Last update: November 3, 2023


This website (the “Website”), published by the company Gradient Denervation Technologies (“Gradient”, “we”, “us”, “our”), is a corporate website presenting the expertise and business activities of Gradient.

While you are accessing, consulting, browsing, and using the Website, you communicate your personal data to Gradient.

Please read this privacy policy carefully as it explains how Gradient uses your personal data and how to exercise your rights. This privacy policy completes the Terms of Use of the Website, as well as any documents or notices that may refer to this privacy policy.

Should you have any questions, you may directly contact Gradient by sending an email at contact@gradientdenervation.com.

1. WHO IS THE DATA CONTROLLER OF YOUR PERSONAL DATA?


As Website publisher, Gradient is the data controller of the personal data collected for the administrative, operational and commercial management of the Website.

2. WHAT KIND OF PERSONAL DATA IS PROCESSED BY GRADIENT?


All personal data provided by you through the Website or when you directly communicate with Gradient, namely:

Type of data Examples of data
Identification data First name, last name, title, company name
Contact details Email address, phone number
Data related to
your request		 Date and hour of your request, subject and content of your request, your exchanges with Gradient’s services concerned by your request, follow-up to your request

The provision of certain types of personal data may be necessary or optional, depending on the services you wish to receive. If applicable, mandatory data will be marked as such at the moment of collection of your personal data. If you refuse to provide mandatory data, Gradient may not be able to process your request.

Furthermore, the Website also automatically collects the following data through cookies and other trackers:

Type of data Examples of data Purposes
Internet or other electronic
network activity information		 Date and time of the visit, IP address, location (city), device, browser, operating system, system configuration data, pages viewed, downloads Such data is necessary for the proper functioning of the Website, as well as for audience measurement. For more information, please see our Cookies Policy .

3. FOR WHAT PURPOSES DOES GRADIENT USE YOUR PERSONAL DATA?


Gradient processes your personal data for the following purposes only:

Purposes Examples of use of your personal data Legal bases
Managing your
contact request		 • to manage your contact request Legitimate interest of Gradient to manage its contact requests
Direct marketing
communications for
professionals		 • to send you electronic communications about Gradient’s activities that might interest you as professional Legitimate interest of Gradient to develop its business activities with professionals
Improving the Website
and your user experience 		• to evaluate and improve the Website
• to facilitate your navigation on the Website
• to take steps designed to protect the security of the Website. 		Legitimate interest of Gradient to improve the Website and your user experience
Pre-litigation or litigation
management 		• to take action against any identified breach
• to manage any dispute or litigation 		Legitimate interest of Gradient in defending its rights and interests
Compliance with legal and
regulatory obligations		 • to comply with applicable legal and regulatory obligations
• to manage your requests when you exercise your rights 		Legal and regulatory obligations to which Gradient is subject

4. WHO CAN ACCESS YOUR PERSONAL DATA?


Your personal data may be transmitted to the following recipients when you access, consult, browse, and use the Website and its services:

Recipients Purposes
Gradient and its duly
authorized employees		 Gradient and its duly authorized employees For the administrative, operational and commercial management of the Website as indicated in the Section 3 of this privacy policy
Service providers
(hosting provider, IT solutions providers,
services providers)		 For operational and technical purposes related to the Website and its services
Administrative or judiciary authorities Exclusively in case of an express and justified request from them or in case of an alleged violation of legal or regulatory provisions
Lawyers and all
interested parties 		Exclusively in the case of the management of possible disputes and other legal matters where appropriate
Other third parties Following or during a restructuring, reconstitution, acquisition, debt financing, merger, sale of assets of Gradient or a similar transaction, as well as in case of insolvency, bankruptcy or receivership where personal data are transferred to one or more third parties as assets of Gradient

5. WILL YOUR PERSONAL DATA BE TRANSFERRED OUTSIDE OF THE EUROPEAN UNION/EUROPEAN ECONOMIC AREA?


As far as possible, your personal data is processed within the European Union (EU)/European Economic Area (EEA). However, some of service providers being located outside the EU/EEA, your personal data may therefore be processed in third countries.

In the event that the third country does not ensure a level of protection of personal data equivalent to the European Union, Gradient ensures that the appropriate safeguards to protect your personal data (in particular the standard contractual clauses of the European Commission) in the absence of an adequacy decision and after having carried out an assessment of the level of protection of your rights in the third country. A copy of such safeguards can be obtained by sending an email directly to Gradient at contact@gradientdenervation.com.

6. HOW DOES GRADIENT PROTECT YOUR PERSONAL DATA?


Gradient has implemented appropriate technical and organizational measures in order to protect your personal data, in particular against potential personal data breaches likely to cause, either by accident or unlawfully, the destruction, loss, modification, unauthorized access or divulgation of your personal data. These measures guarantee a level of security adapted to the data and take into account the state of the art and the cost of implementation in relation to the risks and nature of the data to be protected.

Gradient ensures that all members of its personnel and any other person processing your personal data will respect the internal rules and procedures related to the processing of your personal data. In this context, Gradient reviews and updates its practices regularly to enhance your privacy.

If you have found a vulnerability or would like to report a security incident, you may send an email to contact@gradientdenervation.com.

7. FOR HOW LONG ARE YOUR PERSONAL DATA STORED?


As a general rule, your personal data will only be retained for the period necessary for the accomplishment of the purposes for which said data was collected, or as necessary to fulfill legal or regulatory obligations.

In particular, the data collected via you contact request will be kept until the complete processing of your request.

In addition to this, Gradient will keep your personal data for:

  • three (3) years for the data processed for direct marketing purposes if you are a professional; and
  • five (5) years for the data processed for evidence purposes.

    • 8. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?


    If you are based in the EU/EEA/UK, you have the following rights over your personal data:

    Your rights Scope of you rights
    Right to access You have the right to request:
  • the confirmation on whether Gradient processes your personal data or not;
  • a copy of such personal data; and
  • information on the use of your personal data by Gradient in a clear, transparent and understandable way (as provided in this privacy policy).
    • Right to rectification You have the right to request the rectification of your personal data, in order to obtain the modification of your personal data if your personal data is obsolete, inaccurate or incomplete
    Right to delete You have the right to request the deletion of your personal data (or right to be forgotten), when one of the following conditions applies:
  • you object to the processing of your personal data and there are no overriding legitimate reasons justifying to maintain the processing of your personal data (e.g., legal obligation);
  • you object to marketing activities;
  • you decide to withdraw your consent on which the processing is based;
  • your personal data are no longer useful for the original purposes for which it was collected or for any other type of processing;
  • the use that is made of your data does not comply with the applicable legal or regulatory provisions.
    • Right to restriction of processing You have the right to request the restriction of the processing during a limited period of time, in particular in order to carry out some verifications, where one of the following conditions applies:
  • you contest the accuracy of your personal data, the processing of which is thus restricted for the period necessary for Gradient to verify the accuracy of such personal data;
  • the processing is unlawful and, rather than requesting their deletion, you prefer to restrict their use;
  • Gradient no longer needs your personal data for the purposes of the processing, but you need them for the establishment, exercise or defense of legal claims;
  • you have objected to the processing, which is thus restricted pending the verification of whether the compelling legitimate grounds of Gradient may override your interests, rights and freedoms.
    • Right to data portability You have the right to request a copy of your personal data in a structured, commonly used and machine-readable format and also can request their transmission to another data controller where technically feasible. This right is not exercised in all circumstances, it applies only if it fulfils all the following conditions:
  • your request is only related to your personal data (excluding anonymous or third party data);
  • your request does not adversely affect the rights or freedoms of others, in particular those of Gradient (e.g., trade secrets) those of third-parties (e.g,. intellectual property right);
  • the processing is carried out by automated means (paper files are therefore not included);
  • the processing is based on consent or the performance of a contract (to check if it is the case, you can see the Section 3 of this privacy policy).
    • Right to object You have the right to object to our processing of your personal data at any time if the processing is based on our legitimate interest. Gradient will no longer process your personal data, unless they demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation or for the establishment, exercise or defense of legal claims.
    Right to withdraw your consent You have the right to withdraw your consent when it has been obtained, without this withdrawal affecting the lawfulness of the ersonal data processing operations previously carried out.
    Other rights Depending on your country of residence, you may have additional local rights with respect to our processing of your personal data. For example, if you are based in France, you can define either general or specific guidelines regarding your personal data in the event of your death (e.g., their deletion or transmission to any person of your choice). You may revoke your instructions at any time.

    It is specified that the exercise of these rights is based on the legal basis of the processing as indicated in Section 3 of this privacy policy, as follows:

    Access Rectification Erasure Restriction Data portability Objection
    Consent Yes Yes Yes Yes Yes Withdrawal of consent
    Steps prior to
    entering into a
    contract    		 Yes Yes Yes Yes Yes No
    Contract Yes Yes Yes Yes Yes No
    Legitimate interest Yes Yes Yes Yes No Yes
    Legal obligation Yes Yes No Yes No No

    Under certain circumstances, Gradient may ask you for specific information in order to confirm your identity and ensure the exercise of your rights. This is another appropriate security measure to ensure that personal data is not disclosed to an individual who does not have the right to receive it

    UIf you have any questions or wish to exercise your rights, you may directly contact Gradient by sending an email at contact@gradientdenervation.com.

    If needed, you may also lodge a complaint with your national data protection authority. This right may be exercised at any time and free of charge, at the exclusion of potential postal fees or expenses related to legal representation or assistance should you choose to engage third party assistance for the procedure.

    9. CHANGES TO THIS POLICY


    This privacy policy is clearly dated and may be modified and updated by Gradient at any time, in particular in the event of changes related to the services available on the Website or the applicable law. Therefore, we recommend that you consult this privacy policy each time you access the Website. If applicable, the updated privacy policy will be communicated to you by any appropriate means.