1.Who are we?

1.1. Identity and contact details of the data controller

Axelife is a simplified joint-stock company registered under SIREN 520759150, with its registered office at 2-10 RUE D ORADOUR SUR GLANE 75015 PARIS

Standard telephone: +33 (0)1 89 71 54 68 Email address: contact@axelife.com

We have designed and developed a Class IIa medical device that measures Pulse Wave Velocity using photoplethysmography technology.

2. Definitions

“Data Protection Act”: Law No. 78-17 of January 6, 1978, relating to data processing, files, and freedoms, amended by Law No. 2018-493 of June 20, 2018, relating to the protection of personal data.

"Regulation" or "GDPR": Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, concerning the protection of individuals with regard to the processing of personal data and the free movement of such data (General Data Protection Regulation), repealing Directive 95/46/EC.

"Data Controller" means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

"Processor" means a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the data controller.

"User" or "Data Subject" means any visitor to the website whose personal data is processed.

"Personal Data" means any information relating to an identified or identifiable natural person; 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 one or more specific elements specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.

"Personal Data Breach" means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.

3. Origin and collection of the data concerned

In the course of our activities, we process your personal data as a data controller in accordance with the provisions of the GDPR and the Data Protection Act, particularly in terms of lawfulness, transparency, and fairness.

All data concerning you is collected directly from you through your use of the site.

We also commit to collecting and processing only personal data strictly necessary for the purposes of the determined processing, in compliance with the principle of data minimization.

4. Data processing

We may process your personal data for the following purposes: Subscription to the electronic newsletter; Management of contact forms on the website; Handling your requests via WhatsApp;

Management and execution of your pOpmeter orders.

The legal basis for the processing is your consent. You can withdraw your consent at any time by contacting our Data Protection Officer at the following address: dpo@axelife.com. For more information on your rights, please refer to section 7 of this Policy.

The processing of managing your pOpmeter orders is based on the contract.

Your personal data is retained only for the duration necessary for the purposes for which they are processed.

In cases where you have given us your consent for the processing of your personal data, we keep the personal data until your consent is revoked. If the data processing is necessary for the execution of your order, we keep the data until the warranty or validity period expires. In exceptional cases, we process your personal data for longer periods if required by applicable regulations in the European Union (e.g., accounting and tax regulations and those related to medical devices).

4.1 Electronic newsletter subscription

Following your subscription to our electronic newsletter, we will provide you with information about our various products, ongoing and upcoming promotions, and other offers for which you have shown interest. We use your email address to send you electronic newsletters specifically designed to inform you about our offers. Your consent to receive the electronic newsletter can be revoked at any time by clicking on the unsubscribe link at the end of each electronic newsletter we send you. For technical reasons, the processing of the unsubscribe request by the system may take a few hours. During this time, you may still receive our electronic newsletters. The data marked as mandatory for newsletter subscription are necessary for the processing of your request.

For more information on this processing, please read Annex 1 to this Policy.

4.2 Contact or interaction with us via contact forms

For messages and questions, you can contact us by phone, email, or through the contact forms published on the axelife.com website. All personal data is collected, processed, and used to handle your requests. During phone conversations, your personal data is processed only if necessary to resolve your request. Data used in the resolution of your request by phone or email and data marked as mandatory in the contact form are necessary for the processing of your request. We retain the data only until the purpose has been achieved or until consent is withdrawn.

For more information on this processing, please read Annex 2 to this Policy.

4.3 Handling your requests via WhatsApp

On our website, you can contact us via WhatsApp. In this context, to provide a response to your request, we collect your phone number and, if necessary, your identity data, such as name and surname. We retain the data only until the purpose has been achieved or until consent is withdrawn.

For more information on this processing, please read Annex 3 to this Policy.

4.4 Management and execution of your pOpmeter orders

On our website, you have the option to purchase a pOpmeter. In this context, to fulfill your order, we collect your name, surname, email address, delivery address, phone number, and your banking details. We retain your personal data in compliance with applicable legal and regulatory obligations.

For more information on this processing, please read Annex 4 to this Policy.

5. Cookies

When you visit the website axelife.com, only cookies necessary for the functioning of the website are installed. Cookies that are not necessary for the operation of the site or service are not used and are activated only after obtaining your explicit consent by selecting a specific consent type and clicking "Accept all" or "Save." In the latter case, cookies are installed in your browser, and their use is authorized only after obtaining your explicit consent.

With your consent, cookies can also be used to store selected settings from your previous visit. This includes, for example, language, font size, and other website display settings you have set on your computer or mobile device, so you don't have to redefine them with each visit. These cookies include marketing tools used to collect and evaluate data to analyze user behavior for the purpose of improving their experience.

Most web browsers automatically accept cookies. If you want to revoke your consent for all websites that include axelife.com in their domain name, you can disable tools for which you have already given consent by appropriately adjusting your browser or mobile device settings. You can change your web browser's operating mode in its settings, so the computer or mobile device rejects cookies or gives you a warning before a cookie is stored. You can also completely prevent the installation of cookies for all websites you visit in your web browser. Finally, you can delete cookies already stored on your computer or mobile device.

5.1 Marketing and Customization Tools

Marketing tools are generally used to determine where users come from and which parts of our website they visit. They are used to collect and evaluate data to analyze user behavior on websites to ensure a better experience. This is a type of personalized marketing strategy, as it involves targeted advertising tailored to the user. By integrating analysis tools, we aim to continuously improve and optimize the website for the user. These cookies can only be installed and used after obtaining your explicit consent.

5.2 External Users

To ensure additional functions and content, third-party content elements and plugins are used in some cases on our website. As with any visit to a website, the transmission of information related to your IP address to the provider of the various extensions is technically necessary. This transmission takes place directly from your browser, and Axelife does not process your personal data in this regard. Plugins are only activated with your explicit consent, which you give either by visiting the Axelife.com website or by using the respective plugin.

6. Terms of Use of the Website

When using axelife.com, copyright, name and trademark rights, as well as other related rights of third parties, must be respected. All content on the site is also protected, including images, videos, music, fonts, and trademarks. Users of the axelife.com website undertake to refrain from any abusive use of the content, especially not to include the content in private or commercial websites and not to use the content for commercial purposes. The same applies to downloading and using the content of the website for the aforementioned purposes.

7. Technical and Organizational Security Measures

Axelife is committed to protecting the personal data of users through the implementation of technical and organizational security measures to prevent unauthorized disclosure, alteration, use, or destruction of processed personal data. Axelife uses all available measures to create an environment that preserves the quality, security, confidentiality, and integrity of the processed personal data. Axelife also uses reasonable technologies to secure the processing of personal data processed for the purposes described in this policy, including:

• Access management;
• SSL Let’s Encrypt encryption (Secure Socket Layer);
• Physical protection of premises, authentication processes with nominative and secure access, confidential username and password policy, traceability and logging of connections, encryption of personal data;

Regular evaluation and improvement of its information technology systems, facilities, and practices for the collection, storage, and processing of personal data.

• However, Axelife cannot assure or guarantee against all risks regarding the security of this personal data. Axelife does not guarantee that this data cannot be accessed, disclosed, modified, or destroyed in case of a breach of any of our guarantees due to negligence or negligence on the part of the website users, failure of our data hosting provider, or any of our subcontractors.

8. User Rights

Axelife is committed to respecting your rights regarding the protection of personal data. In accordance with the French law on information technology, data files, and civil liberties of January 6, 1978, as amended, and the European Regulation on the protection of personal data of April 27, 2016, except in cases of limitation, your data rights are as follows:

• Right of access: the right to be informed and to request access to the personal data that Axelife processes;
• Right to rectification: the right to request the modification or updating of personal data when they are inaccurate or incomplete;
• Right to erasure (right to be forgotten): the right to request the permanent deletion of personal data processed for the purposes described in this Policy;
• Right to restrict processing: the right to request the temporary or permanent cessation of the processing of all or part of the personal data;
• Right to object: the right to refuse the processing of personal data at any time;
• Right to withdraw your consent;
• Right to data portability: the right to request a copy of personal data in electronic format and the right to transmit this personal data for use by a third-party service;
• Right not to be subject to automated decision-making: the right not to be subject to a decision based solely on automated decision-making, including profiling, in cases where the decision has a legal effect on you or produces a similar significant effect.

You can also inform us of your desire to define the fate of your personal data after death. In such a case, we undertake to respect the terms of processing of this personal data within the limits of applicable legal obligations. In the absence of specific instructions from you, we undertake to destroy the relevant personal data, unless its retention is necessary for probative purposes or to comply with a legal obligation.

9. Assistance and Contact

If you have any questions or complaints regarding this Policy or our practices of collecting or processing personal data, if you wish to exercise your rights regarding the protection of personal data, or if you wish to report any security breaches, please contact us by email at dpo@axelife.com or by mail to Axelife - DPO - 2-10 rue d’Oradour sur Glane - 75015 PARIS.

Following your complaint, if you have identified a breach related to the processing of personal data concerning you and you can file a complaint with the French National Commission on Informatics and Liberties (CNIL):

By mail: Service des Plaintes - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.

Online: https://www.cnil.fr/fr/plaintes/

Annex 1 - Registration for Electronic Newsletter Subscription

Annex 2 - Management of Contact Forms on the Website

Annex 3 - Management of visitor requests via WhatsApp

Annex 4 - Management and execution of pOpmeter orders