Privacy Statement

This privacy statement explains how we process personal data through our web and mobile apps and our website incision.care. Please take your time to read everything stated below. This policy applies to any users of our services, and to anyone else who contacts us or otherwise submits information to us, unless noted below.

1. Who we are?

We are Incision Group B.V., a scale-up company based in the Netherlands. Our headquarters are in Mauritskade 63, 1092 AD Amsterdam; if you want to have more information visit our page 'About Us'.

We believe in the importance of data protection and information security as a standard of excellence, trust, and ethics. We daily work together to comply with relevant legislations and international standards with the intention to bring our services to an even higher level of quality, in a prospective of continuous growth of information security, accountability and care of human rights.

If you have any questions about the Privacy Statement or any other questions regarding how we process personal data, you can write to privacy.security@incision.care, we’ll take care of your request and answer you back as soon as possible.

2. Our role

When we process your data we normally act in the capacity of Controller, meaning that we will be the ones fully accountable to inform you regarding the processing of your data and to handle your requests and privacy rights. In some specific cases, and in particular when we process your data to provide your employer, training institution, or similar, with our services (Incision Academy and Incision Assist), we will act in the capacity of Processor, meaning that we will process your data in line with the instructions of the entity you belong to (our Customer). To have a better overview of our responsibilities when we act in the capacity of Processor, visit our page 'Processor Obligations'.

3. This website incision.care

When you enter our website, this one automatically processes a certain amount of information (IP address, the model of the device, browser, local code, and the universally unique identifier) that is necessary to allow your device to properly interact with it. Our website stores this information only for the duration of the single session. If you contact us through the contact forms available on our website, we’ll process you data exclusively to answer your questions and support you, and we will store your data as long as necessary for these activities.

Cookies

Our website stores cookies on your device to remember your personal preferences and settings, maintain a high level of security, and to analyze how visitors interact with it. In addition to cookies, we log information about your device, including the existence of cookies, your IP address and information about your browser.
Out of technical cookies, necessary for the correct interaction with the website, we will process only anonymous analytic information related to how visitors interact with our website, without recording any personal data.
If you want to know more about how we use cookies and/or if you want to see in detail the cookies we use, please see our Cookie Policy.

4. Our Products

Incision Academy

Incision Academy is a web application completely based on the computing services of Amazon Web Services, to ensure a high level of security of your data and availability of the service. Your data will be stored in Europe.

The provision of our services: We process your login information, payment data (if you activate your own license for our product), the courses you complete, the communications you’ll send us, etc. to allow you to properly use our application. We will process your data as long as you have a user profile on Incision Academy; you can update your data autonomously and at any time, and you can request to delete your user profile writing to hi@incision.care. After two years of continuous inactivity, we will contact you using your email address to ask if you’re still interested in our products. If you won’t confirm your interest to remain our user, we will delete your user profile.

Feedback: If you use our feedback panel to either comment on a feature or report a bug, we will keep it in the highest consideration and, if you’ll decide not to be anonymous, we could get in touch with you via email or, if you specifically ask, via telephone to provide you with all the necessary support. We will process the feedback and your data also to understand how to implement our services, storing them for no longer than six months.

Marketing communications: If you opt-in to receive marketing communications during the activation of your user profile, we will send you email communications regarding our products, new features, and events that we will participate in.

Other communications: You may receive other email communications form us, and in particular: if necessary for the provision of our services (activation of your user profile, follow up to your request, etc.); to invite you to participate to surveys (the participation to our surveys is always free and not necessary to access our products); or to inform you regarding new features/courses of Incision Academy.

Every email communication that is meant to inform you regarding our products or sponsor our business will provide you with the possibility to opt-out by receiving further communications, simply by clicking on a link that you’ll find in the body of the email.

Cookies and usage data: Our web application stores cookies on your device. This happens mainly to optimize your interactions with Incision Academy, to maintain high standards of security, and to analyze the performance and usage of our product (“analytical purpose” - understand how to implement our products to better fit users’ needs). In addition to cookies, we log information about your device, including the existence of cookies, your IP address and information about your browser. For analytical purpose, if you’ll provide us with your consent, we will also process your usage data, and in particular every interaction you have with the different features; this includes, but is not limited to, the duration and the date of each interaction, surgical films watched, etc. These activities are performed with particular attention to limiting the amount of personally identifiable information we process about you. If you decide to delete your profile, usage data will be anonymized by removing every reference to you (such as user ID, name, email).

NOTE: If we’re processing your data on behalf of a customer, we may share (after receiving a legitimate request) with it some specific usage data.

Other processing activities: In addition to everything stated in this document, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Incision Assist

Incision Assist is a web and mobile application completely based on the computing services of Amazon Web Services, to ensure a high level of security of your data and availability of the service. Your data will be stored in Europe.

The provision of our services: We process your login and user information, the communications you’ll send us, etc. to allow you to properly use our application. We will process your data until the customer you belong to will tell us either return or delete your data.

Feedback: If you use our feedback panel to either comment on a feature or report a bug, we will keep it in the highest consideration and, if you’ll decide not to be anonymous, we could get in touch with you via email or, if you specifically ask, via telephone to provide you with all the necessary support. We will process the feedback and your data also to understand how to implement our services, storing them for no longer than six months.

Marketing communications: If you opt-in to receive marketing communications during the activation of your user profile, we will send you email communications regarding our products, new features, and events that we will participate in.

Other communications: You may receive other email communications and in-app push notifications form us, and in particular: if necessary for the provision of our services (activation of your user profile, follow up to your request, etc.); to invite you to participate to surveys (the participation to our surveys is always free and not necessary to access our products); or to inform you regarding new features of Incision Assist.

Every email communication that is meant to inform you regarding our products or sponsor our business will provide you with the possibility to opt-out by receiving further communications, simply by clicking on a link that you’ll find in the body of the email.

Cookies and usage data: Our web application stores cookies on your device. This happens mainly to optimize your interactions with Incision Assist, to maintain high standards of security, and to analyze the performance and usage of our product (“analytical purpose” - understand how to implement our products to better fit users’ needs). In addition to cookies, we log information about your device, including the existence of cookies, your IP address and information about your browser. For analytical purpose, if you’ll provide us with your consent, we will also process your usage data, and in particular every interaction you have with the different features; this includes, but is not limited to, the duration and the date of each interaction, key words typed, usage of each feature, etc. These activities are performed with particular attention to limiting the amount of personally identifiable information we process about you.

NOTE: We may share (after receiving a legitimate request) usage data with the Customer you belong to.

Other processing activities: In addition to everything stated in this document, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. Service providers and guarantees

All our third-party service providers are committed to taking appropriate security measures to protect your personal data in line with our policies. We only allow them to process your personal data for specified purposes and in accordance with our instructions. In case a third-party service provider requires to process personal data on our behalf outside the European Union, we will adopt in advance adequate guarantees to ensure the same level of protection to that data (the preferable mean will be signing with the third-party service provider appropriate standard contractual clauses as issued by the European Commission on 04th June 2021).

6. Your rights

You can at any time exercise the following rights:

  • Right to withdraw the consent: To the extent that the legal basis for the processing of your data is your consent, you have the right to withdraw that consent at any time.
  • Right to access: You have the right to confirmation as to whether we process or not your personal data and, where we do, receive a copy of that data, together with additional information regarding the processing activities (purposes, disclosures, etc.).
  • Right to rectification: You have the right to have any inaccurate data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed.
  • Right to erasure: You have the right to request the erasure of your data without undue delay.
  • Right to restriction of processing: You have the right to request the restriction of processing.
  • Right to data portability: You have the right to receive your data in a structured, commonly used and machine-readable format and the right to transmit those data to another controller.
  • Right to object: You have the right to object to the prevalence of interests legitimating the processing over your interests, rights and freedoms.

Out of some circumstances in which you can autonomously honor your rights (for instance, opt-out from receiving marketing communications; correct you data on your user profile, etc.), to exercise your right you can write at any time to privacy.security@incision.care; we will take care of your request.

Please note that:

  • We can honor your request if we are processing your data in the capacity of controller, otherwise we will forward your request to the controller.
  • We may ask you to verify your identity and/or to provide more information regarding your request.
  • We will answer you without undue delay and in any event within one month (we may require more time taking into consideration the complexity or the amount of the requests).
  • Sometimes your rights are restricted, and, in some legitimate circumstances, we may decline your request (in these cases, we will always explain to you why we did so).
  • In no circumstance we will sell your data.

If you consider that the processing of your data infringes data protection laws, you have the right to lodge a complaint to:

  • The National Supervisory Authority.
  • The Information Commissioner’s Office (ICO) if you’re based in the United Kingdom.
  • The Swiss Federal Data Protection and Information Commissioner (FDPIC) if you’re based in Switzerland.

Minors under age of 16

Our application and services are intended for business use, and we do not expect them to be of any interest to minors. We do not intentionally collect any personal information of consumers under the age of 16.

7. Information security

We are committed to protecting the security of your data by implementing appropriate technologies and procedures, to avoid unauthorised access or disclosure. We utilize a variety of security technologies and organizational procedures to help protect your data, such as access controls, firewalls and secure servers, encryption, secure connections, etc.

8. Changes to this Privacy Statement

We may revise this privacy statement from time to time. The most current version of this document will govern our use of your data. If we make a change to this statement that, in our sole discretion, is material, we will notify you via email or in-app notification. By continuing to access or use our services after those changes become effective, you agree to be bound by the revised privacy statement.