1. Who we are
This privacy policy (the "Privacy Policy") explains how Surgerii Robotics (Netherlands) B.V. processes personal data in connection with this website (the "Website").
Surgerii Robotics (Netherlands) B.V.
Herengracht 449 A, 1017 BR Amsterdam, The Netherlands
Business Register (KvK) number: 98179950
VAT (BTW) identification number: NL868389523B01
Email: branding@surgerii.com
For the purposes of Regulation (EU) 2016/679 (the "GDPR"), Surgerii Robotics (Netherlands) B.V. acts as the data controller for the personal data processed through the Website, as described in this Privacy Policy. Surgerii Robotics (Netherlands) B.V. has not appointed a Data Protection Officer. Questions or requests concerning this Privacy Policy or the processing of your personal data can be directed to the email address above.
2. Scope of this Privacy Policy
This Privacy Policy applies to personal data collected through the Website, including: (i) data submitted via the contact form; (ii) data submitted when subscribing to our newsletter; and (iii) data collected through cookies and similar tracking technologies used on the Website, as further described in our Cookie Policy.
The Website is intended for healthcare professionals and does not knowingly collect personal data from members of the general public or from patients. This Website does not offer any products or services for sale, does not process orders, and does not constitute a webshop or other online sales channel. No contract of sale can be concluded through this Website and no payment or order-related personal data is collected.
3. What personal data we collect and why
3.1 Contact form
When you use the contact form on the Website, we collect the personal data you choose to submit, which typically includes your name, professional email address, telephone number, the organisation or institution you represent, and the content of your message or enquiry.
We use this information to respond to your enquiry, to correspond with you about the products or information you have requested, and, where relevant, to route your enquiry to the appropriate manufacturer or internal team. The legal basis for this processing is our legitimate interest in responding to enquiries and maintaining professional relationships with healthcare professionals (Article 6(1)(f) GDPR), or, where your enquiry relates to steps taken prior to entering into an agreement, the performance of or entry into a contract (Article 6(1)(b) GDPR).
3.2 Newsletter
If you subscribe to our newsletter, we collect your name and email address, and, where provided, your professional affiliation. We use this information to send you updates about our products, regulatory developments, and related content relevant to healthcare professionals.
The legal basis for sending you the newsletter is your consent (Article 6(1)(a) GDPR). You may withdraw your consent at any time by using the unsubscribe link included in every newsletter email or by contacting us using the details in Section 1. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.
3.3 Cookies and similar technologies
The Website uses cookies and similar tracking technologies, including analytics and marketing cookies. Strictly necessary cookies, which are required for the Website to function, are placed without requiring consent. Analytics and marketing cookies are placed only after you have given your consent through the cookie consent banner shown when you first visit the Website.
Through analytics cookies, we collect information such as your IP address (which may be truncated or anonymised), browser and device type, pages visited, referring website, and time spent on the Website, in order to understand how the Website is used and to improve its content and functionality. Marketing cookies may be used to measure the effectiveness of our communications to healthcare professionals.
The legal basis for the use of non-essential cookies is your consent (Article 6(1)(a) GDPR), given via the cookie consent banner. You can withdraw or change your consent at any time through the cookie settings available on the Website, or through your browser settings. Further details on the specific cookies used, their purpose, and their retention periods are available in our Cookie Policy.
4. Recipients of personal data
We may share your personal data with the following categories of recipients:
(a) Group companies and manufacturers. Where your enquiry relates to a specific medical device, we may share relevant contact and enquiry information with Beijing Surgerii Robotics Company Limited (abbreviated as SHURUI Robotics) ("Manufacturer"), the device manufacturer for whom Surgerii Robotics (Netherlands) B.V. acts as EU distributor and Authorised Representative, so that the Manufacturer can respond to your enquiry.
(b) Service providers. We engage third-party service providers to support our operations, including website hosting providers, email and newsletter distribution platforms, analytics and marketing tool providers, and customer relationship management (CRM) providers. These providers process personal data on our behalf and are contractually bound to protect it and to use it only for the purposes we specify, in accordance with Article 28 GDPR.
(c) Competent authorities. We may disclose personal data to regulatory, supervisory, or judicial authorities where required to comply with a legal obligation, including obligations arising under the Medical Device Regulation (EU) 2017/745.
We do not sell personal data to third parties.
5. International transfers of personal data
Some of the recipients described in Section 4, including the Manufacturer for whom we act as EU Authorised Representative and certain service providers, are located outside the European Economic Area ("EEA"), in countries that may not have been recognised by the European Commission as providing an adequate level of data protection.
Where personal data is transferred outside the EEA to a country without an adequacy decision under Article 45 GDPR, we ensure that the transfer is subject to appropriate safeguards under Chapter V GDPR, in particular by entering into the European Commission's Standard Contractual Clauses with the recipient, together with any supplementary measures required following a transfer risk assessment. Where an adequacy decision applies to the destination country (for example, in respect of transfers to certain recipients), we rely on that adequacy decision instead.
You may request further information about the safeguards applied to a specific transfer, and obtain a copy of the relevant safeguards, by contacting us using the details in Section 1.
6. Data retention
We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable law:
(a) Contact form submissions are retained for the duration necessary to handle and follow up on your enquiry, and for a limited period thereafter to allow for any follow-up correspondence, after which they are deleted or anonymised.
(b) Newsletter subscriber data is retained for as long as you remain subscribed, and is deleted within a reasonable period after you unsubscribe.
(c) Cookie data is retained in accordance with the retention periods specified for each cookie in our Cookie Policy.
Where personal data is processed in connection with our role as EU Authorised Representative under the MDR, certain records may need to be retained for longer periods to comply with the documentation retention obligations under Regulation (EU) 2017/745.
7. Your rights
Subject to the conditions set out in the GDPR, you have the right to:
(a) request access to the personal data we hold about you;
(b) request rectification of inaccurate or incomplete personal data;
(c) request erasure of your personal data;
(d) request restriction of the processing of your personal data;
(e) object to the processing of your personal data, in particular where processing is based on our legitimate interest;
(f) request data portability, where the processing is based on consent or on a contract and is carried out by automated means; and
(g) withdraw your consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, please contact us using the details in Section 1. We will respond to your request within one month of receipt, with an extension of a further two months, where necessary, taking into account the complexity and number of requests.
You also have the right to lodge a complaint with a supervisory authority. In the Netherlands, the competent supervisory authority is the Autoriteit Persoonsgegevens (Dutch Data Protection Authority), P.O. Box 93374
2509 AJ, The Hague, the Netherlands, www.autoriteitpersoonsgegevens.nl. You may also lodge a complaint with the supervisory authority of your own EU member state of residence or of the place of the alleged infringement.
8. Security of personal data
We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or unauthorised access, having regard to the risks presented by the processing and the nature of the personal data concerned.
9. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, the Website, or applicable law. The date at the top of this Privacy Policy indicates when it was last updated. We encourage you to review this Privacy Policy periodically.
11. Contact
If you have any questions about this Privacy Policy or about how we process your personal data, please contact:
Surgerii Robotics (Netherlands) B.V.
Herengracht 449 A, 1017 BR Amsterdam, The Netherlands
Email: branding@surgerii.com