1. Purpose and Scope
The Paris Brain Institute (“ICM”) is a private foundation recognized as being of public utility, committed to the development of scientific and medical research. Through its NeurAL innovation and acceleration program, the ICM supports the emergence of neuroscience projects and start-ups and promotes the transfer of discoveries toward concrete applications for patients. As a data controller, the ICM has established this privacy policy to inform subscribers, professional contacts, and users of how their data is managed within the context of its NeurAL contact database and its quarterly newsletter.
In the context of its scientific animation and institutional communication activities, the Brain Institute attaches fundamental importance to the respect of privacy and the protection of personal data.
The personal data processing described in this document is implemented in accordance with the European Regulation No. 2016/679/EU of April 27, 2016 (“GDPR”), under the common conditions and guarantees set out in this document, and with the amended French Data Protection Act (Loi Informatique et Libertés) No. 78-17 of January 6, 1978.
2. Data controller and data protection officer
The processing activities described in this policy are carried out under the responsibility of the Paris Brain Institute, located at Hôpital de la Pitié-Salpêtrière, 47 Boulevard de l’Hôpital, 75013 Paris, France.
To ensure compliance with data protection regulations and guarantee the effective exercise of individuals’ rights, the Paris Brain Institute has appointed a Data Protection Officer (DPO).
The NeurAL operational team and the DPO may be contacted regarding any question or request relating to personal data at: neural@icm-institute.org and dpo@icm-institute.org
3. Purposes of Processing
Your data is processed for the following purposes:
– Management of the NeurAL professional contact database : This processing activity aims to maintain institutional relationships with researchers, applicants to calls for projects, and ecosystem partners met at events or through the ICM network.
– Quarterly distribution of the NeurAL startup studio newsletter : The sole purpose of this processing activity is to provide subscribers with strategic monitoring and updates regarding program activities (R&D reports, clinical developments, fundraising rounds, patent filings, performance indicators, agenda updates, and calls for projects). This communication is intended exclusively for scientific information and outreach purposes and supports the development of translational research, without any commercial solicitation or marketing activities.
4. Legal basis for processing
These processing activities are based on the legitimate interests of the Paris Brain Institute and NeurAL in promoting research and innovation, maintaining relationships with individuals encountered in the course of their activities, fostering their innovation network, and sustaining ongoing engagement with ecosystem stakeholders.
You may object at any time to inclusion in the newsletter or contact database without providing justification, either by contacting us directly or through the unsubscribe link included in each communication.
5. Nature, relevance and proportionality of collected data
The data collected directly from you, in accordance with Articles 13 and 14 of the GDPR, includes:
– First and last name;
– Email address (mandatory for newsletter distribution);
– Professional position/title;
– Affiliated company or organization;
– Preferred communication language.
NeurAL may also indirectly collect connection data through its website, including date, time, IP address, technical identifiers, software and hardware information, and cookies. In this case, such data will be retained for a maximum period of 13 months.
6. Data recipients and processors
The personal data collected is intended exclusively for authorized internal departments and NeurAL teams within the Paris Brain Institute whose functions require managing the contact database and distributing the newsletter. All individuals with access to such data are bound by a signed confidentiality obligation.
For newsletter distribution, ICM uses the services of Sarbacane, a French specialist provider acting as a data processor within the meaning of Article 28 of the GDPR. This processor acts solely under ICM’s instructions and within the framework of a contract guaranteeing the security and confidentiality of personal data.
7. Transfer of data outside the European Union
All processing, hosting, and distribution operations are carried out within the territory of the European Union. No transfer of personal data outside the European Union is performed as part of these processing activities.
8. Data retention period
Your data is retained in a form that permits identification only for as long as strictly necessary to fulfill the purposes for which it was collected.
Data collected through the NeurAL contact database and newsletter is retained for a maximum period of five (5) years from your last active interaction with ICM. At the end of this period, the data is deleted or anonymized.
For the avoidance of doubt, an active interaction includes a positive action such as clicking on a hyperlink or requesting information.
When a person unsubscribes from the newsletter, their email address is immediately removed from active mailing lists.
9. Your rights and how to exercise them
In accordance with applicable personal data protection laws, you have the following rights:
– The right to object at any time, without providing justification, to receiving the newsletter or to the processing of your data for network engagement purposes.
Each newsletter contains an unsubscribe link enabling immediate and simple
removal from the mailing list.
– The right of access to, communication of, correction, and updating of your data.
– The right to restriction of processing, allowing you to request a temporary suspension of the use of your data in cases provided for by law.
– The right to erasure of your data.
– The right to object.
To exercise these rights, including unsubscribing, you may:
– Contact the NeurAL team directly at: neural@icm-institute.org;
– Or use the unsubscribe link included at the bottom of each communication [insert link], allowing immediate and simple removal from the newsletter.
For any question relating to data protection or if you encounter difficulties exercising your rights, you may also contact ICM’s Data Protection Officer:
– By email: dpo@icm-institute.org;
– By post: Data Protection Officer, Paris Brain Institute, Hôpital de la Pitié-Salpêtrière, 47 Boulevard de l’Hôpital, 75013 Paris, France.
The Paris Brain Institute undertakes to respond to requests submitted through these channels within 30 days.
You also have the right to lodge a complaint with the French Data Protection Authority (CNIL):
– Online: https://www.cnil.fr/fr/webform/adresser-une-plainte
– By post: CNIL, 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France.