Privacy Policy
This personal data policy has been drawn up by Kiosk, a simplified joint-stock company registered with the Paris Trade and Companies Register under number 980 428 072, whose registered office is located at 3 Boulevard de Sébastopol, Paris (75001) (hereinafter “Parallel”).
Parallel is a company that has developed a software solution designed to assist healthcare facilities in performing and automating the medical coding of hospital stays using artificial intelligence.
The sole purpose of this privacy policy is to describe the processing of personal data carried out by Parallel acting as data controller.
This privacy policy is established in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and with French Law No. 78-17 of 6 January 1978 on information technology, data files and civil liberties, in its latest version (the Personal Data Rules).
1. Definitions
The following definitions apply throughout this privacy policy:
- Data Subject: means a Visitor, an employee of a client, a prospect or any other person whose personal data is processed by Parallel acting as data controller.
- Site: means Parallel's website accessible at https://www.beparallel.com/fr/ and its sub-domains.
- Solution: means the software solution developed by Parallel, designed to assist healthcare facilities in performing and automating the medical coding of hospital stays using artificial intelligence.
- Visitor: means any person consulting or browsing the Site.
Unless the context requires otherwise, definitions in the singular include the plural, and vice versa.
2. Personal data collected
Parallel may process the following personal data, which will be processed for the purposes set out below.
- General information (first and last name(s), email address, telephone number);
- Information relating to the healthcare facility associated with the Data Subject;
- Browsing data within the Solution or the Site;
- Data relating to the Data Subject's consent to receive emails from Parallel;
- Visitors' browsing preferences on the Site (language and display preferences);
- Data relating to the signature of contracts and their performance;
- Data exchanged during interactions with Parallel's customer support (e.g. issues encountered, solution proposed by Parallel).
3. Processing activities, their purposes and their legal bases
Parallel carries out the following processing activities, each with its purpose and legal basis:
- 1. Contacting interested Visitors - Purpose: to contact Visitors who have left their details. Legal basis: consent.
- 2. Newsletter - Purpose: to keep interested persons informed about Parallel news. Legal basis: consent.
- 3. Handling support requests - Purpose: to respond to support requests and enable the client to benefit from the services as contractually agreed. Legal basis: performance of the contract.
- 4. Prospecting - Purpose: to develop Parallel's client base. Legal basis: legitimate interest.
- 5. Visit statistics - Purpose: to compile statistics on Site Visitors (e.g. number of Visitors per page). Legal basis: consent.
- 6. Browsing analysis - Purpose: to analyse browsing on the Site and/or the Solution. Legal basis: consent.
- 7. Contract monitoring - Purpose: to monitor and retain proof of acceptance of contracts entered into between Parallel and its clients or partners. Legal basis: performance of the contract.
- 8. Managing the commercial relationship - Purpose: to manage the commercial relationship with Parallel's clients and partners. Legal basis: legitimate interest.
- 9. Litigation - Purpose: to enable Parallel to organise its defence in the event of litigation or pre-litigation. Legal basis: Parallel's legitimate interest in defending itself.
- 10. Compliance with legal obligations - Purpose: to ensure Parallel complies with its legal obligations. Legal basis: legal obligations.
4. Recipients of the personal data processed
The personal data collected about Data Subjects and processed is necessary to pursue all of the purposes listed above and is intended exclusively for Parallel's internal management departments and, where applicable, its processors.
The categories of processors to whom personal data may be disclosed are as follows:
- Day-to-day operations: processors providing digital solutions used in Parallel's day-to-day operations, such as data hosting, detection of errors or bugs in the Solution or the Site, monitoring of the use of the Solution and the Site, and updates and proper functioning of the Solution or the Site.
- Marketing and communication operations: processors providing online and social media communication solutions and enabling data analysis, in particular for marketing purposes.
- Maintenance operations: processors with access to Parallel's technology in order to carry out maintenance or to address technical issues with the Solution or the Site in an emergency.
- Management and advisory operations: processors supporting Parallel with its compliance management, whether in accounting, legal, financial or audit matters.
Neither Parallel nor its processors sell Data Subjects' personal data in any way whatsoever.
In the context of restructuring, reorganisation, fundraising, disposal or acquisition transactions (or any similar transaction), Parallel may disclose certain personal data to third parties (for example investors, potential acquirers, advisers and auditors) where this is necessary to prepare and/or complete the transaction, in compliance with the Personal Data Rules and subject to appropriate safeguards (in particular confidentiality undertakings and access limited to authorised persons only).
5. Retention of personal data
Data Subjects' data is not kept beyond the period strictly necessary for the purposes pursued and set out in article 3 of this privacy policy, in particular:
- Data processed in connection with support requests is kept for as long as it takes to handle the request.
- Prospects' data is kept until consent is withdrawn or the prospect objects, or for 3 years from the prospect's last contact.
- Data relating to the signature and performance of contracts is kept for the entire duration of the relationship with the client or partner.
- Cookies are kept for up to 13 months, subject to the limitations imposed by your browser.
Parallel anonymises, archives or deletes Data Subjects' data as soon as the purpose and the retention period expire, subject to the time needed to comply with its legal obligations, in particular in view of civil and commercial limitation periods.
6. Transfer of personal data
The personal data processed by Parallel is hosted by Amazon Web Services, whose servers are located in France (with backup in Germany).
Some of the personal data processed by processors may be transferred outside the European Union, in particular to the United States. In such cases, where transfers are made to countries not covered by an adequacy decision, Parallel ensures that the processors concerned implement appropriate legal, technical and organisational measures to frame any transfer of personal data, in particular by using the standard contractual clauses drawn up by the European Commission.
7. Cookies and other trackers
Parallel uses cookies and other trackers, which are small computer files stored on your devices in order to collect data relating to your browsing, measure the Site's audience and improve the Site.
7.1 Strictly necessary cookies
Some cookies/trackers are strictly necessary for the operation and security of the Site and/or for the provision of a service expressly requested by the User (for example, keeping a session open). As such, they may be placed without your consent.
7.2 Cookies subject to your consent
Audience measurement cookies are, in principle, only placed if you consent to them via the cookie banner.
7.3 List of cookies and trackers
The list below summarises the main cookies and trackers that may be placed on your device while browsing the Site. The durations indicated correspond to the default durations documented by the relevant providers (or, where applicable, to the durations communicated by them) and may vary depending on the configuration used, your browser and your choices (acceptance or refusal). As of today, the cookies subject to consent used on the Site are Google Analytics (GA4) audience measurement cookies.
- Google Analytics / GA4 - Category: audience measurement. Purpose: to distinguish visitors in order to measure the Site's audience (traffic statistics, content performance). Legal basis: consent. Duration: 2 years (default). Domain: beparallel.com (or sub-domains). Placed by: Google.
- Google Analytics / GA4 - Category: audience measurement. Purpose: to maintain session state and associate interactions with a GA4 property. Legal basis: consent. Duration: 2 years (default). Domain: beparallel.com (or sub-domains). Placed by: Google.
7.4 Managing your preferences
In accordance with article 82 of the French Data Protection Act, you may accept or refuse all or some of the cookies subject to consent via the banner displayed on your first visit, and then change your choice at any time by clicking on Cookie settings, accessible from the Site.
Refusing non-essential cookies does not prevent access to the Site, but may degrade certain features (for example the chat module) and reduce Parallel's ability to measure audience and improve the user experience.
8. Data subjects' rights
8.1 Nature of the rights
In accordance with the Personal Data Rules, Data Subjects have rights over their personal data, namely:
- Right of access: any Data Subject may find out what personal data Parallel holds about them and obtain a copy of it.
- Right to rectification and erasure: any Data Subject may request that inaccurate or outdated personal data concerning them be corrected, and that it be deleted.
- Right to object and to restriction of processing: any Data Subject may object to the way Parallel processes their personal data or request that the processing concerning them be restricted, to the extent possible and subject to any compelling legitimate grounds Parallel may have for continuing the processing, such as legal obligations in relation to anti-money laundering and counter-terrorist financing.
- Right to withdraw consent: any Data Subject may withdraw their consent for processing carried out on that basis.
- Right to portability: any Data Subject may ask Parallel to send the personal data concerning them in a structured, commonly used and machine-readable format in order to transmit it to another data controller, where this is possible.
- Right to give directives on the fate of personal data after death: anyone may send Parallel directives on what should happen to their data in the event of death, in particular whether or not it should be disclosed to third parties.
- Right to lodge a complaint with a supervisory authority: any Data Subject may contact the CNIL or any other competent supervisory authority if they consider that Parallel has not complied with certain rules laid down by the Personal Data Rules (information on referring a matter to the CNIL is available on its website).
8.2 Exercising these rights
For any question relating to the processing of their personal data, or to exercise their rights, Data Subjects may contact Parallel at the following addresses:
- By email, writing to: dpo@beparallel.com;
- By post, writing to: KIOSK, 3 Boulevard de Sébastopol, 75001 Paris, France.
The exercise of the rights offered by the Personal Data Rules is not unlimited (Parallel is entitled not to respond to manifestly unfounded or excessive requests) and each of them is subject to conditions imposed by those Rules. In this respect, the following points are specified:
- Identity: any Data Subject must provide proof of identity and indicate the address at which they wish to be contacted.
- Response time: requests are handled by Parallel within a reasonable time, taking into account their complexity, the number of requests made and the Personal Data Rules.
- Free of charge: exercising these rights is, in principle, free of charge. Where a request would involve significant costs, the Data Subject may be required to bear those costs.
These requirements must be met, failing which requests may not be processed.
9. Security measures
Parallel takes all physical, logical and organisational security measures to ensure a high level of security for the protection of personal data, in particular to prevent it from being distorted, damaged or disclosed to unauthorised persons. Should the means used to ensure the security of personal data change, Parallel undertakes not to reduce the level of security.
10. Changes to the privacy policy
Parallel may amend this privacy policy from time to time, as the way personal data is processed may change due to developments in the Solution, the Site or the applicable rules.
In such a case, Data Subjects will be informed of the updates, either by email or by means of a notice in the Solution or on the Site, at least fifteen (15) days before any substantial change to the policy.