Effective date:  10th of August 2020


This privacy policy (“Privacy Policy”) describes how and when Allurion S.a.s. (“Allurion”, “we”, “us” and/or “our”) collects, uses and shares your personal data when you use the website https://allurion.com/en and/or communicate with Allurion through another contact channel (collectively, the “Services”). Please note, however, that this Privacy Policy does not cover how we process your personal data collected via the Allurion Scale mobile application (the “App”). For further details on how we process your personal data in connection with the App please see our App Privacy Policy https://allurion.com/en/privacy-policy-mobileapp.

 

Allurion S.a.s. with its registered office at 11 rue de Tehéran, 75008, Paris, France will be the controller of your personal data. We collect your personal data through  your interaction with our Services. When you use our Services, you agree to the collection, transfer, retention, organization, consultation, processing, modification, selection, recovery, comparison, use, interconnection, blocking, communication, dissemination, deletion and other uses of your information as described in this Privacy Policy, therefore we recommend that you read it carefully.

 

1. PERSONAL DATA WE COLLECT

When you interact with our Services we may collect personal data when you submit it to us in the following ways:

  • Allurion Elipse Programme: if you wish to learn more about the Allurion’s Elipse Programme, you will be asked to provide your information on our website such as your name, telephone number, email, gender, age, height and weight, preference of clinic, preferred contact method and your preferences in how you wish to proceed with Allurion’s Elipse Programme. Providing you agree, your information will be shared with our customer care managers who will arrange for an Elipse Advisor to contact you to ask you more questions and potentially arrange an appointment with your selected Allurion Clinic. You can also submit your details using our Body Mass Index (BMI) calculator to find out whether your BMI is below 27 or more than 27 and determine whether Allurion’s Elipse Programme might be suitable for you.
     
  • Allurion Clinic: to assist you with selecting your Allurion Clinic you will be asked to provide your location, or select a clinic that is closest to you. Also, if your enquiry with us turns into an appointment or a placement, your selected Allurion Clinic may share your name and email address with us so we are able to determine how many appointments lead to placements of our Allurion’s Elipse Programme.  
     
  • Call with an Elipse Advisor: if you are contacted by an Elipse Advisor, the details of your call may be recorded for training and monitoring purposes.
     
  • Your questions: if you are a prospective or an existing Elipse patient,  a healthcare professional or other person who wishes to contact us with an enquiry in connection with Allurion’s Elipse Programme or have any other question or concern you wish to raise, you will be asked to provide your name, email address, telephone number, location and the details of your enquiry. You can also use our WhatsApp click feature on our website to ask for more information. If you use this WhatsApp feature you may be asked to provide your telephone number, location and your preferences on how you wish to be contacted.
     
  • Customer engagement: if you are a Health Care Professional and wish to offer Allurion’s Elipse Programme at your practice, we may collect certain personal data from you, or your representatives, such as name, contact details, business address and country.
     
  • Webinars: when you register for a webinar on our website, you will be asked to provide your name and email address.
     
  • Automated technologies: the servers hosting the website automatically record certain information about you when you use the website, including details of your IP address, software configurations, smartphone identification numbers and other data of a similar nature. Allurion may use this information to understand the manner in which pages of the website have been visited in order to monitor and improve the website. For further details please see the section on “COOKIES AND OTHER SIMILAR TECHNOLOGIES” below.

 

When sharing information or content through our Services, we invite you to think carefully about what you are deciding to make public.

 

If you choose to invite your acquaintances to learn more about our Services, you choose to do so under your sole responsibility, and warrant that you have received the necessary authorizations and approvals after having duly informed the person to whom the personal data belong.

 

2. OUR USE OF YOUR PERSONAL DATA AND OTHER INFORMATION

 

When you use our Services you may choose to provide your health-related information in order for us to determine your eligibility to join Allurion’s Elipse Programme or to respond to a question and/or concern which you have raised with us. This health-related information may include: details regarding your BMI and weight.

We will ask you for your explicit consent to the processing of your health-related information as described in this Privacy Policy, which you can withdraw at any time by contacting us at: privacy@allurion.com.

  • We process the personal data with your consent, to enable us to perform our contract with you and for the purposes of our legitimate business interests, as necessary for scientific research, as follows: To process any request or enquiry you make in connection with our Services, including Allurion’s Elipse Programme;
     
  • To contact you via email, telephone, SMS or WhatsApp to ask questions concerning your eligibility to join Allurion’s Elipse Programme and, if the criteria is met, arrange an appointment with an Allurion clinic;
     
  • To notify you about changes to our Services;
     
  • To improve and monitor the quality of our Services;
     
  • To protect the security of and managing access to our premises, IT and communication systems, online platforms, website and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;
     
  • To comply with our legal and regulatory obligations and requests, including reporting to and/or being audited or investigated by national and international regulatory bodies;
     
  • To comply with court orders and to exercise and/or defend our legal rights;
     
  • To understand how you visit our website, how you interact with us and to enrich your user experience, and to customize your relationship with us;
     
  • To conduct data analysis, testing and research, including for statistical purposes;
     
  • To conduct scientific research relating to Allurion’s Elipse Programme;
     
  • To enable you to register for webinars on our website; and
     
  • To send you communications about our products and services which may be of interest to you, as described in the “MARKETING” section below.  

If Allurion intends on using any personal data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the personal data is collected.

 

3. MARKETING

We may contact you to provide you with information about products and services similar to those which were the subject of a previous sale or negotiation of a sale to you. You may be contacted by us or one of our selected partners. 

 

You may opt out of receiving our marketing communications at any time by contacting by contacting us at: privacy@allurion.com.

 

We will continue to contact you for non-marketing related purposes where we need to issue a field corrective or safety notice, or to where we need to send certain information to you under a legal, regulatory, or ethical requirement.

 

 

4. COOKIES AND OTHER SIMILAR TECHNOLOGIES

 

As many other websites, we use the Cookie technology to collect data concerning the use of website and to improve our Services.

 

Cookies may be stored on your device and sent back to you when you use the Services a second time.  Through Cookies, websites record the actions and preferences of users (such as, for example, the language chosen, the font size, other settings regarding the layout of the site, etc.), so as to prevent the user to enter them when he/she returns to the site a second time or when he/she browses another page of the same site. Cookies are also used to monitor browsing sessions, to store information about users who have access to the site and may contain a unique identification code that makes it possible to trace the user's browsing session in the site, for statistical and advertising purposes. Users may also download on their devices Cookies owned by websites and servers other than the site they are visiting at that time ("Third Party Cookies"). Some Cookies are necessary for the technical functioning of the site; if you do not accept this type of Cookies, some functionalities and features of the site may not be accessible.

 

There are different types of Cookies, depending on their characteristics and functions, and they may be stored on the users’ devices for different periods of time: session Cookies are erased at the end of each browsing session; persistent Cookies can persist until the date predetermined by their owner.

Allurion uses the following Cookies on the website:

  • “strictly necessary cookies” which are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website,
  • “analytical cookies" to the extent that they are used directly by the website operator to collect aggregate information and information on visits to the website,
  • "functional cookies", which allow users to navigate according to certain predetermined criteria, such as the language or products to be purchased, in order to improve the quality of the service.
  • “tracking cookies”, which allow us to verify the origin of a user from another site.

Strictly necessary cookies are necessary to provide the website to you. We use such cookies without your prior consent. All other cookies are dropped after you have consented via the cookie banner on our website.

 

We may change our use of cookies over time, but our use of cookies will generally fall into the above categories. Please visit this page regularly so that you are aware of any changes.

 

Please pay attention to the fact that if you choose to disable the technical / functional cookies, even through the browser as described below, the website may not work properly, and some of its features may not be available or may not work properly.

How to view and change the Cookies settings through the browser

Users can select the Cookies that they wish to enable, disable or delete (totally or partially) using the tools offered by the browser used. In any case, it should be noted that the disabling of technical / functional cookies could lead to a deterioration in the use of the site and that some services offered or some features of the site may not work properly or not be available, and that users may be asked to change or insert manually some information or preferences whenever they visit the site.

To learn more about how to set Cookies preferences through your browser, please read the information available at the following links (Allurion does not control third-party navigation sites or their instructions on how to enable and disable cookies; these pages may be updated, modified or removed by third-party browsers at their sole discretion):

For more information about the cookies used by the website, please refer below.

 

  1. SSESSabe34bca7fafb37f71ee1ffcc82fb1f9 and cookie-agreed
    Functional cookies
    They are technical cookies aimed at facilitating and speeding up the navigation of the site.
     
  2. Quantcast Pixel
    Third-Party Analytical Cookie. 
    Quantcast Pixel is aimed at measuring how users interact with website content, in order to improve the content and the services provided.
    https://www.quantcast.com/it/privacy/
    https://www.quantcast.com/it/opt-out/
     
  3. Google Analytics
    Third-Party Analytical Cookie.
    Google Analytics Cookie is aimed at measuring how users interact with website content, in order to improve the content and the services provided.
    ttps://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?hl=it
    https://marketingplatform.google.com/about/
    https://policies.google.com/privacy?hl=ithttps://tools.google.com/dlpage/gaoptout?hl=it
     
  4. Facebook pixel
    Third-Party Analytical Cookie.
    Facebook Pixel is aimed at  measuring how users interact with website content, in order to improve the content and the services provided.
    https://www.facebook.com/policies/cookies
    https://www.facebook.com/full_data_use_policy

Please note that if you wish to opt out of Third Party cookies, as described above, please do so by following relevant instructions contained within the links to the Third Party sites provided.

For more information on cookies and how they can be managed and deleted please visit http://www.allaboutcookies.org/ or http://www.networkadvertising.org/choices/.

 

5. OUR DISCLOSURE OF YOUR PERSONAL DATA

We may share your Personal Data with the following:

  1. Subjects predetermined by law or when necessary to protect our Services. There may be cases of communication of your information to other parties in order to:
  • protect the rights of Allurion and its affiliates, as well as users of its Services;
  • protect the security of users of the Services;
  • prevent fraud (or for risk management purposes); or
  • to comply with the requirements of the law or judicial proceedings or in the event of a request for cooperation from a government agency, whether or not required by law.
  1. Our Service Providers. We engage service providers to process personal data for any of the purposes listed in this Privacy Policy on our behalf and in accordance with our instructions, such as IT support, customer care management, legal services, marketing campaigns, auditing.
     
  2. Allurion clinics which you prefer to be contacted.
     
  3. Affiliates of Allurion.
     
  4. Other Subjects in aggregate form. We may also share your information with third parties in aggregate or non-personally identifiable form.
     
  5. Prospective sellers or buyers of any business, stock, or assets to which we might assign or novate any of our rights and obligations; in such case we may disclose your personal data to the prospective seller or buyer of such business, stock, or assets.

 

6. SECURITY MEASURES

We make use of physical, technical and administrative measures to safeguard the information in our possession against loss, theft and unauthorized use, communication or modification of personal data. Please pay attention to the fact that, in any case, no transmission or storage of personal data can be guaranteed as 100% secure. Consequently, while committing ourselves to protect the information in our possession, we cannot guarantee or ensure the total security of any information that you send us.

 

7. POLICY FOR THE PROCESSING OF PERSONAL DATA RELATING TO MINORS

Our Services are not aimed at individuals under 18. If you are aware of the fact that a minor under 18 has given us your personal data, please contact us at privacy@allurion.com.

We do not intentionally collect personal information from children under 18. If we are aware of the fact that a minor under 18 has given us his/her personal data, we will take the necessary measures to remove this information.

 

8. RIGHTS OF THE USERS  

Allurion does not share your personal data with third parties for direct marketing purposes. Some browsers may transmit the "non-traceability" signal to the websites with which the user communicates. We do not take initiatives to deal with these signals. If industry standards were established and accepted in response to these signals, we could re-evaluate how to respond to these signals.

 

9. AMENDMENTS TO THIS PRIVACY POLICY

We may revise this Privacy Policy over time. The most recent version of the Privacy Policy will govern Allurion's use of your personal data and will be available on the website: https://allurion.com/en. We may make changes to this Privacy Policy in our sole discretion. By continuing to access  or use our Services after any changes have become effective, you accept the terms of the Privacy Policy as revised.

 

10. DATA RETENTION

Your personal data will be retained for a reasonable period of time, and in any event for a period no longer than 3 years, but also for any purpose connected to the protection of Allurion’s rights and the fulfilment of obligations set forth by any applicable law within the limits provided for by the aforesaid laws.

 

11. INTERNATIONAL DATA TRANSFERS

For individual based in the European Economic Area (“EEA”) and the United Kingdom: we will store your personal data within the EEA, and will not transfer your personal data outside the EEA.

For individuals based outside the EEA and the United Kingdom: we will store your persoanl data with an appointed service provider in your local region.

 

12. LINKS TO OTHER WEBSITES

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by Allurion (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that Allurion endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

 

13. OTHER TERMS AND CONDITIONS

Your access to and use of the website is subject to the Terms of use.

 

14. EXERCISE OF USERS’ RIGHTS

If you need to update, correct, access or delete your personal data, you can notify us.

 

For individuals based in the United Kingdom or the EEA: If you are based in the United Kingdom or the EEA, you may have the right to: (a) access the personal data we hold about you; (b) request we correct any inaccurate personal data we hold about you; (c) request we delete any personal data we hold about you; (d) restrict the processing of personal data we hold about you; (e) object to the processing of personal data we hold about you; and/or (f) receive any personal data we hold about you in a structured and commonly used machine readable format or have such personal data transmitted to another company.

 

Please note that we may ask you to verify your identity before responding to such requests.

 

Where you have been asked to consent to the processing of your personal data, you can withdraw consent, such as by contacting us using our contacts details below. Any withdrawal of consent will not affect the lawfulness of the processing based on your consent before the withdrawal. Please also note that where you withdraw consent, we will only stop processing your personal data that relates to the withdrawal of consent.

 

To exercise any of your rights in connection with your personal data, please contact us using the contact information in the “CONTACT US” section below. If you are located in the United Kingdom or the EEA, you have the right to complain to a Data Protection Authority in your country about our collection and use of your personal data.

 

15. CONTACT US

 

If you have any questions regarding this Privacy Policy or about your privacy when using our Services, please contact us at privacy@allurion.com.