General Data Protection Regulation

1. In general

This privacy policy regulates the processing of your personal data as part of your use of our website and related services. This processing is carried out by Neo Medical Systems S.A as data controller, whose registered office is rue Jean Engling 2, L-1466 Dommeldange, Luxembourg and registered with the Luxembourg Trade Register under number B148809 in accordance with current legislation on the protection of personal data.

Please note that we may use “cookies” or similar technologies as part of the Website and/or Services. Cookies are small text files that are stored on your device's hard disk and contain certain information, including your personal data. In this way, the site can automatically collect standard information. Any information collected indirectly will only be used to monitor the volume, type and configuration of traffic using this site, to develop the design and layout of the site and for other administrative and planning purposes, and more generally to improve the service we offer you.

Where appropriate, “cookies” issued by the site editor and/or third-party companies may be deposited on your terminal, with your consent. In this case, when browsing this site for the first time, a banner explaining the use of cookies will appear. Before continuing, you will be asked to accept or refuse the use of cookies. Users can deactivate cookies at any time. The following cookies are present on this site: essential, functional, performance and targeting cookies. We reserve the right to modify the Privacy Policy. Any such changes will be communicated via the website.

2. What data do we process and why ?

When you use the Website we process personal data about you. Your personal data will be processed for the following purposes:

- IP and cookies

- Identification information (name, address, e-mail, telephone, etc.)

- Contact details

When and on what basis?

- Use of the website (consent and, where applicable, legitimate interest)

- Contacting us (consent and, where applicable, legitimate interest)

- To provide you with personalized and efficient information about the products and services you have requested, either via the website, e-mail, telephone or social media.
In principle, we receive the above personal data directly from you. However, if you choose to register for a social media account (e.g. Instagram or LinkedIn), this information is collected via your social media profile. We recommend that you consult the privacy policy of your social media service provider to determine what data is processed by your social media service provider when you use the social media login function. We do not send personal data that you have communicated via the website to social media providers, unless we have your permission to do so. In addition to the above purposes, we may also process your personal data:

- To deliver them to a financial institution or payment service provider, to enable your financial institution and payment service provider to comply with legal obligations.

- To transmit them to the police or judicial authorities as evidence of possible offences or if there are well-founded suspicions of an unlawful act or offence committed by you through your registration on or use of the Website or the Services.

- In the context of a possible merger, takeover of/by or division of a third party, even if that third party is located outside the EU.

3. With whom we share data ?

We do not send your personal data in an identifiable form to third parties if this is not necessary for the provision of the Services, without your explicit consent. We may use external partners to provide you with the website and/or Services. We ensure that third-party subcontractors may only

process your personal data on our behalf and in accordance with our written instructions. We guarantee that all external subcontractors have been selected with the necessary care so that we can rely on the security and integrity of your personal data.

4. Where we process data ?

We and our external processors will only process your personally identifiable data within the EU. We may transfer your anonymous and/or approved data to organizations outside the EU. If such a transfer takes place, we will ensure that adequate safeguards are in place to preserve the security and integrity of your personal data, and that all personal data rights you may have under applicable mandatory law are guaranteed.

5. How we process data?

We will do our utmost to process only the personal data necessary to achieve the objectives mentioned in this Privacy Policy. We will process your personal data lawfully, fairly, and transparently. We will do everything possible to keep personal data accurate and up to date. Your personal data will only be processed for as long as it is necessary to achieve the purposes mentioned in this Privacy Policy or until you revoke your consent to its processing. Please note that revoking your consent may result in you no longer being able to use the website in whole or in part. We will take appropriate technical and organizational measures to secure your personal data against unauthorized access or theft and against accidental loss, manipulation, or destruction. Access by our staff or the staff of our external subcontractors is only possible when absolutely necessary and is subject to very strict confidentiality obligations. However, you must understand that ensuring security and protection is only a commitment to make every effort to the best of our ability and can never be guaranteed. If and when your registration on the website or use of the website or services can be considered (a) a violation of the terms and conditions or intellectual property rights or any other rights of third parties, (b) a threat to the security or integrity of the Services, (c) a danger to the website or Services or systems belonging to us or our subcontractors as a result of viruses, Trojan horses, spyware, malware, or any other form of malicious code, or (d) in any way illegal or unfair, discriminatory, or offensive, we may process your personal data in our interest, that of our partners, or that of third parties.

6. How long do you keep my data?

The data retention period varies depending on the nature of the service provided. We keep your data:

• As long as necessary to fulfill the purposes for which your data is collected and processed.

• As long as necessary to comply with our legal, contractual, and regulatory obligations and to fulfill our business operations.

7. Your rights

You have the right to request access to all your personal data that we process. However, requests for access that are clearly harmful to us and could cause overload or damage will not be processed. You have the right to request that any incorrect or inaccurate personal data about you be corrected free of charge. You have the right to revoke your consent to the processing of your personal data.

You can revoke your consent at any time by sending an email to info@neoms.com.

You have the right to request that your personal data be deleted when it is no longer necessary in light of the purposes described in this Privacy Policy or when you revoke your consent to its processing. However, you should be aware that a request for deletion will be evaluated by us in light of legal and regulatory obligations or judicial or administrative orders that may prevent us from deleting the personal data concerned. Instead of requesting deletion, you may also request that the processing of your personal data be restricted when (a) you contest the accuracy of such data, (b) the processing is unlawful, (c) the data is no longer useful for the purposes mentioned, but you need it to defend yourself in legal proceedings.

You have the right to object to the processing of personal data when you can demonstrate that there are serious and justified reasons related to special conditions that justify such an objection. If the processing in question is marked as direct marketing, you have the right to object to such processing free of charge and without justification.

When your personal data is processed on the basis of authorization or on the basis of a contract and the processing is carried out by automated means, you have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format and, if technically possible, you have the right to transmit this data directly to another service provider. The technical feasibility of this is assessed exclusively by us. If you wish to submit a request to exercise one or more of the above rights, you can send an email to info@neoms.com. This request must clearly state the right you wish to exercise and the reason why you wish to exercise it. It must be dated and signed and accompanied by a scanned digital copy of a valid identity card proving your identity. We will inform you immediately upon receipt of such a request. If the request is justified, we will

respond as quickly as reasonably possible and no later than thirty (30) days after receipt of the request. If you have a complaint about the processing of your personal data by us,

you can always contact us via the email address info@neoms.com. If our response is still unsatisfactory, you are free to lodge a complaint with the competent data protection authorities, the National Commission for Data Protection (CNPD), Boulevard du Jazz 15, L-4370 Belvaux, Luxembourg. For more information, visit https://cnpd.public.lu/fr.html.

Moderation Policy and langages

Moderation Policy

Any user in contact with neoms.com on social media agrees not to use the social media to publish comments or statements that constitute a discrimination based on race, color, religion, gender, sexual orientation, age, origin, disability, marital status or professional situation.

Insulting, offensive, racist or sexist comments or statements have no place on social media. Such comments or statements will be deleted and reported.

Languages

Neoms communicates primarily in French. Depending on the recipients, information may be communicated in other languages, namely English and Dutch, as well as in Portuguese.

To the extent possible, answers to any question or comment will be given in the language used by the recipient. 

Last update 25/07/2025