Privacy Notice

Version 1.0 – last updated 18 July 2024

1. Who are we?

Welcome to the website of Oenobiol®. This is the Privacy Notice applicable to Oenobiol’s website, accessible via the following link https://oenobiol.com/en_fr/ (the “Website”). Oenobiol is a trademark owned by Cooper Consumer Health B.V.

This Website is operated by and this Privacy Notice is applicable to Coopération Pharmaceutique Française, a company organized and existing under the laws of France, with enterprise number 399 227 636 and with its registered office at Place Lucien Auvert, 77020 Melun Cedex, France (“Cooper” or “we”).

Coopération Pharmaceutique Française and Cooper Consumer Health B.V. are part of the Cooper Consumer Health Group, a group of companies primarily active in the development, registration, manufacturing and marketing of consumer health medicines, medical devices, food supplements and health products in Europe.

You can contact us by using the contact information provided in Clause 11 of this Privacy Notice.

2. General information about this Privacy Notice

• Purpose – This Privacy Notice is intended to inform the users of the Website (“you” or “your”) about why and how we process your personal data, who your personal data may be shared with and what rights you have;
• Personal data – Through your visit of this Website, we may collect and process information about you as an identified or identifiable natural person (“personal data”);
• Scope – This Privacy Notice applies to all processing of personal data carried out by or on behalf of Coopération Pharmaceutique Française in relation to the Website. Coopération Pharmaceutique Française is not responsible for websites of other companies of the Cooper Consumer Health Group;
• Role – Coopération Pharmaceutique Française is the data controller (within the meaning of the EU Regulation 2016/679 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 data and on the free movement of such data, and repealing Directive 95/46/EC, (the “GDPR”)) of the personal data collected and processed in the context of the services provided on this Website;
• Applicable data protection legislation – We understand that your privacy is very important. Therefore, we process your personal data only in accordance with the applicable privacy and data protection legislation;
• Governing law and jurisdiction – This Website and this Privacy Notice shall be governed by the laws of France. Any disputes arising out of or in connection with this Website and this Privacy Notice shall be submitted to the competent courts of France;
• Changes – This Privacy Notice may be amended from time to time to possibly accommodate feedback or to reflect changes in our processing operations. It will always be the latest version of our Privacy Notice that applies. We therefore invite you to always check the latest version of this Privacy Notice on our Website.

3. What personal data do we collect?

By using this Website, your personal data may be collected and processed by us. This will be the case when a) you choose to provide us with this information yourself; or b) analysing your browsing behaviour on our Website.

3.1. Personal data provided by you

3.1.1. When you contact us

If you contact us via e-mail, contact forms or other means of communication, we may use your contact details, such as your name, e-mail address, telephone number or other relevant information, to respond to your request, question or comment.

We will only use your contact details to communicate with you and process your request. We may also store a copy of your communication for internal administrative purposes or to comply with legal obligations.

We will not share your contact details with third parties without your explicit consent, unless required by law. By contacting us, you consent to us using your contact details to contact you.

3.1.2. Special categories of personal data

Unless specifically requested by us, please do not send or disclose to us any sensitive personal data (also referred to as “special categories of personal data”, e.g. data relating to racial or ethnic origin, political opinions, religion or philosophical beliefs, health or medical conditions, sex life or sexual orientation, criminal background, trade union membership, or biometric or genetic data).

If you send us data about you us sensitive data, please limit this to what is strictly necessary. We will only process this data on the basis of your explicit consent, the substantiation of a legal claim, or if necessary for reasons of substantial public interest or the provision of healthcare and always in accordance with applicable data protection law.

3.1.3. When you subscribe to our newsletter or participate in promotional offers

If you subscribe to our newsletter or other promotional e-mails, we may use your e-mail address to periodically send you information, offers and updates on our products, services or events. We will not share your email address with third parties for direct marketing purposes without your express consent. You may unsubscribe from receiving such emails at any time by following the unsubscribe link included in the emails you receive from us or by emailing us at the email address provided below in Clause 11.

3.2. Personal data relating to your browsing behaviour

The Website uses Google Analytics, a web analytics service. Google Analytics uses cookies, which are small text files placed on your device, to help us analyse the use of our Website. The information generated by the cookies about your use of the Website also falls under the concept of personal data.

You can find more information about our use of cookies and other tracking technologies under Clause 9. Cookies and tracking.

4. Why do we process your personal data?

We process your personal data for the purposes described below and on the following legal bases:

4.1. Legitimate interests

We process your personal data if this is necessary to pursue our legitimate interests as a company. In doing so, we always ensure that there is a fair balance between our legitimate interest and your rights to privacy. In this case, you can always exercise your right to object to such processing (see Clause 8 below).

This includes processing operations carried out for the purpose of:

• Having to be able to function as a business
  • testing, evaluating, analysing and optimising our Website to improve the user experience and detect technical problems;
  • understand how our Website is used by collecting general statistical data (e.g. IP address, likely place of consultation, hour and day of consultation, which pages were visited) regarding the use of our services and the Website;
  • taking note of and responding to your requests, questions and comments for evidence purposes, quality control, coaching and training of our staff;
• Conducting internal audits and research on our products and services and improving communication with our customers;
• Exercising and defending our rights (e.g. in legal disputes) and compiling evidence.

4.2. Execution of an agreement

We process some personal data because it is necessary in the context of the conclusion or performance of a contract. For example, when you visit our Website, we process certain personal data to allow you to use our Website or when the processing takes place in the context of providing the services you have requested.

4.3. Legal obligations

In certain cases, we may process your personal data based on a legal obligation. For example, based on tax and accounting legislation or to meet our legal obligations with regard to public health, we may be required to retain certain information.

4.4. Consent

In certain cases, we process your personal data on the legal basis of consent. This is in cases where none of the previous legal bases can be used. You can withdraw your consent at any time (see Clause 8 below).

We will seek your consent for:

• sending our newsletter. You can unsubscribe from this at any time. This can be done on simple request by email or at the bottom of each email via the ‘opt-out’ choice;
• placing cookies or other tracking technologies on our Website to track your click and browsing behaviour (if not based on legitimate interests). (For more information on Cookies, see Clause 9. Cookies and tracking);
• processing certain personal data in the context of promotional campaigns, providing feedback or if you use the contact form on our Website.

5. How do we secure your personal data?

We take the security of your personal data very seriously, which is why we apply technical and organisational measures to protect the confidentiality, integrity and availability of your personal data and to prevent its unwanted loss, misuse, alteration or destruction, depending on the nature of the processing, the risk and the security means available. While we take this very seriously, you should be aware that it is impossible, even with all the security tools that exist today, to completely eliminate every conceivable security risk.

6. With whom do we share your personal data?

1. In certain cases, we will partner with other companies, organisations or public authorities to perform our services. We may share your personal data with:

• other entities in the Cooper Consumer Health Group;
• our third-party service providers to provide services such as web hosting service providers, data analytics service providers, cloud providers, IT service providers, email service providers, auditors, legal service providers and other service providers;
• service providers that support us in analysing your browsing behaviour on our Website (e.g. Google Analytics);
• other companies we partner with for certain products or services;
• in the event of a possible (partial) reorganisation, acquisition, merger, sale, joint venture, assignment, or other disposition of Cooper’s business, it may be that your personal data will be shared with an interested third-party acquirer or other third parties to the extent necessary to study, evaluate, negotiate and, if applicable, implement any reorganisation, acquisition, merger, sale, joint venture, assignment, or other disposition;
• competent authorities authorised to retrieve your personal data or to whom we need to transfer your personal data, for example as a result of legal proceedings or court proceedings.
• to the extent necessary in the context of medical surveillance, your personal data may be communicated to service providers and subcontractors in charge of managing medical surveillance files, as well as to third parties if we are obliged to do so by a law or a regulatory provision, and in particular: the health experts involved in medical vigilance, the national, community and foreign public bodies in charge of medical surveillance in the exercise of their duties as defined by laws and regulations (the information collected may therefore be transmitted outside the European Economic Area for important reasons of public interest), the legal representative of products commercialised by Cooper, and third-party laboratories whose products might be at stake, except for the identity of the non-health professional making the notification.

2. When we cooperate with external service providers who perform certain services on our behalf, we share only the personal data necessary to perform those services. We require these service providers to always take the necessary measures to store and process your personal data in a secure manner. Third parties with whom we share your personal data may only act on the basis of our instructions and may under no circumstances use your personal data for their own purposes.

3. We generally do not intend to transfer your personal data to countries outside the European Economic Area (this is European Union and additionally Iceland, Norway and Liechtenstein) or not included in the list of countries that have received an adequacy decision by the European Commission (e.g. the United Kingdom). If we should nevertheless transfer your personal data to other countries that do not offer an adequate level of protection, we will take appropriate security measures so that such transfer complies with applicable data protection legislation.

7. How long do we keep your personal data?

We will retain your personal data no longer than necessary for the purpose for which it was collected, in accordance with applicable law. After fulfilling the intended purpose, we will delete or anonymise the personal data, unless further retention is required by law or for archival purposes.

8. What are your rights?

If and to the extent provided for in the applicable data protection legislation on data protection (which contains several exceptions), you have the right:
(a) to obtain confirmation whether or not your personal data is being processed and, if so, you have the right to obtain further information about such processing, as well as the right to obtain a copy of your personal data (or, in some cases, to have your personal data transferred to another controller);
(b) to have incorrect personal data rectified and incomplete personal data completed;
(c) to object to the processing of your personal data if the processing is based on legitimate interests;
(d) to withdraw your consent if the processing is based on your consent (note that this does not affect the lawfulness of the processing that took place before the withdrawal of consent);
(e) to obtain the erasure of personal data that is not or no longer lawfully processed; and
(f) to suspend (“restrict”) the processing of personal data in certain cases (e.g. while we assess whether we should indeed rectify or stop processing your personal data); and
(g) to define guidelines on the processing of personal data after your death.

In the case of data collected to fulfil our legal obligations, you have no right to portability, deletion of your data or the right to object to processing.

You can find more information on how to exercise these rights under Clause 11.

Finally, you have the right to complain to the data protection supervisory authority (the CNIL in France) at any time if you believe that we have violated your right to data protection, directly on the website: https://www.cnil.fr or by writing at the following address: 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France

9. Cookies and tracking

During your visit of our Website, cookies or other tracking tools may be placed on your device. A cookie is a text file placed by a website’s server in your computer’s browser or on your mobile device when you consult a website.
Our Cookie Notice provides a more detailed explanation of our use of cookies (e.g. which cookies are used, their purposes, how to delete them, etc.) and can be accessed via this link https://oenobiol.com/en_fr/cookie-notice/.

10. External links

This Privacy Notice does not apply to external links within this Website to websites operated by third parties. We have no control over the content of these third-party websites or how these websites process your personal data.

When you visit other websites, we recommend that you always read their privacy notice.

11. How can you contact us for queries and complaints?

For questions or comments on this Privacy Notice or to exercise your rights under applicable data protection legislation, please contact us by sending an email to: dataprivacy@cooperconsumerhealth.com or by sending a letter to our address: Place Lucien Auvert, 77020 Melun Cedex, France.