Privacy notice

1. Privacy Notice

Update date: March 31, 2025

This privacy notice tells you what to expect when Endo Tools Therapeutics S.A. (ETT) collects information about you (“personal data”) in connection with the activities described below, including when you visit this website and ETT locations, when you contact ETT, or when you participate in ETT events, surveys or clinical studies. 

Unless set out otherwise below, the company responsible for processing your personal data is Endo Tools Therapeutics S.A. Rue Clément Ader 10, 6041 Gosselies, Belgium or the ETT company that you interact with (together, “ETT“, “we” or “us”).

In this privacy notice, we’ll tell you what personal data we collect about you, how we use that information, with whom we share it, what rights you have regarding your information, and how to contact us to exercise these rights.

This privacy notice does not apply when you have been notified that an alternative notice applies (for example on other websites) or where ETT processes your personal data on behalf of your medical institution or healthcare professional in connection with your medical treatment. Your medical institution and/or healthcare professional is solely responsible for the processing of your personal data for the provision of your medical treatment and care.

This notice also does not apply to data processing activities specifically relating to current or former ETT employees or applicants.

2. Personal data we collect and how we use it

This section explains, for each situation, what personal data we may collect, how we use that information and what is our lawful basis to do so. 

2.1 Visiting websites and applications

When you visit our websites or apps, we may collect certain information by automated means, including cookies and similar technologies, such as Flash cookies, local storage, web beacons and pixels, JavaScript, software development kits (SDKs) and device identifiers.

What personal data we collect

The information collected in this manner may include your device IP address, domain name, identifiers associated with your devices, device and operating system type and characteristics, web browser characteristics, language preferences, your interactions with our site or app (such as the pages you visit, links you click and features you use, dates and times of access to our site/app, the pages that led or referred you to our site), and other information about your use of our site or app.

How we use your data

Cookies and similar technologies (“Cookies”) are used by ETT for several reasons. Cookies are sometimes necessary for our sites or apps to operate correctly and secure log-ins to work properly. Cookies allow us to count the visitors to our sites/apps and learn how they use our sites/apps and their features, enabling us to continually improve the visitor’s experience. Cookies may also allow us to provide you with enhanced functionality such as video content, and show you targeted ads on other sites or social media channels. Depending on your location, some Cookies may require your consent. Click here to know more about our use of Cookies and how to manage your Cookie settings and preferences.

2.2 Visiting ETT locations

You may visit our locations in order to interact with our personnel, to provide services or perform certain tasks. 

 

What personal data we collect

If you visit ETT locations, the types of personal data we collect or process about you include:

  • Your contact information and visit details, such as your name, signature and arrival/departure time and date, to enable you to access our premises and provide you with a badge as applicable;
  • Video recordings of you if we operate closed-circuit television (CCTV) systems in the location you visit.

 

How we use your data

We will use this information for security and safety reasons. We will do so as necessary for the purposes of ETT’s legitimate interests in ensuring the security of ETT personnel, property and assets and complying with our internal security policies. 

2.3 Contacting ETT

You may make an inquiry, require assistance or support by contacting our customer service or support team by phone, email or by using our “Contact Us” form, our chatbots or other customer support tools.

 

What personal data we collect 

If you contact our customer and support services to make an inquiry or request support, the types of personal data we collect or process about you include:

  • Identification and contact information, such as your name, title, email address, telephone number, address (as relevant);
  • Location data, such as country/region;
  • Information about you that you submit in your request;
  • Any other information about you necessary for dealing with your request, including data relating to your device or health if you’re a patient;
  • Audio recordings and notes if we record the conversation we have with you.

 

How we use your data

We will use your data to respond to you, provide you with required support, and follow up on your request, including, where applicable, ensuring compliance with our regulatory obligations and establishing, exercising or defending ourselves from legal claims. We may also keep a record of the communications we have with you for evidentiary purposes and to train our personnel and improve the quality of our services. If you call us, you will be notified at the beginning of the call whether our conversation will be recorded.  

We will use your data for the above reasons based on the following bases:

  • Our need to perform the contract we may have with you (if you are an existing customer), or to take pre-contractual steps at your request;
  • Our legitimate interests, in particular in training our personnel, improving our services to you and defending our legal rights; or
  • Our need to comply with our legal obligations. 

If we need to use sensitive information about you (e.g., health data) as part of your request, we will seek your explicit consent or we will do so as necessary to ensure high standards of quality and safety of our products.

Please note that, in some circumstances, we may use your data to provide technical support on behalf of and in the name of your medical institution or healthcare professional. This is the case if the ETT product you use was provided to your medical institution or healthcare professional, as part of the services ETT provides to them. If that product requires technical support, we’ll use your data as directed by your medical institution and/or healthcare professional, as part of your medical treatment. Please contact your medical institution or healthcare professional to learn more on their use of your data for the provision of medical treatment or care. 

2.4 Using ETT products

If you’re a patient, your medical institution and/or healthcare professional (your “Medical Institution”) may use ETT products as part of your medical treatment. In such instance, we may obtain information about you, including health data, as determined by your Medical Institution. We will use this information on behalf of your Medical Institution in order to provide the services requested by your Medical Institution. Please contact your Medical Institution or physician to learn more on the use of your data for the provision of your medical treatment and care. ETT is not responsible for this use. In such instance, your data is subject to your Medical Institution’s own data policies and privacy notices.  

When we obtain your data this way, we’ll use it only based on the instructions of your Medical Institution, unless we are required to do so to comply with our regulatory obligations, or your Medical Institution has authorized us to further use your data, as described below.

2.4.1 Health vigilance/Post-Market Surveillance/Recalls/Complaints

As a manufacturer of medical devices, we are subject to regulatory obligations when we place (or make available or put into service) our products on the market. Compliance with those obligations require us to process personal data.

What personal data we collect

The types of personal data we collect or process as a manufacturer of medical devices include:

  • Data allowing the indirect identification of the patient or person exposed to an adverse health event, such as age, year or date of birth, sex, weight, height, or identification number;
  • Data relating to the identification of the product concerned, such as the type of product used, serial number, implant date; 
  • Health data; 
  • Any other information necessary for the assessment of an undesirable health event, such as professional life, consumption of tobacco, alcohol, drugs, life habit and behavior; and
  • Contact details of the person who made a complaint or notified us of an adverse health event, or of any health professional likely to provide details. 

How we use your data 

We will use your data to conduct health-vigilance related activities, manage adverse health events and handle product complaints. We’ll do so to ensure compliance with our legal obligations and with high standards of quality and safety of healthcare and medical devices.

The ETT entity responsible for processing your data for the above purposes is the manufacturer of your ETT product or the ETT affiliate responsible for placing it on the market as mentioned on the product, package label or instructions for use.

2.8 Marketing

We may share relevant information and updates about our products and services, either via direct communication with you, or by using online advertisements.

2.8.1 Direct Marketing Communications

When we communicate with you directly to promote our product and service offerings (e.g., by email or phone), we will use your personal data to do so. 

What personal data we collect  

The types of personal data we collect or process about you to send you such communications include:

  • Information you have shared directly with us (e.g., when you complete a form to sign-up for such communications), such as your name, email address and/or phone number, age and status as a patient or caregiver, or – if you are a business customer, your professional details; 
  • Information that we have obtained through our interactions with you, such as expressions of interest you have made to our sales representatives;
  • Publicly available information about you (e.g., from the public website of the medical institution where you work); 
  • Metadata collected from cookies or similar techniques, including to understand how you have interacted with our website and whether you have opened or clicked on the content in the emails that we have sent you. For more information on how we use cookies, and your choices in that regard, please click here.   

How we use your data

We use such information to tailor our communications to your specific interests and preferred method of communication, to avoid sending you communications that are not of interest or for which you have not consented, and to follow up with you on the subjects that appear to be most relevant and useful for you. To this end, we may organize the data we collect into interest-based groups.  

We will ask you to “opt-in” or consent to the use of your personal data for the purposes of such communications, where required by law. You can decide at any time to stop such communications by using the opt-out procedure provided in the relevant message (e.g., clicking the unsubscribe link in our promotional emails), or alternatively by contacting us as specified in the How to Contact Us section below.  If permitted by applicable law, we may rely on our legitimate interests to carry out some of the activities mentioned above. 

Please note that if you choose to no longer receive promotional messages from us, we may still continue to send you relevant information for other lawful purposes, such as to administer any account or contract you may have with us, send you communications of an operational nature (e.g., planned outage or updates), respond to your requests and as required by law (e.g., in case of a product recall). 

The ETT entity responsible for processing your data for the above purposes is the ETT affiliate contacting you.

2.8.2 Online Advertising

From time to time, you may come across ETT ads online, including on social media platforms. Such ads are often presented to you based on your perceived interests, as gathered from your activities on social media or browsing the internet.  

What personal data we collect and how we use it 

Online advertising may be based on your search terms (in the case of ads on search engines) or user information on online platforms (such as the email address associated with your social media account, the country or professional interests selected on a social media platform). 

In some instances, we will use your email address to show ads for our products and services on social media platforms. To do so, we will provide your email address, in a hashed or other secure manner, to the social media platform. The social media platform will then match your email address with the personal data (such as email addresses) you provided to them, and use that information to show you, or other platform users, a particular ETT ad. For more information on how social media platforms use your data, please refer to their privacy notices.  

We may also place on our websites or apps advertising cookies or similar technologies that are made available by social media platforms or other third parties. If you visit our websites or apps and accept those advertising cookies and similar technologies, where required by law, then the information they collect (such as device identifiers and information on the pages visited) may also be used to display relevant ads for our products and our services on the social media platform or third party’s site, and create interest based profiles for advertising purposes. Often ETT itself will not actually receive identifiable data about you when such ads are displayed, but we may be able to further tailor our advertising to you depending on what ads you have already seen, and we can receive aggregated statistics on how many ads have been viewed and clicked on, etc. 

We will rely on your consent for the use of your data for online advertising purposes (e.g., when you accept advertising cookies), or otherwise on our legitimate interest to do so where legally permissible. You should be able to configure your cookie settings on websites that use tracking cookies for advertising purposes. For more information on how ETT uses cookies, and how to configure your preferences on ETT websites, please see our cookie policy.    

The ETT entity responsible for processing your information for the above purposes is the entity placing the advertisement. For advertising on social media and other platforms, the platform provider itself will also have responsibility for how the advertising on its platform works. Please refer to the policies, privacy controls, and notices on the platform itself for more information on how advertising may be displayed to you, and your choices in this regard. 

2.9 Managing your B2B relationship with ETT

If you or the entity that employs you have a business relationship with ETT – as a current or prospective supplier, business customer or partner, distributor or agent, we will process personal data to manage this relationship and ensure compliance with applicable laws.

For more information, please read the ETT B2B Privacy Notice.

2.10 Ensuring compliance and defending legal rights

In some circumstances, we are obliged to process personal data to comply with legal requirements and our policies, to perform auditing and other internal functions, or for litigation and dispute resolution purposes. 

 

What personal data we collect

When this is the case, the types of personal data we collect or process about you include your identification and contact information, and any other information as is necessary and relevant to the particular case, e.g., in the event of an (internal) audit, information contained in documents and materials audited, or in the event of litigation, information gathered in the evidence necessary for the litigation. 

 

How we use your data

We will use your information – in an anonymized, de-identified or redacted form, where appropriate in order to: 

  • comply with applicable legal requirements, regulations, court orders or other legal processes;
  • comply with our policies; 
  • establish, exercise or defend our legal rights;
  • conduct (internal) audits, investigations or due diligence checks for the above reasons. 

We will do so as necessary to comply with legal obligations to which we are subject in your country or region, or as needed to fulfil our legitimate interests, in particular in conducting business in compliance with all applicable laws and the highest ethical standards,  protecting our rights or property; and asserting or defending legal claims, or with your consent where required by law.

3 Data sharing

Only duly authorized ETT personnel will have access to your personal data as needed to perform their job duties. In addition, we may share your personal data with third parties for the purposes described in this privacy notice.

We may share your personal data with:

  • ETT affiliated companies: given the corporate structure of ETT, your personal data may be shared with other ETT affiliates.
  • Service providers: we may share personal data with relevant third-party service providers, who act on our behalf to fulfil the activities noted in this privacy notice, including IT providers, providers of communication tools and customer relationship management systems, survey tool providers or platforms, event organization management tools providers, outsourced operations such as Accounts Payable providers, email automation tool providers, cloud hosting service providers, and contract management platform providers.  
  • Business partners and other specialists: ETT may also share personal data with external organizations with which it has partnered (such as research partners and as part of co-branding initiatives), and with external specialists or professional advisors within a particular field (such as lawyers, consultants, tax advisors, auditors, specialist delivery providers, banks, payment service providers, and benchmarking agencies).
  • Parties to a corporate transaction: We also reserve the right to share your personal data in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation). 
  • Public authorities and others for legal reasons:  In addition, we may disclose your personal data with other parties, including public and judicial authorities, (1) if we believe we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement or regulatory authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; or (5) in connection with an investigation of suspected or actual illegal activity. 
  • Others, per your request: With your consent, we will share your personal data with any other parties you choose, such as your caregivers.  

4 International transfers

The above recipients may be located in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the one in which you initially provided the information. When we transfer your personal data to recipients in other countries (including the United States), we will implement appropriate safeguards to ensure an adequate level of data protection as provided for by applicable law. This can include selecting service providers and business partners located in a country recognized as providing an adequate level of data protection, and implementing safeguards based on standard data protection clauses (such as the European Commission’s Standard Contractual Clauses), where applicable. Subject to applicable laws, you may request a copy of these safeguards by contacting us as specified in the “How contact us” section below. 

5 Data retention

We will keep your personal data for so long as necessary to fulfill the purposes for which we are allowed to use them, as set out in this privacy notice. Your data may be kept longer in order to take into account applicable statute of limitation periods, or as otherwise required by law. For more information on the retention of your personal data, please contact us as specified in the “How contact us” section below. 

6 Your privacy rights

You may have certain rights in relation to the personal data we process about you, depending on the reason for which we process your data or the lawful basis we rely on to do so. To the extent provided by applicable law, you can:

  • request access to the personal data we hold about you. Your request should contain a detailed, accurate description of the personal data you want access to;
  • ask us to correct information about yourself you think is inaccurate or incomplete. 
  • object, based on your particular situation, to any use or processing of your personal data based on our legitimate interests;
  • withdraw the consent you previously provided to us for using your data. If you do so, this will not affect the lawfulness of data that we have processed before you withdraw consent;
  • ask us to receive, in a structured, commonly used and machine-readable format, the personal data you have provided to us and to have this information transmitted to another company, where it is technically feasible. This right may apply only in certain circumstances, where you have provided your personal data to us based on your consent or a contract to which you are party;
  • ask us to restrict or limit our use of your personal data;
  • ask us to delete your personal data. Note that we may not be able to delete all your personal data as this right only applies in certain circumstances, e.g., when your data is no longer necessary in light of the purposes explained in this privacy notice and there is no legal or regulatory obligation which obliges us to keep it. 

 

If you wish to exercise your rights, please contact us as specified in the “How contact us” section below. In certain cases, we may ask you to confirm your identity before we can process your request.

Depending on your location, you may have the right to file a complaint with a data protection authority, in particular in the country of your habitual residence, if you are not satisfied with our response.

7 How to contact us

If you would like to exercise your privacy rights or if you have any questions about this privacy notice, please contact us at dpo@endotools.be or directly on the “Contact” section of ETT website.

ETT’s Data Protection Officer may be contacted at dpo@endotools.be.  

8 Updates to this privacy notice

This privacy notice may be updated periodically to reflect changes in our personal data practices. We will indicate at the top of the privacy notice when it was most recently updated.

9.1 Introduction

This Cookie Policy provides information on how cookies and similar technologies are used by ETT on the website, application, or platforms (“Online Services”) as well as emails that link to this Cookie Policy, so that you can make an informed choice about your acceptance of cookies and similar technologies. 

9.2 What are cookies?

A “cookie” is a small text file that is placed and stored on your computer, smartphone or other device or internet browser by websites or apps that you visit. Cookies allow websites to recognize your computer, smartphone, tablet or other device as you browse. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies can be set directly by the website owner, in which case they are called “first party cookies”. “Third party cookies” are cookies from a domain different than the domain of the website you are visiting. Depending on how long a cookie remains in place, cookies can be either session or persistent cookies. A session cookie is a cookie that expires at the end of your browser session (normally when you exit your browser). Cookies that can be stored for longer are called “persistent cookies”. Web beacons, pixels, JavaScript, and other tracking technologies also utilize cookies or use invisible images or code to gather information about a visitor session in a manner similar to cookies. For the purpose of this Policy, “cookies” refers to both cookies and similar technologies. 

9.3 How does ETT use cookies?

Like many companies, ETT uses both session and persistent cookies, as well as first-and third-party cookies. Cookies are used by ETT for several reasons. Cookies are sometimes necessary for our Online Services to operate correctly and secure log-ins to work properly. Cookies allow us to count the visitors to our Online Services and learn how they use our Online Services and their features, enabling us to continually improve the visitor’s experience. Cookies may also allow us to tailor the content of our Online Services to your preferences. To learn more on the cookies we use and the third parties which are setting cookies on ETT’s Online Services, please see below. Depending on your location, you may also visit our Cookie Preference Center by clicking on the cookie icon at the bottom left of each page of our Online Services.

9.4 Cookies we use

Our Online Services use the following types of cookies:

9.4.1 Necessary cookies

These cookies are necessary for our Online Services to function or are set in order to enable services that you request, such as setting your privacy or language preferences, logging in or filling in forms. 

9.4.2 Technical analytics cookies (audience measurement)

These cookies are necessary for the day-to-day operation of our Online Services. They are set and used only by ETT to produce anonymized statistics about your use of our Online Services to ensure they are performing correctly.

9.4.3 Non-technical analytic cookies

These cookies allow us to further analyze your activity on our Online Services and collect information on how you use them so that we can measure and improve the effectiveness of our Online Services. They may be set by us or by third-party analytics service providers.

9.4.4 Functionality cookies

These cookies enable our Online Services to provide enhanced functionality such as video content. They may be set by us or by third party providers whose services we have added to our pages. 

9.4.5 Advertising cookies

These cookies may be set throughout our Online Services by ETT or our advertising partners which may include social media services. They are capable of tracking your browser across other sites and building up a profile of your interests. They may be used by ETT or our partners to show you targeted adverts on other sites or social media channels based on your browsing history and profile. 

9.4.6 Cookies in emails

In addition to the cookies we use on our Online Services, we use cookies in some emails. These help us to understand whether you’ve opened an email and how you’ve interacted with it. Cookies may also be set if you click on a link within the email and interact with pages on our website. If you do not wish to accept cookies from our emails, you can configure your email settings to restrict or avoid images in emails (which may contain the relevant cookies) from being automatically downloaded. Similarly, if using a browser to access your emails, browser settings can be configured as described below to restrict or reject the cookies. 

9.5 Your choices

If you are using ETT’s Online Services from the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland, you can manage your cookie preferences at any time.    

9.5.1 Browser settings

You also can manage cookies through your web browser. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting http://www.allaboutcookies.org/. Please note, however, that without cookies you may not be able to take full advantage of all our Online Service features.

The following external links will explain how to manage cookies for the most common browsers:

To find information relating to other browsers, visit the browser developer’s website. In addition to the browser-based controls, you can manage third party cookies by visiting aboutads.info/choices/ and youronlinechoices.eu/.

9.6 Device settings

Your device settings may also allow you to prohibit mobile app platforms (such as Apple or Google) from sharing with ETT certain information obtained by automated means.

9.7 Opting out of specific cookies

You may also opt out of specific cookies directly with the provider of the cookie. For more details, please follow the external links below:

9.7.1 Analytics cookies:

For more information on how to opt out of being tracked by Google Analytics across all websites, please visit: http://tools.google.com/dlpage/gaoptout.

9.7.2 Third party targeted advertising cookies:

For more information on how to opt-out of advertising cookies, please see the following external links:

  • If you are in the US:  http://optout.aboutads.info or http://optout.networkadvertising.org
  • If you are in Canada: http://youradchoices.ca/choices/ 
  • If you are in the EU: http://www.youronlinechoices.eu/ 

Please note that opting out of advertising cookies will not remove advertising from the pages you visit; it will simply mean that the ads you see will not be matched to your interests and browsing history.

9.8 Contact us

If, at any time, you have requests or queries concerning this policy please contact us at dpo@endotools.be.

9.9 Effective date and changes

This version of the cookie policy is effective as of March 31, 2025. We may update this Cookie Policy from time to time.

10 ETT Privacy notice – Business to business

This privacy notice tells you how we use information that we collect about you in the specific situations concerning you or your company or institution’s commercial relationship with ETT as an actual or prospective business to business (B2B) partner, including as a: 

  • customer or purchaser of ETT products;
  • supplier of goods or services to ETT; 
  • distributor, agents or sales intermediaries of ETT products or services; or 
  • another contracting partner with ETT.

This privacy notice does not apply to situations where we have notified you that an alternative privacy notice applies or where ETT acts as the data processor (e.g., ETT may process Personal Data on behalf of some B2B partners in the course of delivering certain products or services). 

10.1 Introduction

ETT (hereinafter referred to as “we”), as a provider of healthcare products, may have a need to process certain information which can identify you (“Personal Data”) in the course of our commercial activities. This privacy notice describes ETT’s practices regarding our collection and use of your Personal Data in relation to the B2B scenarios described in this privacy notice. We encourage you to read this privacy notice carefully.

10.2 Personal data categories

In connection with our commercial relationship with you or your company or institution, ETT may process the following categories of Personal Data:

10.2.1 Contact and Account Log-in Details

When you come into contact with ETT for commercial purposes, we may collect Personal Data to facilitate our communication and negotiations with you such as: first name, last name, academic prefix or courtesy/honorific title, email address, telephone number, postal address/zip code, profession, therapy group, primary medical specialty, hospital/clinic name, city, and country of practice. If a platform is used to facilitate our dealings, commercial transactions or performance of our respective contractual obligations then we may also need to record your access credentials (e.g., for supplier replenishment request platforms or distributor stock management tools).

10.2.2 Due Diligence Information

ETT may conduct due diligence screening of business partners, including distributors, agents or sales intermediaries, to assess their integrity, quality, credibility and compliance with laws. In such circumstances, information about you and individuals who are current or former employees, officers, directors, partners or significant owners of your business may be collected including but not limited to: name, title, business contact details, address, nationality, passport number, company ownership details, beneficial or other interests in the business, ownership or interests in other businesses, current or former positions or associations with governmental, public or international organizations (including any family member positions or associations), establishments or operations in sanctioned countries, and details of any individuals listed on restricted parties lists. 

10.2.3 Repair/Maintenance Activities

ETT may process certain information in connection with repair or maintenance activities carried out or paid for by ETT including but not limited to details of B2B partner personnel submitting and performing repair/maintenance requests, and associated mileage and expenses, as applicable. 

10.2.4 Transparency and Compliance Reporting Information

ETT may collect certain information to track and manage reports of compliance violations, and to enable compliance with transparency requirements, in particular concerning payments to healthcare professionals and organizations. Such information may include: basic identity information, contact details, professional activities and affiliations, professional qualifications, amounts paid and products or services supplied, financial information (including bank account), physician number or nurses and allied professional number and tax ID number (if required by applicable law), and other relevant information included in compliance reports. 

10.2.5 Details Relevant to Contract Performance

We may process Personal Data in order to perform and administer our contract, including but not limited to: basic identity information, contact details, professional activities and affiliations, professional qualifications, financial information (which may include amounts owning, credit details if necessary for credit checks, or bank account or credit card information if relevant to the method of payment), details of goods provided/services performed, details of services performed by our B2B partner personnel, expenses incurred and relevant Personal Data appearing on invoices and shipping documentation. 

10.2.6 Meetings and Events (Including Remote Meetings that may capture Images/Video/Audio)

Your commercial interactions with ETT may involve meetings or attendance at ETT organized events, including remote meetings and events that make use of a platform that will facilitate interactions by transmitting your audio, video and/or image to ETT or other participants.  You will be informed if ETT intends to actually capture and record any Personal Data in the form of photographs or audio or video recordings during such meetings for further use. 

10.2.7 Training/Education and Certification

ETT may engage in training, education and certification of third-party business partners, including personnel of our distributors and agents. The personal information processed for this purpose may include: name, contact details, position, qualifications, organization, training completed and the outcome of any assessments carried out.  

10.2.8 Travel Information

To organize and facilitate in-person commercial meetings and events we may process additional Personal Data needed for travel and event management purposes such as: national ID/passport number and expiry date, nationality, dietary and travel preferences, logistics and travel details, expenses.

10.2.9 Professional Profiles

ETT may also identify and compile available information regarding current and prospective B2B partners in order to assess the feasibility of any future contracting opportunities (this may include healthcare professional qualifications, specialties, publications and previous engagements). In order to manage our interactions, engagements and support services, ETT may also create and maintain commercial, professional or interest-based profiles based on identified, inferred or derived characteristics, interests or key skills of current or prospective B2B partners.

10.2.10 Cookies and Website Analytics

To the extent that our commercial interactions may make use of an ETT website, we may also use cookies and similar technologies to analyze website visits for purposes of developing and improving the website user experience and other notified purposes. For more information, please consult the cookie policy displayed on the relevant website. 

10.2.11 Additional Information

If you provide any additional information to ETT, we will process such data in accordance with this privacy notice.

10.3 Purposes and legal basis for processing

As a manufacturer of medical devices, we are subject to regulatory obligations when we place (or make available or put into service) our products on the market. Compliance with those obligations require us to process personal data.

What personal data we collect

The types of personal data we collect or process as a manufacturer of medical devices include:

  • Data allowing the indirect identification of the patient or person exposed to an adverse health event, such as age, year or date of birth, sex, weight, height, or identification number;
  • Data relating to the identification of the product concerned, such as the type of product used, serial number, implant date; 
  • Health data; 
  • Any other information necessary for the assessment of an undesirable health event, such as professional life, consumption of tobacco, alcohol, drugs, life habit and behavior; and
  • Contact details of the person who made a complaint or notified us of an adverse health event, or of any health professional likely to provide details. 

How we use your data 

We will use your data to conduct health-vigilance related activities, manage adverse health events and handle product complaints. We’ll do so to ensure compliance with our legal obligations and with high standards of quality and safety of healthcare and medical devices.

The ETT entity responsible for processing your data for the above purposes is the manufacturer of your ETT product or the ETT affiliate responsible for placing it on the market as mentioned on the product, package label or instructions for use.

10.3.1 Contract

We may process your Personal Data for the purpose of entering into or performing a commercial agreement (or contract) with you and such serves as our legal basis for processing your Personal Data for the following purposes:

  • To enter into and perform the contract, including: to negotiate and agree on the contract terms, to send you relevant communications and to perform the essential elements of the contract (which may include accounting activities, shipment and tracking of goods, stock reporting, invoicing, payment processing, debt collection, and gathering feedback via surveys or interviews, as applicable).    

10.3.2 Legitimate Interests

When we process your Personal Data for carefully considered purposes based on the legitimate interests of ETT or another party, we do so, based on our assessment that such legitimate interests do not override your data protection rights. We may process your Personal Data for the following purposes, based on legitimate interests:

  • To conduct due diligence screening on our actual and prospective commercial partners;
  • To investigate and report any potential compliance violations;
  • To perform our contractual obligations in situations where you are not a party to the contract;
  • To assess and identify areas of optimization or improvement under our contract;
  • To measure the effectiveness of internal processes;
  • To optimize the experience and the services provided under our contracts, by tracking and managing individual and account-based processes;
  • To track and analyze performance under our contracts and gather relevant feedback (whether through surveys or otherwise) in order to assess key performance indicators, measure deliverables, measure customer satisfaction levels, identify areas of potential improvement or carry out market research;
  • To aggregate Personal Data to a level where you are no longer directly identifiable. Such information is used to create and communicate statistics in order to gain a better understanding about our commercial activities (including expenditure, business needs, and strategy development). 
  • For the organization of ETT events and meetings: to enable you to attend ETT events and meetings and authenticate your access (including through issuance of attendee badges, as applicable); to facilitate your participation in any interactive ETT sessions; to allow you to effectively engage with ETT personnel and other participants (including in a virtual environment); 
  • To use imagery, audio or video footage from ETT training, events or meetings for educational, promotional or other legitimate business purposes. In such circumstances ETT will take measures designed to reasonably protect your privacy rights;
  • To compile professional profiles for purposes of managing our engagements and interactions with you;
  • To send you communications regarding products or services that may be of interest to the extent permissible (see further Marketing Communications below).

10.3.3 Legal rights and obligations

We may also process your Personal Data on the basis of our legal right or obligation do so in order to:

  • Comply with laws including those regarding transparency, clinical investigations and the management of training on the safe and effective use of our products; 
  • To track, manage and report compliance approvals and violations;
  • In the event of a legal claim: for the establishment, exercise or defense of any such claims.

10.3.4 Consent

We may also process your Personal Data for other purposes for which you have specifically given consent. Such purposes may include:

  • Use of your image or audio or video footage for educational, promotional, or other legitimate business purposes to which you specifically consent;
  • Gathering feedback via surveys or interviews not otherwise based on legitimate interests or contract;
  • Where consent is required to send you communications regarding products or services that may be of interest (see further Marketing Communications below);
  • In case we need to process any sensitive Personal Data (such as health data) in connection with our B2B relationship with you, we will only do so on the basis of your explicit consent.

10.3.5 Marketing communications

To the extent that we send you communications regarding products and services that we believe may be of interest to you, we will only do so on the basis of legitimate interests or your consent, where required under applicable laws. For example, you may be provided with the opportunity to sign up to receive such communications through our ordering platform. You may at any time opt-out of receiving such communications via the opt-out mechanism included in the relevant communication, or by Contacting Us as set out below. In case you ask ETT to send you a particular communication (e.g. to send you a certain product brochure) we may also use the contact details that you provide for this purpose.  

10.4 How long does ETT keep your personal data for?

Your Personal Data will only be retained by ETT for so long as necessary and relevant to fulfill the purposes set out herein and may be retained beyond the duration of your business relationship with ETT to enable us to fulfill such purposes and comply with legal requirements, including compliance and record retention regulations.

For more information on where and how long your Personal Data is stored, please refer to “Contact us” section below.

10.5 Cross border data transfer

Personal Data may be processed by ETT and its affiliates, as well as its third-party service providers, contractors and consultants inside and outside the jurisdiction where it was received. Where there is a need to transfer your Personal Data within ETT or to our third-party service providers, we will ensure that there are appropriate safeguards in place to protect your information as required by applicable laws. When European Personal Data is transferred outside the EEA, UK or Switzerland, we use approved legal mechanisms, which may include standard data protection clauses (EU Model Clauses), to meet data protection laws and requirements. For more details, please refer to “Contact us” section below.

10.6 Data sharing

We may use third parties in order to achieve the purposes set out in this privacy notice including:

  • Enterprise Resource Planning (ERP) platform providers
  • Customer Relationship Management tool providers
  • Email Automation tool providers 
  • Due Diligence Screening providers 
  • Outsourced Operations, such as Accounts Payable service providers 
  • Credit Check agencies
  • Debt Collection service providers
  • Connectivity Tools (e.g., video conferencing tools) 
  • Survey Tool providers or platforms
  • Event Organization Management tool providers
  • Contract Management Platform providers (including for collection of digital signatures)
  • Compliance Reporting Tool providers
  • Cloud Hosting Service providers
  • Postal Services, Couriers or other Freight Services providers  
  • Professional Advisors (e.g., consultants, legal advisor, auditors)

Where required, we will enter into binding agreements with such third parties to ensure that your Personal Data is always processed in accordance with applicable data protection laws and regulations.

Please note that subject to applicable laws, we may need to disclose your Personal Data if required to do so to comply with any law, regulation, court order, legal or government request. In the unlikely event that all or part of our business is subject to a potential acquisition by a third party, your information may be transferred to the prospective corporate owner insofar as relevant to the business in question and subject to appropriate safeguards being in place.

10.7 Security of your personal data

ETT is committed to protecting the security and confidentiality of your Personal Data. We use technical and organizational measures designed to protect your Personal Data against unauthorized or unlawful destruction, loss, alteration, disclosure or access.

10.8 Your rights

Subject to applicable law, you may have the right to:

  • Request access to the Personal Data we have concerning you
  • Request rectification, erasure, or restriction of the processing of your Personal Data (including deletion of your learning management account).
  • Object, based on your particular situation, to any use or processing of your Personal Data which we have based on our legitimate interests;
  • Request your Personal Data in a structured, commonly used and machine-readable format (data portability)
  • If we use your Personal Data based on your Consent, you can withdraw your Consent at any time and discontinue the relevant data processing activities. Note that this does not affect the lawfulness of processing based on Consent before your withdrawal. 

Please note that we may keep using aggregated data (statistics, trends), even after you request deletion of your Personal Data or withdraw your consent, as there may be no technical means available to isolate or identify the data elements to exclude.

Please note that the above rights are generally applicable to situations where ETT offers our services, or is based, in Europe but may be limited in some other jurisdictions according to applicable law. 

To exercise these rights, or for more information, please refer to “Contact us” section below. Please note that in accordance with applicable laws, we may ask you to provide some proof of identity before we can process your request.

Subject to applicable law, if you are not satisfied by the response you receive, or if you consider your privacy rights have been breached, you may lodge a complaint with a data protection authority, in particular in the country of your habitual residence. 

10.9 Contact us

The ETT entity identified in the relevant commercial contract or other documentation provided in connection with your B2B relationship with ETT is your primary point of contact. Please note that in some cases your company or institution may be jointly or independently responsible for the processing of your Personal Data as part of a commercial engagement or collaboration with ETT, in which case your institution or employer should be your first point of contact in that regard. 

 

ETT’s Headquarters is located at:

Rue Clément Ader 10

6041 Gosselies – Belgium

 

Email: dpo@endotools.be

 

We recognize that data protection is an ongoing responsibility, so we may update this privacy notice from time to time. 

11 HCP education services

11.1 Privacy Statement

This Privacy Statement tells you how we use information that we collect about you in relation to the consultancy, training and education services that link to this Privacy Statement. This Privacy Statement does not apply to situations where we have notified you that an alternative privacy statement applies. 

11.2 Introduction

ETT (hereinafter referred to as “we”) provides and facilitates consultancy, training, and education services delivered by and to healthcare professionals (hereinafter referred to as “you”), focusing on the safe and effective use of ETT products or specific to a disease or protocol (hereinafter referred to as “Services”). The Services may be delivered in-person or remotely, including through accessing or logging into a teleconferencing or learning management system provided by ETT or a third party engaged by ETT for this purpose. The systems and programs used to deliver the Services are hereinafter referred to as the “Platform”.

Some minimal personal information is typically collected in order to deliver these learning Services. We will Process your Personal Data, as strictly relevant to the provision of the Services. We understand that you are aware of and care about your own personal privacy interests and we take that seriously. This Privacy Statement describes ETT’s practices regarding its collection and use of your Personal Data and sets forth your privacy rights. We encourage you to read this Privacy Statement carefully.

11.3 Definitions

By “Personal Data” we mean any information which relates to an identified/identifiable natural person, in other words, any information which can lead to knowing who you are (either directly or indirectly).

By “Processing” we mean any operation which is performed on Personal Data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restrictions, erasure or destruction.

By “Consent” we mean your freely given, specific, informed and unambiguous (not subject to misinterpretation or more than one interpretation) indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the Processing of your Personal Data.

By “Aggregated Data” we mean that data from different sources are combined to observe trends and patterns over a large population/group. By using a large population/group and deriving statistics from it, we minimise identification to unique individuals.

11.4 Personal data categories

For the provision of our Services, we may Process the following categories of Personal Data:

  • Contact and account details– when you register for the Services, we may collect Personal Data such as: first name, last name, email-address, postal address, profession, therapy group, primary medical specialty, hospital/clinic name, city, country of practice, access rights requested, username and password as needed for any Platform log-in. In case required by national law, physician number, nurses and allied professional number will be collected.
  • Training and education data– when you access the Services the following data may be collected and linked to you, including through the creation of a learning profile for this purpose: course attendance, learning program progress, assessment/observation results at single question level, course evaluation, course completion, certification, training exemptions, results of knowledge tests, learning modules and resources viewed, and feedback assessments.
  • Travel information– to organise and facilitate in-person training, events or meetings we may process the following additional Personal Data needed for trip and event management purposes: national ID/passport number, dietary and travel preferences, logistics and travel details, expenses.
  • Trainer/Consultant Information– If you are engaged by ETT to provide the Services we may process additional Personal Data in order to administer our contractual relationship, including basic identity information, contact details, professional activities and affiliations, professional qualifications, financial information on honoraria paid by ETT, and bank account information.
  • Images/Video/Audio– The delivery of the Services may involve photography or video recording by ETT, or make use of a Platform that will transmit your audio, video and/or image to other participants.  You will be informed if ETT intends to actually capture and record any such Personal Data for further use.
  • Additional Information– If you provide additional information such as personal preferences, we will process such data in accordance with this privacy statement. may identify certain characteristics, preferences or traits on the basis of which we may create or compile professional, financial or behavioural profiles for the purposes mentioned below.

11.5 Purposes and legal basis for processing

  • Contract: We process your Personal Data to provide the Services, based on your free choice to enroll / participate in our Services or your engagement with ETT to provide the Services. This serves as our contract with you or with the organisation on whose behalf you are engaged or subscribe/participate (hereinafter referred as a “Contract”) and such serves as our legal basis for Processing your Personal Data for the following purposes:
  • For the provision of the Services: to design and deliver the Services, to create and maintain your learning account, to create charts, tables and reports which can help you understand your progress through ETT learning pathways, to enable ETT to provide you with additional training and education content and other information to assist you with your training and education experience, to create and distribute Service deliverables (e.g., training materials and recordings, if applicable);
  • To facilitate event/training support: to communicate with you regarding the Services (including replying to your queries and questions), to provide you with notifications of event or training information (e.g., registration, schedule) and relevant follow up (surveys, thank you notes).

 

  • Legitimate Interests: When we process your Personal Data for carefully considered purposes based on the legitimate interests of ETT or another party, we do so, based on our assessment that such legitimate interests do not override your data protection rights. We may process your Personal Data for the following purposes, based on legitimate interests:
  • To get a better understanding of how effective our Services are;
  • To identify where our Services may require improvement;
  • To optimize the learning experience, by tracking and managing individual and account-based learning pathways and progress, and analyzing such data within the Platform;
  • To measure event participation and effectiveness;
  • To analyze performance metrics and survey results, in order to improve training effectiveness;
  • To aggregate Personal Data to a level where you are no longer directly identifiable. Such information is used to create and communicate statistics on the general use of our Platform in order to:
    • Gain a better understanding about the use of our products and training and education services;
    • Measure expenditure on our training and education activities and face to face events per region/Business Unit, to better understand business needs and further develop our strategy;
    • Understand how training has been delivered within categories like medical specialty, country of practice;
    • To get better insights into the resources and costs associated with providing our Services.
  • To use imagery, audio or video footage from the Services for educational, promotional or other legitimate business purposes. In such circumstances ETT will take measures designed to reasonably protect your privacy rights. 

 

  • Legal Rights and Obligations: We may also process your Personal Data on the basis of our legal right or obligationdo so in order to:
  • Comply with laws including those regarding transparency and the management of training on the safe and effective use of our products;
  • To track and manage compliance approvals and violations;
  • In the event of a legal claim: for the establishment, exercise or defense of a legal claim.
  • Consent: We may also process your Personal Data for other purposes for which you have specifically given Consent. Such purposes may include:
  • Use of your image or audio or video footage for educational, promotional, or other legitimate business purposes to which you specifically Consent (where such use is not already covered by the terms of your Contract);
  • Where Consent is required to send you communications regarding products or services that may be of interest (see further Marketing Communications below);
  • In case we need to process any sensitive Personal Data (such as health data) in connection with the Services, we will only do so on the basis of your explicit Consent.

 

  • Marketing Communications: to the extent that we send you communications regarding products and services that we believe may be of interest to you, we will only do so on the basis of legitimate interestsor your Consent, in accordance with applicable laws. You may at any time opt-out of receiving such communications via the opt-out mechanism included in the relevant communication, or by Contacting Us as set out below. 

11.6 How long does ETT keep your personal data for?

Your Personal Data will only be retained by ETT for so long as necessary and relevant to fulfil the purposes set out herein and may be retained beyond the duration of your business relationship with ETT to enable us to fulfil such purposes and comply with legal requirements to demonstrate adherence to ETT’s obligation to manage training to Health Care Professionals for safe and effective use of our products.

11.7 Cross border Data Transfer

Personal Data may be Processed by ETT and its affiliates, as well as its third-party service providers, contractors and consultants inside and outside the European Economic Area (EEA). When European Personal Data is transferred outside the EEA, UK or Switzerland, we use approved legal mechanisms, which may include standard data protection clauses (EU Model Clauses), to meet data protection laws and requirements.

11.8 Data sharing

Certain components of the Platform are provided by third party providers. We may use third party service providers in order to achieve the purposes set out in this Privacy Statement including:

  • to deliver the Services through a Virtual Classroom, Teleconferencing or Learning Management System;
  • to manage our relationship and communications with you through Communications Tools and Customer Relationship Management Systems;
  • to effectively gather your feedback through a Survey Tool; and
  • to manage your registration and travel arrangements through an Event Management Tool.

We will enter into binding agreements with these service providers which include data processing clauses to ensure that your Personal Data is always Processed in accordance with applicable data protection laws and regulations.

In the event that you engage directly with a third party service provider outside the scope of the ETT Services (e.g. by interacting with their website or availing of additional services from them) please note that the third party’s own privacy statement will apply to any resulting Processing of your Personal Data.

11.9 Security of your personal data

ETT is committed to protecting the security and confidentiality of your Personal Data. We use technical and organizational measures designed to protect your Personal Data against unauthorized or unlawful destruction, loss, alteration, disclosure or access.

11.10 Your rights

Subject to applicable law, you may have the right to:

  • Request access to the Personal Data we have concerning you
  • Request rectification, erasure, or restriction of the Processing of your Personal Data (including deletion of your Learning Management account).
  • Object, based on your particular situation, to any use or Processing of your Personal Data which we have based on our legitimate interests;
  • Request your Personal Data in a structured, commonly used and machine-readable format (data portability)
  • If we use your Personal Data based on your Consent, you can withdraw your Consent at any time and discontinue the relevant data Processing activities. Note that this does not affect the lawfulness of Processing based on Consent before your withdrawal.

Please note that we may keep using Aggregated Data (statistics, trends), even after you request deletion of your Personal Data or withdraw your Consent, as there may be no technical means available to isolate or identify the data elements to exclude.

Please note that the above rights are generally applicable to the Services offered to our customers in Europe but may be limited in some other jurisdictions according to applicable law. To exercise these rights, or for more information, please send an email to dpo@endotools.be.

Please note that in accordance with applicable laws, we may ask you to provide some proof of identity before we can process your request.

In case you are not satisfied with our handling of your request you may contact the applicable Data Protection Authority. 

11.11 Contact us

The Services are facilitated and carried out by the ETT entity identified in the Contract or other documentation provided in connection with the Services. Please note that in case the Services are provided through an engagement or collaboration with your institution or employer, then they may also be responsible (independently, or together with ETT) for the Processing of your Personal Data in connection with the Services, in which case your institution or employer should be your first point of contact in that regard. ETT’s Headquarters is located at:

Rue Clément Ader 10,

6041 Gosselies, Belgium

Email dpo@endotools.be

This Privacy statement is published on March 31, 2025.

We recognize that data protection is an ongoing responsibility, so we will update this Privacy Statement in case we undertake new Personal Data practices or adopt new privacy policies.