PRIVACY POLICY AND COOKIES
Preamble:
When you visit the website: https://spineway.com (hereinafter the “Website”), Spineway, a public limited company located at 7 allée du Moulin Berger 69130 Ecully (France), processes your data as the data controller (hereinafter “Spineway”).
Spineway attaches particular importance to respecting your privacy and protecting your data and, in this context, undertakes to comply with Regulation (EU) 2016/679 of April 27, 2016 on the protection of personal data (known as the “GDPR”) and Law 78/17 of January 6, 1978 on information technology, files, and civil liberties (known as the “French Data Protection Act” or ‘LIL’) (hereinafter referred to as the “Regulations”).
Below you will find all the information you need about how your data is processed and used, as well as your rights.
General information:
In general, the Website has been designed to comply with the principle of data minimization.
This means that it is in principle possible to visit the Website without providing any personal data.
The Website consists of a public interface accessible to all visitors to the Website (with the exception of restrictions on the “Products” pages, which are intended for healthcare professionals only);
In addition, the Website allows redirection to a private access interface. Access to this private interface is via redirection to the My Spineway application by logging in (username and password provided by Spineway) and allows secure access to specific content reserved for certain users. For more information on how your data is processed when using the My Spineway application, you can consult the privacy policy by clicking here.
On the Website, your personal data may be collected when you choose to use cookies or when you fill out the contact form.
Below you will find details concerning:
- the manner and purposes for which Spineway uses and stores your personal data;
- the legal basis under which your personal data is processed;
- the categories of recipients of your personal data;
- your rights and our obligations in relation to its processing.
What personal data is processed and for what purposes?
| Personal data processed | Purpose(s) of processing | Legal basis for processing |
| Last name*, first name*, occupation*, company, country, email address*, subject of the request*, any other information entered by you in the field | Management of requests received via the contact form | Spineway has a legitimate interest in processing your data in order to process your request and contact you. |
| Last name*, first name*, email address*, phone number*, resume*, cover letter*, any other information you enter in the free field (Message) | Management of applications in response to advertisements posted on the Site | Spineway has a legitimate interest in processing your data in order to process your request and contact you. |
| Email address*, any other information entered by you in the email | Management of unsolicited applications | Spineway has a legitimate interest in processing data in order to handle the applications it receives and recruit candidates who meet its requirements. |
| IP addresses, browser used, language, operating system, device information (including device categories and characteristics), referring web page, pages visited, location (city), and other cookie information. (depending on the permissions you have granted us) | Website management and audience measurement | Spineway has a legitimate interest in processing your data in order to enable you to access the Website under the best possible conditions and to compile audience statistics when you have given us your consent. |
*: mandatory data, essential for processing to be carried out and the purpose to be achieved.
To which categories of recipients are your personal data transmitted?
Your personal data may be transmitted to the categories of recipients listed below:
- Internally to the departments authorized to process your request.
In the contact form, the drop-down menu allowing you to choose the type of request also allows you to select the recipient responsible for responding to you and to transfer your request directly to them, without an intermediary. Spineway employees are bound by a contractual obligation of confidentiality.
- To third-party service providers, acting as subcontractors, who provide support for internal operations and assist Spineway in managing them.
These service providers, acting as subcontractors, may only process your personal data for the purposes authorized by Spineway and under conditions that ensure confidentiality and security in accordance with the Regulations.
- To legally authorized authorities in order to comply with its legal, regulatory, or contractual obligations, particularly with regard to medical device vigilance.
In all cases, Spineway makes every effort to ensure the confidentiality and security of personal data when it is transmitted to the above-mentioned categories of recipients.
How long are your personal data kept?
In principle, your personal data are kept for the period necessary to fulfill the main purpose referred to above.
Your personal data may also be kept for legal purposes and to assert Spineway's rights and interests until the applicable limitation period expires.
The retention period for your data is therefore variable and determined according to the following two criteria:
- the purpose for which it is used: Spineway must retain the data for the period necessary to fulfill the purpose related to the processing; and
- legal obligations: legislation or regulations may set a minimum period during which Spineway must retain personal data.
At the end of this period, your personal data is destroyed or anonymized. Anonymization ensures that personal data can no longer be associated with the person concerned.
Finally, you may request the deletion of your data at any time. If such deletion is permitted by applicable regulations, Spineway will permanently delete your data within thirty (30) days of your request.
What rights do you have over your data?
Your rights are listed below.
These rights can be exercised by emailing: dpo@spineway.com or by writing to the following address: Spineway, 7 allée du Moulin Berger, 69130 Ecully (France).
Your right to access and rectify your data: you have the right to access and rectify your personal data.
Your right to erasure of your data: you may ask us to erase your personal data in the cases provided for by the Regulations.
Your right to restrict data processing: you may request the restriction of the processing of your personal data in the cases provided for by the Regulations.
Your right to withdraw your consent: when the data processing carried out by Spineway is based on your consent, you may withdraw it at any time. Spineway will then cease to process your personal data without affecting the previous operations for which you had given your consent.
If you believe that Spineway has not respected these rights, you have the right to appeal. You can file a complaint with the French Data Protection Authority (CNIL) - https://www.cnil.fr/fr/cnil-direct/question/adresser-une-reclamation-plainte-la-cnil-quelles-conditions-et-comment
How is your data protected?
Spineway is committed to ensuring the security of your personal data and takes all necessary measures (physical, technical, administrative, and organizational) to protect your data and prevent its loss, alteration, destruction, or use by unauthorized third parties, taking into account the risks associated with the processing operations carried out.
In addition, we require our service providers and subcontractors who may have access to your personal data to implement appropriate technical and organizational security measures with regard to this personal data.
What is the cookie policy?
On the Website, information is collected and stored using browser cookies or similar tools.
A cookie is a small text file that is stored on your device and records certain settings and data for interaction with our system from your browser.
A cookie usually contains the name of the domain from which the data originates, information about the date of its creation, and an alphanumeric identification code.
You can configure cookies at any time via the “cookie preferences” link at the bottom of the Website.
Below is a list of the cookies used on the Website.
- Necessary cookies
These cookies are necessary for the Website to function properly. They are used to optimize and simplify your user experience.
These cookies are necessary for the proper functioning of the Website. They are used to optimize and simplify your user experience.
These cookies do not require your prior consent and cannot be disabled, as without them the Website cannot function properly.
- Functional cookies
These cookies are necessary for the proper functioning of the Site. They are used to optimize and simplify your user experience. These cookies are used to remember the choices you make when using the Site.
For example, we may use functional cookies to remember your language preferences or login credentials.
| Cookie name | Finallity | Default expiration period |
| cookie_consent_level, cookie_consent_user_accepted cookie_consent_user_consent_token | Used by the cookie consent modal to save user settings | 1 year |
- Third-party cookies:
The Website also uses the following third-party cookies:
| Cookie name | Finallity | Default expiration period |
| Performance cookies | ||
| __ga__ (Google Analytics) | Analyse statistique et mesure d’audience | 14 months |
| ga_container id(Google Analytics) | Analyse statistique et mesure d’audience | 14 months |
- Third-party tools:
The Site uses the following third-party tools:
Google Maps
Google Maps is an interactive map display service for viewing geographic information. We use this service to enable you to locate our geographic position.
The terms of use for Google Maps are available at https://www.google.com/intl/fr/help/terms_maps.html
For detailed information on data protection in connection with the use of Google Maps, please visit the Google website (“Google Data Protection Policy”): http://www.google.fr/intl/fr/policies/privacy/
reCaptcha
We use Google reCAPTCHA to protect our Site from abuse and automated submissions (spam). This tool verifies that certain actions are performed by a human and not by a robot.
When using reCAPTCHA, certain data (such as IP address, browsing behavior, mouse movements, etc.) may be collected by Google. This data is subject to Google's privacy policy.
For more information, please see Google's privacy policy: https://policies.google.com/privacy
And the terms of use: https://policies.google.com/terms
YouTube
Our Site uses third-party services provided by YouTube (owned by Google LLC) for the integration and playback of videos. When you access a page containing a YouTube video, data (such as your IP address and the pages visited) may be transmitted to YouTube.
YouTube may also use cookies or other tracking technologies to collect information about your browsing, in accordance with its own privacy policy.
To learn more about how YouTube processes your data, you can view their privacy policy here: https://policies.google.com/privacy
Changes to the privacy policy
Spineway reserves the right to change the privacy policy at any time.
Any changes will be posted directly on this page. To ensure that you have the latest version, Spineway invites you to check this page regularly.
Last updated: October 7, 2025.