Privacy policy

LXO Group with registered office at 170 Bureaux de la colline, 92113 SAINT-CLOUD France, acting as data controller, attaches great importance to the protection and respect of your privacy. This policy aims to inform you of our practices regarding the collection, use and sharing of information you provide us through our website, our applications, our one-to-one interactions, and in the context of LXO’s Group activities and services.

This policy also aims to inform you of the rights you have regarding your personal data and how you can exercise them.

1. The Data We Collect

By using our website, you may transmit information to us, some of which may identify you and therefore constitute personal data (hereinafter referred to as “Data”). This is the case in particular when you contact us via our contact forms or when you apply for our job offers.

Your data is collected directly during your browsing on the Website, either automatically through cookies, or via the information entry forms presented on the Website.

With regard to the information entry forms displayed on the Website, the personal data whose communication is mandatory for the processing of your request is identified by an asterisk “Required fields”. Failure to provide data identified as mandatory will result in the non-validation of the form in question. LXO Group will therefore be unable to follow up on your request.

We also collect your data when creating and using your training account on the LXO Group Learning Hub platform.

This section explains the different data processing activities in which we process your data:

Online Account Creation: refers to data you provide when creating your LXO Group Learning Hub training account via the registration form, which are marked as “mandatory”. Collecting this data is necessary for the use of your training account.

This processing activity may include the following categories of data:

• Your contact details: title, first and last name, Email, Year of Birth, City;
• Professional information: Profession, Specialty, Practice Setting, Country of Practice; language.
• Optional: Zip code, Professional ID.

Conclusion and Performance of Contracts: The processing of this data is necessary for the performance of a contract with you as an individual, or based on the legitimate interests pursued in the context of our commercial relationship with your employer. Without your data, we cannot establish and maintain contact with you in the context of a specific contract.

This processing activity may include the following categories of data:

• Your contact details: title, first and last name, profession, professional postal address, telephone numbers, email address;
• Your payment information: bank account details, tax identification number, etc.

Organisation of Events for HCPs: We process your data for events that we organize ourselves or for which we act as sponsor or partner and receive certain information about you. In the event of remuneration or events involving hospitality, we may be required to declare these to the public authorities under the obligations arising from the transparency framework.

The data we collect may vary and may include:

• Your contact details: title, first and last name, profession, professional postal address, gender, telephone numbers, email address;
• Details about your profession: profession, position held, professional number;
• Information about your travel to the event: hotel accommodation, flights, transport;
• Your bank details in case of payment for your services as a speaker or reimbursement of your participation expenses.

Promotional Communication & Marketing: We process your data to manage our relationship with you, communicate with you in person or remotely, carry out individual communication operations by email, mail or telephone of a promotional, institutional, medical or scientific nature, invite you to events, and collect and process your comments or observations regarding the quality of the information provided by LXO Group.

This processing activity may include the following categories of data:

• Your contact details: title, first and last name, profession, professional postal address, gender, telephone numbers, email address;
• Information about your profession: profession, professional number, areas of interest.

Pharmacovigilance: As a pharmaceutical company, LXO Group is required to fulfil its health surveillance obligations. In this context, when potential adverse health events related to its products come to its attention, LXO Group processes the following data:

• Data enabling the indirect identification of the person exposed to the adverse health event, such as demographic information (age, year or date of birth, gender, weight, height) or a coded identification number;
• Data relating to the identification of the product concerned by the report, such as the device or product used, the serial number, etc.;
• Health data, including administered treatments, examination results, the nature of the adverse effect(s), personal or family medical history, associated diseases or events, risk factors, and information relating to prescribing, drug use and the prescriber’s therapeutic approach;
• Other data, provided it is strictly necessary for the assessment of the adverse health event, such as information relating to professional life, tobacco, alcohol or drug consumption, and lifestyle.

When the data subject directly reports the adverse event, this declaration has the effect of lifting the confidentiality of their identity with respect to LXO Group. As data controller, LXO Group ensures that access to data is strictly limited to authorized persons who need to know it in order to fulfil their health surveillance obligations, and only for the duration necessary to comply with those obligations.

Recruitment: We process your data in the context of your response to our job offers or the submission of an unsolicited application. In this regard, we collect your first and last name, email address, CV, cover letter, the content of your message and, optionally, your telephone number if provided.

Navigation Data: refers to data we collect during your browsing on the Website, such as the date, time of connection and/or browsing, browser type, browser language, and IP address.

2. How Is Your Data Utilized and What Are the Legal Grounds?

The data collected is used for the following purposes, in accordance with the legal bases provided for under applicable regulations:

• The conclusion and management of contracts between us, based on the performance of a contract or pre-contractual measures;
• Communication with you, particularly in connection with our medical, promotional, institutional, or scientific activities, as well as for the organization of events or when we act as sponsors, based on your consent and our legitimate interest;
• The management and provision of our service offerings, based on the performance of a contract or our legitimate interest;
• Compliance with our legal and regulatory obligations, particularly regarding medical information, pharmacovigilance, and the management of requests to exercise rights;
• Managing job applications and talent recruitment, based on our legitimate interest;
• Improving your browsing and user experience, particularly through the analysis of how our services and content function, based on your consent.

3. Who Are the Recipients of the Data We Collect and Why Do We Share It with Them?

Your personal data may be shared, to the extent necessary, with third parties such as our service providers and subcontractors, our partners, our auditors, and other companies within the LXO Group, in order to meet our operational needs and to provide our products and services.

The personal data collected on the Website is intended for LXO Group. It may however be transferred to service providers and suppliers involved in the management of the Website, including its technical manager, its hosting provider and, where applicable, the audience measurement service provider.

LXO Group governs these transfers through appropriate contractual safeguards and ensures that the relevant recipients undertake to implement adequate technical and organizational measures to ensure the protection of personal data.

Finally, LXO Group may be required to share your personal data with competent authorities when such disclosure is required by law or necessary in the context of the prevention, detection or prosecution of criminal activities.

4. How Long Do We Retain Your Data?

Your personal data is not retained for longer than is strictly necessary to fulfill the purposes for which it was collected.

We use the following criteria to determine data retention periods:

• The nature of our relationship with you (job applicants, healthcare professionals, patients, internet users, etc.);
• The requests you make to us regarding your data, such as the exercise of your rights, your participation in a physical or online event, or relating to our products and services;
• Applicable legal or regulatory obligations imposing a retention period;
• Recommendations from competent supervisory authorities, as well as applicable legal requirements, including international, European and national legislation.

5. International Transfers of Data

As part of our international activities and our relationships with partners and subcontractors located in various countries, your personal data may be transferred to other jurisdictions, including outside the European Economic Area (EEA), to countries that may not necessarily offer a level of protection equivalent to that of your country of residence.

In such cases, we ensure that these transfers are subject to appropriate safeguards, in accordance with applicable data protection regulations. These safeguards may include, in particular, the implementation of the European Commission’s Standard Contractual Clauses or any other recognized mechanism designed to ensure an adequate level of protection for your personal data.

6. How Is Your Data Protected?

We take appropriate technical and organizational measures to prevent unauthorized access to, or modification, disclosure, loss or destruction of your Data.

We also require our partners and group companies to maintain a level of protection similar to ours with regard to the processing of your data. The security measures implemented are evaluated and updated to address new threats and challenges, as well as new legal requirements in the countries where we operate.

You are also responsible for maintaining the confidentiality of your credentials to prevent any unlawful use of your account. We recommend that you choose a strong password that meets the latest security requirements, and that you notify us as soon as possible of any unauthorized or suspicious use of your account using the contact details provided below.

7. What Are Your Rights Regarding Your Data?

In accordance with applicable laws and regulations on personal data protection, you have several rights relating to your Data, namely:

• A right of access and information: you have the right to be informed in a concise, transparent, intelligible and easily accessible manner of how your Data is processed. You also have the right to obtain (i) confirmation that Data relating to you is being processed and, where applicable, (ii) access to that Data and a copy of it.
• A right to rectification: you have the right to have inaccurate Data relating to you corrected. You also have the right to complete incomplete Data relating to you by providing an additional statement. If you exercise this right, we undertake to communicate any rectification to all recipients of your Data.
• A right to erasure: in certain cases, you have the right to have your Data erased. However, this is not an absolute right, and we may retain your Data for legal reasons.
• A right to restriction of processing: in certain cases, you have the right to obtain the restriction of processing of your Data.
• A right to data portability: you have the right to receive your Data that you have provided to us, in a structured, commonly used and machine-readable format, for your personal use or to transmit it to a third party of your choice.
• A right to object to processing: you have the right to object at any time to the processing of your Data for processing based on our legitimate interest, a task carried out in the public interest, and for direct marketing purposes. This is not an absolute right, and we may refuse your request for legal reasons.
• The right to withdraw your consent at any time: you may withdraw your consent to the processing of your Data where processing is based on your consent. Withdrawal of consent does not affect the lawfulness of processing based on consent carried out prior to its withdrawal.
• The right to lodge a complaint with a supervisory authority: you have the right to contact your data protection authority if you believe your rights are not being respected.
• The right to give instructions regarding the use of your data after your death: you have the right to give us instructions regarding the use of your Data after your death.

To exercise these rights, you may contact us at any time by sending an email to our Data Protection Officer at dplaboratoirexo@universalmedica.com  or sending a letter to the following address 170 Bureaux de la colline, 92113 SAINT-CLOUD. France.

8. Changes to Our Privacy Policy

We may occasionally amend this policy, in particular to comply with any regulatory, legal, editorial or technical developments. We advise you to consult this page regularly to keep informed of any changes or updates made to our policy.

9. Contact

LXO Group attaches particular importance to the protection of your data and the respect of your rights.

LXO Group has appointed a Data Protection Officer (DPO), who is your primary contact for any questions relating to the protection of your data. They will review your request and respond as soon as possible.

For any questions regarding the processing of your data, you may contact us at any time by: