Privacy Policy

Last updated: February 2026

1. Introduction

Smartemis (“Smartemis”, “we”, “us”, or “our”) is committed to protecting and respecting your privacy.

This Privacy Policy explains how we collect, use, disclose, and safeguard personal data when you visit www.smartemis.com (the “Website”) or otherwise interact with us.

We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable national data protection laws across the European Economic Area (EEA).

2. Data Controller

The data controller responsible for processing your personal data is:

Smartemis AG

Morgartenstrasse 9, 6003 Luzern, Switzerland

info@smartemis.com

For any privacy-related inquiries, you may contact us at:

• France: rgpd@smartemis.com

• Germany: datenschutzbeauftragter@smartemis.com

3. Personal Data We Collect

We may collect and process the following categories of personal data:

a) Information You Provide Directly

• Name

• Email address

• Telephone number

• Professional information (e.g., clinic name, role)

• Any information submitted through contact forms

b) Automatically Collected Information

• IP address

• Browser type and version

• Device information

• Pages visited and time spent

• Referring website

• Cookies and tracking identifiers

c) Investor or Business Inquiry Data

If you contact us regarding investment, partnership, or recruitment opportunities, we may process additional professional or business-related information.

4. Legal Basis for Processing

We process personal data based on:

• Consent (e.g., marketing communications, non-essential cookies)

• Legitimate interests (e.g., responding to inquiries, improving website performance)

• Contractual necessity (where applicable)

• Legal obligations

5. How We Use Your Data

We use your personal data to:

• Respond to inquiries

• Provide information about our services or network

• Improve website functionality and user experience

• Analyze traffic and engagement

• Comply with legal and regulatory obligations

We do not sell personal data.

6. Data Sharing

We may share personal data with:

• IT and hosting providers

• Analytics providers

• Legal and regulatory advisors

Affiliated Smartemis entities within the EU

Where third parties process data on our behalf, they are bound by contractual data protection obligations.

7. International Transfers

If personal data is transferred outside the EEA, appropriate safeguards (such as Standard Contractual Clauses) will be implemented in accordance with GDPR.

8. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this policy, unless a longer retention period is required by law.

9. Your Rights Under GDPR

You have the right to:

• Access your personal data

• Rectify inaccurate data

• Erase data (“right to be forgotten)

Restrict processing

• Object to processing

• Data portability

• Withdraw consent at any time

You also have the right to lodge a complaint with your local data protection authority.

10. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction.

11. Updates

We may update this Privacy Policy from time to time. The latest version will always be available on our website.