enter information on our site,

• • visit us during trade shows,

• • email or call,

• • make a purchase,

• • submit your license for the use of our software suite,

• • respond to a survey or marketing communication,

• • follow us on our social media and when participating in sponsored events, sign in to the LifeViz® Neo mobile application.

How will we use your data?

The personal data will be stored in a secure database on our customer relationship manager system and may be used by our marketing, customer support, sales managers and administration in the following ways:

• • To communicate with you

• • Process your purchase orders

• • Manage your software licenses

• • Email you regarding our special offers, news, applications

• • For after sales: to send you software updates, to organize maintenance, offer upgrades. (remote support, email or phone inquiries)

Legal bases: we process your data to perform our contract with you (orders, licenses, after-sales service), on the basis of our legitimate interest (communication with professional customers and prospects, improvement and security of our services), with your consent where it is required (newsletter, non-essential cookies), and to comply with our legal obligations (invoicing, accounting).

Marketing

Quartier Latin would like to send you periodic emails regarding our special offers, news, applications, events…

You may always opt-out at a later date.

You have the right at any time to stop Quartier Latin from contact you for marketing purposes by clicking on the unsubscribe link at the bottom of one of these e-mails.

How do we store your data?

Quartier Latin securely stores your data in France, with certified hosting providers. Data is encrypted and only accessible to authorized employees.

Prospect data is kept for up to three years after the last contact initiated by you. Customer data is kept for the duration of the contract and then for ten (10) years after its end, for regulatory and accounting compliance, as described in our Terms and Conditions.

LifeViz® Neo Mobile App

This section covers the LifeViz® Neo mobile app, published by Quartier Latin SAS on Google Play (package name: com.lifeviz.lifevizneo) and on the Apple App Store.

Who uses the app
The app is for healthcare and aesthetic professionals only. You can’t create an account in the app: accounts are created and managed by the subscribing organization through the Quartier Latin Customer Hub on our website. The app does not collect the user’s name, email address or organization; it only uses the account’s sign-in credentials to log in. Sign-in tokens are stored encrypted on the device.

Data the app collects

• Photos and documents:photos taken with the camera or imported from the device gallery, including photos of faces, plus scanned documents such as consent forms. Image details such as capture date and camera model are also read.
• Subject informationentered by the professional about the person photographed: first name, last name, date of birth, phone number, email address, gender and skin type. Quartier Latin treats this information and the photos as health data.
• Device information:device model, operating system and app version, and a device identifier. These are used for license management and support.

Location permission and Wi-Fi name
On Android, the app asks for the location permission only because Android requires it before an app can read the name of the Wi-Fi network the device is connected to. The app shows the Wi-Fi name on the login screen so you can see which network the device is using before you sign in. The Wi-Fi name stays on the device and is never sent to us. The app does not read, store or send GPS coordinates or the device’s location. This permission is optional: you can refuse or withdraw it at any time in your device settings, and the rest of the app keeps working.

Data the app does not collect
The app does not collect location data, contacts, or advertising IDs. If you unlock the app with your fingerprint or face, Android or iOS handles the check; the app never sees your biometric data.

Permissions used

• Camera: taking photos

• Photos and media: importing images from the device
• Location (Android only): needed only to read the name of the connected Wi-Fi network; the app does not use GPS or track your location
• Biometrics: optional unlock
• Internet and network status: syncing with our servers
• Background work: finishing uploads

Data stored on the device
Photos and subject information waiting to sync are kept in an encrypted database on the device and are deleted from the device as soon as they have been uploaded to our servers. The app also keeps technical logs on the device to help with troubleshooting; these logs are never sent automatically. Uninstalling the app deletes all data stored locally.

Sharing
The app contains no advertising, analytics or crash-reporting tools from other companies, and it doesn’t load third-party web pages. Document scanning happens entirely on the device; no images or scan data are sent to Google or anyone else. Data goes only to Quartier Latin and our certified health data host (HDS), over encrypted (TLS) connections. It is stored encrypted and is never sold.

Who controls subject data
The professional or organization using the app is the data controller for subject photos and information, and Quartier Latin processes that data on their behalf. The professional must inform subjects and obtain their consent. Subjects who want to access, correct or delete their data should contact the professional who photographed them.

Retention and deletion
Photos and subject data are kept according to the retention rules in [section name/number for subject photos]. Users can ask to delete their account and its data through their organization’s administrator or by emailing dpo@qlatin.com. We delete it within [30] days, except records we must keep by law, such as invoices.

Contact
Quartier Latin SAS, Fairway, Bât. D, 980 Avenue de Roumanille, 06410 Biot, France. Data Protection Officer: dpo@qlatin.com.

 

What are your data protection rights?

You may contact our data controller to exercise any of the rights you are granted under applicable data protection laws, which includes:

1. 1. The right to access – you have the right to request Quartier Latin for copies of your personal data.

1. 1. The right to rectification – you have the right to request that Quartier Latin correct any information you believe is inaccurate. You also have the right to request Quartier Latin to complete information you believe is incomplete.

1. 1. The right of erasure – you have the right to request that Quartier Latin erase your personal data, under certain conditions.

1. 1. The right to restrict processing – you have the right to request that Quartier Latin restrict the processing of your personal data, under certain conditions.

1. 1. The right to object to processing – you have the right to object to Quartier Latin’s processing of your personal data, under certain conditions.

1. 1. The right to data portability – you have the right to request that Quartier Latin transfer the data that we have collected to another organization, or directly to you, under certain conditions.

1. 1. The right to withdraw your consent at any time, where the processing is based on your consent.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please

• • contact us at our email: info.hq@qlatin.com or our data protection officer: dpo@qlatin.com

• • call us at: +33 (0)4 92 91 54 20

• • write us to: Fairway, Bât. D, 980 Avenue de Roumanille, 06410 BIOT, FRANCE

If you are a subject photographed with LifeViz® Neo, please address your request to the professional who photographed you, who is the data controller; we will assist them.

You can also contact us at dpo@qlatin.com if you have any questions, remarks or complaints in relation to this privacy policy.

However, if you have unresolved concerns you also have the right to complain to the CNIL (Commission Nationale de l’Informatique et des Libertés) located in Paris, France. (https://www.cnil.fr/en/contact-cnil)

How do we protect visitor information?

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.

We use regular Malware Scanning.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Transport Layer Security (TLS) technology.

We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.

All transactions are processed through a gateway provider and are not stored or processed on our servers.

What are cookies?

Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology

How do we use ‘cookies’?

We use cookies that are strictly necessary for our website to function and, with your consent, analytics cookies to measure the audience of our website. We do not use cookies for advertising or to track you across other websites. You can accept or refuse non-essential cookies through our cookie banner and change your choice at any time. You can also choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. This can be done through your browser settings. Each browser is different, so consult your browser’s Help menu to learn the correct way to modify your cookies.

If you disable cookies, some features will be disabled that make your site experience more efficient and some of our services will not function properly. However, you can still place orders.

Third-party disclosure

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information, except to service providers acting on our behalf and under contract (such as our hosting providers, our customer relationship management system and our payment gateway), to our authorized distributors when they handle your order, and to authorities when required by law.

Third-party links

We do not include or offer third-party products or services on our website.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA we agree to the following:

Users can visit our site anonymously.

Once this privacy policy is created, we will add a link to it on our home page or as a minimum on the first significant page after entering our website.

Our Privacy Policy link includes the word ‘Privacy’ and can be easily be found on the page specified above.
Users will be notified of any privacy policy changes:

• • On our Privacy Policy Page.

Users are able to change their personal information:

• • By emailing us.

How does our site handle do not track signals?

We honor Do Not Track signals: when a Do Not Track (DNT) browser mechanism is in place, we do not place analytics cookies or use advertising.

Does our site allow third-party behavioral tracking?

It is important to note that we do not allow third-party behavioral tracking

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under 13.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices and with the GDPR, we will take the following responsive action, should a data breach occur:

• • We will notify the CNIL within 72 hours, where required by the GDPR.

• • Where the breach is likely to result in a high risk to your rights and freedoms, we will inform you without undue delay, by email or in-site notification.

We also agree to the Individual Redress Principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• • Respond to inquiries, and/or other requests or questions.

• • Send you additional information related to our product and/or service.

• • Send you our newsletter.

To be in accordance with CANSPAM we agree to the following:

• • We will not use false or misleading subjects or email addresses.

• • We will include the physical address of our business or site headquarters.

• • Monitor third party email marketing services for compliance, if one is used.

• • Honor opt-out/unsubscribe requests quickly and allow users to unsubscribe by using the link at the bottom of each email.

Contacting Us

If there are any questions regarding this privacy policy you may contact us using the information below.

www.lifeviz.com

Quartier Latin SAS

Fairway, Bât. D, 980 Avenue de Roumanille,

06410 BIOT,

FRANCE

info.hq@qlatin.com– Data protection officer: dpo@qlatin.com

If at any time you would like to unsubscribe from receiving future emails, you can email us at info.hq@qlatin.com and we will promptly remove you from ALL correspondence.

Changes to our privacy policy

Our Company keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on November 5th.