Haventure is committed to the protection of personal data and privacy. We believe that respecting your privacy and your personal data is essential. The purpose of this privacy policy (hereinafter the “Policy”) is to inform you about the conditions under which your personal data is collected and processed in connection with the use of the website https://www.haventure.com (hereinafter the “WebSite”), to describe the conditions for compliance with data protection rules, as well as your rights concerning them and how to exercise them.

The Policy has been elaborated in order to ensure that Haventure carries out its activities in compliance with legislation, in particular national and European legislation, relating to the protection of personal data and in particular:

  • Regulation (EU) No. 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter the “General Data Protection Regulation” or “GDPR”); and 
  • French law no. 78-17 of January 6, 1978 relating to information technology, files and freedoms, as amended (hereinafter the “Loi Informatique et Libertés” or “LIL”).

The RGPD and the LIL are hereinafter collectively referred to as the “Applicable Regulations”.

Haventure carries out all the necessary checks as part of its compliance with Applicable Regulations.
If you have any questions about the protection of personal data, Haventure can be contacted by e-mail at the following address: rgpd@haventure.com.

1. Data protection definitions

Personal data (or “personal data”)

This means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.

The data recipient
This is the natural or legal person, public authority, department or other entity authorized to receive personal data. However, public authorities which may receive personal data in the context of a particular investigation in accordance with Union law or the law of a Member State are not considered as recipients; the processing of such data by the public authorities in question complies with the applicable data protection rules according to the purposes of the processing.

The data controller
This is the natural or legal person, public authority, department or other entity which, alone or jointly with others, determines the purposes and means of processing.

The processor
This is the natural or legal person, public authority, department or other entity that processes personal data on behalf of the data controller.

Processing
This refers to any operation or set of operations, whether or not carried out using automated processes and applied to personal data, such as: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, communication by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Consent of the data subject
This is any free, specific, informed and unambiguous expression of will by which the data subject accepts, by a declaration or by a clear positive act, that personal data concerning him or her may be processed.

2. Who is responsible for processing your personal data collected via the Website?
This is Haventure, the startups studio for startups dedicated to surgical robotics. As publisher of the Website, we determine the purposes (hereinafter the “Purposes of processing”) and means associated with the collection of your personal data.
3. What personal data do we collect?
In general, you do not need to provide us with any personal data to access and browse our Website. However, for certain services linked to our Website, you may be asked to provide certain personal data such as: your name, your personal or professional e-mail address, your telephone number and your curriculum vitae. Haventure may also collect personal connection data such as IP address, operating system or browser type. You can consult Haventure’s cookie management policy in the “Cookies” section below.
4. How is your personal data collected?

We collect your personal data directly from you.
This includes personal data that you send us directly by filling in the contact form available via the dedicated page on our Website accessible at the following address: Digital Surgery – Contact Us; when you apply for a job or submit an unsolicited application at the following address: Surgical robotics jobs – Join Us !.
In addition, we may collect any other information you wish us to know, notably by telephone or directly by e-mail to the address shown on the Website (info@haventure.com ).
We may also collect information when we communicate with you in person, by e-mail or by telephone.

We collect your personal data indirectly

We may collect your personal data from partners, third parties such as the startups we support. Your data may also be collected through cookies. For further information about cookies, please refer to the cookie management policy below in the “Cookies” section.

As a matter of principle, you will be informed at the time your personal data is collected that it may be shared with partners and/or service providers of the data controller responsible for the collection.

5. Why do we process your personal data?

We process your personal data for the following purposes:

  • To respond to your request, process your request and/or establish and follow up on the commercial relationship that may result from your messages;
  • To manage applications received through the Website as part of the Haventure recruitment process ;
  • For commercial prospecting purposes;
  • Where applicable, to ensure compliance with its legal and regulatory obligations (in particular with regard to Haventure’ administrative, social and tax obligations);
  • To ensure the proper functioning of the Website through cookies installed under the conditions described in the cookie management policy below indicated in the “Cookies” section;
  • Finally, to meet the regulatory requirements to which Haventure would be subject, in particular to respond to requests to exercise data protection rights transmitted through the Website.
6. What are the legal bases for our processing?

The processing of personal data that we implement is based on:

  • Either on the consent of the data subject (Art. 6.1.a GDPR);
  • Either on the performance of a contract or the execution of pre-contractual measures (Art. 6.1 b. GDPR);
  • Either on a legal or regulatory obligation (Art. 6.1 c. of the GDPR);
  • Or on the pursuit of a legitimate interest (Article 6.1.f of the GDPR).
7.How long do we keep your personal data?

our personal data is kept for the time necessary to achieve the Purposes specified in the section: “Why do we process your personal data? “.
In this context, it is specified that the retention periods implemented by Haventure are either determined, in particular when the data retention period is provided for by law, or can be determined on the basis of objective criteria.

As such, you are informed that Haventure stores your personal data as follows:

  • Your personal data, which is necessary for the management of requests, contacts made via the Website and for commercial prospecting purposes, is kept for a maximum period of three (3) years from the date of collection or the last contact from you. They were then suppressed by Haventure ;
  • Your personal data collected in the context of recruitment set up by Haventure is in principle deleted at the end of the process. However, you are informed that your personal data may be kept for a period of two (2) years from the date of collection in the event that your application has not been selected but which may be of interest to Haventure at a later date, if a position becomes available. Regarding personal data transmitted in the context of an unsolicited application, this data will also be kept for a period of two (2) years from its collection. You are free to object to the retention of your personal data by Haventure ;
  • Vos données personnelles de connexion sont conservées selon les durées indiquées dans la Politique de gestion des cookies accessible depuis la section « Cookies » ci-dessous ;
  • Vos données personnelles traitées dans le cadre de la gestion d’une demande d’exercice de droit seront conservées pendant une durée d’un (1) an à compter de la réception de votre demande.

In addition, in the event of processing based on a legal obligation to which Haventure  is subject, your personal data will be kept for the period provided for by the applicable legislation or regulation.
Finally, you are informed that at the end of the above-mentioned retention period, Haventure may archive your personal data for evidentiary purposes for the establishment, exercise or defense of a legal claim, for the duration of the applicable limitation period (in principle, five (5) years pursuant to Article 2224 of the Civil Code).

8. Who are the recipients of your personal data?

Internal recipients
Your personal data is processed by Haventure’ employees. The data is intended only for employees who are authorized to know about it because of their functions and the purposes pursued by the processing.

External recipients
Your personal data is, in principle, strictly confidential and is processed by Haventure only for the Purposes described above in the Policy.
Haventure undertakes not to disclose, assign, rent or transmit your personal data to third parties without your prior knowledge, unless there is a legal or judicial obligation to do so.
In addition, we undertake to ensure that none of your personal information collected through the Website is published without your knowledge, exchanged, transferred, assigned or sold on any medium whatsoever to third parties.
In this context, Haventure informs you that your personal data may be transmitted to the following recipients:
a) The startups we support;
b) Our partners, service providers and service providers (acting as subcontractors where appropriate) under conditions that guarantee the confidentiality of your personal data;
c) Our IT service providers (in particular the host of the Website acting as a subcontractor).
Your personal data is not transferred outside the European Union. In the event that personal data is transferred to countries outside the European Union, Haventure will implement appropriate safeguards to regulate these transfers, unless the recipient country benefits from an adequacy decision from the European Commission.

9. What are your rights over your personal data?

In accordance with the Applicable Regulations, you have the right to access, rectify, delete, limit, port, and object to the processing of personal data concerning you, subject to the conditions provided for by the regulations on the protection of personal data for the exercise of this right. If the processing carried out is based on your consent, you also have the right to withdraw your consent, at any time and without justification.

All of these rights can be exercised with the GDPR referent by:

  • Email: rgpd@haventure.com
  • address : Haventure, GDPR Referent, 75 avenue Gabriel Péri, 38400 Saint-Martin-d’Hères

In addition, you are informed that you have the possibility at any time to lodge a complaint with the French Commission Nationale de l’Informatique et des Libertés (CNIL).

10. Cookies

he Website uses Cookies.
To find out more, we invite You to read our Cookie Policy available here.

11. Reservation of changes to the privacy policy

Our privacy policy is likely to evolve to take into account legislative, regulatory and societal developments.