XGLab S.r.l. (hereinafter
“XGLab”) respects your right to privacy. The Privacy Policy explains
who we are, how we collect, share and use your personal data and how you can
exercise your privacy rights. If you have any questions or concerns about our
use of your personal data, please contact us using the contact information
provided at the end of this Privacy Policy. For more information about
XGLab, please refer to the “About us” section of our website.
Pleasecarefullysuggest this Privacy Policy to ensure that we have not
overlooked information that is potentially relevant to you.
Purpose of this Privacy
Policy This Privacy Policy is relevant to:
i. Any user, or visitor, of the XGLab website, its platforms, applications and
its online services or products under our control.
ii. Individuals who share their business contact details or other personal
information with XGLab as part of a potential or existing business
relationship, during webinars, trainings or events, including trade shows or
conferences, or for other business purposes, including customer services and
product and laboratory related services, as well as current and potential
customers and their representatives; and
iii. Any citizen who interacts with XGLab and individuals with whom we do
business, which includes, but is not limited to, regulatory staff, suppliers
and visitors to our sites and offices. This Privacy Policy does not apply to
candidates, employees, contractors or other entities operating
on the XGLab website. If you are part of the XGLab staff, please refer to the Privacy Policy for personnel available on
the XGLab Intranet. Applicants
may refer to the privacy policy we share directly.
In certain cases the collection and use of personal information may be
described within a separate privacy policy.
Who is responsible for the
collection and use of your personal data?
The data controller is XGLab S.r.l., with registered
office in Via Conte Rosso, 23 – 20134 – Milan (MI),, which can be contacted through
the channels described in the paragraph “How to contact us” (at
the end of this document).. XGLab S.r.l.
it is therefore
responsible for the collection and use of your personal
data (the so-called “Data Controller”) and determines which data to collect, how to
use it, how long to keep it and with whom to share it.
What personal information does XGLab collect and why?
Your personal information collected by us falls predominantly into the
following categories:
a. Information you voluntarily provide
- We may
collect personal data directly from you when you interact with XGLab and
usere such data for the purposes described below or as a notice to you at
the time of collection. - When you
register an accounton the XGLab platform or when you submit a
contact or feedback form from our website, you may be asked to submit
certain information, such as contact details (name, surname, e-mail
address, telephone number, etc.), your role within your company and your
company’s interaction with XGLab , geographical information (e.g. business
address/country) and how you would justify your interest in XGLab. - When you
attend or have been invited as a speaker at seminars, workshops, trade
fairs or conferences, we may ask you for your contact details (name,
surname, e-mail address, telephone number, etc.), your role within your
company and your company’s interaction with XGLab, geographical
information (e.g. company address/country), and national registration
number, if you are a healthcare professional, in certain countries where
applicable. - When you
complete a survey of your experience with our products or services, to
help us improve our products and services, we may ask you to indicate your
role within your company and your company’s interaction with XGLab, as
well as geographic information (e.g. business address/country). - When you
visit our site or offices, we may record your first name, last name,
e-mail address, telephone number etc., as well as your role within your
company and your company’s interaction with XGLab, as well as geographical
information (e.g. business address/country) in order to register you as
visitors within our system, filter our visitors in relation to the list of
sanctioned parties and provide you with appropriate login credentials. We
may also collect CCTV images for access control and security purposes on
the Site, in accordance with applicable laws and regulations. In the event
of an outbreak or pandemic, and in accordance with applicable local laws
and regulations, we may collect information about your body temperature
(e.g., but not limited to, using a thermoscanner), or if you have traveled
to high-risk countries or areas. - If you
are a consultant to an XGLab
company, work for a company
bound by a contractual relationship with XGLab, or provide other services
to us, we may ask you to forward us certain information, such as contact
details (name, surname, e-mail address, telephone number, etc.), your role
within your company and your company’s interaction with XGLab , as well as
geographical information (e.g. business address/country). - If you
fill out any kind of form at a trade fair or marketing event organized by XGLab
or in which XGLab is represented, we may collect personal data (name,
surname, e-mail address, telephone number, etc.), your role within the
company, your company’s interaction with XGLab, as well as geographical
information (e.g. company address/country), and how you would justify
your interest in XGLab.
b. Information We Collect
Automatically
- In
certain cases we may automatically collect personal information about you
and the device you use when you interact with us. - When you
use and browse our online services, visit our website, subscribe to social
news feeds, watch a webinar, we automatically collect certain information
from your device. This personal data may include: your IP address, device
type, unique device identification numbers, browser type, the URL of the
website from which you came, extended geographical location (e.g. at the
country or city level), date and time of access, amount of time spent
using the services and websites, data transferred, pages visited and
other technical information. We may also collect information about how
your device/hardware has interacted with our website or platform
(including clicked links), what activities users have performed within an
application (e.g. access history). Most of this data is generated and
collected automatically, as part of the standard operation of our online
services and will be processed in accordance with applicable laws and
regulations. - When you
are invited to and participate in a video conference with XGLab, we
automatically collect certain information about you (e.g. first and last
name, email address, profile picture, if any), meeting metadata (e.g.
date, time and duration of communication, meeting name, IP address of
participants), device data (e.g. IP addresses, MAC addresses, Client
version), text data and video data (e.g. chat histories, video, audio and
presentation recordings, to the extent permitted by applicable law and
with the consent of the participants, if applicable), as well as
connection data (e.g. telephone numbers, country names, start and end
times, IP addresses) - When you
receive an email from XGLab, we may collect information about whether the
email has been opened or not and the content accessed by the email.
Some of this information may be
collected using cookies and similar tracking technologies, as explained below
on our Cookie Policy page.
c. Information Collected by Third Parties
We may collect information about you
from third parties, usually to supplement the information we need to create or
maintain our relationship with you.
- We may
collect personal information when we acquire companies and perform
post-merger integrations, in order to evaluate the target company and its
activity, in accordance with the law and regulations in force. - We may
collect additional personal information about you when we perform analysis
for compliance purposes as set out in letter a. (Information you
voluntarily provide) above, in order to supplement part of the personal
information you have already provided. - We may
use publicly available resources that contain personal information
provided by you and/or your company (e.g. chamber of commerce, company
websites, professional networks, universities, publishing websites, social
networks and other digital platforms) or by third party providers acting
on our behalf, in accordance with relevant laws and regulations.
In general, we will only use your
personal information collected by us for the purposes described in this Privacy
Policy or for reasons stated to you at the time of collection of your personal
information. However, we may also use your personal information for other
purposes that are not incompatible with those stated (such as scientific or
historical research grounds or statistical reasons), if and where permitted by
applicable data protection laws. As a general principle, your granting of any
consent and the forwarding of any personal information to
XGLab by you is entirely voluntary; you will not generally suffer prejudicial
effects if you decide not to provide consent or your personal information. However, there are situations in which we cannot proceed without
certain personal data, for example because such personal data is required to
process your orders or requests, manage the contractual relationship between
you or the company for which you work and XGLab, or provide you with access to
a specific online content or newsletter. In these cases it will unfortunately
not be possible for us to provide you with what you have requested in the
absence of the relevant personal data.
Why we process your personal
information
Whether you are a customer, users of our online services (including our
websites), suppliers of products and services to us, participants or speakers
at a conference, event or roadshow organized or attended by XGLab, or
collaborators in a scientific research or project with XGLab , we will process
your personal data for the following purposes (if applicable):i. Create an
account on our online services for you or the company/organization for which
you work, maintain and update that account;
ii. Allow you to access or interact with our online resources, including
webinars
iii. Verify your identity, where required by law;iv. Negotiate and enter into
agreements (such as sales and service agreements or research collaborations)
with the company or organization you work for, as well as fulfill your orders
for products and services and fulfill any obligations arising from our
relationship with the company you work for or imposed by law;v. Update orders
and transactions;vi. To be able to contact you about products and services that
may be of interest to you or to provide you with updates and support on
products and services;vii. Provide the company or organization you work for
with our products and services;viii. Comply with any legal obligation
applicable to us;ix. Verify financial transactions and perform compliance
analysis checks. In accordance with applicable local laws, and based on your
consent where required, we may also:
i. Contact you to send you marketing emails or newsletters, advertising
material via regular email or call you on the phone, to understand whether or
not you are interested in our products and services. In these cases you will
have the option to choose never to be contacted by XGLab;ii. Collect personal
information about you (e.g. your location, specialization and publications)
from publicly available sources such as company websites, universities and
publications, and combine it with personal information we collect about you, in
order to improve the customer profile in support of our sales and marketing
activities.
Third
parties We may disclose your personal information to the following categories
of recipients:
- to our
website or application hosting partners and other third parties who assist
us in the operation of our platforms, in conducting our business or in
providing the services to you, to the extent that these third parties
consent to process personal data in accordance with applicable data
protection law; - to our group
companies, third-party service providers and partners, including
distributors and other commercial intermediaries, who provide data
processing services on our behalf or who otherwise process personal
information for the purposes described in this Privacy Policy or notified
to you when we process your personal information. - An
overview of Bruker’s sales and service offices can be found here:
https://www.bruker.com/about-us/offices.html. A list of the current
companies in the group is made available on request. Third-party service
providers and partners, including providers of Customer Relationship
Management (“CRM”) or Marketing Automation Solutions, and a list
of third-party service providers and partners relevant to personal
information are made available upon request; - to any
law enforcement body, regulatory body, government agency, court or other
third party where we believe disclosure is necessary (i) by virtue of
applicable law or regulation, (ii) to exercise, enforce or defend our
legal rights, or (iii) to protect your vital interests or those of others; - to an
actual or potential buyer (and its agents and advisors) in connection with
any current or proposed purchase, merger or acquisition of any part of our
business, assuming that we will inform the buyer that he must use your
personal information only for the purposes set out in this Privacy Policy; - to any
other person, subject to your consent to disclosure.
Cookies and similar tracking
technologies
We use cookies and similar tracking
technologies (generally “Cookies”) to collect and use your personal
information, including to understand and save your preferences in case of
future visits and provide you with advertising messages based on your interests.
For more information on the types of Cookies we use, why and how you can manage
Cookies, please see the Cookie Policy.
How does XGLab keep my personal information safe?
We use appropriate technical and
organizational measures to protect your personal information collected and
processed by us. The measures we take are designed to provide a level of
security appropriate to the risk of processing your personal information. Some
specific measures we use include regular malware scanning. Your personal information
is protected within secure networks and accessible only to a limited number of
persons who have special access rights to such systems and who are required to
keep the information absolutely confidential. We require the same level of
diligence from any third party involved in processing your personal information
in accordance with applicable law.
International data transfer
Because XGLab is active within a global
network of partners, your personal information may be transferred to and
processed in countries other than the one in which you reside, including the US
and EU. Transfers of data outside your country of origin are carried out in
accordance with applicable data protection laws, based on your consent, if
required, or by implementing appropriate protection measures including a
resolution of the competent data protection authority, which declares that the
level of data protection in the destination country is adequate, EU standard
contractual clauses or similar contracts, where legally permitted. If you would
like to learn more about how
XGLab ensures compliance in the transfer of your personal information
internationally, please contact us using the contact information below.
Data retention
We retain your personal information if
there is a legitimate activity to be carried out (for example, to provide you
with a service requested by you or to comply with applicable legal, tax and
accounting requirements). When a legitimate activity is no longer in progress
that requires the processing of your personal information, we will either
delete or anonymize such information; if this is not possible (for example in
the event that your personal information has been stored in backup archives),
we will then keep your personal information securely and detach it from any
further processing until it is possible to delete it.
Your data protection rights
Please note that in manycircumstances
and we cannot carry out activities together with you without the processing of
some of your personal information (e.g. your contact information). You can use
our online services without giving your consent to cookies (unless strictly
necessary); the consequence that some features will be less customized to your
needs. You have the right to opt out of receiving commercial communications at
any time. Please use the unsubscribe feature in connection with such
communications.
You can submit a request to XGLab regarding your personal information by
contacting us at po-xglab@oneseal.eu. More information about the specific
rights for individual entities located in the EU/EEA or california residents is
described below.
We will endeavor to respond quickly to your requests, in accordance with
applicable laws. When you contact us, we may ask you to provide us with
information to authenticate your identity, in order to support you in your
request. If you are unable to provide this information, we may not be able to
process your request. When we receive your personal data from our customers and
process your personal information on their behalf to fulfil our contractual
obligations, we do so as Data Processors. We have no control over our
customers’ privacy and security practices and processes. If your personal
information has been forwarded to us by an
XGLab customer and you wish to exercise any of the
rights mentioned above, please contact the customer in question directly, or
provide us with the customer’s name so that we can adequately report your
request to them.
EU/EEA and Swiss Privacy Policy
If you reside in the EU/EEA or Switzerland, the following supplemental privacy
policy applies. Legal basis for the processing of your personal dataIn
accordance with applicable laws, we rely in many cases on the following legal
bases for the processing of your personal data, in a manner appropriate to the
case:
- Contractual
obligations: The processing is necessary for us to enter into a contract
with you or to proceed with operations at your request before concluding a
contract - Legal
obligation: The processing is necessary for us to comply with an
applicable legal obligation - Legitimate
interest: The processing is necessary for us to consider a justified and
legitimate interest in view of your privacy and other fundamental rights
and interests - Consent:
Processing is carried out based on your consent
The specific legal bases on which we
rely for each of the purposes for which we process your personal information
are defined below:
|
Purpose |
Legal basis (applicable in individual cases) |
||
|
Sale of our products and services Create an account related to our online services for Allow you to use the online platform to access the Enter into and conclude a contract with you or the Send you information (by email or through other Fulfill your orders or those of your organization To perform our contractual obligations to you or to Maintain and update your account, orders and Fulfill our contractual obligations to you or to the |
Contractual obligations on the basis of the Legitimate interests in providing services. Consent. |
||
|
Authentication Authenticate your identity, where necessary or |
Legal obligation. Legitimate interest. Contractual obligations. |
||
|
Satisfaction of your requests Provide the requested services, information and Respond appropriately to your questions. Request for feedback |
If your request or question relates to a service you If we are legally obliged to respond to your request In all other cases, Legitimate Interest applies as Consent. |
||
|
Conformity Comply with any legal obligation applicable to us. Verify financial transactions and perform compliance |
Legal obligations as per applicable laws. Legitimate interests for the protection of customers |
||
|
Marketing and communication Personalize your experience on online services. Contact you to determine whether or not you wish to To collect personal information about you (e.g. your Invite you to participate in questionnaires and |
Legitimate interest. Consent as required by law. |
||
|
Establish and maintain communication with you Invite you to join video conferencing using online |
Consent. Legitimate interest to ensure consistency and high Contractual obligations. |
||
|
Customer service To deal with the recordings of your calls with the |
|
||
|
Health and safety Process CCTV CCTV CCTV recordings to ensure the In the event of an outbreak or pandemic, collect |
Legal obligation. Consent. Legitimate interest to maintain the health and |
||
|
|
|
Your rights as a data subject
- If you
wish to access, correct or request the deletion of your personal
information, you can do so at any time by completing the Request Form
as a data subject. - You can
also object to the processing of your personal information, request
that we process your personal information to a limited
extent or request the portability of your personal information. Also in
this case you can exercise these rights by contacting us through the
contact details provided in the section below “How to contact
us”. - You have
the right to opt out of receiving commercial communications from
XGLab at any time. You can exercise this right by clicking on the
“unsubscribe” or “opt-out” link in the commercial
emails we send you. To select other forms of marketing (such as postal
marketing or telemarketing), please contact us using our contact details
set out in the “How to Contact Us” section below. - Similarly,
if we have collected and processed your personal information with your
consent, you can still withdraw your consent at any time. The
withdrawal of your consent will not affect the legality of any processing
carried out by us prior to your withdrawal, nor will it affect the
processing of your personal information conducted on the basis of legal
grounds for processing other than consent. - You have
the right to lodge a complaint with the Data Protection Supervisor
in relation to our collection and use of your personal information. For
more information, please contact your local data protection officer.
We respond to any request received from
individual entities wishing to exercise their data protection rights in
accordance with applicable data protection laws.
CCPA Privacy Policy
If you are a California resident, California state law grants you the following
rights with respect to your personal information:
- The right
to know what personal information we have collected, used, disclosed and
sold. To submit a request for disclosure, you can contact us on +1 (888)
914-9661 and enter PIN 960300 or submit your request via the Request Form
as a Data Subject. - The right
to request that we delete any personal information we have collected about
you. To submit a cancellation request, you can contact us on +1 (888)
914-9661 and enter PIN 960300 or submit your request via the Request Form
as a Data Subject.
When you exercise these rights and
submit a request to us, we will verify your identity by requesting your e-mail
address, telephone number, information about your company’s contract or your
direct relationship with XGLab. We may also use a third-party verification
service provider to verify your identity. The exercise of these rights by you
will not have a negative effect on the price and quality of goods and services.
For the period of 12 months prior to the date of this Privacy Policy,
XGLab has not sold personal information, nor does it plan to do so in the
future. Please note: If you are a customer of one of our customers, you should
first contact them in relation to your California privacy rights.
Updates to this Privacy Policy
We may update this Privacy Policy from time to time, to comply with changes in
legal, technical or business development requirements. When updating our
Privacy Policy, we will take appropriate steps to inform you, in relation to
the extent of the changes we have made. You can see when the Privacy Policy was
last updated by checking the “last updated” date indicated at the top
of this Privacy Policy.
How to contact us
If you have any questions or concerns
about our use of your personal data, please contact us using the following
details:
XGLab S.r.l.
Via Conte Rosso, 23 – 20134 – Milan (MI)
The Chief Privacy Officer of XGLab can be reached at the e-mail address privacy@bruker.com
