Privacy Policy

By accessing and using this Site or any of our other websites through this Site, and by submitting Personal Information and other information to the Site, you consent to the collection, use, and disclosure of such information as set out in this Privacy Policy.

Where there is a need to request and receive your consent prior to collection, processing and transfer, Cobodoc is committed to seeking such consent and obtaining it in line with the conditions set by the applicable data protection legislation/regulations.

You may withdraw this consent at any time by notifying officer.data-protection[a]cobodoc.com.

Generally, you may browse the Site without providing any Personal Information. However, we may ask that you provide information at various times and locations through the Site.

For example, if you decide to register with the Site to request information or when you fill in the contact form, you will be asked to provide information such as your first name, last name and email address. You may also choose to volunteer additional Personal Information by completing forms on other sections of the Site, for example for the subscription to newsletters, seminars or events or during the recruitment process (up to, including and after the shortlisting stage, and before making a final decision to recruit).

We collect certain Personal Information, such as, but is not limited to:

• Personally identifying information:
  • Your title, your name and contact details (street and/or email address, home and mobile phone numbers, or similar information);
  • Details of your academic and professional qualifications, experience, previous academic and/or employment history (including job titles, company or organisation, salary, working hours, details of any conduct, grievance or performance issues, appraisals, time and attendance) and interests;
  • Details of your referees;
  • Information regarding any criminal record, in criminal records certificates and enhanced criminal records certificates;
  • Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information if required by law;
  • Your ethnic origin, sex, religious or similar beliefs if required by law;
  • A copy of your driving licence;
  • Other details as provided by you from your CV and Covering Letter.
• Unique identifiers and preference information (like IP address);
• Medical information (like dietary information, clinical specialism...);
• Professional activity linked to utilization of Cobodoc products and services, including utilization of Cobodoc surgical systems or training history.

We may collect this information from you, your referees (details of whom you will have provided), your education provider, the relevant professional body and the Site.

Information provided to the Site by you is not subject to the privacy rule promulgated under the US Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) but may be subject to the requirements of privacy laws or regulations adopted by your state of residence.

Cobodoc products and services may also collect certain Personal Information. You may find out more information about that collection in their associated privacy policies, notices, and terms of service, or by looking for the associated notice for each product or service. The information we collect and how we handle it depends on the data type and what you do when you use our services and products.

Usually, Personal Information will be made anonymous, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Personal Information may be held at our offices, in the company email system and people HR applicant tracking system.

Cobodoc uses “Cookies” on this Site, but only in relation to log analysis, forms completion, to offer you a better experience and to aid in your ease of use. We do not track individual Users.

By continuing navigation you agree to the use of Cookies. For more information and to change your preferences, see our Cookie Policy.

The information collected by and through this Site may be used by Cobodoc and other entities that are involved in the operation of this Site for Cobodoc' purposes. Internally your details will be accessible by Cobodoc’s hiring managers, senior leaders and IT employees.

Cobodoc will use Personal Information only for the purpose for which it was provided, as well as other purposes for which the user gives consent.

We only collect and use Personal Information for the following purposes:

• to successfully provide the contents, projects, products, services and latest news requested and only for the purposes you agreed with;
• to take steps to enter into a contract (recruitment process):
  • for compliance with a legal obligation (for example, our obligation to check that you are eligible to work in some countries);
  • for the performance of a task carried out in the public interest;
  • for the purposes of our legitimate interests, but only if these are not overridden by your interests, rights or freedoms.

Therefore, to protect your safety, you should not provide to the Site with any Personal Information that is not specifically requested.

Processing of Personal Information is lawful and where applicable is based on at least one of the following grounds:

• Consent;
• Fulfilling a contractual obligation;
• Complying with a legal obligation;
• Protecting any data subject’s vital interests;
• Legitimate interests of Cobodoc when balanced against the rights and interests of the data subject;
• Other regionally appropriate basis;

If you are not sure which lawful ground is relevant in a particular case you shall start by eliminating the grounds that cannot be relied upon and seek the advice and guidance of our Data Privacy Officer at officer.data-protection[a]cobodoc.com.

When available, where decision-making, including profiling, is based solely on automated processing and produces legal effects that concern you or similarly you are significantly affected by it, you have the right to object not to be subject to such a decision.

We do not base decision making or profiling solely on automated processing; human involvement ensures that the collaborators have the authority and competence to change the decision that concerns your Personal Information.

Cobodoc has implemented appropriate technical and organizational security measures in place to protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. It may include, among other mechanisms, secured back-up and archiving servers, access control, firewalls or encryption.

You should keep in mind, however, that no Internet transmission is ever 100% secure or error-free. As a result, while we strive to protect this information, we cannot guarantee its security. In particular, e-mail sent to or from this site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Moreover, where you use passwords, ID numbers, or other special access features on this site, it is your responsibility to safeguard them.

Our servers are either located in Canada, the United States, or EU, if located in other countries, data may be replicated to servers in Canada, the United States, or EU. Please note that in countries outside your own country, and in particular outside the EU and EEA, a different standard on data protection might apply than the one you are used to in your own country.

By volunteering Personal Information on the Site, you acknowledge and consent that these data will be transferred across national borders, including, if you are a resident in the EU/EEA, to countries outside the EU/EEA.

Personal information will be stored as long as the information is required to fulfill our legitimate business needs or the purposes for which the information was collected, or for as long as is required by law. In principle, we will retain your Personal information for as long as reasonably necessary for our legitimate business purposes. Personal information must be kept to be available for legal or regulatory compliance. Retention deadlines vary depending on the type of data and the need to delete obsolete data is assessed on a case-by-case basis.

We are responsible for the secure destruction of Personal information once the necessary period that was required to achieve the processing purpose ends. Such destruction must be done through a specific procedure and in order to be secure and avoid potential unlawful data processing, for instance any disclosure to Third Parties, appropriate control mechanisms to monitor the data destruction procedure are in place.

Cobodoc may transfer personal information to other entities.

Any transfer of Personal information which is undergoing processing or is intended for processing after it is transferred to a third country or international organization requires special consideration and shall be carried out in compliance with local data protection legislation/regulations.

Currently, Cobodoc entities perform intragroup transfers of personal data on the basis of an adequacy decision or on the basis of Standard Contractual Clauses (SCCs) and certifies to the Privacy Shield.

Pursuant to the GDPR, each Cobodoc entity which is subject to the GDPR shall, amongst other things, ensure that one of the following safeguards are in place when transferring data to a recipient in a third country (i.e. Non-EU country).

For example, as a general rule, in accordance with the GDPR, Personal information shall be transferred outside the EU only if Appropriate Safeguards are in place ensuring the same level of data protection as guaranteed under the GDPR.

Appropriate Safeguards

Personal data may be transferred if one of the following appropriate safeguards are in place:

In addition, member states are, unless the transfer is based on an Adequacy Decision, entitled to restrict the transfer of specific categories of personal data under their national laws.

Adequacy decision

Personal data may be transferred if the European Commission has decided that the relevant third country or international organization ensures an adequate level of protection. The list of adequate countries can be found below:

• Andorra
• Argentina
• Canada
• Switzerland
• Faroe Islands
• Guernsey
• Israel
• Isle of Man
• Jersey
• New Zealand
• Uruguay

Any Personal Information that you provide to us will be used for our purposes only. Your personal identifying information or medical information will not be shared, sold, rent, transferred or exchanged in any form with other individuals or other companies other than as described in this Privacy Policy.

In some instances we may contract with reputable companies and individuals (hereinafter referred as: “Third Parties”) to assist us in processing information, or to perform functions on our behalf, including, but not limited to website developers, shipping or direct mail organizations, storage facilities, or parties assisting us in the recruitment process. Such Third Parties may be provided with access to your Personal Information to perform the functions they have been retained for. Our agreements with these Third Parties do not permit them to sell or use your Personal Information for any other purposes, other than helping us to provide the products and services, and commit them to comply with applicable data privacy standards.

We further may disclose any information, including Personal Information, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request.

Our Site may contain links to other third-party sites. When you click on one of these links you are visiting a website operated by someone other than Cobodoc, and the operator of that website may have a different privacy policy.

Cobodoc is not responsible for their individual privacy practices. We encourage you to investigate the privacy policies of these third-party operators.

Under the applicable data protection legislation/regulations, you have various rights in connection with the processing of your Personal Information. These rights may differ based on your region.

Cobodoc shall strictly uphold your rights and is responsible for implementing adequate procedures and policies to effectively protect your rights and monitoring compliance with applicable data protection laws and regulations. We will respond and provide information upon request without undue delay and in any event within the legally required timeline for your jurisdiction. That period may be extended where possible by local law.

Please note that we will have to identify you in order to fulfill your request; this requires identification documents that can prove your identify. We will retain archival copies of the information you have requested. Until our backups are overwritten, we will retain the information, but make no further use of your personal information. You can submit your requests to our Data Protection Officer via email at officer.data-protection[a]cobodoc.com.

As data subjects, your rights may include the following, depending on your jurisdiction and applicable laws.

Where Personal Information is collected from you directly, Cobodoc will ensure that you will receive all the information required at or before the time your personal information is obtained.

We ensure that upon request, as available in your jurisdiction, access to your Personal Information will be granted and the regionally appropriate information will be provided, such as:

• • The specific pieces of Personal Information that are being held;
  • The purposes of processing;
  • The categories of Personal Information concerned;
  • The recipients or categories of recipients to whom the Personal Information has been or will be disclosed, in particular, recipients in third countries or international organizations;
  • Where possible, the envisaged period for which the Personal Information will be stored or, if not possible, the criteria used to determine that period;
  • The existence of the right to request from Cobodoc rectification or erasure of personal data or restriction of processing of Personal Information concerning the data subject or to object to such processing;
  • The right to lodge a complaint with a Data Protection Authority;
  • Where the Personal Information is not collected from you, any available information as to their source;
  • The existence of automated decision-making, if any, including profiling and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing.

You have the right to ask for rectification of any inaccurate, incomplete, ambiguous, outdated information concerns you and as appropriate, we will ensure that any inaccurate or incomplete information is erased, amended or rectified.

Cobodoc is committed to ensuring that your information is kept accurate and up to date. Please assist us to comply with this obligation by ensuring that you inform us of any changes to your information by sending us a written request to Cobodoc with a copy of a document of identification containing a signature.

by email:

officer.data-protection[a]cobodoc.com

by letter to the following postal address (North America):

Cobodoc, Inc.

Attn: Legal Service

1111B S Governors Ave

STE 6819

Dover, DE 19904, USA

by letter to the following postal address (Rest of the World):

DAVIOT Group SAS / Cobodoc

Attn: Legal Service

43 rue Jean Jaurès

69100 Villeurbanne, FRANCE

In some jurisdictions, you may have the right to have your Personal Information erased, e.g. if any of the following apply in your region:

• The data is no longer needed for its original purpose and no new lawful purpose exists;
• The lawful basis for the processing is consent, you withdraw that consent, and no other lawful ground exists;
• You exercise the right to object, and we have no overriding grounds for continuing the processing;
• The data has been processed unlawfully;
• Erasure is necessary for compliance with European Union law or national law.

To make such a request, please send an email to us at officer.data-protection[a]cobodoc.com.

We will communicate any erasure of personal data to each recipient to whom the data has been disclosed, unless this proves impossible or involves a disproportionate effort.

You have the right to request the restriction of processing of your Personal Information if:

• • The accuracy of the Personal Information is contested (and only for as long as it takes to verify that accuracy);
  • The processing is unlawful (and you request the restriction of processing instead of the erasure of your personal information);
  • We no longer need the Personal Information for the original purposes of the processing, but still need it for the establishment, exercise or defense of legal claims;
  • There is a verification of overriding grounds pending in the context of an erasure request.

When available, the right to data portability allows you to receive the Personal Information you have provided to us, in a structured, commonly used and machine-readable format, and to transmit those data to another controller.

When available, where processing is justified on the basis of legitimate interests, you may object to such processing, including profiling, unless we are in a position to demonstrate that compelling legitimate grounds, which override your interests, rights and freedoms, exist for the processing or for the establishment, exercise or defense of legal claims.

We are conducting business within the European Economic Area (EEA) or processing the Personal Information of data subjects within EEA in accordance with all applicable data protection legislation/regulations of all relevant jurisdictions, including the European Union’s General Data Protection Regulation 2016/679 (GDPR) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Information and on the free movement of such data, and repealing Directive 95/46/EC.

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to us at officer.data-protection[a]cobodoc.com.

You are informed that, in accordance with article 32 of French law n°78-17 related to Information Technology, Files and Civil Liberties, of January 6th 1978 as modified, any information provided through online forms featured on our Site is necessary for us to answer requests, and is used only by Cobodoc responsible for its processing.

You have the possibility to lodge a claim with a supervisory authority such as the CNIL.

We understand the need to protect children's privacy online (we define "Children" as minors younger than 13 years of age).

Our Site is not intended for Children. No one under age 13 may provide any information to us through the Site. We do not knowingly collect or use any Personal Information from Children. We do not knowingly allow Children to register with us, order our products, communicate with us, or to use any of our online services. If you are under 13, do not access, use, or provide any information on the Site or on or through any of its features.

If you are a parent or guardian of a child under 13 and you become aware that he or she has provided us with personally identifying information without your consent, you should contact us at officer.data-protection[a]cobodoc.com.

If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information from our records.

Cobodoc reserves the right to change this Privacy Policy at any time whereby relevant changes take effect for the future. If significant changes are made in how your Personal Information is collected, processed or shared, this Privacy Policy will be updated and an alert will be displayed on our Site. If required by law, we will seek your consent prior to any significant change.

Our Data Privacy Officer is responsible for the maintenance and accuracy of the present Privacy Policy. This policy shall be reviewed at least annually or more frequently, as appropriate, by the Data Privacy Officer.

The applicable version of this Privacy Policy is available on the Site. Please check this Privacy Policy regularly, and before you submit additional Personal Information via the Site.

The policy effective date is at the bottom of the Privacy Policy page.

We welcome comments and questions regarding this Privacy Policy. Any inquiry regarding the present Privacy Policy can be addressed directly to the Data Privacy Officer:

Data Privacy Officer located in the USA:

by email:

officer-us.data-protection[a]cobodoc.com

Data Privacy Officer located in Europe:

by email:

officer-eea.data-protection[a]cobodoc.com

by letter to the following postal address (North America):

Cobodoc, Inc.

Attn: Legal Service

1111B S Governors Ave

STE 6819

Dover, DE 19904, USA

by letter to the following postal address (Rest of the World):

DAVIOT Group SAS / Cobodoc

Attn: Legal Service

43 rue Jean Jaurès

69100 Villeurbanne, FRANCE

As mentioned above, we will address your request without undue delay and in any event within the legally required timeline for your jurisdiction. That period may be extended where possible by local law.